Submission Objecting to SSD-68287712 – Douglas Park Memorial Park
To the NSW Department of Planning, Housing and Infrastructure,
I wish to lodge a formal objection to SSD-68287712, the proposed Douglas Park Memorial Park development.
I have been a resident of Trentham Avenue, Douglas Park, for more than three decades and live in close proximity to the proposed site. In addition, I work at a business on Dredge Avenue and travel through the local area every day. My long-term connection to Douglas Park has provided me with extensive firsthand knowledge of the area's road network, environmental limitations and rural-residential character.
For the reasons outlined below, I do not believe this development is suitable for the proposed location and I am concerned about the lasting impacts it will have on the community.
Traffic, Access and Flooding
My greatest concern relates to the existing road network and its ability to accommodate a development of this scale.
Residents have long experienced difficulties associated with access to and from Douglas Park, particularly via Douglas Park Gorge Road. The Gorge is regularly affected by flooding, maintenance works and other closures, often leaving residents, businesses and emergency services with limited access options. These disruptions are not occasional inconveniences but recurring issues that the community has dealt with for many years.
The ongoing discussions surrounding upgrades, management and the future of the Gorge itself highlight the existing challenges within the local transport network.
The proposed cemetery, crematorium, chapel and associated facilities will inevitably generate additional traffic from funeral services, visitors, contractors, maintenance staff and operational vehicles. Introducing a major regional facility into an area already constrained by access issues raises significant concerns regarding traffic flow, road safety and emergency access.
Current traffic volumes through the Gorge are already problematic, particularly when road closures occur due to flooding, council works or major incidents elsewhere. The situation is often exacerbated when Menangle Bridge is inaccessible or when accidents on the Hume Highway or Picton Road divert traffic through Douglas Park. During these periods, a trip from Dredge Avenue to Douglas Park Railway Station can take up to 20 minutes, despite normally requiring only around five minutes.
The addition of funeral processions and increased visitor traffic is likely to further congest local roads and significantly affect residents travelling to work, as well as students commuting to school. Travel times could easily increase well beyond what is already experienced during peak disruption periods.
I am also concerned about the practical effectiveness of the proposed restriction preventing vehicles from turning right when exiting the cemetery. In reality, drivers may simply turn left and perform U-turns further along Douglas Park Drive, Mitchell Place or Dredge Avenue. Given that Douglas Park Drive has an 80 km/h speed limit, this could create additional safety hazards for local motorists and residents.
Furthermore, much of Douglas Park Gorge Road remains a single-lane section controlled by traffic lights. The fact that this arrangement is necessary demonstrates the limitations of the existing road infrastructure. Increased traffic associated with a regional cemetery raises concerns not only about congestion but also about the long-term structural impacts on the road and the safety of those who use it daily.
Before any approval is considered, I believe the Department must be fully satisfied that the existing road network can safely and reliably accommodate the traffic impacts associated with this proposal. Based on current conditions, I do not believe this has been demonstrated.
Mine Subsidence
I am also concerned about the site's suitability given the history of underground mining in the region and the potential risk of mine subsidence.
A cemetery represents a permanent land use that requires long-term stability for burial areas, buildings and supporting infrastructure. Any risks associated with historical mining activity and future ground movement should be comprehensively assessed to ensure there will be no adverse impacts on public safety, infrastructure or environmental values.
There is currently a mine subsidence issue affecting an area near my workplace, resulting in the closure of part of the riverbank that we previously accessed on a regular basis. The existence of these issues within the broader area raises legitimate concerns about the long-term suitability of the proposed site.
Water Quality and Environmental Impacts
I am concerned about the potential effects of this development on local waterways, groundwater systems and the wider river environment.
A cemetery of this size has the potential to influence water quality over many decades due to the long-term nature of burial operations. Douglas Park contains numerous creeks, drainage corridors and hydrological connections to the broader river system. Any contamination of groundwater or surface water could have lasting consequences for local ecosystems and downstream environments.
Given the environmental sensitivity of the area, these risks should be carefully considered before any approval is granted.
Planning Consistency and Rural Character
As a local landowner, I am concerned by what appears to be an inconsistency between the planning restrictions imposed on existing residents and the scale of development proposed under this application.
For many years, residents have been subject to planning controls designed to preserve the rural character and environmental values of Douglas Park. These controls have limited opportunities for more intensive development and subdivision.
In my view, the scale and intensity of the proposed development are inconsistent with the planning objectives that have shaped and restricted development within the area for many years.
Douglas Park's rural-residential character is one of its defining features and is a significant reason why many families, including my own, have chosen to live and invest here. Approval of this proposal would permanently change that character and alter the nature of the community.
Conclusion
Having lived and worked in Douglas Park for many years, I have witnessed firsthand the ongoing challenges relating to flooding, traffic congestion, access limitations, environmental protection and development pressures.
Based on my experience and the concerns outlined above, I do not believe the proposed Douglas Park Memorial Park is an appropriate development for this location.
I respectfully request that SSD-68287712 be refused.
Thank you for taking the time to consider my submission.

