Exhaustive environmental and economic studies must be conducted. I do not believe this has been properly addressed. In fact, I am appalled at the "find results to match the desired outcome" method of the whole process.

Citizens' concerns about air quality have been pooh-poohed. One morning, attempting to cross Newbridge Road near Moorebank Avenue on my bicycle, I had to get off my bike because I was about to faint. I had to walk carefully because I was gagging and woozy. I could taste the exhaust fumes in my mouth. I eventually made it to Light Horse Bridge, where there was a bit of air movement and I was able to get back on my bike. This is OK by you? And we don't have an intermodal yet!

The river is sick and filthy as it passes through Liverpool. Hardstand developments should not be built on the banks of rivers. All over the world, waterfront land is being reclaimed from industry and returned to the people. Why is Liverpool being treated as if it were a third world country?

The fundamental appropriateness of this development has never been examined. It is not appropriate because it is on the banks of the river, in the middle of residential areas, surrounded by schools and cultural centres.

The traffic will not function. You are talking about traffic volumes exceeding Sydney Harbour bridge. Think about the support infrastructure around Sydney Harbour Bridge. This is what will need to be built in Liverpool in order for the intermodals to function. Neither State nor Federal governments have signed up for that. Why is this so hard to understand?

The social, health and economic disbenefits to this community have not been addressed.

The newly-built Enfield intermodal still has not commenced operation. Why is there a problem getting someone to operate it? Could it be that it is not economically viable? It is only a stone's throw from Chullora, who have just doubled their capacity with the introduction of new technology. If they cannot even get Enfield up and running, why on earth are you considering opening another at Moorebank?

It should be built at Eastern Creek for now, and Badgery's Creek down the track.

I am appalled that reason has had to date so little influence on decision making.

Liverpool City Council (Council) raised significant concerns about the scale of impacts associated with the proposal and have raised its strongest objection to the development scheme. It engaged Cardno (NSW/ACT) Pty Ltd to prepare a submission on behalf of and in conjunction with council to the public exhibition period.
The review found that environmental impacts are extensive and primarily localised to the area around the site at Moorebank and along key transport routes servicing the site. It is Cardno's view that these impacts must be mitigated and requires sufficient analysis, supporting infrastructure, management plans, operating procedures and compensation schemes be developed, which the current scheme and associated assessment fails to provide. Consequently, Cardno found that the proposal at this location is unacceptable and should not proceed.
Key issues associated with the project include:
* Traffic congestion and associated impacts on amenity due to additional vehicles on the network.
* Noise and vibration impacts associated with site construction and operation, as well as vehicle movements beyond the site.
* Air quality impacts associated primarily with vehicle movements beyond the site, as well as site construction and operation.
* Hazard and risk both within the site and beyond the site boundary associated with the transport network.
* Human health impacts resulting from a reduced level of amenity within a heavily populated area.
During the assessment of the environmental aspects a number of reoccurring themes were identified that either created significant impacts individually, or reoccurred throughout the review and therefore had the potential for cumulative effects on account of their repetitive nature.
East Liverpool Progress Association : MIT destined to be a costly, stunted freight yard
Michael Byrne, president of the East Liverpool Progress Association said: "Dr Schott as chair of the Moorebank Intermodal Company in commenting on the Federal Government's approval of the Moorebank Intermodal Freight Terminal repeats the mantra that it will reduce traffic congestion.
"Dr Schott is talking through her hat. The development simply relocates the congestion from a port tucked away in a corner of Sydney to Moorebank, which is located in a corner of the region it is planned to service. "
"The most nonsense Dr Schott expresses is that the Trust, holding the publicly owned lands valued at over $500 million, will attain rental income streams to attract buyers," commented Mr Byrne.
The Moorebank Intermodal, in East Liverpool, from its earliest conception was justified on its proximity to the M5/M7 road systems and the Southern Sydney Freight Line. These massive public funded assets were there for the picking with smart property asset purchases beginning with SIMTA in 2009.
The facts are that the development contains an inbuilt deformation of stunted growth. The entire financial analysis for economic and commercial return is based on throughput of at least 1.05 million IMEX containers (TEU) annually. It is unattainable. East Liverpool is river bound and bridge reliant. It serves the existing and planned suburbs in the south west region of Sydney as a narrow, congested traffic corridor. To its immediate south runs the Liverpool Military Area for over 25 kilometres thus blocking eastern routes from the far south west area of Campbelltown. The two East Liverpool bridges carry more traffic than the bridges that serve the Sutherland Shire. And they plan to merge into them 5,000-8,000 daily B-doubles.
"Dr. Schott's grand development is now most likely to stand as a monumental infrastructure failure in the form of a much reduced secondary freight yard with Qube / Aurizon making a small margin, whilst over $500 million of public lands are wasted. Not to mention the great disruption to local neighbourhoods and our Georges River," said Mr Byrne.
Resident action group: decision ignores all facts
Allan Corben is a resident of Liverpool, NSW. He is a member of the Liverpool City Council No Intermodal Committee, and a community group named RAID (Residents Against the Intermodal Development). His work background included 47 years in the transport and logistics industry, with 13 years of that period in rail/container transport business.
"It was interesting to read in the media earlier this week that the Federal Government had agreed to enter into a partnership with a private organisation (SIMTA) to develop the Moorebank Intermodal. The majority of media releases were worded in a manner to suggest that the development had been approved to allow construction to commence.
"I'm of the opinion that the wording was such to give those involved in the opposition to this proposal the impression that the development was done deal, so as to have the opponents (local community) cease their opposition.
"Both the Federal and State Governments, together with SIMTA, are deliberately ignoring a number of critical facts covered below:
Traffic: It is well known that the Liverpool road network is near capacity. In an article published in the Daily Telegraph on 4 June, the Federal Government is quoted as rebuffing critics who say it will clog Western Sydney roads with trucks, but in a speech on the intermodal proposal made by NSW MP Ms Melanie Gibbons in the Legislative Assembly on 4 June, she made the following statement: `I have read through the information provided by the company for the next period of community consultation. It says that, should there be an accident on the M5 or Moorebank Avenue, the facility will need to close while the accident is being cleared.'
"Somewhat conflicting comments from the same people! I'm sure that transport companies servicing the site, warehouse tenants and their customers would be less than impressed with this prediction
"Although a traffic model, completed on behalf of our community, has shown that there are many roads and intersections that will require substantial upgrades, the proponent has only acknowledged only one upgrade being Moorebank Avenue, but not till 2029/2030. This is regardless of the fact they intend to bring upwards to an extra 10,000 truck and 5,700 car movements on to the local road network daily.
"One of the main selling points, claimed by the proponents, has been that Moorebank will take thousands of trucks off the Sydney roads each day, which is absolute garbage as all it will do is relocate the trucks to Moorebank, where they will enter the Sydney road network. The fact is that it will remove trucks in the interim from the M5 between Port Botany and Moorebank, but this will only be a short term reduction. The reason for this is due to the handling capacity of the Port Botany freight line. It has been suggested (government has refused to reveal capacity) that the line has a maximum capacity to handle 1.2 million containers per annum. If we consider that Port Botany currently receives 2 million containers per annum and is predicted to handle in excess of 4 millions in future years, how will the additional 2.8 million containers be delivered, simple, on the back of a truck.
Noise: The intermodal site is located in the middle of a number of residential suburbs that are home to many thousands of people. It is a known fact that residents living within a radius of three kilometres of the Port Botany container terminal are suffering from sleep disturbance, yet the proponents and government are obviously of the opinion that residents who live within a radius of 400 to 1000 metres from the proposed site will not be impacted by sleep disturbance. The government claims that the warehousing on what is currently SIMTA's site will act as a buffer zone to the suburb of Wattle Grove, but anyone who has been exposed to the level of noise created by this type of operation knows, the warehouse will barely reduce the overall noise level. The people living in the elevated suburb of Casula (400 metres on the Western side of the site) look directly down into the proposed area, with no chance of avoiding the noise level whatsoever. When asked how the proponents would mitigate the noise level, the CEO of MICL stated that it would be up to the successful company who was appointed to developed the site to address.
Air quality: It is well know that Liverpool area is one of the most polluted areas in Sydney. This is qualified in a statement made in the PAC SIMTA determination that has already shown that PM 2.5 levels in the local area are close to or above the advisory criteria, MICL state that: `Air quality monitoring has demonstrated that the concentration of different airborne pollutants in Liverpool is generally well below guidelines.' Again, conflicting statements.
"Regardless of the above, which substantiates that the proposed area is already highly polluted, the proponents intend to bring 10,000 + diesel trucks, ancient diesel locomotives and thousands of car movements into the site area daily. It should be noted that the emissions created by diesel types of equipment are carcinogenic and in the same category as asbestos, which is a well known cause of death.
Alternative site: With the announcement of the Badgerys Creek airport, it was suggested that the ideal site for the intermodal would be to amalgamate the two projects. This would eliminate the need to spend many millions of dollars upgrading the eastern area of the Liverpool road network, and totally eliminate noise and air quality issues. This suggestion has been completely dismissed by the government and the proponents as not possible due to (1) not sufficient time due the urgency of the predicted increase in import container arrivals, calling for additional handling facilities and (2) no rail line into the Badgerys' site.
Timeframe: There have been two changes that suggest that the urgency to build Moorebank no longer exists. Firstly, the Chullora terminal has announced that it has increased its handling capacity from 300,000 to 600,000 and secondly, the predicted annual increase in import containers of 7%, as advised by the proponents, has not been achieved and, in fact, is only in the area of 4%. Where's the hurry?
"Now that both developments have amalgamated into one, the EIS process should commence again on the overall development.
"We've seen the previous government waste billions of taxpayers dollars rushing into decisions that were an absolute waste of resources and money and we cannot allow the current government to follow suit. I'm afraid that the government, or some senators and MPs believe that Moorebank is the ideal location because the proposed site is next to the rail line and a motorway."

