I have attached a file with most of my comments.

One other question I have is if the proposal is successful, will the initial construction involve excavating all the stage 1 plots during this process? If that is to be the case will the resident's be compensated for the noise and dust created?
Regards,
Amanda Rollason

As a direct neighbour and student living in direct proximity to the proposed site, I submit my objection to the Douglas Park Memorial Park. The change of this rural area into a cemetery of this scale directly threatens my ability to study, live, and maintain my mental well-being. The proposal will create unmanageable strains on local roads and train access, compromises our privacy, and forces an overwhelming environment of grief onto a household meant to serve as a sanctuary for me. Vegetative screening cannot mitigate the psychological impact or physical reality of overlooking a massive, institutionalised burial landscape from my front yard or bedroom window.

The scale of this project will cause constant disruptions to my studies (first year UNSW). The ongoing noise (excavators, service vehicles, lawn mowers and mourners) will all make it impossible to concentrate on assignments, tutorials and lectures while at home. The constant stream of traffic to and from the site will hamper my ability to access the train station on the days that I attend the Kensington Campus. At present trains run on the hour to and from Douglas Park, therefore it makes it virtually impossible to arrive on campus on time for exams and lectures.

I urge you to consider rejecting this large scale development in its entirety as it is inappropriate for this location. It places an unacceptable burden on local students and residents, lacks the necessary public transport links, violates residential privacy, and poses a direct threat to the mental health of the immediate community.

The Nepean River gorge system at Douglas Park is designated as an area of high scenic, biodiversity, and Aboriginal cultural heritage value despite the findings of paid consultants. It is well known that the deep sandstone gorges, gullies, tributaries, and cliff overhangs around the Nepean River—particularly in the southern sections near Douglas Park, Appin, and the Upper Nepean—are globally significant, highly sensitive archaeological zones that been frequented by Indigenous people for millennia.
This specific landscape sits on the traditional country of the Dharawal people. Geologically, these deep Hawkesbury sandstone gullies provided a crucial means of survival. In Australian archaeological catalogues, sandstone cliff overhangs and tributaries leading into ariver system have High Predictive Archaeological Sensitivity. They provided three essential pillars for ancient life. Large overhangs served as natural, weatherproof habitations. Over thousands of years, charcoal from campfires, discarded animal bones, and stone tool flakes accumulated on the cave floors, creating deeply stratified archaeological layers. Sheltered cliff faces that characterise the landscape acted as canvases. The Upper Nepean and surrounding Dharawal country are densely packed with charcoal drawings, ochre hand stencils, and rock carvings. Many of these sites are hidden deep within rugged, heavily forested gullies. The property at number 45 Mitchell Place directly opposite the site has a documented marking in one of their deep overhangs. The flat sandstone beds of the tributaries and creeks feeding into the river were extensively used for the purposes of sharpening stone tools.
Douglas Park is extensively documented in statutory heritage databases like the NSW Aboriginal Heritage Information Management System (AHIMS). Local environmental and mining impact studies conducted around the Douglas Park and Nepean gorge areas have documented several sites in this location with some areas left unexplored. A single local corridor near Douglas Park River and the surrounding areawill reveal many rich artefacts nestled in the shelters and under cliff lines.
In Australian archaeology and the Dharawal cultural history, flat, elevated plateaus above gullies and tributary systems(such as the proposed site) are looked upon as major sources of ancient Indigenous daily life. Gullies and overhangs provided shelter, water, and spaces to make tools and art but the top of the escarpment or the plateau, was the usual type of area designated for camping.
The Douglas Park Memorial Park proposal (SSD-68287712) will have an immense impact on the integrity on the cleared or semi-cleared rural plateau above the Nepean River in this location. In the Sydney and Upper Nepean Basins, the plateau land immediately adjacent to a steep gorge or creek line is classified as an area of High Predictive Archaeological Sensitivity for several critical scientific reasons. Caves were not the only place that Indigenous groups habituated. Largergroups tended to camp on the flat plateaus immediately aboveand adjacent to water sources. The perimeter of a plateau directly overlooking a gully is called an "ecotone"—an area delineated on the boundary between two distinct ecological systems. This provided the Dharawal people with immediate, dual access to plateau resources (such as terrestrial hunting game, medicinal plants, and timber) and deep-gully resources (water, aquatic life, and raw sandstone materials) Rugged gullies are incredibly difficult to traverse for long distances. Consequently, ancient walking tracks, songlines, and trade routes almost exclusively followed the flat ridgelines and plateaus directly flanking major river systems – in other words: the proposed site. The older stands of eucalyptus trees on these plateaus often bear permanent scars where bark was systematically removed to construct canoes, coolamons (carrying shields), or temporary shelters. I think at least one remains on this site despite the brutal amount of clearing that has occurred.
Proponents of large developments try to claim that because a plateau has been previously used for livestock grazing or farming, its cultural heritage has been destroyed. However, this is incorrect according to NSW planning law. This activity does not destroy sub-surface archaeological deposits.
Because the development involves massive and irreversible geomorphic alteration—including deep excavation into the plateau for staged burial plots, foundations for buildings, and internal roads, the proponent should not be allowed to rely on superficial surface observations. If so, it fails to satisfy the due diligence requirements of the National Parks and Wildlife Act 1974 and violates the evaluation criteria under Section 4.15(1)(b) of the EP&A Act 1979 regarding localized environmental and heritage impacts.
I cannot understand why any reports offered by the proponent represent a conciliatory attitude by local indigenous representatives of the Dharawal people. Further investigation must be undertaken to verify that this is a true record of what has occurred because this is a precious and rich area that would be utterly desecrated with what the developer has in mind: turning it into a quarry basically, poisoning the groundwater and air, diminishing further the endangered forest (he already has a very long track record of doing this.) Cynical attempts to feign respect by asking permission to enter their website et cetera should not fool anyone. This is a money-making venture by someone who has never lived here and has never displayed the slightest indication for caring about the environment, the ecology, or the residents that do call this place home and have been the actual care-takers for a very long time.
Thanks for reading my submission,

