I object to the proposed Douglas Park Memorial Park on the basis that the surrounding road network is not suitable to support a State Significant Development of this scale.

The proposal relies heavily upon access via Douglas Park Drive, Broughton Pass and the Douglas Park Causeway. These roads are not major transport corridors. Rather, they are local roads that are already subject to significant physical constraints, including bridge and road infrastructure with weight restrictions, limited road widths, steep grades and constrained vehicle manoeuvrability.

The existence of weight restrictions is itself evidence that elements of the road network have recognised capacity limitations. This raises concerns regarding the suitability of these routes for ongoing construction traffic, service vehicles, maintenance vehicles, funeral-related traffic and other increased vehicle movements associated with a major cemetery, chapel and crematorium.

Of equal concern is the susceptibility of the road network to flooding. Local residents are well aware that access across the Douglas Park Causeway and surrounding routes can be disrupted during periods of significant rainfall. The proposal seeks approval for a development intended to operate for many decades and serve a large catchment population. Reliable all-weather access should therefore be a fundamental requirement.

The combination of flood-prone crossings, constrained road geometry, weight-restricted infrastructure and limited alternative access routes creates a road network that lacks resilience. Should a flood event, motor vehicle accident, bushfire, bridge closure or road maintenance activity occur, access to and from the site may be significantly affected.

This concern extends beyond visitor convenience. Funeral services are time-sensitive events involving large groups of people travelling together. Emergency services, maintenance contractors, staff and visitors must also be able to access the site safely and reliably. A development of State significance should not be dependent upon infrastructure that is regularly affected by flooding and already subject to operational restrictions.

Furthermore, the Environmental Impact Statement should assess not only average daily traffic volumes but also the cumulative effect of funeral processions, peak visitation periods, construction activities and long-term operational traffic on a road network that already experiences recognised constraints.

In my view, the applicant has not demonstrated that the existing access infrastructure possesses the capacity, reliability and resilience necessary to support a development of this scale. Until these concerns are satisfactorily addressed, the proposal should not be approved

This might be the most classic example of the issues with our planning system. The fact this location is being considered at all is absurd.

Cemeteries of this scale are not simple planning matters and are multigenerational decisions in the vein of stadiums, aquatic centres, or quarries.

The site if approved will likely remain a cemetery for hundreds of years. While effective permanence is not an issue, decisions of this nature must be made more cautiously and alternatives must be considered.

If it were any government agency putting this in you would be required under treasury guidelines to submit a business case that clearly shows the value of this site over others in the context of local and regional planning.

Now I understand the landowner and developer dont have that luxury which is the why the impetus on the government to make informed, considered decisions.

So i'll do the pub test assessment for you. You have new Wilton going up with an estimated 40,000 residents. You've got all the expansion in the Macarthur corridor down towards Appin. You've got Menangle Park kicking off that will all increase demand for cemetery space.

This immediate fact hides the planning consideration that most of the surrounding area is being currently masterplanned or rezoned from rural to residential. The opportunity to consider genuine alternate sites is now.

Let's look at this site. Bounded by a river, the Hume Highway and a complete lack of infrastructure on terrain not conducive to to development. Serviced by a one lane road, and a single lane causeway that routinely floods and leads to a single lane road up into Douglas Park which is currently being considered for close due to safety concerns and the cost of remediation.

You've got reports of environmental issues, buried bodies leaching into the water table, and endangered species.

I invite one of any of the planning staff involved to drive down these roads before making a decision. The scale of the site and traffic impact alone should make this untenable.

If the government is so hellbent on destroying the character of this area, while making local roads untenable at least commit to genuine infrastructure upgrades. The Moreton Park industrial precinct and proposed new on and off ramps from the Hume Highway will do nothing to alleviate impact. The Picton road interchange will do nothing. The issue is local roads and their interaction with the sites unique geography.

The only solution would be a complete disregard of everyone who already lives here, making all main roads through town 2 lane, building a genuine 2 lane bridge at the gorge and even then with all that said an done, it would still be in one of the worst locations available.