----------------------------------------------------------------------------------------------------------------

submission mic june 22, 2015
The Environmental Impact Statement prepared by the Moorebank Intermodal Company (MIC) states that the proposed Moorebank intermodal will allow imports and exports to grow through Port Botany. This will mean additional traffic on the already congested road network. 10,000 heavy vehicles per day will need to access and leave the terminal utilising the M5 and local roads.
The MIC state that an additional intermodal is required to reduce supply chain costs; however, it is questioned how the proposal at Moorebank will assist in reducing these costs. The proposed terminal in Moorebank will include transferring freight by rail less than 25 Kilometres from Port Botany, while increasing the handling costs of the supply chain with containers having to be loaded and unloaded multiple times in a very short distance. Infrastructure NSW has also questioned the viability of short haul freight and the funding of additional intermodal facilities until this has been properly investigated. That being the case, the increase in capacity at Chullora should be investigated with proper planning for a true intermodal at Badgerys Creek. Jenny Wiggins, in her Sydney Morning Herald article, states that Asciano is primed to invest $112 million to `compete "vigorously" with its own intermodal terminals', for example Chullora, and challenge the Moorebank intermodal

essentially casting doubts over the economic viability of the Moorebank site (Wiggins, J., 2014, `Asciano challenges Moorebank freight hub', Sydney Morning Herald, 2 July 2014).
To truly reduce supply chain costs, the intermodal location should be moved to Badgerys Creek, a facility more than 40 Kilometres from the Port with access to key roads such as the M7 and the proposed M9. This location will also have the capacity to support future growth centres. The M9 motorway will provide `a direct link between the Central Coast and the Illawarra, connecting the growth centres of Camden, Penrith and Windsor' (O'Rourke, J., 2014, `What Sydney needs to transport us to the future', Daily Telegraph, 3 November 2014). An intermodal at Badgerys Creek demonstrates good strategic and growth planning.
Why Badgerys Creek is a better location than Moorebank
The MIC, in their Environmental Impact Statement, attempt to describe why Moorebank has been selected as a location. However, Badgerys Creek is better suited to meet the criteria that the MIC has listed.
Badgerys Creek is an ideal location for an intermodal terminal to handle both interstate and import-export freight. This is because it is:
* long enough for interstate freight trains without the need for trains to be broken up and shunted, creating unnecessary additional noise in the area;
* big enough to handle the number of container movements required - up to 1.1 million twenty foot Equivalent Units (TEUs) per year of import-export freight and another 500,000 TEUs per year of interstate freight. This is a greater capacity than the proposed Moorebank site;
* strategically located in an area where a new rail line is planned for the airport;



* near the M7 Motorway, a link to the West and North West where it has been identified by Deloitte that most of the container freight will be headed, and accessible to the M5;
* near the proposed M9 Motorway, providing the ability of the intermodal to service future growth centres;
* near the Western Sydney Employment Area (WSEA), future industrial areas and future freight markets in Western Sydney, where two-thirds of container freight received at Port Botany will be transported.
* further from Port Botany than the Moorebank site, making rail a viable alternative to trucks, and reducing supply chain costs;
* in development, meaning that truck access can be configured into the $3.5 billion already allocated to the surrounding road infrastructure network rather than upgrading roads that are already at capacity in the Moorebank precinct; and
* owned by the Australian Government and available for use consistent with the airport.

Problems with the Moorebank proposal
The Moorebank site constrained by a number of issues:
* The area is already suffering from significant traffic congestion, the addition of an estimated 10,000 truck movements and approximately 5,000 passenger car movements per day will exacerbate this congestion.
* The Planning and Assessment Commission (PAC), following their community meeting on the SIMTA proposal, has identified that the Moorebank area is already suffering from significant traffic congestion. `The community has strongly argued that the



proposal is only going to move the congestion from Port Botany to the Liverpool/Campbelltown region. The Commission understands the Moorebank site is constrained by the surrounding residential and industrial land uses and the already heavily congested local and regional road network. If the concept plan were to be approved with the levels of throughput proposed by both SIMTA and MIC, then clearly the community's case is strengthened.' (2014, Planning and Assessment Commission, SIMTA assessment).
* The SIMTA Concept plan was approved by the PAC on the basis that they are limited to 250,000 TEU's, plus an additional 250,000 ONLY if the road network is able to handle the volume of heavy vehicle traffic. This being the determination made by the PAC, and in the absence of a master plan that would have enabled the commission to assess the impact of both proposals as part of the one process, this limit should apply to the operation of both SIMTA and Moorebank intermodal sites combined. TEU's should be limited to a total of 250,000 in this precinct.
* The economic viability of the site has been questioned due to the limits placed by the PAC on the number of TEUs SIMTA can move through their terminal. Chief Executive of Asciano has also questioned the economic viability of the site as previously mentioned, stating that Asciano plan to invest $112 million in their sites to increase capacity and making Chullora more competitive, able to handle an increased capacity from Port Botany, and open for operation before Moorebank (Wiggins, J., 2014, `Asciano challenges Moorebank freight hub', Sydney Morning Herald, 2 July 2014). With the Chullora intermodal capacity increased to 800,000 TEU it will easily be able to support increased in freight through Port Botany while the Badgerys Creek site is planned and constructed.

The Moorebank site is surrounded by water on all sides. This means that the complex road and rail upgrades needed to service an intermodal in this area will be extremely costly. Liverpool Council has estimated these upgrades are likely to cost in excess of $750 million.
* There are significant problems relating to air quality, construction and operational noise impacts created by the intermodals. A proposal of this size and nature should not be earmarked for a residential area.
* The PAC determination of the SIMTA proposal has already revealed that Particulate Matter 2.5 levels in the local area are close to or above the advisory criteria for this pollutant, this applies to the current background levels as well as the predicted impacts. Additional diesel and liquid natural gas powered vehicles in this area will exacerbate this problem.
* Noise impacts, light spill and air pollution will have a detrimental effect on the local community, some of whom live as close as 400 metres from the site. Residents around Port Botany living as far as three kilometres from the port are affected by these factors; many residents in Chifley for example have been very vocal about sleep disturbance in the online domain.
* The Moorebank site will have a detrimental impact on the Casula Powerhouse Arts Centre. The presence and accessibility of an art and cultural facility in a low socio-economic area, such as Liverpool, is essential for positive community growth.

Problems with the process
The Freight Infrastructure Advisory Board (FIAB) recommended a master plan for the site, this was not undertaken. Residents agree the SIMTA and MIC proposals should have been considered as a single precinct application. This has created an unfair advantage for the proponents with confusion being created among the community with both proponents presenting different figures. The fact that both proposals were assessed separately also means that media attention highlighting the different stages of the planning and assessment process has also created confusion in the community. Coupled with this, the relocation of the Defence National Storage Distribution Centre (DNSDC) and the current construction works at Holsworthy Barracks have also exacerbated this confusion with many people within the community thinking the proposal is already in its construction phase.
Liverpool Council, in meeting with PAC expressed disappointment that a master plan was not undertaken and confirms that this has created confusion within the community `The ad hoc approach .........leaves gaps and inconsistencies in the information available resulting in a lack of transparency and reduced faith in government decision making.'
A master plan would have reduced this confusion and allowed the community to better understand the impacts these proposals will have on their family, friends and neighbours. It would have allowed the community to better refute claims made by the proponents, and have a much greater grasp of any proposed mitigation strategies for this proposal.
The MIC has also created confusion and doubt within the community, adding to a reduced faith in government process and decision making. They have done this first by splitting their figures. Rather than telling the community that there will be 1.55 million TEUs going through the site, they have split these figures between import-export and interstate. And rather than stating that there will be an estimated 297 train movements expected at the site, they have again split these figures to make them sound lower. The Liverpool Leader, in their article `Intermodal company gives community $1m for compensation package but concerned residents aren't buying it', reports on community concerns around the consultation process. This `compensation package' will be completely inadequate to address the impacts this proposal will have on the area, and made MIC seem like it was trying to `buy community support'. At the same time MIC also made a highly publicised donation to the Liverpool Mayoral Ball, which Liverpool Council subsequently rejected (Hansen, N., 2014, `Liverpool Mayor knocks back $5k ball donation from intermodal group but the cash is still destined for charity', Liverpool Leader, 22 August 2014).
An intermodal at Badgerys Creek would not require this level of compensation, as it can be properly planned for a suitable area; it also has residential and council support.
Second, the Sydney Morning Herald in their article `Waterfront baron and Liberal Party donor scored inside running on freight hub tender' has highlighted a possible issue around transparency and due process in the awarding of tenders for the Moorebank precinct. In light of the recent ICAC investigations and the problems faced by the Newcastle community, transparency and due process are paramount in the government decision making process.

Key issues from the community
There were some issues raised by local representatives and the community at the PAC determination meeting on the SIMTA proposal. These have remained largely unchanged in relation to the MIC proposal. Traffic and access
* The proposal will move the congestion from Port Botany to Moorebank, which is already congested;
* Modelling does not include the predicted growth of the region;
* The intersections and road network are already congested,



how is it possible for the proposal to decrease traffic delays?
* Trucks `weaving' onto and off the M5 between the Moorebank and Hume Highway interchanges, this is going to cause accidents; and
* Trucks parking and taking short‐cuts through the nearby streets.

Noise
* There is no noise wall along the rail corridor along the Georges River, so noise will carry particularly at night;
* Noise from the unloading/loading and movement of containers within the terminal;
* Noise from the breaking and shunting of trains due to the site sizing constraints; and
* Wheel squeal from the trains exiting the SSFL, tight radius curves lead to wheel squeal.

Air quality
* Increased diesel fumes in the community generated from locomotives, heavy vehicles and other heavy equipment used on site;
* Health impacts from the increased diesel fumes;
* South‐west Sydney is already heavily polluted due to the topography; and
* Dust and odour, particularly during construction.

Two intermodal proposals (SIMTA and MIC)
* There is an ad hoc approach to the two proposals;
* Cumulative impacts of the two proposals have not been adequately addressed; and
* Confusion as to the total traffic generated from the two proposals, as the modelling for each is different.

Heritage
* Removal of heritage features from the site, particularly those of military and indigenous significance.

Location
* Site is surrounded by residential development; and
* Other sites are

preferable, such as Badgerys Creek, which is not surrounded by an established community.




Moorebank Intermodal Company EIS presentation
There was considerable concern from the community over the presentation that was given for the MIC EIS submission. Figures and statistics presented by MIC seemed to be inconsistent and the facilitator tried, on a number of occasions, to ask the community to voice their concerns directly to MIC representatives rather than in the public forum. At each of the three sessions the facilitator kept stating that she was conscious of time; however, the community feel that their questions about a proposal that will impact their family and community deserved an answer, and are more important than clock watching. The number of questions from the community at the final community information session saw the session run over time.

Traffic and Transport
* The MIC recognised that there are significant transport and traffic congestion problems in the Moorebank precinct; however, they claim that the additional 8,160 heavy vehicles and 5,724 cars they predict to be brought into this precinct every day due to an intermodal will not have any further impact.
* The Chief Executive Officer of MIC stated that there would be approximately 1.6 trucks required per TEU. He also stated that 1,400,000 TEUs would be required to leave the terminal by truck. According to this statement, and given that heavy vehicles will have to both arrive and leave from the precinct, the figure of 8,160 heavy vehicles per day seems low, this actually equates to 12,376 heavy vehicles per day. For the purposes of this document the figure of 10,000 heavy vehicle movements per day has been chosen as a more accurate representation of the figures.



