PAC Presentation on behalf of the Georges River Environmental Alliance (GREA) Re; D392/15 MIC Terminal Concept Plan and D393/16 SIMTA intermodal Terminal Facility Stage 1 Contact details; go_river_@hotmail.com The Georges River Environmental Alliance thanks the PAC for this opportunity to comment, and wishes you to note that we object to the siting of any major intermodal developments at Moorebank, and would recommend that the PAC instead promotes an in-depth consideration of alternatives, The GREA represents a network of individuals and groups drawn from all of the Georges River catchment, with its prime concern being the health and amenity of the river, its tributaries and the biodiversity, both aquatic and terrestrial, supported by its water and surrounding natural lands. We support the huge local community voice, which is strongly supported by local MP’s and Liverpool City Council, and which clearly opposes the Moorebank Intermodals. Today we support their sound, evidence based case against the intermodals. We support their well- researched objections based on the impacts of traffic congestion, air and noise pollution, and consequent implications for health and social dis-location. We regret that this local community will disproportionately bear a burden that would not be imposed on other parts of Sydney. So there can be no justification, for dumping a huge transport interchange in the midst of a place where ordinary people wish for clean and decent lives, in the area they chose, before transport companies decided to arrive. Why shatter the established suburban amenity of places like Casula, Moorebank and Wattle Grove when there are better alternatives. The MIC and SIMTA proposals impact upon the major environmental corridor for south- west Sydney, with the Georges River running through it. This river is of extremely high regional value, in an ecological, recreational and aesthetic sense and the MIC sits disrespectfully right on top of it. Anzac Creek, one of the river’s tributaries, has one of the least affected bushland and freshwater wetland systems left on the Cumberland Plain, and SIMTA’s rail link will decimate it. More than a million people live in the Georges River catchment, and most of them are downstream of these development proposals, and yet, there is no particular assessment made by either proponent of downstream consequences for the Georges River that provides them with ecological and recreational services, river uses, amenity and values. We are particularly appalled that these proposals, and their Environmental Assessments, show a breathtaking degree of arrogance, in their scant consideration of the negative 1
impacts on our river, which is the environmental centerpiece of south-west Sydney. A river is the sum of its tributaries and wetlands, and it is protected by its surrounding ribbons of bushland, so our concern extends to these. The increase of hard surfaces with these proposals, will massively compromise water quality with its greasy chemical runoff. Its increased volumes, will impose an unacceptable erosion threat to its friable and crumbly riverbanks, in this most fragile section, the freshwater impoundment behind the Liverpool Weir. Despite its fragility, even here at Moorebank, it provides a very precious fishery with native species like the Australian Bass. The river has great local value and future potential as the winding scenic centerpiece for the emerging status of Liverpool, as one of Sydney’s emerging inland River Cities. The SIMTA and MIC rail links will scar this. If there is any development around it here, it should occur respectfully behind a peaceful, and unbroken corridor of green parkland and bushland, wider than what is proposed. The proposed water management measures are grossly inadequate, and designed without an adequate research base of both current and predicted water quality and flow parameters. A great deal of biodiversity is at stake, and proposed biodiversity off-sets and vegetation management strategies are pathetic. They are not adequate compensation for the anticipated impacts on the known 4 Endangered Ecological Communities (3 rare and precious woodland types and a freshwater wetland complex), 2 threatened plant species, 4 threatened fauna species and 2 endangered fish species. The matter of public trust and what is best for the public. It is important that approval processes for major development projects maintain a level of public trust, and there is a legislative framework with statutory instruments, in NSW, that should ensure the principles of ESD are applied, in order to protect both social and environmental values, whilst economic objectives are pursued. We fear that important elements of existing legislative protection, provided by the state government, are being ignored in this process. In relation to the SIMTA proposal a very specific framework for a Proponent’s Environmental Assessment document, is provided by the Secretary’s Environmental Assessment Requirements , the SEAR’s, yet those for water have not been properly addressed or met; According to these SEARs, the Proponent was supposed to; ⦁ Assess potential cumulative impacts on water resources, and any proposed options to manage these cumulative impacts. Cardno’s comment in regard to this is that “No discussion of cumulative flooding, water quality, water quantity or balance occurs. (Cardno, July 2015, p121) ⦁ The proponent was supposed to consider storm water management with the objective of maintaining or improving existing water quality. Cardno’s comment is 2
that no discussion occurs surrounding the maintenance and ongoing management of that intended drainage infrastructure. (Cardno, 2015, p 122) We would add here that best practice storm water management should be applied, and the standard to be achieved should be a net improvement over existing storm water impacts on the Georges River. ⦁ The proponent was supposed to consider also whether the existing sewerage system can cater for the proposal and whether environmental performance of the existing system will be impacted. We endorse Cardno’s comment that there is no discussion of the size and capacity of the sewer infrastructure serving the site. It is not clear if it retains sufficient capacity to support future stages or the cumulative impacts of the SIMTA and MIC proposals. To this we would also add, that there have been severe past impacts on the Georges River as a result of plant failure of the Glenfield STP, and reported sewer overflows into the Georges, and provide evidence of this in references we cite. It is therefore very contentious for the proponent to claim the Sewer system is adequate. (References; http://www.smh.com.au/environment/water-issues/warning-issued-after-sewage- flows-into-georges-river-20131125-2y5c9.html http://www.liverpool.nsw.gov.au/__data/assets/pdf_file/0015/5361/Attachment- Part-7-Page-412-440.pdf http://www.georgesriver.org.au/Estuary-Management-Plan.html ) Also in relation to the SIMTA proposal we would like to remind the PAC that Statutory Instruments like Regional Environment Plans (REPs), State Environmental Planning Policies (SEPPs) and Local Environmental Plans (LEPs), in this instance, are being overlooked and contravened; ⦁ In relation to the Georges River REP (which is deemed a SEPP) The REP provides principles that aim to assess impacts of development on the Georges River and its tributaries. The SIMTA proposal would have the potential to impact on the Georges River. The consultants, Cardno, in their peer review, have identified a number of shortcomings and a need for further hydraulic and hydrological modelling and assessment to be undertaken to ensure that impacts arising from earth works and infrastructure construction and operation are quantified and reviewed. ( Cardno, July 2015, p30) ⦁ SEPP 19 aims to provide protection for Bushland in Urban areas and SEPP 44 provides for the protection of Koala Habitat. Both are 2 specific statutory instruments that should be applied in this instance, yet it appears neither have been assessed for this Intermodal proposal. 3
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