Make it conditional on any new masterplanned suburbs for new Wilton along the picton road corridor.

Attn: Teresa Gizzi, Department of Planning and Environment
Objector: Long-Term Resident of Douglas Park
Status: Objection

I am writing to formally lodge my strongest objections to the proposed Douglas Park Memorial Park Concept Plan (SSD-68287712).

As a resident who has lived in Douglas Park for many years, I have a deep understanding of and connection to this local environment, its landscape and its community spirit. While I recognise the broader regional need for cemetery and crematoria facilities, I firmly maintain that Douglas Park is entirely unsuitable for a development of this nature, scale and emotional gravity.

The fundamental physical characteristics of the chosen site present severe environmental risks that have not been adequately reconciled. The local topography and geology of Douglas Park are heavily defined by dense shale, intractable clay structures and underlying sandstone rock formations. This specific soil and geological profile is notoriously poorly draining and highly resistant to deep excavation. Introducing a large-scale cemetery into a landscape dominated by these clay and rock layers poses a substantial threat to local hydrology. During heavy rain events, which our region experiences cyclically, the impermeable nature of the clay will prevent proper filtration, leading to surface runoff, waterlogging, and the highly concerning potential for groundwater contamination. The structural realities of this ground make it an scientifically flawed choice for interments.

Our local infrastructure is currently strained and was never designed or scaled to support a major regional facility like a memorial park, chapel and crematorium. The surrounding rural road network consists of narrow, localised thoroughfares that already face safety challenges from existing traffic and heavy vehicles. Forcing hundreds of additional vehicle movements per week—including slow-moving funeral processions, heavy construction equipment and visitors unfamiliar with our narrow, winding roads presents an unacceptable risk to road safety. Furthermore, the local area lacks the robust utility services, stormwater management networks and public transport infrastructure required to sustainably absorb a State Significant Development of this magnitude.

Douglas Park is a unique, historic semi-rural enclave. Its identity is built upon its open green spaces, peaceful agricultural landscapes and a sense of quiet sanctuary. A massive, formalised commercial enterprise encompassing crematoria, vaults and chapels will fundamentally alter the visual and social fabric of our town.

This proposal represents an overdevelopment that clashes directly with the Wollondilly Shire’s commitment to preserving rural lands and keeping distinct village identities intact. It is an industrial-scale operation being forced into a quiet residential and agricultural haven where it simply does not belong.

Beyond the tangible environmental and structural impacts, there is a profound human cost to this proposal that cannot be overlooked by planners. To put a massive reminder of mortality at the gateway of our community is to fundamentally change how we interact with our home. As a long-term resident, Douglas Park has always been a place of life, growth and natural beauty. It is deeply distressing to face a future where every single daily commute, every trip to the local shops and every glance out across our landscape serves as a stark, unavoidable reminder of death.

A community should not have a shadow of perpetual mourning cast over its daily life. The psychological weight of this facility will heavily impact the well-being and peace of mind of the families who live here.

The Douglas Park Memorial Park proposal fails to respect the physical constraints of the land, the limitations of our local infrastructure and the emotional right of long-term residents to enjoy their homes without the oppressive presence of a regional crematorium and cemetery footprint.

For the reasons detailed above, I urge the Department of Planning and Environment to reject this application in its entirety and seek a more appropriate, geologically sound and logistically viable location elsewhere.

Sincerely,
H.
Long term Douglas Park Resident

I am writing in regard to the proposed cemetery and crematorium at 430-490 Douglas Park Drive, SSD-68287712, also the subject of EPBC referral 2025/10343.
I have lived in this street for 42 years and found it a great place to settle and raise a family. I would class it as a rural location away from any infrastructure.
The nearest shops are 3 klms away and this requires crossing the Nepean river causeway. This is a narrow twisty road with traffic lights to regulate traffic due to the narrow one lane conditions on the shops side. There are weight and length restrictions for this road for all traffic. There is no walking track down or up this road, it is for vehicles only. There is major concerns for the condition of this road and talks for closing it for a lengthy period for major repairs. There is a railway station near the shops but with limited services. There is no bus or taxi services from the railway station.

