Prospect Logistics Estate

I strongly object to the State Significant Development titled Prospect Logistics Estate (SSD-10399) proposed on the land adjacent to the Prospect Hill Heritage Reserve. The location of this proposed beverage warehouse or distribution centre is not consistent with the adjacent land use and does not need to be located on this site for any reason whatsoever.

I have proudly lived at the base of Prospect Hill for over 46 years. As a child I vividly remember hearing the explosions from the quarry within the hill and the following rattling of the glass windows in our house. I later learned of its importance to the local Aboriginal people and subsequent events after colonisation. I was recently relieved to hear that Cumberland City Council declared Prospect Hill/Marrong to be an “Area of Cultural Significance”, and the publishing of the Prospect Hill Plan of Management, so what is left of the hill can now be protected into the future.
I can’t believe that this development is claiming to be ‘minimally invasive’ (page 6 ‘Engagement Outcomes Report’. https://majorprojects.planningportal.nsw.gov.au/prweb/PRRestService/mp/01/getContent?AttachRef=SSD-10399%2120200819T015349.659%20GMT), which is an outright lie when the proposal puts a 42 metre warehouses directly across the road from a residential estate and on a declared ‘Heritage item’ and the indigenously significant, and State Heritage Registered, Prospect Hill which will ‘completely obscure Prospect Hill’.
I have provided my full submission as a PDF attachment to this portal (see PDF attachment for full submission) however below is a short summary of my submission.
I object to the Prospect Logistics Estate development in this location for the following reasons:

1. Prospect Hill is a registered a site on the State Heritage Register for its ‘Historic Landscape’ (https://www.environment.nsw.gov.au/heritageapp/ViewHeritageItemDetails.aspx?id=5051526)

2. According to ‘Prospect Logistics Estate – Statement of Heritage Impact’ (https://majorprojects.planningportal.nsw.gov.au/prweb/PRRestService/mp/01/getContent?AttachRef=SSD-10399%2120200819T015352.000%20GMT page 8) it states:
Prospect Hill Pemulwuy is listed in Schedule 5 Environmental Heritage, Part 1 Heritage items in the Holroyd Local Environmental Plan 2013 (Current version for 14 August 2020 to date (accessed 26 September 2020 at 14:08)).
Location: Pemulwuy
Item Name: Prospect Hill
Address: Clunies Ross Street (primary), Butu Wargun Drive 9alternate0, Reconciliation Road (alternate), Great Western Highway (alternate)
Property description: Lots 201 and 202, DP 1121844; Lot 669, DP 1148337; part of Lot 107, DP 1028208; part of lot 901, DP 1078814.
Significance: State

3. According to The State Environmental Planning Policy (Western Sydney Employment Area) 2009 (Current version for 11 June 2020 to date (accessed 26 September 2020 at 20:43) https://www.legislation.nsw.gov.au/view/html/inforce/current/epi-2009-0413#sec.21
a. ‘Part 5 Principal Development Standards – ‘21 Height of buildings - The consent authority must not grant consent to development on land to which this Policy applies unless it is satisfied that— (a) building heights will not adversely impact on the amenity of adjacent residential areas, and (b) site topography has been taken into consideration.’

These critical principal development standards have not been met in this proposed development.

It is clear that the site topography has not been taken into consideration.

b. And if this is not enough ‘Part 5 Principal Development Standards ‘23 Development adjoining residential land
(1) This clause applies to any land to which this Policy applies that is within 250 metres of land zoned primarily for residential purposes….etc

The residential houses on Muttong Street that back directly onto Clunies Ross Street are well within 250 metres of the proposed development. The proposed buildings will not be ‘compatible with the height, scale, siting and character of existing residential buildings in the vicinity’.

c. Part 6 Miscellaneous provisions - 33J Heritage conservation
(1) Objectives – The objectives of this clause are as follows—
(a) to conserve the environmental heritage of the Western Sydney Employment Area,
(b) to conserve the heritage significance of heritage items and heritage conservation areas, including associated fabric, settings and views,
(c) to conserve archaeological sites,
(d) to conserve Aboriginal objects and Aboriginal places of heritage significance.
Again, the above objectives are not being met by the building of warehouses, including one 42 metres high, next to the Prospect Hill Heritage Reserve and also on the State Significant Schedule 5 Environmental Heritage, Part 1 Heritage item named as Prospect Hill

4. On 20th March 2019, Cumberland City Council adopted the Prospect Hill Plan of Management to categorise Prospect Hill as an "Area of Cultural Significance".

