Name Withheld
Object
Name Withheld
Object
OAKDALE
,
New South Wales
Message
I am a resident of the Wollondilly Shire and strongly object to the proposed Douglas Park Memorial Park development.
While I understand the need for additional burial and memorial facilities across Greater Sydney, I do not believe this proposal is appropriate for Douglas Park or the wider Wollondilly region. My concerns relate to traffic and infrastructure, site suitability, environmental impacts, noise, loss of rural character, and the continued approval of major developments before essential infrastructure has been delivered.
Traffic and Road Infrastructure
My primary concern is the impact this development will have on local roads and infrastructure.
Wollondilly is already experiencing significant growth, yet many roads throughout the region remain inadequate, congested, or in need of upgrades. Residents are continually being asked to absorb additional development while infrastructure struggles to keep pace.
This proposal is not a small local cemetery. It is a large regional facility that will attract visitors from across Sydney and beyond. Funeral services, visitors, staff, contractors, maintenance vehicles and future crematorium-related traffic will all contribute to increased vehicle movements.
Approving developments of this scale before major improvements are made to existing road networks is backwards planning. Infrastructure should be delivered first, not promised after the fact.
Inappropriate Scale and Character
Douglas Park is valued for its rural character, open space and relatively low-density lifestyle.
This proposal introduces a large-scale regional memorial park including thousands of burial plots, a chapel, visitor facilities, administration buildings, parking areas, a café and future crematorium infrastructure.
The scale of the development is excessive for the locality and is inconsistent with the character that attracts people to live in Douglas Park and surrounding communities.
Residents should not be expected to continually sacrifice the rural nature of their area through the approval of increasingly large developments that primarily service populations outside the local community.
Site Suitability Concerns
I have concerns regarding the suitability of the site for long-term burial operations.
The Douglas Park and broader Wollondilly area is known for sandstone geology and rocky terrain. Given the scale of the proposed cemetery, I question whether this site represents an appropriate location for extensive burial infrastructure over the long term.
I am concerned about excavation requirements, land disturbance, groundwater impacts, drainage issues and the long-term suitability of the site.
Any geotechnical and environmental assessments should be subject to rigorous independent scrutiny before any approval is considered.
Environmental Impacts
The proposal is located within an area that currently supports native vegetation and wildlife.
The development will inevitably increase vehicle movements, human activity, noise and disturbance across a substantial area.
I am concerned about:
* Increased wildlife road strikes resulting from higher traffic volumes.
* Impacts on native vegetation and habitat connectivity.
* Disturbance to local wildlife.
* Potential impacts on drainage systems and groundwater.
* The cumulative environmental impacts associated with ongoing expansion and development throughout the Wollondilly region.
Environmental protection should be prioritised, particularly where existing natural values remain intact.
Noise and Amenity
The proposal will introduce ongoing operational activity into an area that is currently characterised by rural living.
Funeral services, visitor traffic, maintenance operations, landscaping works, deliveries and future crematorium activities will all contribute to increased noise and activity levels.
The peaceful nature of the area is one of its defining features. Residents should not be expected to accept a permanent reduction in amenity as a consequence of a development that serves a regional rather than local function.
Development is Outpacing Infrastructure
A recurring issue across Wollondilly is that development approvals continue to outpace the delivery of supporting infrastructure.
Residents are repeatedly told that growth is necessary, yet road upgrades, transport improvements and essential infrastructure often lag years behind development approvals.
Many existing issues remain unresolved, yet additional large-scale projects continue to be proposed.
The planning system should prioritise investment in infrastructure and community needs before approving developments that create further demand.
Conclusion
I do not support the Douglas Park Memorial Park proposal.
The development is inappropriate for the locality due to its scale, likely traffic impacts, pressure on existing infrastructure, concerns regarding site suitability, environmental impacts, increased noise and the loss of rural character.
Wollondilly residents should not be expected to continually absorb the impacts of major developments while infrastructure remains inadequate and existing concerns remain unresolved.
For these reasons, I respectfully request that the NSW Department of Planning refuse the application.
Thank you for considering this submission.
While I understand the need for additional burial and memorial facilities across Greater Sydney, I do not believe this proposal is appropriate for Douglas Park or the wider Wollondilly region. My concerns relate to traffic and infrastructure, site suitability, environmental impacts, noise, loss of rural character, and the continued approval of major developments before essential infrastructure has been delivered.
Traffic and Road Infrastructure
My primary concern is the impact this development will have on local roads and infrastructure.
Wollondilly is already experiencing significant growth, yet many roads throughout the region remain inadequate, congested, or in need of upgrades. Residents are continually being asked to absorb additional development while infrastructure struggles to keep pace.
This proposal is not a small local cemetery. It is a large regional facility that will attract visitors from across Sydney and beyond. Funeral services, visitors, staff, contractors, maintenance vehicles and future crematorium-related traffic will all contribute to increased vehicle movements.
Approving developments of this scale before major improvements are made to existing road networks is backwards planning. Infrastructure should be delivered first, not promised after the fact.
Inappropriate Scale and Character
Douglas Park is valued for its rural character, open space and relatively low-density lifestyle.
This proposal introduces a large-scale regional memorial park including thousands of burial plots, a chapel, visitor facilities, administration buildings, parking areas, a café and future crematorium infrastructure.
The scale of the development is excessive for the locality and is inconsistent with the character that attracts people to live in Douglas Park and surrounding communities.
Residents should not be expected to continually sacrifice the rural nature of their area through the approval of increasingly large developments that primarily service populations outside the local community.
Site Suitability Concerns
I have concerns regarding the suitability of the site for long-term burial operations.
The Douglas Park and broader Wollondilly area is known for sandstone geology and rocky terrain. Given the scale of the proposed cemetery, I question whether this site represents an appropriate location for extensive burial infrastructure over the long term.
I am concerned about excavation requirements, land disturbance, groundwater impacts, drainage issues and the long-term suitability of the site.
Any geotechnical and environmental assessments should be subject to rigorous independent scrutiny before any approval is considered.
Environmental Impacts
The proposal is located within an area that currently supports native vegetation and wildlife.
The development will inevitably increase vehicle movements, human activity, noise and disturbance across a substantial area.
I am concerned about:
* Increased wildlife road strikes resulting from higher traffic volumes.
* Impacts on native vegetation and habitat connectivity.
* Disturbance to local wildlife.
* Potential impacts on drainage systems and groundwater.
* The cumulative environmental impacts associated with ongoing expansion and development throughout the Wollondilly region.
Environmental protection should be prioritised, particularly where existing natural values remain intact.
Noise and Amenity
The proposal will introduce ongoing operational activity into an area that is currently characterised by rural living.
Funeral services, visitor traffic, maintenance operations, landscaping works, deliveries and future crematorium activities will all contribute to increased noise and activity levels.
The peaceful nature of the area is one of its defining features. Residents should not be expected to accept a permanent reduction in amenity as a consequence of a development that serves a regional rather than local function.
Development is Outpacing Infrastructure
A recurring issue across Wollondilly is that development approvals continue to outpace the delivery of supporting infrastructure.
Residents are repeatedly told that growth is necessary, yet road upgrades, transport improvements and essential infrastructure often lag years behind development approvals.
Many existing issues remain unresolved, yet additional large-scale projects continue to be proposed.
The planning system should prioritise investment in infrastructure and community needs before approving developments that create further demand.
Conclusion
I do not support the Douglas Park Memorial Park proposal.
The development is inappropriate for the locality due to its scale, likely traffic impacts, pressure on existing infrastructure, concerns regarding site suitability, environmental impacts, increased noise and the loss of rural character.
Wollondilly residents should not be expected to continually absorb the impacts of major developments while infrastructure remains inadequate and existing concerns remain unresolved.
For these reasons, I respectfully request that the NSW Department of Planning refuse the application.
Thank you for considering this submission.
Name Withheld
Object
Name Withheld
Object
DOUGLAS PARK
,
New South Wales
Message
I am writing to formally oppose the proposed cemetery development in Douglas Park. The scale, location, and environmental risks associated with this proposal are fundamentally incompatible with the character, safety, and wellbeing of our rural village.
1. Misleading Use of the Term “Memorial Park”
The proposal repeatedly refers to the development as a “memorial park”, which is misleading and minimises the true nature and scale of what is being proposed. This is not a park in any sense that the community understands the term. A park is a freely accessible public space used for recreation, play, exercise, and community gathering. What is being proposed is a cemetery and crematorium complex - a land use with a completely different purpose, impact, and community perception.
Using softened terminology does not change the reality that this is a large scale cemetery intended to service metropolitan Sydney. Calling it a “memorial park” attempts to sugar coat the proposal and obscure the significant environmental, social, and infrastructure impacts it will impose on Douglas Park. The community deserves transparency, not rebranding.
2. Traffic Impacts, Safety Risks, and the Vulnerability of Douglas Park Drive
The proposed cemetery would dramatically increase traffic volumes travelling from Sydney and surrounding metropolitan areas, funnelling large numbers of vehicles through Douglas Park and across the gorge via Douglas Park Drive. This includes funeral processions, visitors, contractors, service vehicles, and heavy vehicles associated with cemetery operations. The existing road network is already strained, and the gorge road in particular is in a fragile condition.
The Douglas Park Gorge is a known weak point in the local transport network. It already requires significant upgrades simply to remain open, yet Council has publicly acknowledged that it does not currently have the funding required to undertake the necessary works. Any increase in traffic - especially sustained, high volume traffic from outside the region - will accelerate the deterioration of Douglas Park Drive.
If the road were to fail or be closed for safety reasons, Douglas Park would effectively be split in half. Residents would face long detours, emergency services response times would increase, and the social and economic functioning of the town would be severely disrupted. Approving a development that places additional pressure on an already vulnerable piece of infrastructure is irresponsible and contrary to the long term interests of the community.
The cemetery proposal would not only worsen existing traffic and safety issues but also heighten the risk of a major infrastructure failure that would isolate parts of the town and significantly impact daily life for residents.
