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.

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.

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.

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.