I believe allowing the development of the Prospect Logistics Estate development adjacent to the now “Area of Cultural Significance” is not consistent with the Prospect Hill Plan of Management as it will dilute its State Heritage Area significance.
According to Cumberland City Council’s Prospect Hill Plan of Management
a. Council’s Environmental objectives for the management of Prospect Hill includes:
• ‘Maintain the prominence of Prospect Hill as a significant remnant geologic and topographic element. Site and design development at critical locations so that views of the ridgeline are maintained.’
• ‘Protect the integrity of the Prospect Hill State Heritage Registered Area.’

• ‘Consult with local community groups to ensure that future development reflects the historical relevance of the past.’

• ‘Retain the open grass hill character as open space and preserve the distinctive ridgeline.’

• ‘be managed as an Area of Cultural Significance.’

• Retain ‘key features of Prospect Hill including a unique 360‐degree view of Sydney from the top of the hill.

5. The Statement of Heritage Impact Page 69 also states... "While the development will completely obscure Prospect Hill the proposed development will result in a significant reduction in the prominence of Prospect Hill when viewed from viewpoints to the north west of Prospect Hill. This reduction in prominence is particularly prominent from the north of Prospect Hill in which Warehouse 1 will form a substantial obstruction between the Prospect Hill and viewpoints to the north of the study area" (from https://majorprojects.planningportal.nsw.gov.au/prweb/PRRestService/mp/01/getContent?AttachRef=SSD-10399%2120200819T015352.000%20GMT)

I fail to see how the above statements are consistent with the Prospect Hill Plan of Management to categorise Prospect Hill and its categorisation as an "Area of Cultural Significance". The complete obscuring of Prospect Hill should not be allowed, given its status as an "Area of Cultural Significance".

6. The ‘Community Consultation’ that was stated to have been undertaken in 2020 has been totally inadequate for the size of the proposed development.
I have the following problems with the ‘Engagement Outcomes Report’ the ‘Elevation @ Greystanes industrial and logistics estate’ from (https://majorprojects.planningportal.nsw.gov.au/prweb/PRRestService/mp/01/getContent?AttachRef=SSD-10399%2120200819T015349.659%20GMT)
a. ‘documents the engagement and communications process, feedback received and considerations in response to feedback undertaken for Elevation @ Greystanes between 12 March – 5 April 2020
The fact that this so called ‘Community Consultation’ was undertaken during the lockdown period of a major worldwide pandemic, ie Covid-19, made it totally unacceptable. The two page ‘fact sheet’
• was only reportedly delivered to 372 letterboxes when this development will affect the whole suburb and further area.
• It did not state that one of the warehouse buildings was going to be 42 metres in height.
• It states it will support ‘More than 600 jobs once fully operational’, when the existing ‘Greystanes House’ office building has an ‘existing capacity to accommodate up to 800 staff, with the building also benefiting from a 4.0 Star NABERS Energy base building rating.’ (https://www.cbre.com.au/about/media-center/02042015a0204-7830)
• States the site is ‘zoned IN1 General Industrial. There are no proposed changes to the zoning.’
The State Environmental Planning Policy (Western Sydney Employment Area) 2009 (Current version for 11 June 2020 to date (accessed 26 September 2020 at 20:43) https://www.legislation.nsw.gov.au/view/html/inforce/current/epi-2009-0413#sec.9) Zone IN1 - General Industrial - Objectives of zone includes
‘To minimise any adverse effect of industry on other land uses.’
I honestly can’t see how building a 42 mitre high warehouse that will ‘completely obscure Prospect Hill’ is consistent with the SEPP WSEA 2009 to ‘minimising any adverse effect of industry on other land uses’.
• The ‘fact sheet’ didn’t even contain the words ‘Community Consultation’ and as such was hiding behind the premise of a one-way communication tool just providing information to the community but also not truly acting as a robus community consultation tool.
c. From a poll on a local Facebook group, 134 local residents want to know more information about the project. I believe the community is entitled to a proper community engagement process and the truth about this development before any further steps are taken in this development process.