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,
Nin Mahmood

I am writing to formally object to the proposed development of a cemetery and crematorium within our small historic country town.
Our community has long been known for its natural beauty, peaceful rural character, rich history, and welcoming atmosphere. Residents and visitors alike value the unique charm and lifestyle that this town offers. The proposed development threatens to significantly alter the character of our community and place additional strain on already overstretched local infrastructure.
One of the most concerning issues is the impact on local roads. Many roads servicing the proposed site are already in a deteriorating condition and require substantial maintenance. The increased volume of traffic generated by funeral services, crematorium operations, staff, suppliers, and visitors will accelerate road degradation and create additional safety concerns for residents. The cost of repairing and upgrading this infrastructure should not become a burden on local ratepayers.
Furthermore, the sewage and wastewater systems in this part of town are already under pressure. The addition of a large-scale facility with regular public attendance raises serious concerns regarding the capacity of existing infrastructure to cope with increased demand or lack there of.

I am also concerned about the proposed cemetery and crematorium development waste management services. If local residents do not have access to town sewerage services on that side of the river, where will the wastewater from this development be directed? Given the scale of the proposal, it is important that clear information is provided about how sewage and wastewater will be managed without impacting surrounding properties, groundwater, or the local environment given that this location is so close to the river.
There are also concerns regarding the increased number of non-local visitors and road users travelling through the area. While our town has always welcomed visitors, a development of this nature will bring a significant increase in traffic and activity. At a time when many regional communities are already experiencing rising crime and antisocial behaviour, residents have legitimate concerns about the cumulative impacts of increased population movement and reduced community security.
Importantly, this proposal is incompatible with the established character of our town. The area has developed as a peaceful residential and rural community that attracts families, retirees, tourists, and small businesses seeking a tranquil country lifestyle. The introduction of a cemetery and crematorium represents a substantial change in land use that many residents believe is inappropriate for this location.
The long-term impacts on property values, community wellbeing, local infrastructure, and the historic identity of our town have not been adequately addressed. Once approved and constructed, these impacts will be permanent and irreversible.
For these reasons, I strongly urge the relevant authorities to reject this proposal or, at a minimum, require further independent investigations into the infrastructure, environmental, social, and economic impacts before any decision is made.
Our town’s history, character, and future deserve careful protection. Development should enhance our community, not place further strain on already inadequate infrastructure or fundamentally alter the qualities that make this town such a special place to live.

My concerns are as follows:
the site chosen for this project is solid sandstone
The local roads are inadequate for current traffic flow and poorly maintained.
Water running off this property will flow through to the Nepean River and will impact negatively on local homeowners.

To whom it may concern,

I wish to formally object to the proposed cemetery development in Douglas Park.

My concerns relate to environmental risk, public safety, and inadequate infrastructure, all of which make this site unsuitable for such a development.

1. Environmental and Waterway Impacts
The proposed site sits on solid sandstone, which is known for its low absorption capacity. As a result, surface water runoff flows directly into nearby rivers and waterways. Introducing a cemetery in this location raises serious concerns about:

Potential contamination of river systems

Impacts on aquatic ecosystems

Long‑term water quality risks for downstream communities

Given the sensitivity of the local environment, this risk is unacceptable.

2. Road Capacity and Traffic Safety
The existing road network in and around Douglas Park is already struggling with current traffic volumes. Adding a development of this scale would:

Increase congestion on roads not designed for high‑volume or heavy‑use traffic

Create safety hazards for local residents

Place additional strain on infrastructure that is already under pressure

There is no realistic way the current road system could cope with the increased traffic generated by this development.

3. Unsuitability of the Site
Between the sandstone geology, the drainage issues, and the inadequate road network, the site is fundamentally unsuitable for a cemetery. The risks to the environment and the community outweigh any potential benefits.

For these reasons, I strongly urge you to reject the proposed development.

Sincerely,
Michele Drescher

I am writing to object to the proposed memorial park in Douglas Park.

My biggest concern is the traffic that this project could bring. The roads in Douglas Park are already narrow and can become busy. If more cars, trucks, and visitors come to the area, it could make the roads unsafe and harder for local people to travel around.

I am also worried about the noise pollution. Douglas Park is known for being peaceful and quiet. A memorial park may bring more noise from vehicles, services, and large numbers of people, which could disturb residents nearby.

Another concern is the environment. The area around Douglas Park has beautiful bushland and wildlife. Building a memorial park could damage nature, remove trees, and affect animals that live there. Especially as the burial sites will contaminate the rivers.

I believe our town should stay safe, quiet, and natural for future generations.

Thank you for considering my concerns.

Yours sincerely,

Florence Seidel

I support the project

Please refer to the attached documents.