3. Overshadowing of the Rural Village and Loss of Amenity
Douglas Park is a small rural town with a strong sense of identity, open landscapes, and a lifestyle centred around peace, space, and connection to the natural environment. A large metropolitan servicing cemetery would dominate the landscape and overshadow the character of our village.
The scale and intensity of the proposal are entirely out of proportion with the surrounding land uses. It would significantly diminish the rural lifestyle that residents value and have chosen to invest in. Property values are likely to be negatively affected due to the industrial scale nature of the development, increased traffic, visual impacts, and the loss of the quiet rural setting that defines Douglas Park.
4. Geotechnical Concerns: Shallow Soil Depth, Bedrock, and Groundwater
The proposed site is geologically unsuitable for a cemetery. The area is known for shallow soils, limited depth to bedrock, and complex groundwater pathways. These conditions raise serious concerns about the ability to safely manage burial practices without risking contamination.
The proximity to the Nepean River - one of the region’s most important waterways - makes this risk even more unacceptable. Inadequate soil depth and shallow bedrock reduce the natural filtration capacity required to protect groundwater. Any leachate or contamination from burial sites could migrate toward the river system, posing long term environmental and public health risks.
5. Crematorium Emissions and Unsuitable Topography
The inclusion of a crematorium is particularly inappropriate for this location. The site sits above the gorge, where the topography naturally channels air movement downward. Smoke, ash, and particulate pollution from cremation processes would settle into the gorge, the Nepean River corridor, and the village of Douglas Park.
This is not a suitable environment for dispersing emissions. Instead, the geography increases the likelihood that pollutants will accumulate in low lying areas, affecting air quality for residents, local wildlife, and the river ecosystem. The health and environmental implications of this cannot be understated.
6. Resubmission of a Previously Rejected Proposal
It is also important to acknowledge that a similar proposal has already been rejected by both the community and Council. The developer has simply rebranded the project, made minimal changes, and resubmitted it under a new name in an attempt to bypass local opposition and secure approval from higher level decision makers who may have little understanding of, or regard for, the residents of Douglas Park.
This pattern of resubmission shows a clear disregard for the community’s previously expressed concerns. It undermines the integrity of the planning process and places local residents in the position of having to repeatedly defend their town against a development they have already rejected. The proposal remains fundamentally unsuitable, regardless of how many times it is repackaged.
7. Incompatibility with the Community and Local Planning Intent
Douglas Park is not designated for large scale metropolitan infrastructure of this nature. The proposal is inconsistent with the established planning vision for the area, which prioritises rural character, environmental protection, and community wellbeing. A development of this magnitude would fundamentally alter the identity of the town and impose long term impacts that residents do not support.
Conclusion
For the reasons outlined above - the misleading presentation of the development as a “memorial park,” the traffic and safety risks, the vulnerability of the gorge, the loss of rural amenity, environmental and groundwater concerns, unsuitable topography for crematorium emissions, the resubmission of a previously rejected proposal, and the incompatibility with the character and planning intent of Douglas Park - I strongly oppose the proposed cemetery development.
This proposal is not appropriate for our community, our environment, or the long term health and safety of residents and the Nepean River.
1. Misleading Use of the Term “Memorial Park”
The proposal repeatedly refers to the development as a “memorial park”, which is misleading and minimises the true nature and scale of what is being proposed. This is not a park in any sense that the community understands the term. A park is a freely accessible public space used for recreation, play, exercise, and community gathering. What is being proposed is a cemetery and crematorium complex - a land use with a completely different purpose, impact, and community perception.
Using softened terminology does not change the reality that this is a large scale cemetery intended to service metropolitan Sydney. Calling it a “memorial park” attempts to sugar coat the proposal and obscure the significant environmental, social, and infrastructure impacts it will impose on Douglas Park. The community deserves transparency, not rebranding.
2. Traffic Impacts, Safety Risks, and the Vulnerability of Douglas Park Drive
The proposed cemetery would dramatically increase traffic volumes travelling from Sydney and surrounding metropolitan areas, funnelling large numbers of vehicles through Douglas Park and across the gorge via Douglas Park Drive. This includes funeral processions, visitors, contractors, service vehicles, and heavy vehicles associated with cemetery operations. The existing road network is already strained, and the gorge road in particular is in a fragile condition.
The Douglas Park Gorge is a known weak point in the local transport network. It already requires significant upgrades simply to remain open, yet Council has publicly acknowledged that it does not currently have the funding required to undertake the necessary works. Any increase in traffic - especially sustained, high volume traffic from outside the region - will accelerate the deterioration of Douglas Park Drive.
If the road were to fail or be closed for safety reasons, Douglas Park would effectively be split in half. Residents would face long detours, emergency services response times would increase, and the social and economic functioning of the town would be severely disrupted. Approving a development that places additional pressure on an already vulnerable piece of infrastructure is irresponsible and contrary to the long term interests of the community.
The cemetery proposal would not only worsen existing traffic and safety issues but also heighten the risk of a major infrastructure failure that would isolate parts of the town and significantly impact daily life for residents.
3. Overshadowing of the Rural Village and Loss of Amenity
Douglas Park is a small rural town with a strong sense of identity, open landscapes, and a lifestyle centred around peace, space, and connection to the natural environment. A large metropolitan servicing cemetery would dominate the landscape and overshadow the character of our village.
The scale and intensity of the proposal are entirely out of proportion with the surrounding land uses. It would significantly diminish the rural lifestyle that residents value and have chosen to invest in. Property values are likely to be negatively affected due to the industrial scale nature of the development, increased traffic, visual impacts, and the loss of the quiet rural setting that defines Douglas Park.
4. Geotechnical Concerns: Shallow Soil Depth, Bedrock, and Groundwater
The proposed site is geologically unsuitable for a cemetery. The area is known for shallow soils, limited depth to bedrock, and complex groundwater pathways. These conditions raise serious concerns about the ability to safely manage burial practices without risking contamination.
The proximity to the Nepean River - one of the region’s most important waterways - makes this risk even more unacceptable. Inadequate soil depth and shallow bedrock reduce the natural filtration capacity required to protect groundwater. Any leachate or contamination from burial sites could migrate toward the river system, posing long term environmental and public health risks.
5. Crematorium Emissions and Unsuitable Topography
The inclusion of a crematorium is particularly inappropriate for this location. The site sits above the gorge, where the topography naturally channels air movement downward. Smoke, ash, and particulate pollution from cremation processes would settle into the gorge, the Nepean River corridor, and the village of Douglas Park.
This is not a suitable environment for dispersing emissions. Instead, the geography increases the likelihood that pollutants will accumulate in low lying areas, affecting air quality for residents, local wildlife, and the river ecosystem. The health and environmental implications of this cannot be understated.
6. Resubmission of a Previously Rejected Proposal
It is also important to acknowledge that a similar proposal has already been rejected by both the community and Council. The developer has simply rebranded the project, made minimal changes, and resubmitted it under a new name in an attempt to bypass local opposition and secure approval from higher level decision makers who may have little understanding of, or regard for, the residents of Douglas Park.
This pattern of resubmission shows a clear disregard for the community’s previously expressed concerns. It undermines the integrity of the planning process and places local residents in the position of having to repeatedly defend their town against a development they have already rejected. The proposal remains fundamentally unsuitable, regardless of how many times it is repackaged.
7. Incompatibility with the Community and Local Planning Intent
Douglas Park is not designated for large scale metropolitan infrastructure of this nature. The proposal is inconsistent with the established planning vision for the area, which prioritises rural character, environmental protection, and community wellbeing. A development of this magnitude would fundamentally alter the identity of the town and impose long term impacts that residents do not support.
Conclusion
For the reasons outlined above - the misleading presentation of the development as a “memorial park,” the traffic and safety risks, the vulnerability of the gorge, the loss of rural amenity, environmental and groundwater concerns, unsuitable topography for crematorium emissions, the resubmission of a previously rejected proposal, and the incompatibility with the character and planning intent of Douglas Park - I strongly oppose the proposed cemetery development.
This proposal is not appropriate for our community, our environment, or the long term health and safety of residents and the Nepean River.
Name Withheld
Object
Name Withheld
Object
DOUGLAS PARK
,
New South Wales
Message
I am writing to formally object to the proposed cemetery development in Douglas Park, NSW.
As a resident and community member, I have serious concerns regarding the suitability of this proposal and the long-term impacts it may have on Douglas Park, surrounding rural communities, local infrastructure, and the natural environment.
My concerns include the following:
• Traffic and road safety impacts
The proposed cemetery is likely to generate a substantial increase in vehicle movements, including funeral processions, heavy vehicles, maintenance traffic, and visitor traffic on a regular basis. Roads in and around Douglas Park are already limited in capacity, with many being narrow rural roads that are not designed to accommodate significant additional traffic volumes. Increased congestion at intersections and on local roads could create serious safety risks for residents, school buses, cyclists, pedestrians, and emergency service vehicles. Large funeral gatherings and peak visitation periods may further worsen traffic conditions and parking issues in surrounding areas. Although the train station is close by, it is not in walking distance and there are no other forms of public transport that would take people to the cemetery.
• Environmental and groundwater concerns
Douglas Park contains environmentally sensitive land and waterways, and there are serious concerns regarding the potential impact of cemetery operations on groundwater systems, drainage patterns, soil stability, and nearby creeks and watercourses. Cemeteries can create long-term contamination risks through burial practices, chemicals, and disturbed soil conditions, particularly where groundwater tables are high or where flooding may occur. There are also concerns regarding the removal of native vegetation, impacts on wildlife habitat, increased erosion, and the long-term environmental consequences of developing large areas of currently undeveloped or rural land.
• Flooding and drainage issues
Parts of the Douglas Park region are already subject to drainage challenges during heavy rainfall events. Large-scale land alteration associated with cemetery construction, roads, car parks, and associated infrastructure may worsen stormwater runoff, flooding, and erosion both on-site and downstream. There is concern that existing drainage infrastructure may not be adequate to manage these impacts safely over the long term.