I now demand a proper community consultation so the local residents can understand the whole proposal. My preference is for a Covid-19 friendly face-to-face community consultation whit representatives who can answer some of the questions that the local residents are asking about this project before any further progress is made on this application.

Please see attached.

• The proposal states an “an acoustic wall separates the western boundary of the residential area from Clunies Ross Street and the site” This is true to some parts of the residential site, however, the newer residential development has no such “acoustic wall” and backs straight onto Clunies Ross Street and the site.
• Entrance via Clunies Ross Street – this street is used by local residence and have residential homes backing directly onto this street. Having large, heavy vehicles accessing the street on a daily basis and with 24 hours/7 days a week is not acceptable in a residential area.
• Noise levels of heavy vehicles entering and existing (24 hours)
o People have a right to quiet enjoyment to their homes and private space, to have heavy vehicles entering and exiting the location on the street will have immediate negative impact to their use of their lands.
o Primary access to this site should be strongly considered via the industrial zoned section of Pemulwuy; from the Prospect Highway via Foundation Place and not via Clunies Ross Street.

• Heavy vehicle’s accessing local residential zoned traffic; narrow streets; Warin Ave and surrounding streets, only has single car access for times throughout the day. There are examples of where heavy vehicles have used Pemulwuy residential streets as thoroughfare, which is evident on the roundabout on Clunies Ross Street and Wombat Street, Pemulwuy.

• Traffic congestion on Clunies Ross Street with Heavy vehicles and of workers to the logistic site will be exponentially increased. This will have significant impact to the local residence and to the community, families with young children. During the pandemic, many children have been using the footpaths of Clunies Ross street to walk and ride bikes etc. with the increased traffic for the site via Clunies Ross Street, there are real concerns to the safety to the community.

• Currently the site is low-rise profile and integrates seamlessly into the environment,
o Height of development 42 meters will not be integrated into the landscape
o Bulk design out of visual character with the surrounding buildings and landscape
• Although not on Aboriginal land. Prospect Hill is adjacent to the proposed development. A heritage listed site with significant aboriginal heritage impact. It is the highest natural site and the hill is Sydney's largest body of igneous rock, to have a commercial /logistical building 42 meters in height will cause visual disturbance to the significance of Prospect Hill and the historical significance of such a site and the skyline of Prospect Hill.

• Cumberland Council had through community consultation, have discussed a Aboriginal heritage viewing platform, to educate and communicate with their stories, the significance of Prospect Hill in the Aboriginal’s fights against occupation, they have in their stories, told how the warrior Pemulwuy, was able to use Prospect Hill and the ability to see vast and wide the landscape and country to help defend against the British. These stories are communicated to school children at special ceremonies on Prospect Hill and allow for the community to see for themselves the view the Pemulwuy would have seen in the battle against occupation. With a 42-meter warehouse right within the vicinity of Prospect Hill, not only will this building be disrespectful to the surrounding skyline, it will be a visual loss of important historical significance.

• Community consolation has been minimal for a major development, as a community, there was no opportunity to raise issues that could impact on the local residence and what this development would mean to the local residence living in close proximity to the logistic estate.

• Noise and Vibration report was made under the assumption that the nearest residential receivers are approximately 50 metres to the east in Pemulwuy separated by an existing acoustic barrier. This is not the case with the recent development in Pemulwuy. The recent residential development has NO acoustic barrier and backs directly to Clunies Ross Street and directly onto the current commercial development.

Please see attachment

There is lack of infrastructure to support this development. If this project proceeds then first there is need to develop roads or open new roads to cope with the increased demand this will bring. There will be trucks/ vans/ cars/ employees which will use the roads 24 hours and this will cause noise and traffic chaos. Clunies Ross Street has trucks that are parked in a precarious manner (from the Austral Masonry warehouse) which obstruct on-coming traffic view making it very prone to a serious accident . Please consider alternative routes for traffic and do not permit trucks and delivery vans/ car/ employees to enter the area. Noise pollution to the residents must also be considered. All these aspects must be addressed before the project is approved.

See the Attachment for details of our objections and comments.

The Department of Planning, Industry and Environment - Water and the Natural Resources Access Regulator (NRAR) have reviewed the Prospect Logistics Estate EIS and have provided comments in the attached.