As per the guidelines set by Cemeteries and Crematoria NSW in establishing a new cemetery six out of the ten guidelines fail in this instance

1. Site is not next to residential areas or highly visible from neighbouring areas – there are 25 residential homes that run the length of Mitchell Place which border the site.

2. Site is accessible to cemetery visitors – access is available through the causeway which has issues with local traffic. There are no public transport to the site. All access is by personal vehicle.

3. Site is not affected by significant noise from adjoining main roads, airports, industrial sites or similar – The main Sydney to Melbourne highway runs next to the site. This generates road noise 24 hours a day. It also exceeds the governments average noise limits for 60db.

4. Site does not have a high bushfire or flood risk – the area is classified as a bush fire zone by the RFS. Due to the steep nature of the land, a 70 metre drop to the river, stopping a fire in there conditions would not be an easy task.

5. Site has sufficient soil depth to allow the top of a coffin to be not less than 900mm below the natural surface -not shallow rock or groundwater – the land is an area of floating sandstone. Any attempts to dig a single depth grave site would strike sandstone usually in large areas.

6. Site does not contain heritage sites, threatened species or heavy vegetation – site has had an EPBC referral activated for Cumberland Plain Woodland and Shale Sandstone Transition Forest.

The installation of a crematorium on this site would have a high pollutant output which would spread over a large area affecting not just homes in Mitchell Place but in nearby Dredge Ave, the St Mary’s Towers monastery, and the township. This is an industrial setup which should not be allowed in a rural area.

The Green Travel plan submitted by Traffix has some items that need mentioning. The Douglas Park railway station is 2.7 klms distance not 1.8. this low distance seems to taken as a straight line not the road distance. The report states that Douglas Park there is no pedestrian, cycling or bus access through the gorge and due to the nature of the road it is not a viable solution for staff or visitors.
The Action and Strategies plan mostly rely on other people doing what they think is right.
An EV charging bay would have to setup with extra power coming in to run it. How far this comes from is unknown and has Endeavour Energy been consulted on this?
Douglas park has no taxi or ride share service that we know of. Campbelltown or Picton would have both but a 23 klms minimum distance would be very costly. Plus the return journey would mean organising pickups.
Staff car pooling out here would be a bit presumptuous as this would rely on most staff living close to each other and working same hours.
Shuttle buses would have to come from Picton railway stations which is a minimum journey of 23 klms or Campbelltown railways which would be a 36 klms journey
The conclusion in the Green Travel Plan states to reduce reliance on private vehicle trips but will encourage On-site Passenger drop-off / pick-up area which would mean two trips to the site for one funeral. More travel times and more traffic on local roads.
The setup of EV charging facilities does not reduce private vehicle trips. An EV or normal car is still a private car.
The item to Maintain an open channel of communication with Council to maintain / improve existing
sustainable infrastructure in the local area seems to be a way of off loading everything to the local council to fix the issues they are having.
The setup of a Travel Plan Coordinator position seems to be something that would be implemented but what would happen if it gets abolished​? Would it be a government policy to have this running always?
It also states that the subject site is not presently accessible by pedestrian and cycling facilities but states that cycle tracks and parking will be provided.
In conclusion it would be a travesty to allow something as this to proceed. It does not meet the main criteria for a cemetery due to its location which would have issues with roads, environment and the health of the local population.
Guy Howard