Sean Murtagh.

Dear Sir/Madam,
I would like to make a submission for the cemetery and crematorium being proposed for 430-490 Douglas Park Drive, Douglas Park.
In my view this facility is in breach of the Environmental Planning and Assessment Act 1979 Section 4.15(1)(b) because the proponent has failed to address the “likely impacts of that development, including environmental impacts on both the natural and built environments, and social and economic impacts on the locality”, and Section 4.15(1)(c) which mandates an assessment of "the suitability of the site for the development."
It falls upon the developer planning to inflict this cemetery and crematorium on the neighbourhood to prove that it won’t adversely affect the health and safety of nearby residents and the beautiful native ecology that makes up the environment around the Nepean River.
Cemeteries require stable, deep-soil structures to act as natural filtration zones above the water table. A site 650m from a 70m deep gorge sits on a sandstone or highly fractured rock shelf that drains directly toward the gorge system. Rainwater travels through fractured rock at rapid speeds, passing through any future burial plots and migrating horizontally towards the cliff face. This creates a water contamination problem for people who live in and around the gullies and tributaries that lead to the river as well as the many people who visit the river to swim or fish or canoe. It is an enormously popular spot for recreation. The Cataract River Ranch regularly features river activities as part of their facilities.
The pollutants of most concern from crematoria emissions are PCDD/Fs, Hg and fine particulate matter (PM2.5), known to be toxic to humans and can bioaccumulate in tissues. PCDD/Fs are classified as possible human carcinogens and Hg is a neurotoxin. Exposure to PM2.5, which can reach deep into the lungs, can increase the risks of heart disease, lung cancer, asthma, and adverse birth outcomes, and exacerbate other conditions such as diabetes. Additionally, in Western Australia, an atmospheric dispersion study modelled Iodine-131 (I131) emissions following the cremation of a deceased cancer patient who had received a high dose of I131 shortly before death. The study estimated that environmental limits for atmospheric emissions of I131 could have been exceeded at distances of 440 m and 1610 m downwind of the chimney. For these key pollutants, agencies such as the World Health Organization advise that care should be taken to limit exposure, particularly for vulnerable populations such as babies, children, pregnant women, and the elderly. What care can be taken by residents being forced to endure a new crematorium immediately in front of them? Permanent indoor living? This is why crematoriums are now routinely located in industrial zones. They do not belong in a residential zone!
Approved Methods for the Modelling and Assessment of Air Pollutants in NSW must include consideration of background doses of pollution, which in this particular location includes the emissions from the adjacent Hume motorway. Additionally, pollutant dispersion processes over complex terrain are much more complicated than over flat areas, as they are affected by atmospheric interactions with the orography at different spatial scales. Proposing a crematorium on a site hemmed in by a major freeway on one side and a 70-metre-deep river gorge system 650 metres away presents severe, compounded technical vulnerabilities. This site structure is exceptionally high-risk for the community residing close by and the endangered forest ecology documented on-site. The Air quality assessment provided in the EIS is woefully inadequate, based on superficial, basic terrain parameters from flat locations devoid of the specific features on this particular site. In consideration of the river gorge system, capable of generating its own unique weather system, as well as the effects of freeway pollution, consenting authorities should reject this proposal for the cumulative and dangerous effects it will have for the health and safety of the community. When a facility of this nature is located within a tight buffer zone (e.g., within 350 meters from homes), any minor operational malfunction immediately triggers a breach of the Public Health Regulation, threatening local biosecurity and psychosocial health. The risks are unmanageable, the location of it here unnecessary.
Please consider the above points I have outlined as being earnest, educated and heartfelt, and I thank you very much indeed for your valuable time.
Yours sincerely,
Samika