* The Chief Executive Officer of MIC also confirmed that the Moorebank intermodal will not take heavy vehicles off the M5 between Port Botany and Moorebank, and that as Port Botany expands the number of heavy vehicle movements on this stretch of the M5 is expected to grow. It should be noted that Labour Minister Anthony Albanese previously claimed that the Moorebank intermodal would take trucks off the M5; this fallacy gained a lot of momentum especially in the media and it has never been publicly corrected.
* Questions were raised by the community about the problem of Trucks `weaving' onto and off the M5 between the Moorebank and Hume Highway interchanges. MIC recognises this as a significant problem. This `weaving' has the potential to cause a recognised `black spot', with potentially fatal consequences for the community. It is worth noting that a `black spot' is already located at the Nuwarra Road and Heathcote Road intersection, only 2 Kilometres from the `weave' site.
* The traffic modeller for MIC presented information about the predicted impacts on intersections both with the intermodal and without. Intersection surveys were undertaken on Tuesday 7 December 2010, and Tuesday 18 March 2014, in peak hours only. It is concerning that these surveys seem to only have been conducted on two days, four years apart, with the December date being in a peak holiday period.
* A Seven-day automatic traffic count was also conducted from Tuesday 7 December 2010 at only three locations along Moorebank Avenue. It is concerning that four year old data, gathered prior to a number of new and extensive residential developments in the area, is being used as a base for traffic modelling.



* The data presented by the traffic modeller showed a delay of over 200 seconds at some intersections when the intermodal is in operation. A 200 second delay, coupled with a 150-180 second cycle on a normal set of traffic lights is a significant impact (approximately six minutes at EACH set of lights), one that is likely to have flow on effects. He has compared data, which is based on a scenario where the intermodal is operating with road and intersection upgrades, with predicted data based on no intermodal without road upgrades. This is not comparing like for like. Given that intersections in this area are currently operating at D or E classification (near or at capacity), it is hard to believe that the roads in the area will not be upgraded by relevant authorities to attempt to reduce congestion before they reach an F classification.
* It has been noticed that traffic figures do not take into account the recently announced WestConnex which will have major traffic implications on the M5 during construction; this coincides with the proposed opening date of the Moorebank intermodal. The WestConnex project also aims to increase Port Botany by 272% more container ships by catering for a greater number of heavy vehicle traffic movements on the M5. Labour Minister Anthony Albanese criticises the WestConnex `proposal for not going near Port Botany, where it is expected there will be a large rise in the number of container trucks'. He also questions the government's transparency, citing that `the decision to release new information about the impact of WestConnex on Melbourne Cup Day indicates to me that those who support this route are aware of its



shortcomings and are keen to avoid public scrutiny.' (Saulwick, J., 2014, `Albanese pans plans for the WestConnex', Sydney Morning Herald, 10 November 2014).
* Residents are understandably concerned about the impact of intermodal traffic on local and residential roads. The MIC confirmed at the community information session that while they can implement some measures for traffic movements, it will ultimately be up to the design of the precinct, the way the precinct operators choose to use the precinct, and choices made by heavy vehicle drivers as to which route they choose to use. With heavy congestion on Moorebank Avenue and the M5, two of the key roads in the area, it is likely that Anzac Road and Cambridge Avenue will be used as `rat runs' for heavy vehicles.
* The MIC traffic modeller recognised that currently 6% of traffic on Anzac Road in the peak is heavy vehicle traffic; however he failed to include any heavy vehicle movements in his trip distribution figures for this road. In current heavy traffic conditions Anzac Road is a very attractive option, as demonstrated when the M5 is congested. Heavy traffic movements on a congested day are far higher than those measured by MIC. The omission of this traffic flow information from MIC data sets is hard to fathom. For the local residents, especially those with houses that back onto Anzac Road, it creates uncertainty and distrust in the accuracy of the information presented.
* The construction of an intermodal terminal at Moorebank shows a lack of strategic planning, particularly in relation to future traffic movements.
* An intermodal at Badgerys Creek will be a true intermodal with road, rail and air access. This area will serve the purpose of meeting the needs of future growth centres. The government currently has the ability to configure appropriate and safe truck access in the Badgerys Creek area with $3.5 billion in funding dedicated for road infrastructure.



predicted an additional 297 train movements each week, this figure does not include the interstate trains that may transit through the terminal.
* It was unclear how these train movements would impact residents in the area, due to three different rail entry options currently under consideration.
* Due to the length of trains, they will need to be broken up and shunted.
* MIC communicated that the actual rail entry will be decided once a tender for operation of the facility has been awarded. This makes it difficult for residents to understand the impacts of the rail access.
* It is unclear whether rail access will impact the passenger rail line and impact on travel times for people travelling by rail to the Sydney CBD.
* An intermodal at Badgerys Creek will not have the same rail implications. The size of the site will allow trains to remain whole within the terminal without the need for breaking and shunting.


Noise and vibration
* In order to ascertain acceptable noise levels in the area, the MIC have measured ambient noise levels between 2010 and 2011, and then from July 2012 to establish a base index. Approximately 20 of the 34 noise receptors set up and monitored by the MIC to establish this base index were located along train lines and major roads.
* Given that most residents in the area live in quiet, peaceful streets, it is a concern that the receptors set to ascertain the base index for ambient noise seems to have been placed in predominantly noisy locations.
* The residential suburbs of Casula, Wattle Grove and North Glenfield are the closest communities to the Project site; however, these will not be the only locations impacted by the noise generated from the proposed intermodal.
* In a recent article in the Sydney Morning Herald it was learned that `After more than a year of residents around Port Botany being told the night time noises they were complaining about did not exceed "sleep disturbance criteria", the Environment Protection Authority has admitted they were right.' (O'Brien, N., 2014, `EPA admits it was mistaken about Port Botany noise levels', Sydney Morning Herald, 17 August 2014).
* Residents in the precinct are understandably concerned that noise levels will exceed those acceptable. Above acceptable noise levels can have health impacts including: annoyance, sleep disturbance, performance issues (reduced concentration), cardiovascular health problems, hearing problems, mental health effects, and general health impacts (e.g. on the immune system).



* There is currently no noise wall along the rail corridor along the Georges River, so noise will carry particularly at night.
* There is no doubt there will be excessive noise from the unloading/loading and movement of containers within the terminal, which will operate 24 hours a day, as well the breaking and shunting of trains due to the site sizing constraints, and compression breaking of trucks on the surrounding roads.
* Wheel squeal from the trains exiting the SSFL have also been identified, as tight radius curves lead to wheel squeal. The MIC noise analyst has agreed that wheel squeal is likely to be a factor with some of the three different rail entry options currently under consideration. A factor that will apparently be decided once the tender is awarded, a decision that is likely to be economically based with no consideration for the nearby community.
* An intermodal at Badgerys Creek will not have the same noise implications, due to it being located in a purpose built heavy industrial area. The size of the Badgerys Creek site will also allow trains to remain whole within the terminal, negating the need for breaking and shunting of trains. Rail access will not be restricted by the construction of rail bridges over the Georges River, as is the case at Moorebank, reducing the instance of wheel squeal by negating the need for tight entry and exit points. Compression breaking can be limited through planned road upgrades specifically designed for heavy vehicle movements.

Local air quality

MIC have recognised that exposure to pollutants and particulate matter (PM) can contribute to, or exacerbate, respiratory and cardiovascular issues, including



premature mortality and morbidity, in addition to increasing associated hospitalisations. This supports that point that this proposal should not be planned for a residential area.
* Placing a heavy industrial facility in the middle of a residential area is negligent and will be detrimental to the community. The proposed site is located in a basin which allows pollution to lie, rather than easily move away. The NSW Planning and Assessment Commission have already recognised that the air quality in the Liverpool area is generally well below guidelines, particularly PM2.5 concentrations which are close to or above the advisory criteria. Additional diesel emissions and particulate matter released from this proposal will prove dangerous for residents, especially the most vulnerable: children, the elderly and disabled members of the community.
* Diesel fumes and particulate matter are carcinogenic, and as well as causing other serious illnesses, will be fatal for some members of the community.
* It has been identified that diesel locomotives and switch engines are significant contributors of SO2, NOx, PM10, PM2.5 and PAHs, while onsite mobile equipment (ITVs, side picks and forklifts) are the highest contributor to CO and VOC emissions, they also contribute substantially to PM10, PM2.5.
* It is understood the decision about onsite equipment will be made by the tender winner and based on economics rather than community welfare.
* During operation of the Project, combustion engine emissions (i.e. NOx, CO, SO2, PM2.5, PM10, VOCs and PAHs) from locomotives, mobile LNG equipment and heavy vehicles represent the greatest potential for air quality impacts.
* With 297 train movements each week and approximately 10,000 truck movements each day it is concerning that a proposal of this nature could be considered alongside



family homes, and close to pre-schools, primary schools, high schools, as well as aged care facilities.
* Badgerys Creek, an Australian Government owned area, is away from residential properties, and therefore not likely to cause the same risks as the Moorebank site. It is also well placed near the M7 and the proposed M9 Motorways, providing the ability of the intermodal to service future growth centres, near the Western Sydney Employment Area (WSEA), future industrial areas and future freight markets in Western Sydney, where two-thirds of container freight received at Port Botany will be transported.

Human health risks and impacts
* The NSW Chief Health Officer's Report (2010) identified that health gains achieved over the past few decades have not been equally shared across the entire NSW population and that there is a gap between those with good and poor health. This gap is exacerbated in poorer communities.
* South Western Sydney has some of the poorest communities in NSW as measured by the SIEFA data (Australian Bureau of Statistics (ABS 2011).
* South Western Sydney has higher rates of people with disabilities than the NSW average. People with disabilities have health conditions which may or may not be related to their disability.
* In 2004 - 2008, South Western Sydney residents had higher incidence of lung, kidney, head and neck, pancreas, thyroid, stomach, bladder, uterus and liver cancer than NSW.