It is unreasonable that local residents who purchased property and lived in a rural community setting should be subject to a commercial development of this type.
The devaluation of our properties resulting from the development is outrageous. How is it reasonable that a developer (clearly already financially secure) makes a substantial additional financial gain at the expense of normal, working-class people living in a rural community? I doubt this would pass any "pub test".
The local roads cannot sustain the ongoing heavy vehicle movements required to construct the planned development. Douglas Park Drive (which already has a maximum load limit) north of the mine regularly falls into disrepair following periods of wet weather. Heavy vehicle movements will destroy the road. Relying on the developer to maintain the road is not realistic, as it is an additional expense they are not likely to want to deal with, at least not to a reasonable standard.
The local road network is not designed for the substantially increased vehicle movements associated with operating the cemetery and crematorium. The Douglas Park Gorge is already operating with vehicles lining up at traffic lights waiting to use the road. A significant increase in traffic volume will cause a traffic blockage where northbound vehicles lining up across the single-lane causeway would prevent southbound vehicles from crossing. In peak times, this is likely to result in an immovable traffic jam that cannot be cleared.
Furthermore, the Douglas Park Gorge is already subject to significant deterioration issues. Increased traffic volumes will only serve to exacerbate the deterioration of a critical local community road link.
Any suggestion that visitors to the cemetery/crematorium would be diverted away from using the Douglas Park Gorge is naive. By nature, people will always use the shortest route; furthermore, their navigation apps always recommend the shortest route.
The Douglas Park Gorge is a local recreation area, with families needing to cross the road. The significantly increased traffic volumes pose a real safety concern.
In Respect to the Actual Development:
The geology of the area is sandstone. I understand the proposal is to excavate the sandstone and presumably import soil to facilitate the burial sites. The excavation of sandstone will cause significant dust, including silica dust. Dust created from cutting, grinding, or drilling sandstone is extremely hazardous because natural sandstone is composed of about 70% to 95% crystalline silica.
Any suggestion that the developer can adequately suppress the silica dust to prevent harm to local residents is unrealistic. The developer cannot guarantee that safety protocols will be adequately maintained over the entire duration of the development.
The ongoing noise from excavation works and heavy vehicle movements over the lifetime of the proposed development is a substantial burden to local residents who made a decision to live in a rural community, not near a commercial establishment.
The natural effluent resulting from the burials must end up in the groundwater, which naturally drains into the Nepean River, thereby causing contamination to the river system.
Final Comments:
This development has arisen from a developer who purchased a plot of land in a rural setting solely seeking to make a financial gain. It is my understanding that several proposals have been submitted to the council, all of which have been denied because they were not in the best interest of the community.
The developer subsequently sought to override the local council by pursuing this development via the State Government, with no consideration for the local community's best interest, which the proposed development will impact the most.
It is disappointing when those who have the most, and stand to make significant additional financial gain, do so at the expense of normal, working-class residents living their lives in a rural community.
This development was declined by the local council because it was not in the best interest of the community. The development remains entirely conflicted with the best interests of the community and should not proceed.

As a local resident of Douglas Park ,I object to this proposed submission,Douglas Park Memorial Park, for the following reasons.
The proposed location is in Mitchell Place a residential area, Douglas Park ,20+ homes have been long established in this street and the proposed cemetery will be very obvious to these neighbouring homes and the disruption to the home life that these residents enjoy .The egress entrance, frontage ,burial zones and vaults are directly opposite these homes , homes in Dredge Ave and Douglas Park Dr will be also impacted by this proposal ( eg increased traffic ,noise, pollution ,loss of native flora and flora)
The proposal will effect traffic flow throughout the township, The Gorge and the causeway .The only realistic assess to the location is via private vehicle, navigation apps will and does direct through the township. Funeral corteges will increase traffic and congestion throughout the township and down the gorge .Funeral corteges can be up to 100 cars long and multiple times throughout the day. The township has one o main local road access, Camden Road on this road is, a rail crossing (the main southern line), a primary school main entrance ,a preschool entrance, shops ,homes ,and 30+ units presently being built which all feed into this road ,a road which is increasing busy . This road also leads to 'the gorge',a narrow, one way ,under traffic light control down to a cause way , 3tonne limit, which is often closed due to flooding or road works as this road is requiring continual maintenance due to the increased instability from heavy rain ,increased traffic and topography of the area. The congestion will have impact on the local community and emergency services including bush fire brigade, trying to get through town and the gorge .
Douglas Park is a bush fire zone as documented on Wollondilly Shire Council bushfire prone land register.