• Incompatibility with the rural-residential character of Douglas Park
Douglas Park is valued for its semi-rural character, open landscapes, low-density living, and peaceful environment. A major cemetery development, including funeral services, traffic increases, lighting, signage, and ongoing commercial activity, would significantly alter the character of the area and may negatively affect the lifestyle and amenity currently enjoyed by residents. This proposal appears inconsistent with the existing character and intended planning outcomes for the locality.
• Insufficient infrastructure and servicing capacity
There are concerns that the local road network and supporting infrastructure are not equipped to accommodate a development of this scale. Questions remain regarding water management, waste management, traffic handling, emergency access, long-term maintenance obligations, and whether local infrastructure upgrades would be required at public expense. The proposal may place additional pressure on already limited community infrastructure and council resources. We don’t even have sewer infrastructure in the area. If this proposal were to proceed, I believe there would need to be a significant developer contribution to upgrade the Douglas Park Gorge Road to enable appropriate access to the cemetery.
• Impacts on nearby residents and property amenity
Residents living near the proposed site may experience ongoing impacts from increased traffic, noise associated with funeral services and maintenance operations, lighting, public visitation, and changes to the visual landscape. Frequent large gatherings and associated activity could reduce the quiet enjoyment of nearby properties and alter the existing residential and rural amenity of the area. There are also concerns about potential impacts on property values and the attractiveness of the area for existing and future residents.
• Long-term planning and cumulative impacts
A development of this nature would permanently change the use and future planning direction of the area. Once established, the cemetery and associated infrastructure could expand over time or encourage further incompatible development nearby. Residents are concerned about the long-term cumulative impacts on Douglas Park’s identity, environment, infrastructure, and future land use planning.
Given the significant concerns outlined above, I respectfully request that the NSW State Government and the relevant planning authorities reject this proposal. At minimum, I believe the traffic impacts require a comprehensive assessment if approval is considered as I don’t not believe the provided reports express the current traffic constraints. I also request that the State Government give proper consideration to the strong community opposition and whether more appropriate alternative locations exist for a development of this scale.
Thank you for considering the concerns of local residents and the wider community.
Kind regards,
Douglas Park Resident
As a resident and community member, I have serious concerns regarding the suitability of this proposal and the long-term impacts it may have on Douglas Park, surrounding rural communities, local infrastructure, and the natural environment.
My concerns include the following:
• Traffic and road safety impacts
The proposed cemetery is likely to generate a substantial increase in vehicle movements, including funeral processions, heavy vehicles, maintenance traffic, and visitor traffic on a regular basis. Roads in and around Douglas Park are already limited in capacity, with many being narrow rural roads that are not designed to accommodate significant additional traffic volumes. Increased congestion at intersections and on local roads could create serious safety risks for residents, school buses, cyclists, pedestrians, and emergency service vehicles. Large funeral gatherings and peak visitation periods may further worsen traffic conditions and parking issues in surrounding areas. Although the train station is close by, it is not in walking distance and there are no other forms of public transport that would take people to the cemetery.
• Environmental and groundwater concerns
Douglas Park contains environmentally sensitive land and waterways, and there are serious concerns regarding the potential impact of cemetery operations on groundwater systems, drainage patterns, soil stability, and nearby creeks and watercourses. Cemeteries can create long-term contamination risks through burial practices, chemicals, and disturbed soil conditions, particularly where groundwater tables are high or where flooding may occur. There are also concerns regarding the removal of native vegetation, impacts on wildlife habitat, increased erosion, and the long-term environmental consequences of developing large areas of currently undeveloped or rural land.
• Flooding and drainage issues
Parts of the Douglas Park region are already subject to drainage challenges during heavy rainfall events. Large-scale land alteration associated with cemetery construction, roads, car parks, and associated infrastructure may worsen stormwater runoff, flooding, and erosion both on-site and downstream. There is concern that existing drainage infrastructure may not be adequate to manage these impacts safely over the long term.
• Incompatibility with the rural-residential character of Douglas Park
Douglas Park is valued for its semi-rural character, open landscapes, low-density living, and peaceful environment. A major cemetery development, including funeral services, traffic increases, lighting, signage, and ongoing commercial activity, would significantly alter the character of the area and may negatively affect the lifestyle and amenity currently enjoyed by residents. This proposal appears inconsistent with the existing character and intended planning outcomes for the locality.
• Insufficient infrastructure and servicing capacity
There are concerns that the local road network and supporting infrastructure are not equipped to accommodate a development of this scale. Questions remain regarding water management, waste management, traffic handling, emergency access, long-term maintenance obligations, and whether local infrastructure upgrades would be required at public expense. The proposal may place additional pressure on already limited community infrastructure and council resources. We don’t even have sewer infrastructure in the area. If this proposal were to proceed, I believe there would need to be a significant developer contribution to upgrade the Douglas Park Gorge Road to enable appropriate access to the cemetery.
• Impacts on nearby residents and property amenity
Residents living near the proposed site may experience ongoing impacts from increased traffic, noise associated with funeral services and maintenance operations, lighting, public visitation, and changes to the visual landscape. Frequent large gatherings and associated activity could reduce the quiet enjoyment of nearby properties and alter the existing residential and rural amenity of the area. There are also concerns about potential impacts on property values and the attractiveness of the area for existing and future residents.
• Long-term planning and cumulative impacts
A development of this nature would permanently change the use and future planning direction of the area. Once established, the cemetery and associated infrastructure could expand over time or encourage further incompatible development nearby. Residents are concerned about the long-term cumulative impacts on Douglas Park’s identity, environment, infrastructure, and future land use planning.
Given the significant concerns outlined above, I respectfully request that the NSW State Government and the relevant planning authorities reject this proposal. At minimum, I believe the traffic impacts require a comprehensive assessment if approval is considered as I don’t not believe the provided reports express the current traffic constraints. I also request that the State Government give proper consideration to the strong community opposition and whether more appropriate alternative locations exist for a development of this scale.
Thank you for considering the concerns of local residents and the wider community.
Kind regards,
Douglas Park Resident
Name Withheld
Object
Name Withheld
Object
DOUGLAS PARK
,
New South Wales
Message
To Whom It May Concern,
RE: Objection to Proposed Douglas Park Memorial Park Cemetery and Crematorium Development.
I am writing to formally object to the proposed Douglas Park Memorial Park cemetery and crematorium development currently being assessed under the State Significant Development pathway.
I have lived in Douglas Park for 19 years and have seen firsthand the increasing pressure already placed on our local roads and infrastructure. Traffic in the area is bad enough as it is, particularly during peak times, and the proposed cemetery and crematorium will only make these problems significantly worse.
Douglas Park does not have immediate or direct access to the highway, and local roads are simply not designed to handle the volume of traffic this development would generate. Funeral processions, visitors, maintenance vehicles, and future crematorium operations will create constant congestion and traffic jams throughout the area. Access routes including The Gorge and surrounding rural roads are narrow, winding, and already struggle to cope with existing traffic from surrounding developments in Wilton and Appin.
I am extremely concerned that emergency services access and evacuation during bushfire events could also be negatively impacted by increased traffic congestion. Douglas Park is a bushfire-prone rural community, and adding a major development of this scale is irresponsible and unsafe.
The proposed site is also unsuitable due to poor infrastructure. The area lacks adequate sewerage, public transport, and other essential services required to support a development of this size. The rural character and peaceful lifestyle of Douglas Park will be permanently damaged if this project proceeds.
I am also concerned about the environmental suitability of the land itself. Community concerns have consistently highlighted that the site largely consists of sandstone rock shelf, requiring significant excavation and artificial soil preparation to allow for burials. This raises serious environmental and long-term sustainability concerns.
Furthermore, the crematorium component is inappropriate given its close proximity to residential homes. Many residents, including myself, believe this is incompatible with the surrounding rural residential environment and would negatively affect the amenity and wellbeing of the community.
Although the developer has reduced the proposed burial capacity, this does not resolve the major issues associated with the proposal. The development remains far too large and unsuitable for Douglas Park.
After nearly two decades living in this community, I strongly believe this development is in the wrong location and should either be relocated to a more suitable area with proper infrastructure or rejected entirely.
I respectfully ask the Department to seriously consider the overwhelming community opposition, traffic concerns, bushfire risks, environmental issues, and the long-term impact this development will have on Douglas Park residents before making any decision.
Thank you for considering my objection.
It's a hard pass.
RE: Objection to Proposed Douglas Park Memorial Park Cemetery and Crematorium Development.
I am writing to formally object to the proposed Douglas Park Memorial Park cemetery and crematorium development currently being assessed under the State Significant Development pathway.
I have lived in Douglas Park for 19 years and have seen firsthand the increasing pressure already placed on our local roads and infrastructure. Traffic in the area is bad enough as it is, particularly during peak times, and the proposed cemetery and crematorium will only make these problems significantly worse.
Douglas Park does not have immediate or direct access to the highway, and local roads are simply not designed to handle the volume of traffic this development would generate. Funeral processions, visitors, maintenance vehicles, and future crematorium operations will create constant congestion and traffic jams throughout the area. Access routes including The Gorge and surrounding rural roads are narrow, winding, and already struggle to cope with existing traffic from surrounding developments in Wilton and Appin.
I am extremely concerned that emergency services access and evacuation during bushfire events could also be negatively impacted by increased traffic congestion. Douglas Park is a bushfire-prone rural community, and adding a major development of this scale is irresponsible and unsafe.
The proposed site is also unsuitable due to poor infrastructure. The area lacks adequate sewerage, public transport, and other essential services required to support a development of this size. The rural character and peaceful lifestyle of Douglas Park will be permanently damaged if this project proceeds.
I am also concerned about the environmental suitability of the land itself. Community concerns have consistently highlighted that the site largely consists of sandstone rock shelf, requiring significant excavation and artificial soil preparation to allow for burials. This raises serious environmental and long-term sustainability concerns.