* Mortality rates in South Western Sydney for cardiovascular disease at 83.9 per 100,000 are 5% higher than the NSW average of 100 and are significantly higher in Liverpool LGA (111.4) (2005/06).
* Very high psychological distress was reported by 13.2% of South Western Sydney residents (2.1% above the NSW average).
* As previously noted, MIC have recognised that exposure to pollutants and particulate matter (PM) can contribute to, or exacerbate, respiratory and cardiovascular issues, including premature mortality and morbidity, in addition to increasing associated hospitalisations. And that that diesel locomotives, switch engines, and onsite mobile equipment (ITVs, side picks and forklifts) are significant contributors of PM10, and PM2.5.
* As also noted, above acceptable noise levels that will result from an intermodal terminal can have health impacts including: annoyance, sleep disturbance, performance issues (reduced concentration), cardiovascular health problems, hearing problems, mental health effects, and general health impacts (e.g. on the immune system).
* Traffic impacts with the identified the problem of Trucks `weaving' onto and off the M5 is a significant problem. This `weaving' has the potential to cause a recognised `black spot', with potentially fatal consequences for the community.
* It is highly negligent of the Government to consider building an intermodal at the currently proposed Moorebank site. The site is located in the middle of a residential area, and the consequences of such a decision will prove dire to the community.
* Badgerys Creek is by far a site better suited to meet the criteria that the MIC has listed in their EIS summary.

Support from elected representatives
The role of three tiers of government is to ensure that community needs can be voiced to the government by their local elected representatives. These representatives are based within the community, they understand the local area, and are acutely aware of the geographic typography of the area and their constituents needs.
The representatives from the Liverpool area are all unequivocally stating that the Moorebank Intermodal proposal is in the wrong location. This includes the federal member for Hughes, Craig Kelly MP; the state member for Menai, Melanie Gibbons MP; and Liverpool City Mayor, Ned Mannoun.
It is worth noting these representatives recognise the need for an intermodal terminal within metropolitan Sydney to support future freight growth in New South Wales; however, Badgerys Creek is the ultimate location for this development. Liverpool Council have recently released a discussion paper titled `Badgerys Creek: the ideal location for an intermodal' (October 2014).
It is time for the government to listen to their party members who are voicing some very valid concerns, and join the discussion about a new location for this project.

Alternative uses for the land at Moorebank
The residents of Liverpool also support the Freight Infrastructure Advisory Board (FIAB) recommendation of the development of new intermodal freight capacity within metropolitan Sydney. However, the residents believe that the location of this development should be strategically placed to meet future growth and freight capacity. Therefore, it is proposed that Badgerys Creek, rather than Moorebank, is recognised as the consummate site for development.
`In 2011, the Australian Government developed the Liveable Cities Program (now called the Liveable Communities Programme) to support state, territory and local governments in meeting the challenges of improving the quality of life in our capitals and major regional cities' (2011, Department of Infrastructure and Regional Development website).
As part of this program, Parramatta City Council (the only Sydney council selected for the program) received $16,150,000 in funding to complete three missing links on the Parramatta Valley Cycle way, and undertake a series of related works on the Parramatta River Foreshore. The money used for this revitalisation has given Parramatta an economic and social boost.
The site identified for the Moorebank intermodal is prime, urban, riverfront land. This land should be used to assist the government in solving the housing crisis identified in the draft Metropolitan Strategy for Sydney, by using the development as a premium riverside residential lifestyle precinct. The land is situated less than 30 Kilometres from the Sydney CBD. It is in close proximity to public transport, including the T2 Airport and T2 Inner West & South lines (both of which have capacity to accommodate urban growth in this area), the Liverpool to Parramatta T-Way, the M90 Liverpool to Burwood bus route, and many suburban bus routes. In short, the Moorebank location is perfectly positioned and adequately serviced by public transport to assist the government in meeting its housing targets set in the Metropolitan Strategy for Sydney.

An independent valuation (Cushman and Wakefield Development Opportunity Liverpool Riverside Lands, September 2014) valued the SIMTA and MIC sites at more than $482 million. Revenue raised from the sale of this land could be used to assist in the funding of the infrastructure needed to support, and fast-track an intermodal at Badgerys Creek.
NSW Chief Health Officer's Report (2010) identified that there is considerable evidence that social factors (e.g. income, employment and education) have a critical role in health outcomes. A plan to revitalise the Liverpool area by embracing natural assets, such as the Georges River, and utilising land to its full potential presents an opportunity to lift the socio-economic status and improve overall health in the area. The Liveable Communities Programme in Parramatta is a testament to this.
Preserving the Casula Powerhouse Arts Centre and maintaining its accessibility to the community will boost the social economy of the area and contribute positively to community growth.
Linda Silmalis, in her Sunday Telegraph article (9 November 2014) says that `NEW housing sites for 11,000 homes will be unlocked today as the NSW government seizes on a building boom with one of the biggest land releases in Sydney this year.' On this topic, `State Planning Minister Pru Goward said the areas will help drive the housing construction boom, while placing downward pressure on house prices.' (Silmalis, L., 2014, `Grab your new home out west', Sunday Telegraph, 9 November 2014). Liverpool Council estimates that the land proposed for the Moorebank intermodals has the capacity for approximately 16,500 riverside dwellings, housing more than 40,000 people, and giving the community access to the Georges River. This will assist the government in meeting its targets, identified in the draft Metropolitan Strategy for Sydney, to develop housing for more than 1.6 million people. Affordable housing is a much better use of the land in this area.
Good, well considered, strategic planning is required to maintain New South Wales' status as the Premier State. This includes planning major infrastructure projects, such as an intermodal terminal, in the right location. The right location for this proposal is not Moorebank; Badgerys Creek is far better suited and situated to meet the Government's freight infrastructure needs.
Please reject this proposal on the grounds that it is not in the public interest of the residents of Liverpool or the wider community.

-------------------------------------------------------------------------------------------------------------------------
JOBS
One of the selling points for this proposal is the apparent large number of jobs for the people of the area. This is false advertising as everybody knows that jobs will be awarded on the basis of skill and experience, not location of where one lives.

It's anticipated 1650 full time jobs will be created during construction, and a further 1,700 people could be employed in the Liverpool region once the project is up and running.

Since a technology park or commercial development could employ 15,000 people on that block of land, 1700 jobs in the region, not even at the terminal, but every related industry from the lunch shop to the warehouse to the trucks that are going to congest local roads. That's over 13,000 local people forced to catch the overcrowded trains into town or drive to North Ryde or Rhodes or Mascot because the government doesn't want them to work locally.
This terminal robs around 13,000 local people of the opportunity to work in the local area. A commercial development of a similar density to Rhodes or Macquarie Park could easily accomodate 15,000 office workers on the site and with a station just across the river all that's needed to reduce the traffic is a foot bridge.

Many local residents have raised concerns about the likelihood that other land uses, such as commercial land uses, could provide many more jobs. At the PAC meeting we heard just how much worse a container terminal is as a source of jobs than a commercial development on a hectare for hectare basis.

What shocked me was hearing how the terminal actually takes jobs away from the local area!

If the terminal goes ahead, then it is reasonable to think that light industrial areas will be converted to warehousing. All of those containers have to go somewhere right? But large warehouses employ fewer people per hectare than light industrial developments - each small manufacturer and panel beater, and so write more pay cheques at the end of the week than a huge warehouse does.


TRUCKS OFF ROADS LIE
Another selling point for this proposal has been the false statements that it will take trucks off the M5 motorway between Port Botany and Moorebank. This falsity was even admitted by the CEO of the MIT, Ian Hunt in one of the community consultations in Casula.
"A new freight terminal in Sydney's south-west will take 3,300 trucks off Sydney roads" has been a phrase used to push this proposal through.
Now this lie is so obvious that I can't believe they aren't ashamed to say it. Each container that arrives on a train has to get back onto the same truck that would have taken it away from Port Botany. That's a sum total of zero trucks taken off the road. They might be closer to their destination, but they are still on the road and they are on roads they weren't on before.

Another statement widely used had been
"Moorebank is the ideal location because of its close proximity to major connecting routes such as the M5, M7 and the Southern Sydney Freight Line"

If all of these trucks are disappearing from the roads, why the emphasis on proximity to the M5 and M7? The truth is they are taking trucks off the roads in their electorates and putting them somewhere else. This doesn't fix the problem, it just moves it.



COMMUNITY CONSULTATION

This has been not covered adequately and appropriately. The information sessions at Casula of which I attended 2, were inadequate.

Firstly the timing of some of these meetings was unfair. It coincided with the everyday family's dinner time or after school arrangements or most of all occurred during normal business hours or at times when residents might be travelling home from work.

Secondly the rushed approach by the lady acting as a mediator or host of the meeting was inappropriate. There were many people with questions and concerns which needed answering and naturally that would take a long time to answer all of them. But that is what the community consultation is supposed to be for. It was like the MIT group were trying to dodge the issues and not face the facts that this proposal is inappropriate for Moorebank on so many levels.

The phone book size of each technical EIS relating to the various fields of study is too much information for the everyday person to read and comprehend and therefore makes a detailed technical submission very difficult to produce.



NOISE

Moorebank Intermodal Company state that some mitigation will be required to protect residents of Wattle Grove and Casula from substantial noise levels. I question the words, "some mitigation" due to the fact that residents who live in the suburbs that surround the Port Botany Container Terminal have for some time suffered from sleep disturbance. The noise created by the terminal is so loud that people living up to 3 kilometres from the SITE are being kept awake of a night.
What hope do MICL have of mitigating the noise level on those residents living as close as 400 to 900 metres from their facility. "They are certainly with the fairies"

The EIS states "Negligible increase in noise levels from 8160 trucks, 5724 small vehicles and 39 freight trains per day". How can this be so? Especially to resident living within 400 metres from the site.



POLLUTION

Base line studies for air pollution need to be accurate and based on a wide selection of the community. The testing stations should be placed in schools, child care centres, aged care facilities, local streets, parks etc. The figures should be made available to the public via a website and should be updated on an hourly/daily basis as they do in Japan so the public is warned when the pollution levels get too high for people to be outside for too long.

THE FUTURE

Ian Hunt said during the community consultation that MICL are in negotiations with SIMTA as the preferred operator of the terminal. Whether it is SIMTA or another company that ends up operating it, MICL plan to sell it regardless he told us.
It has also been stated in an MICL booklet that "the plans will be revised by the terminal operator so the final design is likely to be different from the concept plan".
Does this mean that the operator of the terminal will not have to strictly stick to the design features that MICL have said will:
1) mitigate or control the noise
2) mitigate or control the traffic congestion
3) mitigate or control air pollution
4) enhance the community or be beneficial to the community ie in relation to aesthetic appeal or number of predicted jobs

MICL will set the guidelines or recommendations as stated in their EIS, Project Plan and Approval Stage Processes that are intended or estimated (note: not guaranteed) to mitigate (note: not remove) any negatives as a result of the operation being built to their plans. If this isn't terrible enough for the nearby residents or commuters to accept, there is no guarantee that the future operator, as a business trying to save money, will strictly follow all of the recommendations made in the EIS. It is expected that as a company trying to save money, that they will cut corners at the detriment of the nearby residents and commuters of South Western Sydney.