Dear Sir/Madam,
I am a regularly visitor to Douglas Park where this proposal is located and have read the Air Quality Impact Assessment by Neo Consulting. Several project risk indicators and omissions stand out to me, and I don’t believe this report survives critical analysis to the level required for a concept approval for a crematorium.
There is a steep elevation drop created by the Nepean River gorge system nearby, capable of generating an independent weather system. Over night and early morning,dense cool air drains off the upper slopes to lay low at the bottom of the 70m basin, creating a thermal inversion layer. According to the graphics contained within the assessment, the crematorium sits approximately 650m in an uphill direction,meaning its hot exhaust gases will cool as they travel downward toward the gorge. The inversion lid will prevent them from rising and the plume will likely flatten out horizontally to threaten the air quality of the area between the gorge and the crematorium. This is compounded by the proximity of the Hume Highway to the proposed crematorium stack. At approximately 200 metres away, high-volume motorway traffic will generate a continuous trough of low-pressure frictional turbulence. This low-pressure column will act as an aerodynamic wall preventing the crematorium smoke from dispersing in a 360-degree direction and creating a toxic corridor of pollution over residents and ecology trapped in the box created between the stack, highway and the 70m drop river gorge, to the east. Within this box, an endless loop of fluctuating emissions of varying concentration levels will occur, with katabatic flow - downward from the stack toward the gorge – and anabatic flow - as the sun heats the 70m gorge walls, travelling upwards again.
The topography over the region was assumed to be flat for the AERMOD simulation, despite Douglas Park featuring rolling terrain combined with the steep gorge. Surface data from Camden Airport and upper-air data from the airport at Sydney were utilized for modelling and this does not adequately assess the microclimate, wind channelling, and cold-air drainage pooling created by the gorge system. The CALPUFF modelling should have used a 3D meteorological dataset drafted by CALMET, which considers local terrain datasets. CALMET modelling details are missing, calling into question whether CALPUFF modelling using a 3D meteorological input was undertaken. The CALPUFF modelling was probably prepared using the same Camden Airport meteorological input file, which relegates it to a mere screening level model run, denying assessors the opportunity to make asound assessment. A site bordered by a 70-metre drop on one side and a major freeway on another creates a shifting and complex microclimate, combining to createopposing aerodynamic and thermal forces and preventing effective plume dispersal into the upper atmosphere.
Upper air data (radiosonde data) from Sydney Airport is utilized to calculate temperature, atmospheric pressure and upper-level wind. This is a coastal, sea-level environment, markedly influenced by flat topography and ocean breezes. Douglas Park is located approximately 80 kilometres inland, on an elevated plateau adjoininga 70-metre-deep gorge. The wind shearing, thermal boundaries and upper-air behaviour over a coastal airport is in stark contrast to conditions over an inland gorge system. Sydney Airport's upper air data has been coupled with the relative humidity and surface temperatures of Camden airport to calculate the daytime mixing height. Mixing heights are highly sensitive to local terrain. Being a flat floodplain, Camden’s atmosphere mixes smoothly but Douglas Park's 70m gorge drop generates localized and immediate cold-air pooling with notable night/morning thermal inversions. Using Camden data to calculate mixing heights means an artificially cleaner and higher atmospheric ceiling is portrayed rather than what is actually the case for this particular Site, giving the impression that the crematorium plume will disperse cleanly instead of being confined at ground level.
Stack parameters aren’t available which gives them leeway to make them up.
Some of the raw weather data has been manipulated to make the computer program run smoothly: "Small gaps filled with previous or following hour records" and "Gaps in vertical temperature profiles were filled with previous or following day data." Weather data has been copied and pasted from previous or following days to cater for gaps in the information, which likely removes dangerous worst-case weather scenarios and doesn’t provide an accurate portrayal of conditions here.
The authors state that "Suspected wind stalls... were removed and filled appropriately" and notes the equipment cannot detect winds under 2 km/h. However, completely calm is the most hazardous condition for an industrial emitter - when a plume isn’t blown away but is deposited straight down. Erasing wind stalls from the data set and filling them with fabricated wind, also erases the worst conditions for pollution of the year from the modelling.