Furthermore, the crematorium component is inappropriate given its close proximity to residential homes. Many residents, including myself, believe this is incompatible with the surrounding rural residential environment and would negatively affect the amenity and wellbeing of the community.
Although the developer has reduced the proposed burial capacity, this does not resolve the major issues associated with the proposal. The development remains far too large and unsuitable for Douglas Park.
After nearly two decades living in this community, I strongly believe this development is in the wrong location and should either be relocated to a more suitable area with proper infrastructure or rejected entirely.
I respectfully ask the Department to seriously consider the overwhelming community opposition, traffic concerns, bushfire risks, environmental issues, and the long-term impact this development will have on Douglas Park residents before making any decision.
Thank you for considering my objection.
It's a hard pass.
Craig Butler
Object
Craig Butler
Object
DOUGLAS PARK
,
New South Wales
Message
Objection to SSD-68287712: Douglas Park Memorial Park (Concept Plan and Stage 1) – Cemetery and Crematorium Proposal at 430-490 Douglas Park Drive, Douglas Park, NSW. 
Submission to: NSW Department of Planning, Housing and Infrastructure (via Major Projects Portal). Exhibition closes 9 June 2026. 
I strongly object to the approval of this State Significant Development (SSD) for a large-scale cemetery, crematorium, chapel, vaults, and associated infrastructure. The proposal (revised to ~37,000 burial plots overall, with Stage 1 ~15,000) is unsuitable for the site due to fundamental conflicts with environmental, planning, infrastructure, safety, and community laws and policies. It should be refused or relocated. 
1. Biodiversity and Conservation Impacts – Inconsistent with Cumberland Plain Conservation Plan
The site impacts endangered ecological communities and habitat in an area protected under the Cumberland Plain Conservation Plan (CPCP). Reports indicate ~9.63 ha of endangered forest at risk, despite proponent claims of retaining >95% of trees. 
• This conflicts with the Biodiversity Conservation Act 2016 (BC Act) and the CPCP, which prioritises protection of the Cumberland Plain’s remaining vegetation for housing growth offsets and biodiversity corridors to 2056. 
• The project is a controlled action under the federal Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act, ID 2025/10343), requiring rigorous assessment. Clearing, fragmentation, and edge effects on koalas, arboreal mammals, reptiles, and birds violate avoidance and mitigation hierarchies. 
• Even with buffers, long-term operations (burials, maintenance, visitors) and potential crematorium emissions will degrade habitat. This fails the “avoid, minimise, offset” principles in the BC Act and SSD guidelines.
Request: Independent peer review of the Biodiversity Development Assessment Report (BDAR) and refusal if impacts are not fully avoided.
2. Unsuitable Geology, Soil, and Groundwater Risks
The site is a “sandstone rock shelf” requiring rock whipping/milling to create burial depth, which is impractical and risky. 
• Groundwater contamination and leachate risks from embalming fluids (formaldehyde), decomposition byproducts, and stormwater runoff. This threatens local aquifers and downstream waterways (Nepean River catchment). It contravenes Protection of the Environment Operations Act 1997 (POEO Act) water quality objectives and Water Management Act 2000.
• Inadequate soil depth and rock excavation generate silica dust, erosion, and sedimentation, breaching Environmental Planning and Assessment Act 1979 (EP&A Act) requirements for suitable land capability.
• Stormwater and wastewater management claims (roof capture, etc.) are insufficient for a site without sewerage. 
Cemeteries must demonstrate long-term containment; this site fails basic site suitability tests under NSW cemetery guidelines and environmental laws. 
3. Traffic, Access, and Infrastructure Deficiencies
No public transport; reliance on Douglas Park Drive and winding river causeways for processions (potentially hundreds of daily visitors for large multi-faith services up to 200-300 people). 
• Significant increases in traffic, noise, and safety risks on inadequate rural roads, conflicting with State Environmental Planning Policy (Transport and Infrastructure) 2021 and Austroads standards.
• Lack of sewerage, gas, and reliable services. Claims of on-site management do not meet Public Health Act and council infrastructure standards for high-visitation facilities. 
• Parking (~130 spaces) is inadequate for peak events.
This creates unacceptable cumulative impacts on the local road network and emergency access.
4. Bushfire Risk
The area is bushfire-prone. A cemetery/crematorium with public access, vegetation management challenges, and potential fuel loads (or reduced buffers) heightens risks to life, property, and firefighters. 
• Fails Planning for Bush Fire Protection 2019 (PBP) and Rural Fires Act 1997 requirements for Asset Protection Zones (APZs), access, water supply, and evacuation in a high-risk interface area.
• Operations during total fire bans or emergencies would be problematic.
5. Visual Amenity, Social, and Cultural Impacts
The development would industrialise a rural residential area, imposing a constant visual reminder of mortality on nearby homes and reducing amenity/property values. It conflicts with Wollondilly Shire’s character and local planning controls. 
• Aboriginal heritage (Dharawal/Gundungurra Country) and European history require proper assessment under the National Parks and Wildlife Act 1974 and Heritage Act 1977. Claims of “honouring” history do not substitute for full due diligence.
• Social Impact Assessment (SIA) must address community opposition, mental health, and sense of place per the Social Impact Assessment Guideline for State Significant Projects.
Wollondilly Shire Council and the community have consistently opposed the project. 
6. Planning and Procedural Concerns
• Inconsistency with local zoning and strategic plans: Cemeteries require careful siting; this overrides community expectations and prior council objections. 
• Scale (even reduced) and SSD classification appear designed to bypass local input. Previous approvals were rushed; revisions do not resolve core flaws. 
• Crematorium emissions (air quality, odours) raise POEO Act and EPA licence issues.
• Long-term perpetual care and renewable tenure raise questions under the Cemeteries and Crematoria Act 2013, especially on unsuitable land. 
Conclusion and Requested Outcomes
This proposal fails multiple tests under the EP&A Act (s 4.15 evaluation), BC Act, EPBC Act, POEO Act, bushfire planning, and infrastructure standards. It is not in the public interest. Greater Sydney’s burial needs should be met on more suitable sites with better access, services, and lower environmental sensitivity.
I request:
• Refusal of the Concept Plan and Stage 1.
• Full independent review of all technical reports (biodiversity, geotech, traffic, hydrology, bushfire, heritage).
• Public hearing and extension of exhibition if needed.
• Consideration of alternatives or relocation.
The community deserves protection from this incompatible development. Thank you for considering this objection.
Craig Butler
Sydney, NSW
References/Sources: NSW Planning Portal (SSD-68287712 documents), ABC reports, proponent site, community groups, relevant NSW legislation (EP&A Act, BC Act, etc.), CPCP, and cemetery guidelines. Additional objections from Wollondilly Council and residents should be given significant weight.
Submission to: NSW Department of Planning, Housing and Infrastructure (via Major Projects Portal). Exhibition closes 9 June 2026. 
I strongly object to the approval of this State Significant Development (SSD) for a large-scale cemetery, crematorium, chapel, vaults, and associated infrastructure. The proposal (revised to ~37,000 burial plots overall, with Stage 1 ~15,000) is unsuitable for the site due to fundamental conflicts with environmental, planning, infrastructure, safety, and community laws and policies. It should be refused or relocated. 
1. Biodiversity and Conservation Impacts – Inconsistent with Cumberland Plain Conservation Plan
The site impacts endangered ecological communities and habitat in an area protected under the Cumberland Plain Conservation Plan (CPCP). Reports indicate ~9.63 ha of endangered forest at risk, despite proponent claims of retaining >95% of trees. 
• This conflicts with the Biodiversity Conservation Act 2016 (BC Act) and the CPCP, which prioritises protection of the Cumberland Plain’s remaining vegetation for housing growth offsets and biodiversity corridors to 2056. 
• The project is a controlled action under the federal Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act, ID 2025/10343), requiring rigorous assessment. Clearing, fragmentation, and edge effects on koalas, arboreal mammals, reptiles, and birds violate avoidance and mitigation hierarchies. 
• Even with buffers, long-term operations (burials, maintenance, visitors) and potential crematorium emissions will degrade habitat. This fails the “avoid, minimise, offset” principles in the BC Act and SSD guidelines.
Request: Independent peer review of the Biodiversity Development Assessment Report (BDAR) and refusal if impacts are not fully avoided.
2. Unsuitable Geology, Soil, and Groundwater Risks
The site is a “sandstone rock shelf” requiring rock whipping/milling to create burial depth, which is impractical and risky. 
• Groundwater contamination and leachate risks from embalming fluids (formaldehyde), decomposition byproducts, and stormwater runoff. This threatens local aquifers and downstream waterways (Nepean River catchment). It contravenes Protection of the Environment Operations Act 1997 (POEO Act) water quality objectives and Water Management Act 2000.
• Inadequate soil depth and rock excavation generate silica dust, erosion, and sedimentation, breaching Environmental Planning and Assessment Act 1979 (EP&A Act) requirements for suitable land capability.
• Stormwater and wastewater management claims (roof capture, etc.) are insufficient for a site without sewerage. 
Cemeteries must demonstrate long-term containment; this site fails basic site suitability tests under NSW cemetery guidelines and environmental laws. 
3. Traffic, Access, and Infrastructure Deficiencies
No public transport; reliance on Douglas Park Drive and winding river causeways for processions (potentially hundreds of daily visitors for large multi-faith services up to 200-300 people). 
• Significant increases in traffic, noise, and safety risks on inadequate rural roads, conflicting with State Environmental Planning Policy (Transport and Infrastructure) 2021 and Austroads standards.
• Lack of sewerage, gas, and reliable services. Claims of on-site management do not meet Public Health Act and council infrastructure standards for high-visitation facilities. 
• Parking (~130 spaces) is inadequate for peak events.
This creates unacceptable cumulative impacts on the local road network and emergency access.
4. Bushfire Risk
The area is bushfire-prone. A cemetery/crematorium with public access, vegetation management challenges, and potential fuel loads (or reduced buffers) heightens risks to life, property, and firefighters. 