Who will monitor their movements and practices?

How will statistics such as air and noise pollution be monitored and made available to the public?

Can we trust this information to be an accurate representation of the area? Even the EPA get things wrong-this fact was displayed recently when noise pollution figures at Port Botany were shown to be incorrect and the local residents within a 3 km radius were affected

Who will be responsible for all the noise, pollution and traffic accidents due to the operator not sticking to the guidelines set in the EIS?

Who will be responsible for all the noise, pollution, traffic congestion and traffic accidents due to the experts in their field that have carefully worded their part of the EIS by using weasel words and phrases such as "expected to", "not expected to", "likely", "unlikely" etc to remove any responsibility from themselves once the negative impacts actually begin to take place?

"Mitigating the impact" will not "remove" the negative impacts this intermodal will produce if built at Moorebank which are far too many in number to make this proposal a viable and fair project to go ahead with.

An MIC booklet states " Most of the vehicles using the terminal...are expected to enter the terminal from , and exit to the north....Entrances to the terminal will be designed to prevent trucks travelling to/from the south".
To me this does not give any guarantee to what they are implying because it is only "expected to" (not guaranteed) and "will be designed" (does not mean will be built that way).
This sort of terminology throughout all of the documents does not give the local residents and commuters any sense of security as to what they can expect in the future should this monstrosity be built.

On the same page, "the terminal is likely to have a small impact on vehicle speeds on the M5 Motorway, Hume Hwy and other roads near the terminal. Some local intersections may experience a slightly longer delay time. These impacts will be further investigated in the EIS for the terminal's project approval".
This message is subjective. The words "small" and slightly longer delay time" might mean something totally different to the roads expert writing the EIS verses the commuter who uses the local roads on a daily basis. I also find it hard to believe that only small increase in delay at intersections will be experienced as a result of the terminal's operations in the year 2030 given the volume of vehicles expected to use this site on a 24 hour basis..


Who will pay for all the upgrades to the roads (not on Moorebank Ave) that will be required should this intermodal go ahead? I can see a blame game will start to occur and nothing will get done and commuters will suffer.
Upgrades to roads from Anzac Road to Newbridge Road via the intersections of Wattle Grove Drive, Nuwarra Road, Heathcote Road, Brickmakers Drive have not been mentioned in any literature. Trucks and smaller vehicles will use these roads and nothing has been said about upgrading them to cope with the traffic generated from the intermodal.


Other more appropriate locations have been suggested but everyone seems to be turning a blind eye and going with a poorly considered and ill-conceived plan. Badgerys Creek and Eastern Creek do not cause the same impacts and would make far more sense.

--------------------------------------------------------------------------------------------------------------------------


POLLUTION
Placing a heavy industrial facility in the middle of a residential area is negligent and will be detrimental to our community. The proposed site is located in a basin which allows pollution to lie, rather than easily move away. The NSW Planning and Assessment Commission have already recognised that the air quality in the Liverpool area is generally well below guidelines. Additional diesel emissions and particulate matter released from this proposal will prove dangerous for residents, especially children and the elderly.

TRAFFIC CONGESTION/INFRUSTRUCTURE REQUIREMENTS
The M5 motorway and surrounding roads in the South West Region are already suffering from chronic traffic congestion and this will significantly worsen with the 10,000 additional truck movements per day expected from the new Intermodal - that's an extra truck every 8 seconds, 24 hours a day, 7 days a week. It will also mean $750 million worth of works will be required on major road and rail connections to accommodate this outdated proposal.


LOCATION
MOOREBANK may not the best place for two proposed intermodal freight terminals, the Leader of the Government in the Senate, Eric Abetz, has conceded.
During a community meeting in Wattle Grove Senator Abetz said that he supported Liverpool Council's campaign to have the terminals relocated to Badgerys Creek.
"The proposed intermodal, which may have been a good idea all those years ago, is no longer a good idea," he said.
Senator Abetz said something that might have been a good idea 10 or 15 years ago was not necessarily a good idea today.
"A good government, I believe, should always be open-minded and should always be flexible," he said. "I happen to agree, that with the current financial status we face as a nation, any decision we make should be looking at the best economic opportunity.
"From what I have heard there is apparently no doubt. That is the message I will be taking back to my ministerial colleagues, that putting an intermodal here, on the face of it, would be extremely inefficient."

The good news is that there is a smart alternative, and this is to build the new Intermodal at the site of the new international airport at Badgerys Creek. Here, it can connect with existing and planned major transport routes while also reducing traffic on our roads.

Badgerys Creek is the better option

It is located where $3.5 billion of new roads and rail lines will be built for the new airport and will save tax payers money
It is big enough to handle the 1.1 million containers each year with room to grow in the future
It would save money as the road and rail upgrades needed for the Moorebank plan would cost more than $750 million.
It will reduce truck traffic in a highly populated residential area, protect air quality and the local environment around the Georges River from permanent degradation, leading to better health outcomes
It is closer to the industial and freight markets of Western Sydney
Badgerys Creek is already owned by the government
The sale of land at Moorebank could raise more than $482 million to fund an intermodal at Badgery's Creek and would house 40,000 people
DEMAND OR NEED FOR AN INTERMODAL AT MOOREBANK
Existing intermodals in Western Sydney have the capacity to expand. The economic viability of the proposed intermodals at Moorebank have already been questioned by the industry (se Asciano challenges freight hub, SMH, July 2, 2014). The PAC's decision to limit the operational capacity of the Moorebank site further calls into question it's viability.
Any intermodal at Moorebank will attract heavy competition from Chullora intermodal in which $112 million is being invested to expand it's capacity to 600,000 TEUs per year by 2015. It is reported that there is further potential to increase capacity at Chullorato 800,000 TEUs per year and the Enfield intermodal is expected to accept up to 300,000 TEUs per year.
Development of the proposed intermodal at Moorebank will take considerable time as it involves the construction of complex rail spurs and intersection upgrades. Chullora and Enfield could address Sydney's freight problems in the short term leaving room to plan for the Badgerys Creek option.

Decades ago, when Moorebank was put forward as the site for the Intermodal, Sydney was not facing a chronic housing crisis and cities didn't value their rivers like we do now. If developed into premium riverside homes, the Moorebank site, worth $482 million, has the potential to help alleviate the current housing crisis identified in the Metropolitan Strategy for Sydney.

A plan to revitalise the Liverpool area by embracing natural assets, such as the Georges River, and utilising land to its full potential presents an opportunity to lift the socio-economic status and improve overall health in the area. Liverpool should be considered as a prime location for the government's Liveable Communities Programme which has been successful in other locations.


MORE REASONS AGAINST AN INTERMODAL AT MOOREBANK

Political leaders Local, State and Federal agree that the intermodals should not be at Moorebank for so many reasons.
Just ask Craig Kelly MP, Melanie Gibbons MP, The Mayor of Liverpool , Ned Mannoun and now Senator Eric Abetz.
Craig Kelly MP and Melanie Gibbons MP have made informative speeches in their parliaments outlining why an intermodal at Moorebank is the wrong thing to do. As not many people were in the house at he time to hear these speeches I feel their message is not getting through to the decision makers. Copies of their speeches displaying just some of the evidence as to why Moorebank is the wrong move can be found on the Hansard records.


In Craig Kelly MP's words in Parliament of Australia:
Mr CRAIG KELLY (Hughes) (17:45)
Tuesday, 16 June 2015
Page: 59
"By having an intermodal at Moorebank instead of at Badgerys Creek, we are losing one of our abilities as a nation to fund the railway line into Badgerys Creek. The member for Grayndler emphasised the importance of building that railway line, but our funding is not unlimited. By investing in Moorebank--by pouring Commonwealth money down the toilet in Moorebank--we are simply making it harder and harder. That money should have been put into the rail link to get it set up at Badgerys Creek.
That draws me to an article that I came across after reading an article by Nick Cater today. This article is called 'Policy and planning for large infrastructure projects: problems, causes, cures'. It is a World Bank working policy from December 2005, and it talks about the exact problem that we have with Badgerys Creek, the 'planning fallacy'. It says:
... a major problem in the planning of large infrastructure projects is the high level of misinformation about costs and benefits that decision makers face in deciding whether to build, and the high risks such misinformation generates.
This is exactly what we have at Moorebank. It goes on, and it cites examples of how forecasts for rail projects have failed. It does a study across different continents, and for rail transportation infrastructure projects it finds the cost overruns, averaged across more than 50 projects, are 44.7 per cent measured in prices. It finds not only that the cost is more than 40 per cent higher but that the actual passage of traffic is 51 per cent lower than predicted. We have seen this in Sydney with our planning debacles: the Cross City Tunnel and the Lane Cove Tunnel. We have seen this in Brisbane. The article goes on:
84 percent of rail passenger forecasts are wrong by more than ... 20 per cent.
9 out of 10 rail projects have overestimated traffic.
Again, this is what we are at risk of seeing at Moorebank. It goes on to ask why this is happening, and it says:
In the grip of the planning fallacy, planners and project promoters make decisions based on delusional optimism rather than on a rational weighting of gains, losses, and probabilities. They overestimate benefits and underestimate costs. They involuntarily spin scenarios of success and overlook the potential for mistakes and miscalculations.
That sums up the Moorebank Intermodal to a tee. It also gives a warning about how to overcome this. It says:
The key weapons in the war on ... waste are accountability and critical questioning.
That is again the problem that we have with Moorebank. There is simply no answering of the critical questions. There are three completely failed premises: it takes trucks off the road, it reduces air pollution and it saves costs. Any critical analysis of those three premises shows that they are completely faulty. In the Moorebank Inter+

The cumulative effects from both the SIMTA and the MIC proposals need to be put together in one EIS FOR A WHOLE OF PRECINCT proposal. NOT SEPARATE as they are so close to each other and the cumulative effects of the 2 proposals running at the same time is disastrous for the local area.

This project should not go ahead due to noise and disruption to residents who have been there all their lives.

This project should not go ahead due to noise and disruption to residents who have been there all their lives.

This project should not go ahead due to noise and disruption to residents who have been there all their lives.

Moorebank Intermodal is a well illustrated example of corporations and govt colluding at the expense of democratic principle and local communities. The traffic and environmental modelling done to date is flawed, conflicted and breathtaking in it's unreliability.