The Location is within the Cumberland plains and shale sandstone transitional forest an area that is critical endanged and is protected by the Cumberland Plains Conversation Plan.An area the flora and fauna need to be protected and grow, this proposal will destroy the area ,stripping the land of its natural growth and habitat. Any vegetation that remains will struggle to survive due to construction and long term operation of the proposed cemetery ,by way of impacting of soil, interruption and polluting groundwater,disrupting stormwater /rainfall for water supply .There is no avoidance biodiversity or corridor of endanged species, especially for the koalas.The koalas which are present in this area of Wollondilly ,are known to travel over land and require travel corridor, to keep them safe ,along with another animals in the area .
Increased traffic will also be of detriment to the animals due to road strike .

The land is predominately sandstone with inadequate soil depth to dig graves ,therefore digging into sandstone which is difficult and rare , the depth required in NSW single depth 1.5m double depth 2.1 m ,? triple depth as noted in proposal, digging of graves will be very noisy ongoing process for local residents ,wildlife and general community , as heavy machinery is needed.Burial will occur 7 days a week 10am til 4pm also as noted in proposal ,more disruption to the local residents and the community in general . Sandstone being porous will not contain the bodily fluids as the bodies decompose, these toxic fluids leak and will eventually drain via grondwater into our waterway, the Nepean River ,located behind the proposed site . The Nepean River is within the water catchment for Sydney Water. The river is also use for recreation and home to flora and fauna, including platypus .

The proposed crematorium also presents issues, the potential emissions into air are great including, carbon monoxide, nitrogen oxides, sulphur dioxides, mercury, amongst many pollutants .These pollutants adding to the air ,which can cause breathing difficulties for local people, Wollondilly already exceeds NSW state average for recorded asthma rates . Polluntants will also interfere with the flora and fauna and the ecosystem of the river. Let alone the chimney stack being a visible pollutant to the community .

The proposal suggests up to 37000 burial plots ,at present in the south west area there are approximately 10 cemeteries and 3 crematoriums ,Douglas Park has a small population of 1300 people ,this area as well as being unsuitable in the issues discussed above ,this proposal is unwarranted .To"do nothing" as suggested in the proposal is very much considered the right and obvious outcome to protect Country , the land ,the flora, the fauna ,the river , our drinking water and the air we breath and the community of Douglas Park and surrounding villages.
I for the reasons above ask the department to reject this submission
thank you
Jan Miller