• Fails Planning for Bush Fire Protection 2019 (PBP) and Rural Fires Act 1997 requirements for Asset Protection Zones (APZs), access, water supply, and evacuation in a high-risk interface area.
• Operations during total fire bans or emergencies would be problematic.
5. Visual Amenity, Social, and Cultural Impacts
The development would industrialise a rural residential area, imposing a constant visual reminder of mortality on nearby homes and reducing amenity/property values. It conflicts with Wollondilly Shire’s character and local planning controls. 
• Aboriginal heritage (Dharawal/Gundungurra Country) and European history require proper assessment under the National Parks and Wildlife Act 1974 and Heritage Act 1977. Claims of “honouring” history do not substitute for full due diligence.
• Social Impact Assessment (SIA) must address community opposition, mental health, and sense of place per the Social Impact Assessment Guideline for State Significant Projects.
Wollondilly Shire Council and the community have consistently opposed the project. 
6. Planning and Procedural Concerns
• Inconsistency with local zoning and strategic plans: Cemeteries require careful siting; this overrides community expectations and prior council objections. 
• Scale (even reduced) and SSD classification appear designed to bypass local input. Previous approvals were rushed; revisions do not resolve core flaws. 
• Crematorium emissions (air quality, odours) raise POEO Act and EPA licence issues.
• Long-term perpetual care and renewable tenure raise questions under the Cemeteries and Crematoria Act 2013, especially on unsuitable land. 
Conclusion and Requested Outcomes
This proposal fails multiple tests under the EP&A Act (s 4.15 evaluation), BC Act, EPBC Act, POEO Act, bushfire planning, and infrastructure standards. It is not in the public interest. Greater Sydney’s burial needs should be met on more suitable sites with better access, services, and lower environmental sensitivity.
I request:
• Refusal of the Concept Plan and Stage 1.
• Full independent review of all technical reports (biodiversity, geotech, traffic, hydrology, bushfire, heritage).
• Public hearing and extension of exhibition if needed.
• Consideration of alternatives or relocation.
The community deserves protection from this incompatible development. Thank you for considering this objection.
Craig Butler
Sydney, NSW
References/Sources: NSW Planning Portal (SSD-68287712 documents), ABC reports, proponent site, community groups, relevant NSW legislation (EP&A Act, BC Act, etc.), CPCP, and cemetery guidelines. Additional objections from Wollondilly Council and residents should be given significant weight.
Heidi Seidel
Object
Heidi Seidel
Object
DOUGLAS PARK
,
New South Wales
Message
I write to formally object to the proposed State Significant cemetery and crematorium development at Douglas Park on environmental, planning, public health, traffic, and social equity grounds.
The proposal is fundamentally incompatible with the ecological sensitivity, rural character, and infrastructure limitations of the Douglas Park area and should be refused.
The proposal is inconsistent with the Cumberland Plain Conservation Plan. Approximately 9.63 hectares of endangered forest are proposed to be impacted, including Cumberland Plain Woodland and Shale Sandstone Transition Forest. The operation of a cemetery and crematorium facility inherently involves ongoing soil disturbance, water contamination risks, atmospheric pollution, and destructive “edge effects” that threaten not only impacted areas but also surrounding retained vegetation communities.
Further concern arises from the developer’s documented history of bushland destruction on the site, which undermines confidence in the effectiveness of any proposed mitigation or environmental management measures.
The proposal also places the Nepean River catchment at unacceptable risk. The site is characterised by a shallow sandstone rock shelf with average soil depths of only approximately 0.7–0.9 metres. Coffins buried above fractured sandstone geology create a substantial risk that decomposition fluids may leach into tributaries flowing into nearby waterways.
The developer cannot guarantee that historical mine subsidence and associated micro-fracturing beneath the site will not facilitate contamination of groundwater systems. Repeated excavation activities are likely to increase these risks over time.
Importantly, the proposal fails to satisfy six out of the ten site suitability guidelines established by Cemeteries and Crematoria NSW. Specifically:
The site is immediately adjacent to residential areas.
The site is not easily accessible to cemetery visitors due to the absence of public transport and the severe traffic constraints associated with Douglas Park Drive, the gorge crossing, and the M31/Picton Road interchange.
The site is subject to significant noise impacts from adjoining major roads, particularly the Hume Highway.
The site is located within a high bushfire risk zone.
The site has insufficient soil depth to ensure the required minimum burial depth of 900mm beneath natural surface level.
Also, please note the water table level compared to the burial depth proposed. The bodies with be below the water table and therefore contaminate the local water ways and my place, opposite the site.
The site contains threatened ecological communities, including Cumberland Plain Woodland and Shale Sandstone Transition Forest.
Previous concept approval by the local planning panel specifically prohibited the use of the site for a crematorium “in the interests of the public” and to preserve the amenity of the neighbourhood. This position remains entirely valid.
Crematoriums are industrial-scale facilities that emit toxic pollutants and should not be situated near residential communities or environmentally sensitive conservation areas. The topography of the Douglas Park Gorge, including an elevation drop of approximately 70 metres, creates a heightened risk of temperature inversions and “valley trap” effects that may concentrate pollutants within surrounding residential and ecological areas.
The industrial scale of the proposed State Significant development and the traffic volumes it would generate are also inconsistent with the objectives of the Wollondilly Local Environmental Plan 2011, which seeks to preserve and protect the rural character of the Shire.
Traffic and accessibility impacts have been significantly understated in the proposal documentation. The development lacks public transport access, creating inequitable access for elderly residents, low-income earners, and young people, and disadvantaging vulnerable members of the community.
The proposed shuttle bus solution is impractical and fails to adequately address the limitations of the surrounding road network. The report does not properly acknowledge the three-tonne limit associated with the gorge crossing, the approximately 14-kilometre distance from Picton train station, or the severe congestion already experienced at the M31/Picton Road interchange.
The traffic modelling also fails to adequately account for the reality that funeral attendees arrive concurrently, resulting in concentrated traffic movements and significant bottlenecks. This is particularly problematic for funeral corteges and would create unacceptable impacts on local residents and road users.
For all the reasons outlined above, I strongly object to the proposed Douglas Park cemetery and crematorium development and respectfully request that the application be refused.
The proposal is fundamentally incompatible with the ecological sensitivity, rural character, and infrastructure limitations of the Douglas Park area and should be refused.
The proposal is inconsistent with the Cumberland Plain Conservation Plan. Approximately 9.63 hectares of endangered forest are proposed to be impacted, including Cumberland Plain Woodland and Shale Sandstone Transition Forest. The operation of a cemetery and crematorium facility inherently involves ongoing soil disturbance, water contamination risks, atmospheric pollution, and destructive “edge effects” that threaten not only impacted areas but also surrounding retained vegetation communities.
Further concern arises from the developer’s documented history of bushland destruction on the site, which undermines confidence in the effectiveness of any proposed mitigation or environmental management measures.
The proposal also places the Nepean River catchment at unacceptable risk. The site is characterised by a shallow sandstone rock shelf with average soil depths of only approximately 0.7–0.9 metres. Coffins buried above fractured sandstone geology create a substantial risk that decomposition fluids may leach into tributaries flowing into nearby waterways.
The developer cannot guarantee that historical mine subsidence and associated micro-fracturing beneath the site will not facilitate contamination of groundwater systems. Repeated excavation activities are likely to increase these risks over time.
Importantly, the proposal fails to satisfy six out of the ten site suitability guidelines established by Cemeteries and Crematoria NSW. Specifically:
The site is immediately adjacent to residential areas.
The site is not easily accessible to cemetery visitors due to the absence of public transport and the severe traffic constraints associated with Douglas Park Drive, the gorge crossing, and the M31/Picton Road interchange.
The site is subject to significant noise impacts from adjoining major roads, particularly the Hume Highway.
The site is located within a high bushfire risk zone.
The site has insufficient soil depth to ensure the required minimum burial depth of 900mm beneath natural surface level.
Also, please note the water table level compared to the burial depth proposed. The bodies with be below the water table and therefore contaminate the local water ways and my place, opposite the site.
The site contains threatened ecological communities, including Cumberland Plain Woodland and Shale Sandstone Transition Forest.
Previous concept approval by the local planning panel specifically prohibited the use of the site for a crematorium “in the interests of the public” and to preserve the amenity of the neighbourhood. This position remains entirely valid.
Crematoriums are industrial-scale facilities that emit toxic pollutants and should not be situated near residential communities or environmentally sensitive conservation areas. The topography of the Douglas Park Gorge, including an elevation drop of approximately 70 metres, creates a heightened risk of temperature inversions and “valley trap” effects that may concentrate pollutants within surrounding residential and ecological areas.
The industrial scale of the proposed State Significant development and the traffic volumes it would generate are also inconsistent with the objectives of the Wollondilly Local Environmental Plan 2011, which seeks to preserve and protect the rural character of the Shire.
Traffic and accessibility impacts have been significantly understated in the proposal documentation. The development lacks public transport access, creating inequitable access for elderly residents, low-income earners, and young people, and disadvantaging vulnerable members of the community.
The proposed shuttle bus solution is impractical and fails to adequately address the limitations of the surrounding road network. The report does not properly acknowledge the three-tonne limit associated with the gorge crossing, the approximately 14-kilometre distance from Picton train station, or the severe congestion already experienced at the M31/Picton Road interchange.
The traffic modelling also fails to adequately account for the reality that funeral attendees arrive concurrently, resulting in concentrated traffic movements and significant bottlenecks. This is particularly problematic for funeral corteges and would create unacceptable impacts on local residents and road users.
For all the reasons outlined above, I strongly object to the proposed Douglas Park cemetery and crematorium development and respectfully request that the application be refused.