Now that the intial 2 proposals have been merged,please advise the extent of the remodelling of traffic and air quality work you will undertake.Please confirm that revised air quality modelling will include assessment of diesal particulate matter, formaldehyde as part of the new proposal.

The Environmental Impact Statement prepared by the Moorebank Intermodal Company (MIC) states that the proposed Moorebank intermodal will allow imports and exports to grow through Port Botany. This will mean additional traffic on the already congested road network. 10,000 heavy vehicles per day will need to access and leave the terminal utilising the M5 and local roads.
The MIC state that an additional intermodal is required to reduce supply chain costs; however, it is questioned how the proposal at Moorebank will assist in reducing these costs. The proposed terminal in Moorebank will include transferring freight by rail less than 25 Kilometres from Port Botany, while increasing the handling costs of the supply chain with containers having to be loaded and unloaded multiple times in a very short distance. Infrastructure NSW has also questioned the viability of short haul freight and the funding of additional intermodal facilities until this has been properly investigated. That being the case, the increase in capacity at Chullora should be investigated with proper planning for a true intermodal at Badgerys Creek. Jenny Wiggins, in her Sydney Morning Herald article, states that Asciano is primed to invest $112 million to `compete "vigorously" with its own intermodal terminals', for example Chullora, and challenge the Moorebank intermodal essentially casting doubts over the economic viability of the Moorebank site (Wiggins, J., 2014, `Asciano challenges Moorebank freight hub', Sydney Morning Herald, 2 July 2014).
To truly reduce supply chain costs, the intermodal location should be moved to Badgerys Creek, a facility more than 40 Kilometres from the Port with access to key roads such as the M7 and the proposed M9. This location will also have the capacity to support future growth centres and will allow for airfreight. The M9 motorway will provide `a direct link between the Central Coast and the Illawarra, connecting the growth centres of Camden, Penrith and Windsor' (O'Rourke, J., 2014, `What Sydney needs to transport us to the future', Daily Telegraph, 3 November 2014). An intermodal at Badgerys Creek demonstrates good strategic and growth planning.
Why Badgerys Creek is a better location than Moorebank
The MIC, in their Environmental Impact Statement, attempt to describe why Moorebank has been selected as a location. However, Badgerys Creek is better suited to meet the criteria that the MIC has listed.
Badgerys Creek is an ideal location for an intermodal terminal to handle both interstate and import-export freight. This is because it is:
* long enough for interstate freight trains without the need for trains to be broken up and shunted, creating unnecessary additional noise in the area;
* big enough to handle the number of container movements required - up to 1.1 million twenty foot Equivalent Units (TEUs) per year of import-export freight and another 500,000 TEUs per year of interstate freight. This is a greater capacity than the proposed Moorebank site;
* strategically located in an area where a new rail line is planned for the airport;
* near the M7 Motorway, a link to the West and North West where it has been identified by Deloitte that most of the container freight will be headed, and accessible to the M5;
* near the proposed M9 Motorway, providing the ability of the intermodal to service future growth centres;
* near the Western Sydney Employment Area (WSEA), future industrial areas and future freight markets in Western Sydney, where two-thirds of container freight received at Port Botany will be transported.
* further from Port Botany than the Moorebank site, making rail a viable alternative to trucks, and reducing supply chain costs;
* in development, meaning that truck access can be configured into the $3.5 billion already allocated to the surrounding road infrastructure network rather than upgrading roads that are already at capacity in the Moorebank precinct; and
* owned by the Australian Government and available for use consistent with the airport.
Problems with the Moorebank proposal
The Moorebank site constrained by a number of issues:
* The area is already suffering from significant traffic congestion, the addition of an estimated 10,000 truck movements and approximately 5,000 passenger car movements per day will exacerbate this congestion.
* The Planning and Assessment Commission (PAC), following their community meeting on the SIMTA proposal, has identified that the Moorebank area is already suffering from significant traffic congestion. `The community has strongly argued that the proposal is only going to move the congestion from Port Botany to the Liverpool/Campbelltown region. The Commission understands the Moorebank site is constrained by the surrounding residential and industrial land uses and the already heavily congested local and regional road network. If the concept plan were to be approved with the levels of throughput proposed by both SIMTA and MIC, then clearly the community's case is strengthened.' (2014, Planning and Assessment Commission, SIMTA assessment).
* The SIMTA Concept plan was approved by the PAC on the basis that they are limited to 250,000 TEU's, plus an additional 250,000 ONLY if the road network is able to handle the volume of heavy vehicle traffic. This being the determination made by the PAC, and in the absence of a master plan that would have enabled the commission to assess the impact of both proposals as part of the one process, this limit should apply to the operation of both SIMTA and Moorebank intermodal sites combined. TEU's should be limited to a total of 250,000 in this precinct.
* The economic viability of the site has been questioned due to the limits placed by the PAC on the number of TEUs SIMTA can move through their terminal. Chief Executive of Asciano has also questioned the economic viability of the site as previously mentioned, stating that Asciano plan to invest $112 million in their sites to increase capacity and making Chullora more competitive, able to handle an increased capacity from Port Botany, and open for operation before Moorebank (Wiggins, J., 2014, `Asciano challenges Moorebank freight hub', Sydney Morning Herald, 2 July 2014). With the Chullora intermodal capacity increased to 800,000 TEU it will easily be able to support increased in freight through Port Botany while the Badgerys Creek site is planned and constructed.
* The Moorebank site is surrounded by water on all sides. This means that the complex road and rail upgrades needed to service an intermodal in this area will be extremely costly. Liverpool Council has estimated these upgrades are likely to cost in excess of $750 million.
* There are significant problems relating to air quality, construction and operational noise impacts created by the intermodals. A proposal of this size and nature should not be earmarked for a residential area.
* The PAC determination of the SIMTA proposal has already revealed that Particulate Matter 2.5 levels in the local area are close to or above the advisory criteria for this pollutant, this applies to the current background levels as well as the predicted impacts. Additional diesel and liquid natural gas powered vehicles in this area will exacerbate this problem.
* Noise impacts, light spill and air pollution will have a detrimental effect on the local community, some of whom live as close as 400 metres from the site. Residents around Port Botany living as far as three kilometres from the port are affected by these factors; many residents in Chifley for example have been very vocal about sleep disturbance in the online domain.
* The Moorebank site will have a detrimental impact on the Casula Powerhouse Arts Centre. The presence and accessibility of an art and cultural facility in a low socio-economic area, such as Liverpool, is essential for positive community growth.
Problems with the process
The Freight Infrastructure Advisory Board (FIAB) recommended a master plan for the site, this was not undertaken. Residents agree the SIMTA and MIC proposals should have been considered as a single precinct application. This has created an unfair advantage for the proponents with confusion being created among the community with both proponents presenting different figures. The fact that both proposals were assessed separately also means that media attention highlighting the different stages of the planning and assessment process has also created confusion in the community. Coupled with this, the relocation of the Defence National Storage Distribution Centre (DNSDC) and the current construction works at Holsworthy Barracks have also exacerbated this confusion with many people within the community thinking the proposal is already in its construction phase.
Liverpool Council, in meeting with PAC expressed disappointment that a master plan was not undertaken and confirms that this has created confusion within the community `The ad hoc approach .........leaves gaps and inconsistencies in the information available resulting in a lack of transparency and reduced faith in government decision making.'
A master plan would have reduced this confusion and allowed the community to better understand the impacts these proposals will have on their family, friends and neighbours. It would have allowed the community to better refute claims made by the proponents, and have a much greater grasp of any proposed mitigation strategies for this proposal.
The MIC has also created confusion and doubt within the community, adding to a reduced faith in government process and decision making. They have done this first by splitting their figures. Rather than telling the community that there will be 1.55 million TEUs going through the site, they have split these figures between import-export and interstate. And rather than stating that there will be an estimated 297 train movements expected at the site, they have again split these figures to make them sound lower. The Liverpool Leader, in their article `Intermodal company gives community $1m for compensation package but concerned residents aren't buying it', reports on community concerns around the consultation process. This `compensation package' will be completely inadequate to address the impacts this proposal will have on the area, and made MIC seem like it was trying to `buy community support'. At the same time MIC also made a highly publicised donation to the Liverpool Mayoral Ball, which Liverpool Council subsequently rejected (Hansen, N., 2014, `Liverpool Mayor knocks back $5k ball donation from intermodal group but the cash is still destined for charity', Liverpool Leader, 22 August 2014).
An intermodal at Badgerys Creek would not require this level of compensation, as it can be properly planned for a suitable area; it also has residential and council support.
Second, the Sydney Morning Herald in their article `Waterfront baron and Liberal Party donor scored inside running on freight hub tender' has highlighted a possible issue around transparency and due process in the awarding of tenders for the Moorebank precinct. In light of the recent ICAC investigations and the problems faced by the Newcastle community, transparency and due process are paramount in the government decision making process.
Key issues from the community
There were some issues raised by local representatives and the community at the PAC determination meeting on the SIMTA proposal. These have remained largely unchanged in relation to the MIC proposal.
Traffic and access
* The proposal will move the congestion from Port Botany to Moorebank, which is already congested;
* Modelling does not include the predicted growth of the region;
* The intersections and road network are already congested, how is it possible for the proposal to decrease traffic delays?
* Trucks `weaving' onto and off the M5 between the Moorebank and Hume Highway interchanges, this is going to cause accidents; and
* Trucks parking and taking short‐cuts through the nearby streets.
Noise
* There is no noise wall along the rail corridor along the Georges River, so noise will carry particularly at night;
* Noise from the unloading/loading and movement of containers within the terminal;
* Noise from the breaking and shunting of trains due to the site sizing constraints; and
* Wheel squeal from the trains exiting the SSFL, tight radius curves lead to wheel squeal.

Air quality
* Increased diesel fumes in the community generated from locomotives, heavy vehicles and other heavy equipment used on site;
* Health impacts from the increased diesel fumes;
* South‐west Sydney is already heavily polluted due to the topography; and
* Dust and odour, particularly during construction.
Two intermodal proposals
(SIMTA and MIC)
* There is an ad hoc approach to the two proposals;
* Cumulative impacts of the two proposals have not been adequately addressed; and
* Confusion as to the total traffic generated from the two proposals, as the modelling for each is different.

Heritage
* Removal of heritage features from the site, particularly those of military and indigenous significance.

