Submission for: Light Horse Interchange Business Hub Eastern Creek
PROSPECT, New South Wales
As a local resident I oppose the proposed development of land which the government (the former Premier Bob Carr MP) on 4 December 2004 said "It will really be the lungs of western Sydney, open space never to be developed, a great part of our environment."
According the Environmental Impact Statement, it has via the “Natural Resource Access Regulator (NRAR), indicated in-principle support for relocating parts of Eskdale Creek.” and, “Further consultation following the detailed surveys confirmed in-principle acceptance of the relocation of Eskdale Creek by NRAR.”
I am obliged to remind the Natural Resources Access Regulator (NRAR) of the Act 2017 No 64 Clause 10 Principle objectives of the Regulator which says:
The principal objectives of the Regulator are:
(a) to ensure effective, efficient, transparent and accountable compliance and enforcement measures for the natural resources management legislation, and
(b) to maintain public confidence in the enforcement of the natural resources management legislation.
How can the NRAR give prior assent to bring this matter to the present stage?
There has been no effective, efficient, transparent and accountable compliance and enforcement of natural resources management in this matter on what has occurred thus far.
Further, nothing in this matter so far maintains public confidence in the enforcement of the natural resources management legislation.
How can the public have confidence when certain individuals within government allow one rule for the public and another rule for developers?
I remind you of the occasion a bit more than a decade ago when the then Minister for Natural Resources had to deal with a matter of Blacktown Workers Club seeking to realign Bungarribee Creek (no more than 3.6km from the Light Horse Interchange site) so that the Club could profit from the construction and leasing of warehouses on part of what is Bungarribee Creek.
There are similarities in the past and present matter. Both Eskdale Creek and Bungarribee Creek are the same Strahler Order Streams where realigning has been proposed and both flow into Eastern Creek, a creek in which a population of Australian Bass (Macquaria novemaculeata) has been recorded on at least two separate occasions in the past.
That, it seems, is where the similarities end. In the Bungarribee Creek matter there was concern within government about the environmental impacts of realigning the creek. In the Eskdale Creek matter there is no similar regard for the environmental impacts of realigning the creek. Also, in the Bungarribee Creek matter a disparity exists insomuch it was a community group wanting to realign the creek but in the Eskdale Creek matter it is government bureaucrats looking after 'their own'.
How can that be when all else is the same for the two creeks?
Nothing in this proposal to realign Eskdale Creek does anything to engender, let alone, maintain public confidence in the enforcement of the natural resources management legislation.
The environmental impact statement hypocritically identifies “Cumberland Plain Woodland is a candidate community at risk for Serious and Irreversible Impacts (SAII) as defined under the BC Reg. The proposed development could result in a 0.95% decrease in area of this community within the 1,000 hectares surrounding the site and a 0.22% decrease within 10,000 hectares. ” but then endorses, in this proposed development, the “death by a thousand cuts” action which has been the historical means of reducing the ecological community to 3% of its original extent on the Cumberland Plain.
To 'smooth the conscience' the ecological consultant defers to biodiversity offset credits to offset various impacts and says “It is intended that WSPT will meet their offset requirements by retiring existing biodiversity credits generated under the BioBanking Scheme and the generation of suitable biodiversity credits by entering into a Biodiversity Stewardship Agreement.” To this we ask what is intended here?:
1. What credits and where were the WSPT existing biodiversity credits previously generated?
2. Were the credits derived from land that WSPT was obliged to conserve under its Plan of Management or, more broadly, land that was originally “never to be developed”?
3. Is not the whole NSW Biobanking Scheme corrupted by permitting the biobanking of already conserved lands and particularly conserved lands in public ownership?
4. Is not the NSW Biobanking Scheme corrupted by little or no compliance on the part of the NSW Government thus allowing on-selling of biobanked properties to environmentally insensitive buyers; use of unqualified bush regenerators; overuse of chemicals, insensitive bobcat and other machinery in management practices; creation of trail bike tracks within bushland, erecting built structures in allegedly protected bushland; shooting of native fauna in allegedly protected bushland? (all have been seen)
Biobank Assessment Certifiers manipulate credits for their own gain and have within their entity individuals who have acquired land for their own biobanking benefit.
I ask to be informed of answers to questions I have raised in my submission and objections raised at certain points.