Name Withheld
Object
Name Withheld
Object
DOUGLAS PARK
,
New South Wales
Message
1. Drainage will be a problem and it will spill on the neighbouring residents and causes pollution to the neighbouring lands and to the river at the gorge
2. Traffic infrastructure in the area cannot support such development and it will cost the council to provide suitable infrastructure
3. The gorge at Douglas Park cannot support the resulting traffic flow. The Picton road-Almond St intersection is very dangerous for existing traffic
4. The area has black cockatoos which will be affected
5. The area is rural with many residents. The development is unsuitable for such area and it will lower the value of the properties in the area.
6. There is no need for additional cemetories as others exist in neighbouring areas.
2. Traffic infrastructure in the area cannot support such development and it will cost the council to provide suitable infrastructure
3. The gorge at Douglas Park cannot support the resulting traffic flow. The Picton road-Almond St intersection is very dangerous for existing traffic
4. The area has black cockatoos which will be affected
5. The area is rural with many residents. The development is unsuitable for such area and it will lower the value of the properties in the area.
6. There is no need for additional cemetories as others exist in neighbouring areas.
Name Withheld
Comment
Name Withheld
Comment
CAMPBELLTOWN
,
New South Wales
Message
To Whom It May Concern,
I frequent the Douglas Park area very often and will be adversely affected if the cemetery and crematorium development is passed. I would like to register my objections to the DA based on my reading of the Traffic Assessment. I’ve assessed its many shortcomings and highlighting the ways in which it is in breach of relevant legislation.
There are several parts to the document which fail to comply with the SEARS contravening the EP&A Act and the EP&A Regulation (2021) and even though state law overrides local, relevant LEP instruments they should still be considered in my opinion. The report must provide a lawful, accurate assessment of localized environmental and infrastructure impacts and it has failed to meet this objective.
Claims that the development is compliant with the Greater Macarthur 2040 regional plan and the Wollondilly Development control plan are false as there is no public transport to the site, nor is there pedestrian or bicycle access.
Traffic counts during peak hours at nearby intersections were carried out on a single Tuesday and Saturday during the July school holidays in 2024, during the AM and PM peak hour periods. This is in breach of Section 10.6(1) of the Environmental Planning and Assessment Act 1979 which clearly states that a person must not provide information in connection with a planning matter that the “person knows, or ought reasonably to know, is false or misleading”. By using a holiday period where regional traffic can drop by up to thirty percent, a non-compliant EIS has been submitted, because projections for future vehicle counts will not be representative of normal conditions. There is a general failure to account for the pattern or platoon of vehicular arrivals and departures for cemetery clientele and instead 24-hour traffic counts feature as sufficient to convey the traffic volume of the surrounding network. This method is utterly inadequate in addressing the most critically affected road leading to the Site – the Douglas Park Nepean River causeway. Estimates for up to “six services per day with an average of 60-80 visitors per service” are given, projecting a maximum of 202 vehicles per day, using a 3-visitors-per car calculation. This does not align with the projections which feature in other reports, namely the Social Impact Assessment which projects a possible “up to 300 people” for an Islamic service and this particular faith is seeking 40% of the burial capacity at the facility.
One hundred and thirty-one car spaces vastly underestimate the required amount when considering the above potential numbers. Visitors will be forced to circle the nearby streets, and up and down the 80km Douglas Park Drive trying to find a spot to park. Very unsafe.
Section 2.121 of the State Environmental Planning Policy (Transport and Infrastructure) 2021 requires a full evaluation of traffic efficiency and safety. However, this report offers scrutiny of only three intersections, two of them inconsequential, while the one-way hairpin bends of the gorge were entirely omitted, as was the similar Broughton Pass gorge that is negotiated if travelling from Appin. A large funeral attracting visitors from Sydney arriving at once, at any hour of the day, much less peak hour, will completely block the gorge, leading to frustration and altercations as people miss a farewell service for loved ones. It is an absurd proposition to locate a business of this nature in this location. The planner tries to indicate that the Hume Highway is in close proximity and will remedy any of these problems but doesn’t mention the fact that it is a nearly 12km journey from the turn off to Picton Road, with this juncture being an infamous bottleneck as well, operating at a Los E or F during peak hours. Considering the above, the author’s judgement that the Site is “convenient…to the local road network serving the region is false and an abdication of his responsibility to provide a true and accurate assessment.
The planner assumes that no traffic will use the gorge to get to the Site. Not one car. This is really a puzzling attempt at modelling the traffic flow with no reason given to explain it. It also makes the statement that “all vehicles will be entering from the south on Douglas Park Drive…” This contravenes the tNSW Austroads Guide to Traffic Management (Part 12), which insists that realistic distribution modelling must be provided. Omitting roads entirely from a traffic assessment violates Chapter 2, Part 2.3, Division 17, Subdivision 2 of the State Environmental Planning Policy (Transport and Infrastructure) 2021 Omitting key roads constitutes a failure to provide the essential data required for the consent authority and tNSW to perform their statutory assessment. Section 2.119 Development with frontage to a classified road, is also relevant. This section states that a consent authority must not grant approval unless it is satisfied that it will not put at risk the safety and efficiency of the classified road and by ignoring the north-bound section of Douglas Park Drive, the developer denies the consent authority the ability to assess this.
The Social Impact Statement sources clientele from all over the Sydney metropolitan area, particularly mentioning Parramatta and Lakemba. This plan contravenes SEPP (Transport and Infrastructure) which requires developments that generate extensive travel that they be easily accessed by public transport, which reduces the number and length of private vehicular trips. With no public transport to the proposed Site, the developer can’t possibly meet the requirements of this legislation. The “Green travel Plan” suggested relies on carpooling by staff. This is grossly inadequate in terms of claiming to provide any relief or compensation for the massive amounts of long-distance car travel this development will generate. Navigation apps will guide visitors taking the M5 corridor through the fastest travel route which involves the Nepean River causeway from a north-easterly direction when they attend a service and again when they return home. This is planned for up to six times a day for up to 300 people, as stated may be the case for at least one of the faith community targeted, claiming almost half of the burial space.
The report does not address the dangerous u-turn that visitors will negotiate at the intersection of Mitchell Place and Douglas Park Drive when, after they exit the Site using the 'Left-Turn Only' sign GPS apps lead them back over the Douglas Park River as the fastest route home. This creates a dangerous safety hazard in my opinion.
A 'courtesy bus’ from the Douglas Park train station is offered as the solution to the absence of public transport in breach of Sections 115 and 144 of the Roads Act 1993, which specifies a 3-tonne limit on the single-lane causeway, making yet another mitigation measure impractical.
I have looked at conditions for the recently approved Macarthur Memorial Park and found that this can be accessed from three separate locations on St Andrews Road by the public. This high level of public access was able to be noted by the IPC as was the accessibility of the Hume Highway and the closeness of the T2 and T8 railway lines and bus services.
“No adverse impacts” is the deeply flawed conclusion drawn by the author of this assessment which is based on manipulated and misleading data and suggestions in my view. It does not meet the requirements of the SEARS or the standards set by the LEP and should be rejected outright by consent authorities.
Yours sincerely,
I frequent the Douglas Park area very often and will be adversely affected if the cemetery and crematorium development is passed. I would like to register my objections to the DA based on my reading of the Traffic Assessment. I’ve assessed its many shortcomings and highlighting the ways in which it is in breach of relevant legislation.
There are several parts to the document which fail to comply with the SEARS contravening the EP&A Act and the EP&A Regulation (2021) and even though state law overrides local, relevant LEP instruments they should still be considered in my opinion. The report must provide a lawful, accurate assessment of localized environmental and infrastructure impacts and it has failed to meet this objective.
Claims that the development is compliant with the Greater Macarthur 2040 regional plan and the Wollondilly Development control plan are false as there is no public transport to the site, nor is there pedestrian or bicycle access.
Traffic counts during peak hours at nearby intersections were carried out on a single Tuesday and Saturday during the July school holidays in 2024, during the AM and PM peak hour periods. This is in breach of Section 10.6(1) of the Environmental Planning and Assessment Act 1979 which clearly states that a person must not provide information in connection with a planning matter that the “person knows, or ought reasonably to know, is false or misleading”. By using a holiday period where regional traffic can drop by up to thirty percent, a non-compliant EIS has been submitted, because projections for future vehicle counts will not be representative of normal conditions. There is a general failure to account for the pattern or platoon of vehicular arrivals and departures for cemetery clientele and instead 24-hour traffic counts feature as sufficient to convey the traffic volume of the surrounding network. This method is utterly inadequate in addressing the most critically affected road leading to the Site – the Douglas Park Nepean River causeway. Estimates for up to “six services per day with an average of 60-80 visitors per service” are given, projecting a maximum of 202 vehicles per day, using a 3-visitors-per car calculation. This does not align with the projections which feature in other reports, namely the Social Impact Assessment which projects a possible “up to 300 people” for an Islamic service and this particular faith is seeking 40% of the burial capacity at the facility.
One hundred and thirty-one car spaces vastly underestimate the required amount when considering the above potential numbers. Visitors will be forced to circle the nearby streets, and up and down the 80km Douglas Park Drive trying to find a spot to park. Very unsafe.
Section 2.121 of the State Environmental Planning Policy (Transport and Infrastructure) 2021 requires a full evaluation of traffic efficiency and safety. However, this report offers scrutiny of only three intersections, two of them inconsequential, while the one-way hairpin bends of the gorge were entirely omitted, as was the similar Broughton Pass gorge that is negotiated if travelling from Appin. A large funeral attracting visitors from Sydney arriving at once, at any hour of the day, much less peak hour, will completely block the gorge, leading to frustration and altercations as people miss a farewell service for loved ones. It is an absurd proposition to locate a business of this nature in this location. The planner tries to indicate that the Hume Highway is in close proximity and will remedy any of these problems but doesn’t mention the fact that it is a nearly 12km journey from the turn off to Picton Road, with this juncture being an infamous bottleneck as well, operating at a Los E or F during peak hours. Considering the above, the author’s judgement that the Site is “convenient…to the local road network serving the region is false and an abdication of his responsibility to provide a true and accurate assessment.