Location
* Site is surrounded by residential development;
* Our Defence personnel live and work at this location; and
* Other sites are preferable, such as Badgerys Creek, which is not surrounded by an established community.
Moorebank Intermodal Company EIS presentation
There was considerable concern from the community over the presentation that was given for the MIC EIS submission. Figures and statistics presented by MIC seemed to be inconsistent and the facilitator tried, on a number of occasions, to ask the community to voice their concerns directly to MIC representatives rather than in the public forum. At each of the three sessions the facilitator kept stating that she was conscious of time; however, the community feel that their questions about a proposal that will impact their family and community deserved an answer, and are more important than clock watching. The number of questions from the community at the final community information session saw the session run over time.

Traffic and Transport
* The MIC recognised that there are significant transport and traffic congestion problems in the Moorebank precinct; however, they claim that the additional 8,160 heavy vehicles and 5,724 cars they predict to be brought into this precinct every day due to an intermodal will not have any further impact.
* The Chief Executive Officer of MIC stated that there would be approximately 1.6 trucks required per TEU. He also stated that 1,400,000 TEUs would be required to leave the terminal by truck. According to this statement, and given that heavy vehicles will have to both arrive and leave from the precinct, the figure of 8,160 heavy vehicles per day seems low, this actually equates to 12,376 heavy vehicles per day. For the purposes of this document the figure of 10,000 heavy vehicle movements per day has been chosen as a more accurate representation of the figures.
* The Chief Executive Officer of MIC also confirmed that the Moorebank intermodal will not take heavy vehicles off the M5 between Port Botany and Moorebank, and that as Port Botany expands the number of heavy vehicle movements on this stretch of the M5 is expected to grow. It should be noted that Labour Minister Anthony Albanese previously claimed that the Moorebank intermodal would take trucks off the M5; this fallacy gained a lot of momentum especially in the media and it has never been publicly corrected.
* Questions were raised by the community about the problem of Trucks `weaving' onto and off the M5 between the Moorebank and Hume Highway interchanges. MIC recognises this as a significant problem.
This `weaving' has the potential to cause a recognised `black spot', with potentially fatal consequences for the community. It is worth noting that a `black spot' is already located at the Nuwarra Road and Heathcote Road intersection, only 2 Kilometres from the `weave' site.
* The traffic modeller for MIC presented information about the predicted impacts on intersections both with the intermodal and without. Intersection surveys were undertaken on Tuesday 7 December 2010, and Tuesday 18 March 2014, in peak hours only. It is concerning that these surveys seem to only have been conducted on two days, four years apart, with the December date being in a peak holiday period.
* A Seven-day automatic traffic count was also conducted from Tuesday 7 December 2010 at only three locations along Moorebank Avenue. It is concerning that four year old data, gathered prior to a number of new and extensive residential developments in the area, is being used as a base for traffic modelling.
* The data presented by the traffic modeller showed a delay of over 200 seconds at some intersections when the intermodal is in operation. A 200 second delay, coupled with a 150-180 second cycle on a normal set of traffic lights is a significant impact (approximately six minutes at EACH set of lights), one that is likely to have flow on effects.
He has compared data, which is based on a scenario where the intermodal is operating with road and intersection upgrades, with predicted data based on no intermodal without road upgrades. This is not comparing like for like. Given that intersections in this area are currently operating at D or E classification (near or at capacity), it is hard to believe that the roads in the area will not be upgraded by relevant authorities to attempt to reduce congestion before they reach an F classification.
* It has been noticed that traffic figures do not take into account the recently announced WestConnex which will have major traffic implications on the M5 during construction; this coincides with the proposed opening date of the Moorebank intermodal.
The WestConnex project also aims to increase Port Botany by 272% more container ships by catering for a greater number of heavy vehicle traffic movements on the M5.
Labour Minister Anthony Albanese criticises the WestConnex `proposal for not going near Port Botany, where it is expected there will be a large rise in the number of container trucks'. He also questions the government's transparency, citing that `the decision to release new information about the impact of WestConnex on Melbourne Cup Day indicates to me that those who support this route are aware of its shortcomings and are keen to avoid public scrutiny.' (Saulwick, J., 2014, `Albanese pans plans for the WestConnex', Sydney Morning Herald, 10 November 2014).
* Residents are understandably concerned about the impact of intermodal traffic on local and residential roads. The MIC confirmed at the community information session that while they can implement some measures for traffic movements, it will ultimately be up to the design of the precinct, the way the precinct operators choose to use the precinct, and choices made by heavy vehicle drivers as to which route they choose to use. With heavy congestion on Moorebank Avenue and the M5, two of the key roads in the area, it is likely that Anzac Road and Cambridge Avenue will be used as `rat runs' for heavy vehicles.
* The MIC traffic modeller recognised that currently 6% of traffic on Anzac Road in the peak is heavy vehicle traffic; however he failed to include any heavy vehicle movements in his trip distribution figures for this road. In current heavy traffic conditions Anzac Road is a very attractive option, as demonstrated when the M5 is congested. Heavy traffic movements on a congested day are far higher than those measured by MIC. The omission of this traffic flow information from MIC data sets is hard to fathom. For the local residents, especially those with houses that back onto Anzac Road, it creates uncertainty and distrust in the accuracy of the information presented.
* The construction of an intermodal terminal at Moorebank shows a lack of strategic planning, particularly in relation to future traffic movements.
* An intermodal at Badgerys Creek will be a true intermodal with road, rail and air access. This area will serve the purpose of meeting the needs of future growth centres. The government currently has the ability to configure appropriate and safe truck access in the Badgerys Creek area with $3.5 billion in funding dedicated for road infrastructure.
Rail access
* MIC has predicted an additional 297 train movements each week, this figure does not include the interstate trains that may transit through the terminal.
* It was unclear how these train movements would impact residents in the area, due to three different rail entry options currently under consideration.
* Due to the length of trains, they will need to be broken up and shunted.
* MIC communicated that the actual rail entry will be decided once a tender for operation of the facility has been awarded. This makes it difficult for residents to understand the impacts of the rail access.
* It is unclear whether rail access will impact the passenger rail line and impact on travel times for people travelling by rail to the Sydney CBD.
* An intermodal at Badgerys Creek will not have the same rail implications. The size of the site will allow trains to remain whole within the terminal without the need for breaking and shunting.