A 10km-by-10km grid to approximate the surface reflectivity and moisture exchange of the soil is adopted using Google Maps. This averages out the landscape and treats the whole region as a universal combination of forest/rural. Therefore, the sharpgeographic transition of a sudden 70m vertical drop into the gorge, 650m from the crematorium is flattened out.
While the report presents mapping for Nitrogen Dioxide (NO2), the assessment is deficient in spatial plots as well as a test for cumulative, toxic crematorium emissions such as dioxins, furans, and hydrogen chloride (HCl). It is unclear if NO2 has been assessed by modelling NOx emissions as 100% NO2 or converted in the model using a suitable and approved approach. If 100% NOx as NO2, this would be conservative and further explanation is warranted. The assessment notes that the chosen year – 2022 - was a very "wet year." By modelling exclusively during the cleanest air quality year in NSW on record, an accurate assessment of the impact during stagnant atmospheric conditions has been concealed.
There are no architectural blueprints or heights for any of the planned buildings for the development which makes the building wake effect included in the report impossible to calculate. I think that scientific comparison between the daytime -only hours (9.00am-7.00pm) utilised for AERMOD modelling against CALPUFF 24/7 is invalid.
The report applies the repealed POEO (Clean Air) Regulation 2010 instead of the 2022 Regulation and conflates in-stack particulate emission limits (100 mg/m3) withground-level ambient concentration criteria.
Crematoriums are responsible for dangerous emissions such as radioisotopes from recently treated and deceased cancer victims, and vaporised elemental mercury from dental fillings. When mercury vapour combines with cold, humid air rising from a 70m gorge, it undergoes fast condensation. Rather than travelling kilometres away, itwill convert into particulate form and drop directly onto soils, into rainwater tanks, onto roofing in the surrounding area. It will be carried by rainwater runoff downslope, causing toxic methylation in the river ecosystem. I can’t see how thisassessment proves that pollutants will not cause ecological damage to adjoining endangered ecological communities and to the safety of nearby residents including small children, the elderly and immune compromised - a standard it should definitely be made to meet.
Highway traffic pumps out ultra-fine brake dust, tyre microplastics and black carbon and a crematorium will add ultra-fine fly ash and incomplete combustion particles (dioxins/furans) into the mix. Dangerous organic compounds and heavy metals from the stack will bind to sticky black carbon particles to make a toxic "carrier particle" that can bypass the upper respiratory system, penetrate deep into the lungs, and enter the bloodstream. The people who live here and use the river will be breathing in synergistic particles – a perilous situation to knowingly inflict on people.
Further, in a high-humidity environment such as a river gorge, Nitrogen Dioxidegenerated by highway traffic will combine with the Hydrogen Chloride from the combustion of casket glues and plastics from the stack to form localised, low-level acid aerosols. Elevated levels of eye, nose, and throat irritation, as well as exacerbation of asthma and respiratory ailments are likely to be experienced by Douglas Park residents in close proximity as a consequence.
A look at Google Maps shows that a long line of homes exists just 250-metre from where the crematorium is planned so that the true and cumulative air quality is very likely to be in breach of Impact Assessment Criteria. A basic Level 1 screening assessment is simply not good enough in consideration of this. The failure to address the actual topography and consequent microclimatic conditions, as well as leaving out the Hume Highway Baseline means this Air Quality Assessment has next to no value for assessing the safety of this proposal under Section 4.15 of the EP&A Act and Wollondilly LEP 2011, Zone R5 (Large Lot Residential) / RU2 (Rural Landscape) to "preserve and minimise impacts on environmentally sensitive locations and scenic quality" and fails to maintain neighbourhood amenitythat can only be enjoyed in an environment that is safe.
This is entirely the wrong location for a crematorium and should be rejected in the first instance considering the close proximity of residential housing, the protected river system and the endangered ecology recorded on Site. At the very least rigorous testing must be made mandatory involving CFD modelling, a twelve-month monitoring of on-site weather and a level 2 Refined Dispersion Assessment using CALPUFF, (not AERMOD only).
Regards,
Mia Stevens