The planner assumes that no traffic will use the gorge to get to the Site. Not one car. This is really a puzzling attempt at modelling the traffic flow with no reason given to explain it. It also makes the statement that “all vehicles will be entering from the south on Douglas Park Drive…” This contravenes the tNSW Austroads Guide to Traffic Management (Part 12), which insists that realistic distribution modelling must be provided. Omitting roads entirely from a traffic assessment violates Chapter 2, Part 2.3, Division 17, Subdivision 2 of the State Environmental Planning Policy (Transport and Infrastructure) 2021 Omitting key roads constitutes a failure to provide the essential data required for the consent authority and tNSW to perform their statutory assessment. Section 2.119 Development with frontage to a classified road, is also relevant. This section states that a consent authority must not grant approval unless it is satisfied that it will not put at risk the safety and efficiency of the classified road and by ignoring the north-bound section of Douglas Park Drive, the developer denies the consent authority the ability to assess this.
The Social Impact Statement sources clientele from all over the Sydney metropolitan area, particularly mentioning Parramatta and Lakemba. This plan contravenes SEPP (Transport and Infrastructure) which requires developments that generate extensive travel that they be easily accessed by public transport, which reduces the number and length of private vehicular trips. With no public transport to the proposed Site, the developer can’t possibly meet the requirements of this legislation. The “Green travel Plan” suggested relies on carpooling by staff. This is grossly inadequate in terms of claiming to provide any relief or compensation for the massive amounts of long-distance car travel this development will generate. Navigation apps will guide visitors taking the M5 corridor through the fastest travel route which involves the Nepean River causeway from a north-easterly direction when they attend a service and again when they return home. This is planned for up to six times a day for up to 300 people, as stated may be the case for at least one of the faith community targeted, claiming almost half of the burial space.
The report does not address the dangerous u-turn that visitors will negotiate at the intersection of Mitchell Place and Douglas Park Drive when, after they exit the Site using the 'Left-Turn Only' sign GPS apps lead them back over the Douglas Park River as the fastest route home. This creates a dangerous safety hazard in my opinion.
A 'courtesy bus’ from the Douglas Park train station is offered as the solution to the absence of public transport in breach of Sections 115 and 144 of the Roads Act 1993, which specifies a 3-tonne limit on the single-lane causeway, making yet another mitigation measure impractical.
I have looked at conditions for the recently approved Macarthur Memorial Park and found that this can be accessed from three separate locations on St Andrews Road by the public. This high level of public access was able to be noted by the IPC as was the accessibility of the Hume Highway and the closeness of the T2 and T8 railway lines and bus services.
“No adverse impacts” is the deeply flawed conclusion drawn by the author of this assessment which is based on manipulated and misleading data and suggestions in my view. It does not meet the requirements of the SEARS or the standards set by the LEP and should be rejected outright by consent authorities.
Yours sincerely,
Name Withheld
Object
Name Withheld
Object
Caringbah
,
New South Wales
Message
To the Assessors,
Douglas Park is a place to which I am a frequent visitor, having close friends that reside in this small rural village. I am aware of the high level of distress it is causing the residents and have looked closely at some of the documents pertaining to the SEARS in my capacity as construction manager. In my opinion, the Geotechnique Assessment has not been prepared in accordance with the Guidelines on Earthworks for Commercial and Residential development. It does not contain all available information relevant to the geotechnical assessment of the development and some of the information may be considered false or misleading in my view. It fails to identify and address the relevant SEARS, namely 14.0. S. 13, Suitability of ground conditions for proposed development/16.0 S.12 Suitability of ground conditions for proposed development.
Attachment II, on page 5, The Executive Summary makes the statement: “The depth to bedrock is generally less than 2.0m from existing ground surface except in the southern portion of the site or Stage 1. This is false. Review of the Bore and Test Pit Locations graphic on page 38 reveals depth to bedrock in each of the pit numbers for this “southern portion of the Site or Stage 1” are all less than 2 metres to bedrock:
TP17 1.5m, TP18 1.0m, TP19 0.8m, TP20 0.6m, TP21 0.4m, TP22 0.6m, TP23 1.8m, TP24 1.5m
TP25 1.1m, TP26 1.0m, TP27 0.9m, TP28 0.7m, TP29 1.3m, TP30 1.5m, TP31 1.0m, TP33 1.7m,
TP34 0.7m, BH1 1.1m, BH2 1.7m, BH3 1.5m, BH4 1.2m
Test pits 24, 25, 27, 28, 29 with depths ranging from 0.7- 1.5 m to bedrock, fall in Burial zone A slated to be all triple layer plots with an excavation depth of 2.85 metres. It is stated on page 6 that the depth to medium to very high strength bedrock across stage 1 starts from about 1.0m so this would likely mean excavation of multiple hectares of high strength bedrock for a depth of 1.85m.
Excavating 1.85 metres of high-strength sandstone bedrock across the area of burial zone A is a huge industrial mining operation that is unviable for this Site. If the burial A area spans three acres or 12,140 square metres, excavating that area to a depth of 2.85 metres, with up to 1.85 metres being medium to very high strength bedrock requires carving approximately 22,000 cubic metres of medium to high-strength rock out of the ground. High-strength sandstone cannot be dug with standard construction equipment. To cut down 1.85 metres uniformly across multiple hectares, the proponent will need a 30 to 40-tonne heavy excavator equipped with hydraulic rock-hammers (breakers), heavy ripping tines, or rotary rock-saws. Progress in high-strength rock using heavy hammers can be slow—sometimes averaging only 15 to 30 cubic metres per machine per day. Hydraulic rock-breakers operating on high-strength sandstone generate a piercing, low-frequency impact noise that travels for some distance. The sound levels will easily exceed 90 to 120 decibels at the source. Because the site is constrained, this industrial noise will shatter the peace of the local area, specifically the residents of the adjacent Mitchell Place and visitors to the Nepean River and St Mary’s Retreat Centre. The local fauna will disappear. Because a 30-tonne rock hammer outputs up to 122 dB(A) at the source, acoustic distance attenuation math dictates that the noise will remain well above the 75 dB(A) "strong community reaction" for some distance as per the following table from Transport NSW.
According to the NSW EPA Interim Construction Noise Guideline (ICNG) a 30-tonne excavator operating a hydraulic rock hammer or rotary rock saw is classified as Highly Noise Intensive Plant generating a continuous Sound Power Level of 115 to 122 dB(A). A rock hammer generates an impulsive, repetitive thumping noise and the NSW EPA requires planners to add an automatic +5 dB(A) "modifying factor" penalty to the calculation to account for the disruptive nature of the specific sound profile to human hearing. The Worst-Case Scenario applies to residents along Mitchell Place who have a direct line-of-sight around 60 metres away from the source using the following calculations:
• Source Noise with EPA Penalty: 123 to 127 dB(A)
• Distance Loss at 60m: Minus 44 dB(A)
• Perceived Noise Level at the Property Line: 79 to 83 dB(A)
These decibel levels are highly intrusive and not a mere background construction hum. For example, 80 dB(A) is the same as standing next to a running lawnmower, food blender, or heavy freight traffic right outside your window. It is impossible to have a conversation outside without shouting with this level of noise; 70 dB(A): is the same as a loud vacuum cleaner running inside your living room or being inside a crowded and noisy restaurant. Residents in this zone will not be able to comfortably watch television, sleep, or work from home.
Under NSW planning law, when construction noise hits 75 dB(A), the residents are legally classified as Highly Noise Affected. This project easily breaches that threshold. Residential zones in outer Sydney or regional areas typically have a daytime background noise level of 35 to 45 dB(A). The introduction of 70 to 83 dB(A) represents an increase of 30 to 40 decibels above background levels. NSW EPA guidelines state that any noise increases greater than 10 dB(A) above background is considered a significant intrusive noise impact likely to provoke strong community opposition.
It is surprising then, that page 26 of the Noise and Vibration Impact Assessment (table 12, below) significantly underestimates the effects on the nearby residents of months of a hydraulic hammer breaking medium to high strength bedrock. It’s also essential to consider that Stage two is a much larger area and will require the same bulk excavation in the future and possibly for the life of the project.
The effects on the visitors to St Mary’s Retreat centre on the other side of the Site are underestimated as well:
According to their website, St Mary’s Towers offer silent retreats lasting from six to thirty days. The community protects its environment of absolute quiet to the point where casual visits are by appointment only. The Retreat centre would really struggle with the extensive bulk earthworks proposed to remediate this Site.
In my opinion, the geotechnical risks are severe and difficult to mitigate. The constant, violent impact of 30-tonne rock hammers will send huge acoustic and structural shockwaves through the ground. This presents an extreme risk to the adjacent conservation zone, subject of an EPBC according to the NSW portal. Fracturing the root zones of protected vegetation is an almost certainty, as is likelihood of driving wildlife away. The jointed sandstone has likely already been weakened by mine subsidence micro-fractures. Forcefully hammering 1.85 metres deep into a fragile ecosystem risks triggering localized rock shifts or opening fissures that will drain groundwater out of the protected conservation zone.
The Environmental Impact Statement states that “[c]oncept approval is sought for the use and operation of the site as a cemetery with a maximum staged capacity of up to 37.107 burials”. (p 18) Also, “The works relating to the Concept Masterplan will be carried out incrementally to meet the continuing need for burial space, gradually expanding the cemetery’s footprint as necessary. The works subject to the concept masterplan extent will be carried out in a similar manner to those within Stage 1 and described in Section 4.12, as per below” (p 37), however there is no 4.12 in the report.
Concept approval for further 21, 660 plots as part of stage two (many of them triple layer into high strength bedrock), is sought - the noise pollution and disruption from bulk excavation work to the environment, ecology and residents will begin all over again in the future, conceivably multiple times. The extent of this threat is so egregious yet unaddressed in the assessment, approval should not be granted for an unfeasible concept on the promise of future detail delivery. According to locals, these were the circumstances under which the initial approval was granted, with many of the fatal flaws left unaddressed, the viability of the project so flimsy, that the project is yet to commence six years after approval.