Noise and vibration
* In order to ascertain acceptable noise levels in the area, the MIC have measured ambient noise levels between 2010 and 2011, and then from July 2012 to establish a base index. Approximately 20 of the 34 noise receptors set up and monitored by the MIC to establish this base index were located along train lines and major roads.
* Given that most residents in the area live in quiet, peaceful streets, it is a concern that the receptors set to ascertain the base index for ambient noise seems to have been placed in predominantly noisy locations.
* The residential suburbs of Casula, Wattle Grove and North Glenfield are the closest communities to the Project site; however, these will not be the only locations impacted by the noise generated from the proposed intermodal.
* In a recent article in the Sydney Morning Herald it was learned that `After more than a year of residents around Port Botany being told the night time noises they were complaining about did not exceed "sleep disturbance criteria", the Environment Protection Authority has admitted they were right.' (O'Brien, N., 2014, `EPA admits it was mistaken about Port Botany noise levels', Sydney Morning Herald, 17 August 2014).
* Residents in the precinct are understandably concerned that noise levels will exceed those acceptable. Above acceptable noise levels can have health impacts including: annoyance, sleep disturbance, performance issues (reduced concentration), cardiovascular health problems, hearing problems, mental health effects, and general health impacts (e.g. on the immune system).
* There is currently no noise wall along the rail corridor along the Georges River, so noise will carry particularly at night.
* There is no doubt there will be excessive noise from the unloading/loading and movement of containers within the terminal, which will operate 24 hours a day, as well the breaking and shunting of trains due to the site sizing constraints, and compression breaking of trucks on the surrounding roads.
* Wheel squeal from the trains exiting the SSFL have also been identified, as tight radius curves lead to wheel squeal. The MIC noise analyst has agreed that wheel squeal is likely to be a factor with some of the three different rail entry options currently under consideration. A factor that will apparently be decided once the tender is awarded, a decision that is likely to be economically based with no consideration for the nearby community.
* An intermodal at Badgerys Creek will not have the same noise implications, due to it being located in a purpose built heavy industrial area. The size of the Badgerys Creek site will also allow trains to remain whole within the terminal, negating the need for breaking and shunting of trains. Rail access will not be restricted by the construction of rail bridges over the Georges River, as is the case at Moorebank, reducing the instance of wheel squeal by negating the need for tight entry and exit points. Compression breaking can be limited through planned road upgrades specifically designed for heavy vehicle movements.
Local air quality
* MIC have recognised that exposure to pollutants and particulate matter (PM) can contribute to, or exacerbate, respiratory and cardiovascular issues, including premature mortality and morbidity, in addition to increasing associated hospitalisations. This supports that point that this proposal should not be planned for a residential area.
* Placing a heavy industrial facility in the middle of a residential area is negligent and will be detrimental to the community. The proposed site is located in a basin which allows pollution to lie, rather than easily move away. The NSW Planning and Assessment Commission have already recognised that the air quality in the Liverpool area is generally well below guidelines, particularly PM2.5 concentrations which are close to or above the advisory criteria. Additional diesel emissions and particulate matter released from this proposal will prove dangerous for residents, especially the most vulnerable: children, the elderly and disabled members of the community.
* Diesel fumes and particulate matter are carcinogenic, and as well as causing other serious illnesses, will be fatal for some members of the community.
* It has been identified that diesel locomotives and switch engines are significant contributors of SO2, NOx, PM10, PM2.5 and PAHs, while onsite mobile equipment (ITVs, side picks and forklifts) are the highest contributor to CO and VOC emissions, they also contribute substantially to PM10, PM2.5.
* It is understood the decision about onsite equipment will be made by the tender winner and based on economics rather than community welfare.
* During operation of the Project, combustion engine emissions (i.e. NOx, CO, SO2, PM2.5, PM10, VOCs and PAHs) from locomotives, mobile LNG equipment and heavy vehicles represent the greatest potential for air quality impacts.
* With 297 train movements each week and approximately 10,000 truck movements each day it is concerning that a proposal of this nature could be considered alongside family homes, and close to pre-schools, primary schools, high schools, as well as aged care facilities.
* Badgerys Creek, an Australian Government owned area, is away from residential properties, and therefore not likely to cause the same risks as the Moorebank site. It is also well placed near the M7 and the proposed M9 Motorways, providing the ability of the intermodal to service future growth centres, near the Western Sydney Employment Area (WSEA), future industrial areas and future freight markets in Western Sydney, where two-thirds of container freight received at Port Botany will be transported.
Human health risks and impacts
* The NSW Chief Health Officer's Report (2010) identified that health gains achieved over the past few decades have not been equally shared across the entire NSW population and that there is a gap between those with good and poor health. This gap is exacerbated in poorer communities.
* South Western Sydney has some of the poorest communities in NSW as measured by the SIEFA data (Australian Bureau of Statistics (ABS 2011).
* South Western Sydney has higher rates of people with disabilities than the NSW average. People with disabilities have health conditions which may or may not be related to their disability.
* In 2004 - 2008, South Western Sydney residents had higher incidence of lung, kidney, head and neck, pancreas, thyroid, stomach, bladder, uterus and liver cancer than NSW.
* Mortality rates in South Western Sydney for cardiovascular disease at 83.9 per 100,000 are 5% higher than the NSW average of 100 and are significantly higher in Liverpool LGA (111.4) (2005/06).
* Very high psychological distress was reported by 13.2% of South Western Sydney residents (2.1% above the NSW average).
* As previously noted, MIC have recognised that exposure to pollutants and particulate matter (PM) can contribute to, or exacerbate, respiratory and cardiovascular issues, including premature mortality and morbidity, in addition to increasing associated hospitalisations. And that that diesel locomotives, switch engines, and onsite mobile equipment (ITVs, side picks and forklifts) are significant contributors of PM10, and PM2.5.
* As also noted, above acceptable noise levels that will result from an intermodal terminal can have health impacts including: annoyance, sleep disturbance, performance issues (reduced concentration), cardiovascular health problems, hearing problems, mental health effects, and general health impacts (e.g. on the immune system).
* Traffic impacts with the identified the problem of Trucks `weaving' onto and off the M5 is a significant problem. This `weaving' has the potential to cause a recognised `black spot', with potentially fatal consequences for the community.
* It is highly negligent of the Government to consider building an intermodal at the currently proposed Moorebank site. The site is located in the middle of a residential area, and the consequences of such a decision will prove dire to the community.
* Badgerys Creek is by far a site better suited to meet the criteria that the MIC has listed in their EIS summary.
Support from elected representatives
The role of three tiers of government is to ensure that community needs can be voiced to the government by their local elected representatives. These representatives are based within the community, they understand the local area, and are acutely aware of the geographic typography of the area and their constituents needs.
The representatives from the Liverpool area are all unequivocally stating that the Moorebank Intermodal proposal is in the wrong location. This includes the federal member for Hughes, Craig Kelly MP; the state member for Menai, Melanie Gibbons MP; and Liverpool City Mayor, Ned Mannoun.
It is worth noting these representatives recognise the need for an intermodal terminal within metropolitan Sydney to support future freight growth in New South Wales; however, Badgerys Creek is the ultimate location for this development. Liverpool Council have recently released a discussion paper titled `Badgerys Creek: the ideal location for an intermodal' (October 2014).
It is time for the government to listen to their party members who are voicing some very valid concerns, and join the discussion about a new location for this project.
Alternative uses for the land at Moorebank
The residents of Liverpool also support the Freight Infrastructure Advisory Board (FIAB) recommendation of the development of new intermodal freight capacity within metropolitan Sydney. However, the residents believe that the location of this development should be strategically placed to meet future growth and freight capacity. Therefore, it is proposed that Badgerys Creek, rather than Moorebank, is recognised as the consummate site for development.
`In 2011, the Australian Government developed the Liveable Cities Program (now called the Liveable Communities Programme) to support state, territory and local governments in meeting the challenges of improving the quality of life in our capitals and major regional cities' (2011, Department of Infrastructure and Regional Development website).
As part of this program, Parramatta City Council (the only Sydney council selected for the program) received $16,150,000 in funding to complete three missing links on the Parramatta Valley Cycle way, and undertake a series of related works on the Parramatta River Foreshore. The money used for this revitalisation has given Parramatta an economic and social boost.
The site identified for the Moorebank intermodal is prime, urban, riverfront land. This land should be used to assist the government in solving the housing crisis identified in the draft Metropolitan Strategy for Sydney, by using the development as a premium riverside residential lifestyle precinct. The land is situated less than 30 Kilometres from the Sydney CBD. It is in close proximity to public transport, including the T2 Airport and T2 Inner West & South lines (both of which have capacity to accommodate urban growth in this area), the Liverpool to Parramatta T-Way, the M90 Liverpool to Burwood bus route, and many suburban bus routes. In short, the Moorebank location is perfectly positioned and adequately serviced by public transport to assist the government in meeting its housing targets set in the Metropolitan Strategy for Sydney.
An independent valuation (Cushman and Wakefield Development Opportunity Liverpool Riverside Lands, September 2014) valued the SIMTA and MIC sites at more than $482 million. Revenue raised from the sale of this land could be used to assist in the funding of the infrastructure needed to support, and fast-track an intermodal at Badgerys Creek.
NSW Chief Health Officer's Report (2010) identified that there is considerable evidence that social factors (e.g. income, employment and education) have a critical role in health outcomes. A plan to revitalise the Liverpool area by embracing natural assets, such as the Georges River, and utilising land to its full potential presents an opportunity to lift the socio-economic status and improve overall health in the area. The Liveable Communities Programme in Parramatta is a testament to this.
Preserving the Casula Powerhouse Arts Centre and maintaining its accessibility to the community will boost the social economy of the area and contribute positively to community growth.
Linda Silmalis, in her Sunday Telegraph article (9 November 2014) says that `NEW housing sites for 11,000 homes will be unlocked today as the NSW government seizes on a building boom with one of the biggest land releases in Sydney this year.' On this topic, `State Planning Minister Pru Goward said the areas will help drive the housing construction boom, while placing downward pressure on house prices.' (Silmalis, L., 2014, `Grab your new home out west', Sunday Telegraph, 9 November 2014). Liverpool Council estimates that the land proposed for the Moorebank intermodals has the capacity for approximately 16,500 riverside dwellings, housing more than 40,000 people, and giving the community access to the Georges River. This will assist the government in meeting its targets, identified in the draft Metropolitan Strategy for Sydney, to develop housing for more than 1.6 million people. Affordable housing is a much better use of the land in this area.
Good, well considered, strategic planning is required to maintain New South Wales' status as the Premier State. This includes planning major infrastructure projects, such as an intermodal terminal, in the right location. The right location for this proposal is not Moorebank; Badgerys Creek is far better suited and situated to meet the Government's freight infrastructure needs.
Please reject this proposal on the grounds that it is not in the public interest of the residents of Liverpool or the wider community.

I very much opposed to the Moorebank Intermodal Terminal at Moorebank for several reasons:

It's proximity to suburban development already there.
Traffic congestion.
Noise pollution.
Air pollution.
Detrimental affect on Casula Powerhouse Arts Centre.
Detrimental affect on Georges River use and proposed recreational development of the river and riverbank.

It makes so much more sense to have the freight terminal at Badgerys Creek close to theproposed airport and not affecting so many people living there as would affect at Moorebank.

I am writing to vehemently oppose the Moorebank Intermodal as it is great injustice to the local Liverpool area.The area has similar traffic flows to the Sydney harbour bridge and hasn't the same infrastructure to support it.The diesel emissions associated with the trucks locomotives vans would expse residents to up to 120 increase of cancer rates and this totally unacceptable and residents will do what they seem necessary to stop this impact on their families.The area next to the Moorebank Intermodal has some of the most valuable endangered species plants and flora in Australia like the koala and Cumberland woodland plain powerful owl etc.With 450000 new residents expected in the south west Sydney in the next 25 years traffic is tipoped to increase 10 told and a delay of 1km is expected on the M5 which makes the possibility of coping with the extra 10000 trucks and 5723 extra cars vans a impossible task with the gridlock on the M5 a 24/7 situation.Our research has revealed that noise in Port Botany travels 3km and this project will be very close to residential areas and my personal experience where I witnessed load noise in the recently upgraded defence supply depot a worrying experience for local residents.the matter of sending heavy freight through heavy residential areas has to stop there are much better options and if placed at a less congested site it would be able to be better accfomadated.The area has a very bad health record due the badly polluted nature of the area and with the largest number of residents with diabetes and large lung cancer and asthma rate and a higher mortality rate it is obvious this project has no place in this area.With the NSW Government planning ametro train network to bankstown in the future to have a container terminal just done 8 km away is poor planning by the government.The container trade is a very automated trade and the jobs created would be few and much mo5re job intensive industries would be a greater help for employment

---------------------------------

Our organisation has ascertained that if the Moorebank Intermodal proceeds it will result in the local road network running 53% over the local road network capacity .How can any government ot organisation run a container terminal under these conditions it is pure madness.Everyone is selling short one of the most valuable environmental areas in Australia which has many threatened and endangere4d species and plants and flora that is unique to this area .The level of diesel emissions that would be generated will have massive impact on our residents our wildlife our Georges River,Hoslworthy army reserve and unique precious parks and historic buildings like Glenfield farm.This is pure lunacy and if it proceeds their will be many who have a lot to answer for.The health of residents is atrocious due to the present pollution and contamination and further pollution will be deadly

---------------------------------------

The pollution and contamination from the projects will be toally unacceptable.I know that next to these projects the cancer risk will be 1000 in a million and it doesent decrease noticeable until 1 mile.With thousand of residents within this area it poses a unacceptable risk which cant be mitigated.The normal cancer risk in a normal community is 8 in a million..I am aware of many contaminated areas in the project zone and if the project proceeds this will be added to the pollution risk.I know a youth until 25 body is not fully developed and these projects will have a greaterimpact on them.I have seen research whyere a kid can have health problems within 45 minutes and adult in a 1 hour .The pollution from these projects will expose many residents to unnecessary risk from PM10 and Pm 2.5.Also I have great fears for the wildlife ,Georges River,aquatic species.Casula Powerhouse Art centre which do many programmes for Kids and residents wth disabilities.The area is a bad health area and I cannot believe any responsible government or organisation impact such a area..You couldn't have found a worst site if you tried the whole project has been deeply flawed from the start

-----------------------------------------------------

The Georges River is one of the most flood prone area in NSW and in the recent floods in Liverpool showed that the only secure intersection was the M5 and Moorebank Avenue with 2 roads closed any others close to closing.You cannot run a container terminal in these type of circumstances and with the road network going to be 53 % over capacity by 2030 what they are trying to achieve is impossible.The area picked for a container terminal is shocking and a worst spot couldn't have been chosen.The people behind these projects are ignorant of the impact on the area.The pollution noise impact on wildlife georges River and historic areas like glenfield farm are a national disgrace.Our Koalas will be decimated and other wildlife will desert the area causing environmenjtal disasters