To the Assessing Officer,
As an immediately downslope neighbour, I have serious concerns regarding both the proposed wastewater system and the adequacy of the environmental, hydrogeological and geotechnical investigations for the Douglas Park Cemetery.
The applicant has shifted from an on-site treatment system to a 50,000 L pump‑out-only system without adequate justification. This approach is not appropriate for a large public development and appears to be a fallback solution. The report does not demonstrate why on-site treatment or Sydney Water servicing are unviable, nor does it properly assess the impacts of frequent pump‑outs, including traffic, noise, odour, access and spill risks.
More broadly, the supporting investigations rely on limited data and assumptions and do not demonstrate that the site is suitable without unacceptable long-term risks. Shallow and perched groundwater (as little as ~2.1 m) may be intersected by proposed burial depths (up to 2.85 m), yet assessments rely on average conditions and exclude surface water impacts despite drainage toward neighbouring properties and the Nepean catchment.
Site investigations are limited, with insufficient borehole coverage and unreliable groundwater observations. The proposal involves extensive excavation and engineered fill, raising unresolved risks of settlement, instability, seepage and long-term performance. There is also no detailed modelling of contaminant transport, pathogen migration or long-term groundwater quality.
Impacts to adjoining residents—including seepage, erosion, drainage changes and contamination—have not been adequately assessed. The site’s Hawkesbury Sandstone geology makes a cemetery of this scale highly unusual within the Sydney Basin.
Additionally, traffic assumptions are flawed, relying on access from the northern side and nearby train station despite constrained, unsafe access via a narrow gorge currently under consideration for closure due to landslip and safety risks.
Conclusion:
The proposal is unsupported by adequate, transparent or comprehensive assessment. I request that it not be approved unless a properly justified wastewater strategy and significantly more rigorous, independent investigations are undertaken.
Kind Regards,
Lindsay