The establishment of a cemetery in Douglas Park, a community of some 1300 residents that spread across and divided by the Nepean river, southern railway line and the M5 motorway seems like a bad planning proposal. Within close proximity to our town there are 6 currently operational cemeteries and 3 crematoriums within 40km of Douglas Park. The proposal would mean that a significant number of burials, families, friends and residents from outside of the Wollondilly and surrounding council areas coming to the area thus creating daily congestion.
Douglas Park a small community in Wollondilly shire is near the M5 southern expressway and the main southern rail line. Although very close to the proposed cemetery site, neither of these access ways contributes to this proposal. There is no access off the M5 and none planned to the site thus only putting significant traffic on our already congested local road system, a local road system, it is used as a major thoughafare to the south coast. A road system that would have hundreds of extra vehicles using Douglas Park Drive with a section of this road listed historically significant threatened by embankment instability along the Harris Creek and Nepean River cliff lines. The causeway and local roads with traffic volumes on Douglas Park Drive heavily constrained by gorge slope instability and 3 ton weight limits, a narrow one-way under traffic lights road, narrow causeway, traffic banking up on dangerous hairpin corners as their way to access the site and a road closed during wet weather and predicted rainfall triggers. Funeral corteges that can be off 100 cars traveling these roads will cause significant congestion as GPS guides motorists this way. This congestion will also impact emergency vehicles that travel the area as well as volunteer community service personnel attending the bushfire brigade trying to get to their station to respond to an emergency call.
The rail system, although a train station at Douglas Park with a infrequent service, there is no connection to public transport to access the cemetery site, however some people do walk down to the causeway and beyond, which is extremely dangerous due to the lack of a physical buffer, speeding vehicles, blind corners, and poor visibility both with shadows of the narrow road and sandstone walls.
How is a burial site going to be a burial site if a hole cannot be dug? The sandstone rock in this area is shallow some 700 – 900mm below ground level with burial hole to be 1200 plus mm deep, depending on a single, double or triple stack, yes it can be dug out, mulched up or quarried using excavators, saws, drill rigs and rock blasting but this is considered a very noisy operation that will have significant effect on the road system with machinery coming and going, local community, wildlife and ecology. The sandstone is porous and once broken up even more so and seepage off decaying bodies, Necroleachate is highly phototoxic and poses a significant environmental hazard to local plant community and waterways and with the nearby Nepean River only a short distance away it would affect the water quality and plant material in its path.
Necroleachate contains high concentrations of biogenic amines, particularly cadaverine and putrescine. Studies show that these compounds are highly toxic to plant cells and their growth. The raw liquid also alters the physicochemical and biological makeup of the soil, although in this case a very shallow sandstone base soil. It can introduce heavy metals, pharmaceutical residues, and a high volume of mineral salts, leading to long-term soil degradation and high salinity that plants cannot tolerate. As the fluid percolates into the groundwater, it acts much like raw sewage. It spreads pathogens, viruses, and elevated levels of compounds like ammonium and nitrates. This contaminated groundwater can be poisonous downstream to vegetation and aquatic life, all within the Nepean River catchment area. The Biodiversity and Conservation within the state environmental planning policy requires development to be carried out only with development consent and consideration to whether the development will maintain and enhance the structure and floristics of native vegetation in the catchment.
So how does contaminated water enhance plant growth and then provide scenic quality of the locality?
The site is within the Cumberland plain, a significant soil and vegetation type in south west Sydney. The site does have grassland and is part of a critically endangered ecological community. This community is facing an extremely high risk of extinction in the future. The proposal will only significantly ensure that the ecological community is irreparable and gone forever. Several nearby properties have already been listed a seed back areas thus protecting what we have left of the Cumberland plain plant community.
The proposed cemetery development does not have links to improving the local infrastructure, council roadways and intersections, the development only lists work occurring for the proposal to the site. Future local housing development in surrounding areas of Wilton, Appin and Menangle, will also increase traffic along Douglas Park Drive and across the narrow causeway. There are no plans for a new crossing of the Nepean River to allow future higher traffic volumes in the area.
For motorist that would attend the site from the Appin area, to the east of the proposed site, they also have a narrow, steep, one lane weight limited road with a hairpin corner that is prone regular accidents to travel through.
The area is listed under Wollondilly’s Shire Council Bushfire prone land register and has links to adjacent fire prone areas. This creates a high dangerous situation should there be a fire as the only road in / out is Douglas Park drive and the congestion, panic and confusion of visitors in an unknown area could be horrific.
The structures within the proposed site that will supposably be concealed by vegetation however many established trees would be removed thus creating a greater impact to facilitate the proposal. Replacement trees take along time to grow and the impact is not felt for many many years and will do nothing to hide the fact that there still cemetery opposite residential properties. The site next to residential area to the east will be highly visible from their properties. To the west of the proposed site is the main southern motorway linking Sydney to the southern areas of the state, a very busy roadway. These residents would have to view a cemetery and its structure constantly reminded by mortality, suffering reduced property values as high as 10% and significant increase in noise and traffic. Daily maintenance activities including mowing, excavation work, the funeral cortege and deliveries will also significantly impact the adjoing residents.
This proposal will have significant changes to the street scene, pedestrian passages, transport usage and parking along with noise and public views will affect the immediate locals adjacent to the proposal and would loose the rural impact of the area, something that Wollondilly Shire Council promotes.
An alternative of “doing nothing” or considering other options that do not effect the local waterways, flora and fauna, environment and residents of the community and those adjacent to the site could result in the use of an underutilised site better. This case as viewed by the New South Wales government but the significance of the fauna and flora and the community as a seed bank linking the Cumberland plains is more value long term.
I strongly support the refusal to the development
Thank You

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.

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.

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