The Earthworks Depth table on page 138 of the report appears to have the minimum and maximum depth values back the front.
Point 11 of the Executive summary outlines plans to crush the sandstone rock to “sizes finer than 75mm” but for crushed rock to be considered a functional, flowable, and diggable fill material the nominal maximum aggregate size should be 20mm to 25 mm maximum. Page 4 of the report states: “Infiltration rate of subsurface soils across the site is estimated to be in range of 9.5X10-4 m/s to 9.5X10-4 m/s." (This is not a range, as the values are exactly the same).
When the depth for burial cannot be achieved between bedrock and ground, concrete vault structures or engineered encasements are required via a suite of workplace safety codes, public health mandates and civil asset guidelines. This prevents dangerous shifting against the rock and stops leachate from running straight onto the bedrock face. The proponent is attempting to avoid the extra cost (millions) to install the pre-placed crypt grid – an essential measure to ensure the stability and safety of the huge quarry-like undertaking on fractured sandstone rock (under which future mining will eventually take place), and the prevention of leachate into the water table and offsite.
There are plans to “[p]lace about 150mm thick layer of impermeable clay liner on the surface of the backfilled compacted controlled fill to prevent infiltration of surface water into compacted backfilled materials”, but this is not viable. When a small excavator punches a 1.2m x 2.4m hole through the clay sheet to create a plot, the integrity of the hydraulic seal will be broke
Douglas Park is a place to which I am a frequent visitor, having close friends that reside in this small rural village. I am aware of the high level of distress it is causing the residents and have looked closely at some of the documents pertaining to the SEARS in my capacity as construction manager. In my opinion, the Geotechnique Assessment has not been prepared in accordance with the Guidelines on Earthworks for Commercial and Residential development. It does not contain all available information relevant to the geotechnical assessment of the development and some of the information may be considered false or misleading in my view. It fails to identify and address the relevant SEARS, namely 14.0. S. 13, Suitability of ground conditions for proposed development/16.0 S.12 Suitability of ground conditions for proposed development.
Attachment II, on page 5, The Executive Summary makes the statement: “The depth to bedrock is generally less than 2.0m from existing ground surface except in the southern portion of the site or Stage 1. This is false. Review of the Bore and Test Pit Locations graphic on page 38 reveals depth to bedrock in each of the pit numbers for this “southern portion of the Site or Stage 1” are all less than 2 metres to bedrock:
TP17 1.5m, TP18 1.0m, TP19 0.8m, TP20 0.6m, TP21 0.4m, TP22 0.6m, TP23 1.8m, TP24 1.5m
TP25 1.1m, TP26 1.0m, TP27 0.9m, TP28 0.7m, TP29 1.3m, TP30 1.5m, TP31 1.0m, TP33 1.7m,
TP34 0.7m, BH1 1.1m, BH2 1.7m, BH3 1.5m, BH4 1.2m
Test pits 24, 25, 27, 28, 29 with depths ranging from 0.7- 1.5 m to bedrock, fall in Burial zone A slated to be all triple layer plots with an excavation depth of 2.85 metres. It is stated on page 6 that the depth to medium to very high strength bedrock across stage 1 starts from about 1.0m so this would likely mean excavation of multiple hectares of high strength bedrock for a depth of 1.85m.
Excavating 1.85 metres of high-strength sandstone bedrock across the area of burial zone A is a huge industrial mining operation that is unviable for this Site. If the burial A area spans three acres or 12,140 square metres, excavating that area to a depth of 2.85 metres, with up to 1.85 metres being medium to very high strength bedrock requires carving approximately 22,000 cubic metres of medium to high-strength rock out of the ground. High-strength sandstone cannot be dug with standard construction equipment. To cut down 1.85 metres uniformly across multiple hectares, the proponent will need a 30 to 40-tonne heavy excavator equipped with hydraulic rock-hammers (breakers), heavy ripping tines, or rotary rock-saws. Progress in high-strength rock using heavy hammers can be slow—sometimes averaging only 15 to 30 cubic metres per machine per day. Hydraulic rock-breakers operating on high-strength sandstone generate a piercing, low-frequency impact noise that travels for some distance. The sound levels will easily exceed 90 to 120 decibels at the source. Because the site is constrained, this industrial noise will shatter the peace of the local area, specifically the residents of the adjacent Mitchell Place and visitors to the Nepean River and St Mary’s Retreat Centre. The local fauna will disappear. Because a 30-tonne rock hammer outputs up to 122 dB(A) at the source, acoustic distance attenuation math dictates that the noise will remain well above the 75 dB(A) "strong community reaction" for some distance as per the following table from Transport NSW.
According to the NSW EPA Interim Construction Noise Guideline (ICNG) a 30-tonne excavator operating a hydraulic rock hammer or rotary rock saw is classified as Highly Noise Intensive Plant generating a continuous Sound Power Level of 115 to 122 dB(A). A rock hammer generates an impulsive, repetitive thumping noise and the NSW EPA requires planners to add an automatic +5 dB(A) "modifying factor" penalty to the calculation to account for the disruptive nature of the specific sound profile to human hearing. The Worst-Case Scenario applies to residents along Mitchell Place who have a direct line-of-sight around 60 metres away from the source using the following calculations:
• Source Noise with EPA Penalty: 123 to 127 dB(A)
• Distance Loss at 60m: Minus 44 dB(A)
• Perceived Noise Level at the Property Line: 79 to 83 dB(A)
These decibel levels are highly intrusive and not a mere background construction hum. For example, 80 dB(A) is the same as standing next to a running lawnmower, food blender, or heavy freight traffic right outside your window. It is impossible to have a conversation outside without shouting with this level of noise; 70 dB(A): is the same as a loud vacuum cleaner running inside your living room or being inside a crowded and noisy restaurant. Residents in this zone will not be able to comfortably watch television, sleep, or work from home.
Under NSW planning law, when construction noise hits 75 dB(A), the residents are legally classified as Highly Noise Affected. This project easily breaches that threshold. Residential zones in outer Sydney or regional areas typically have a daytime background noise level of 35 to 45 dB(A). The introduction of 70 to 83 dB(A) represents an increase of 30 to 40 decibels above background levels. NSW EPA guidelines state that any noise increases greater than 10 dB(A) above background is considered a significant intrusive noise impact likely to provoke strong community opposition.
It is surprising then, that page 26 of the Noise and Vibration Impact Assessment (table 12, below) significantly underestimates the effects on the nearby residents of months of a hydraulic hammer breaking medium to high strength bedrock. It’s also essential to consider that Stage two is a much larger area and will require the same bulk excavation in the future and possibly for the life of the project.
The effects on the visitors to St Mary’s Retreat centre on the other side of the Site are underestimated as well:
According to their website, St Mary’s Towers offer silent retreats lasting from six to thirty days. The community protects its environment of absolute quiet to the point where casual visits are by appointment only. The Retreat centre would really struggle with the extensive bulk earthworks proposed to remediate this Site.
In my opinion, the geotechnical risks are severe and difficult to mitigate. The constant, violent impact of 30-tonne rock hammers will send huge acoustic and structural shockwaves through the ground. This presents an extreme risk to the adjacent conservation zone, subject of an EPBC according to the NSW portal. Fracturing the root zones of protected vegetation is an almost certainty, as is likelihood of driving wildlife away. The jointed sandstone has likely already been weakened by mine subsidence micro-fractures. Forcefully hammering 1.85 metres deep into a fragile ecosystem risks triggering localized rock shifts or opening fissures that will drain groundwater out of the protected conservation zone.
The Environmental Impact Statement states that “[c]oncept approval is sought for the use and operation of the site as a cemetery with a maximum staged capacity of up to 37.107 burials”. (p 18) Also, “The works relating to the Concept Masterplan will be carried out incrementally to meet the continuing need for burial space, gradually expanding the cemetery’s footprint as necessary. The works subject to the concept masterplan extent will be carried out in a similar manner to those within Stage 1 and described in Section 4.12, as per below” (p 37), however there is no 4.12 in the report.
Concept approval for further 21, 660 plots as part of stage two (many of them triple layer into high strength bedrock), is sought - the noise pollution and disruption from bulk excavation work to the environment, ecology and residents will begin all over again in the future, conceivably multiple times. The extent of this threat is so egregious yet unaddressed in the assessment, approval should not be granted for an unfeasible concept on the promise of future detail delivery. According to locals, these were the circumstances under which the initial approval was granted, with many of the fatal flaws left unaddressed, the viability of the project so flimsy, that the project is yet to commence six years after approval.
The Earthworks Depth table on page 138 of the report appears to have the minimum and maximum depth values back the front.
Point 11 of the Executive summary outlines plans to crush the sandstone rock to “sizes finer than 75mm” but for crushed rock to be considered a functional, flowable, and diggable fill material the nominal maximum aggregate size should be 20mm to 25 mm maximum. Page 4 of the report states: “Infiltration rate of subsurface soils across the site is estimated to be in range of 9.5X10-4 m/s to 9.5X10-4 m/s." (This is not a range, as the values are exactly the same).
When the depth for burial cannot be achieved between bedrock and ground, concrete vault structures or engineered encasements are required via a suite of workplace safety codes, public health mandates and civil asset guidelines. This prevents dangerous shifting against the rock and stops leachate from running straight onto the bedrock face. The proponent is attempting to avoid the extra cost (millions) to install the pre-placed crypt grid – an essential measure to ensure the stability and safety of the huge quarry-like undertaking on fractured sandstone rock (under which future mining will eventually take place), and the prevention of leachate into the water table and offsite.
There are plans to “[p]lace about 150mm thick layer of impermeable clay liner on the surface of the backfilled compacted controlled fill to prevent infiltration of surface water into compacted backfilled materials”, but this is not viable. When a small excavator punches a 1.2m x 2.4m hole through the clay sheet to create a plot, the integrity of the hydraulic seal will be broke