St Marys Waste Facility

Our company operates manufacturing facilities in both Kommer Place and Links Road in St Marys. We have the following concerns regarding the expansion plans for the Bingo Recycling site:

1. Traffic has already dramatically increased in Dunheved circuit, most notably within the area around Bingo Recycling.
2. Access to Kommer Place is already restricted as it has only one exit and entry point. The increased traffic already creates very long queues to enter/exit Kommer Place. This creates a great deal of frustration for transport companies, visitors and staff due to the time wasted. There is real concern that the Kommer Place exit could become blocked due to an accident or breakdown or perhaps something worse such as a fire, leaving the public with no alternate escape route.
3. The amount of dust around the site has substantially increased since Bingo entered the Dunheved Circuit area. This is evident from dust surrounding the site and also the damage to the small park directly opposite the existing entrance to the Bingo Recycling site.
4. Bingo Recycling do currently attempt to address the obvious dust issue through the use of a road cleaner, however this often turns the dirt into mud making a larger mess.
5. The public park is also being abused and damaged by bingo truck drivers, driving over the top of it when the road is blocked.
6. When there is maintenance, or a hold up within the Bingo premises, the trucks simply park on the road, completely blocking access into Kommer place.

Any expansion of the current Bingo Recycling site would only exacerbate the above issues.

Please refer to uploaded letter. Thank you.

MRP Superannuation Pty Ltd (MRP) has received Notice of Exhibition SDD 8200 regarding St Marys Resource Recovery Facility (Proposal).

MRP and MRP Property Pty Ltd (MRPP) own 13-15 Vallance Street, St Marys. The land fronts both Vallance Street, St Marys and Charles Street, St Marys. The land is leased to Natform Pty Ltd (Natform) for warehousing/manufacturing business.

This submission is made on behalf of MRP, MRPP and Natform (Affected Parties).

MRP, MRPP and Natform object to the Proposal due to the severe traffic impact and serious safety issues that will result from the development.

The Affected Parties submit the Proposal should be rejected.

Site

The proposed development is within an older industrial area. The infrastructure put in place at the time of the subdivision is clearly unable to cope with any greater intensity of use than currently exists.

Natform for many years has operated a warehousing/manufacturing business at 13-15 Vallance Street, St Marys. The Affected Parties are well placed to comment on the application from direct experience. The objection is not against use in accordance with zoning for the area. It is based on serious health and safety concerns and high traffic impact where congestion is already an acute problem.

Ingress and egress from the Vallance Street premise is via both Vallance Street and Charles Street. These streets lead directly on to Dunheved Circuit. For some time it has been clear that the traffic volumes are at full capacity and safety issues become increasingly prevalent.
The area is suitable for the existing volume of use only.

Traffic Impact

The existing road system was not designed and is not capable of taking any more large trucks and B-Double trucks.

If there are additional truck movements (which may be more than 200 movements per day) the infrastructure would need to be upgraded very substantially.

The road changes proposed in the application will not solve the problem. The problem could only be solved by doubling of the width of the carriageway for the full length of Dunheved Circuit to cope with the additional traffic. There would also need to be a complete upgrading of traffic controls at intersections.

Unfortunately, in this industrial area construction of appropriate dual carriageway may not be practical. It would require existing factories to be demolished.

The minor road improvements referred to in the Traffic Impact Assessment Appendix are wholly inadequate to deal with any increase in traffic.

As mentioned, Natform and its employees have used these roads for many years. Those roads are already heavily congested. There are often queues of up to a kilometre from our premises leading on to Dunheved Circuit. Attached is a location diagram showing the areas affected.

It is now also almost impossible to turn right on to Dunheved Circuit due to the volume of traffic. The roundabouts and intersections are already subject to heavy congestion.

The Traffic Impact Assessment provided itself confirms that the Proposal is not in conformity with the applicable Roads & Maritime traffic generation rates. These rates are relevant and need to be applied.

Proper analysis will confirm what is obvious to every person using the roads. There is no scope for increased traffic volumes.

Safety

Natform and its employees are already raising concerns about traffic safety and high levels of dust being generated by the current traffic to the St Marys Resource Recovery Facility.

Any expansion of that Facility will considerably worsen the problems that exist.

If there is an approval, the Consent Authority will be responsible for the work health and safety issues that will inevitably flow if approval is given.

The health and safety issues will include the probability of serious traffic accidents involving large heavy vehicles and illnesses from the continued deterioration in the air quality from dust.

In relation to air quality, Natform's employees have increasingly raised concerns that the materials the trucks are carrying, including the concrete and dust, are creating high levels of dust particles in the air.

In relation to safety, Natform's employees have raised on many occasions safety issues concerning so many heavy vehicles on the existing road. As one example, it is unsafe and often impossible to turn right onto Dunheved Circuit. We refer you again to the attached diagram.

The employees have described the current conditions at intersections as "Russian roulette" with heavy trucks carrying concrete.

These issues are also being raised by other factory owners in the area and road users. The staff has observed Police attending the area on many occasions regarding both dust and traffic issues. We assume that the input of the local Police will be obtained.

It is obvious that the size and speed of trucks is already a major issue even without any further development.

The statement in the Traffic Impact Assessment on page 38 that the Proposal is "not expected to compromise the safety or function of the surround network and the surrounding road network, public transport services and pedestrian connections will remain unchanged" is simply wrong.
The existing infrastructure is used to its limit and any intensification of use will create serious safety issues.

Conclusion

The Affected Parties submit that the application should be rejected on the grounds of high health and safety risks and unacceptable traffic impact.

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