I would like to object to the state significant cemetery and crematorium application for Douglas park. I live with my family on Mitchell place and we have been battling this development for 8 years now. Apart from the major traffic issues, there is a severe lack of soil on the property for the purpose of adequately burying dead bodies. In fact, the geology is all wrong, and they have to escavate thousands of tonnes of sandstone rock and try to crush it and treat it to manufacture the soil. The "treatment" proposed sterilises the Earth and ruins its capacity to act as a cemetery. It creates a dead synthetic barrier by mixing sterile bedrock with clay and potentially adding lime or cement chemical stabilisers, which will kill off any remaining top soil bacteria, organic fungi and soil microbes. Instead of creating a healthy, absorbent loom that can capture and safely break down cadeva leachates, this treatment turns into a dense heavily packed road subbase.
I recall the geotechnical report for the original concept approval, the warnings were explicit that the jointed hawksbury sandstone at this site, likely features micro-fractures caused by mine subsidence, meaning the bedrock cannot be trusted to act as a safe filter. The developer intends to place an unlined 98% compacted rock plug directly on top for this fractured bedrock shelf. Because of the compacted fill itself cannot absorb the fluid the highly concentrated aeropic leachate will pool at the bottom of the 2.85 m grave. Over time, gravity will force this liquid through the base. The risk is substantial and that it will enter open mind subsidance. Fractures, which will have been made worse by the extensive hydraulic hammering and flow directly into the local groundwater table as untreated pollution. We don't trust any so-called monitoring of wells or any other measures they promise before approval, as they have never yet delivered on anything they have promised and have a long track record over many years of destroying their habitat on that block, until it's almost despite many of us contacting the council to please keep an eye on what is going over there. Even worse, we are told that nearly half of the burial space will be taken up by people of Islamic faith, Islamic law dictate that deceased should be wrapped strictly in a simple, plain white cloth or linen fabric shroud (Kafan), in place directly into the Earth, the burial of thousands of bodies without a coffin. In this highly constrained, burial environment is an extremely alarming prospect for the safety of Douglas park, ecology and residents. We are very worried as during heavy rain events, stormwater floods, the tributaries that run across the road from the site in underground gradients follow the same trajectory down toward the river, just behind us. My daughter is a wildlife carer here for WIRES and we are extremely worried about the effect that months of excavation, jack hammering, crushing rocks plus crematorium, soil and water pollution will have on the integrity of our Bushland home, nutrition (leaves/grass) needed from surrounding flora that is collected daily for animals in care and ability to continue and provide safe refuge. We wish this developer would finally just give up and trying to transform our beautiful Nepean River setting into a monsterous graveyard that will not benefit anyone here, only destroy our homes and clog our already challenging roadways. He's not solving a burial crisis, he's creating an ecological crisis here for financial gain. Thank you for your time.
Kind regards
Greg Perrott, Carina Perry, Jasmin Gardener, Robyn Kingston

The local infrastructure cannot support the demand that this project will bring into the area. Douglas park Drive coming through the gorge is a one-way road and cannot support more cars than is currently on it.
The wildlife is going to be DESTROYED with this going ahead. The local koala habitats will be destroyed, along with many other animal species in the area. Getting rid of so many thousands of trees for this project.

I understand that the native vegetation on the property was cleared circa 2003/05 without the necessary approvals or permissions. At the time of clearing the native vegetation on the site was identified as a threatened ecological community described as Shale Sandstone Transition Forest, a Cumberland Plains plant assemblage that has subsequently been declared a critically endangered ecological community.

The native forest on the lot was also identified as koala habitat and remains as such in the Cumberland Plain Conservation Plan.

it is my understanding that there is no 'statute of limitations' for action to be taken in the NSW Land and Environment Court to order the remediation of the property. Similarly, despite the clearing being some time ago, there remains the possibility that a prosecution may be possible if Council can prove it has only recently become aware of the clearing.

Before any development approval assessment can be finalised it is suggested prudent that clarification be sought from the Consent Authority as to whether any action is afoot or alive in relation to remediation or prosecution for the clearing of native vegetation on the property.