St Marys Intermodal

I support the project but believe that the heavy vehicles should not be exiting back in to Lee holm Rd.
Lee Holm Rd supports the use of the entry of vehicles , however it would be dangerous to have heavy vehicles exiting back onto Lee Holm Rd as it is not wide enough as a carriageway to support such traffic and would be dangerous to have heavy vehicles turning right back on to Lee holm Rd when exiting the site.
The alternative would be to have Lee Holm Rd as an entry point only and the exit should be back on to Forrester Rd via the road adjacent to the rail line. That way there is continuity of traffic and Forrester rd is wide enough to be facilitate heavy vehicle movements.
This would in turn allow heavy vehicles to turn right into Glossop st using traffic lights already in situ , and provide access to Boronia Rd and Christie St using the existing roundabout thus making heavy vehicle movements safer and not endangering light vehicle traffic.

Firstly, I lodge my objection to the bureaucratic introduction of a changed process that requires a person or entity to register through a convoluted system should that person wish to lodge a submission on a matter on exhibition.

What was wrong with the former process?

You are doing exactly what the government wants to achieve and that is make it difficult for the public and thus discourage community consultation in planning matters. You are a disgrace to open government and community engagement. You all play your part in making this a closed, behind-the-scenes, structured/organised State.

Having said that I don't expect any favourable consideration to the content of my submission but that then does not make me wrong in what I say. The problem is you road blocks to open government and a better environment.

Blacktown & District Environment Group Inc objects to the loss of remnants of ecological communities on the site of the proposed Intermodal at St Marys. Offsetting off site through biobanking or other means still results in a net loss and continued reduction of extent of ecological communities and species overall and in representation within the proposed development site.

We are also concerned about the impact of the development on the wetland and Little Creek at the northern end of the proposed Intermodal site. We note the site footprint includes a portion of the wetland.

It is not clear to us what it means to the wetland by having a boundary line for the Intermodal transecting part of the wetland. The wetland would be of importance for habitat and foraging for fauna. The recording of presence of the Southern Myotis, a BC Act listed species, is consistent with the species use of the wetland for foraging. The wetland must be protected intact and without hindrance to gliding approach and over the wetland.

The NSW Government commissioned Urban Bushland Biodiversity Study,1997, identified the ecological value of rural dams. This wetland falls sits within that category.

One need not look too far away from this site and a little further downstream along South Creek to an incident a few years ago of human error which caused the poisoning of native fauna including the Australian Bass species in great number. This error came from an industrial site in St Marys.

It is important to redress that human failing which involves the hosing or pouring of toxic substances into drains within domestic but more so within industrial and commercial premises. We note that the site drains to the north and therefore into the wetland and Little Creek. A site proposed to store large quantities of storage containers with almost any sort of contents as well as a site being a hive of truck activity is a potent recipe for contaminants and pollution beyond the site. Trucks are notorious for leaking fuel and oil.

All drains on site should drain to in-site storage areas which will be pumped out periodically for waste matter to be taken away to suitable toxic substance disposal venues. Stormwater run-off into drains and then into in-site storage areas generally emptied of toxic substances will not then be such a hazard to fauna within the wetland, into Little Creek and further downstream into South Creek and the Hawkesbury River as overflows occur. The wetland should not become, over time, a reservoir of toxic waste.

Whilst I support this project in principal and location, I am very concerned with the access roads surrounding the St Marys site, in particular at Lee Holm Rd.
I understand that the new facility is proposed to cater 300,000 containers pa, which relates to 34 containers per hour, or approx. a container every 1.75 minutes.
This is an enormous volume to transport onto existing roads.
I note the new traffic signals at the end of Lee Holm Rd & Christie St which will improve that intersection. However no upgrades of Lee Holm Rd itself or at other intersections with Lee Holm Rd seem evident.
Currently Lee Holm Rd is very congested and only wide enough for 3 vehicles. More significantly, Hi-Quality Group's Land Fill / Recycling facility, just barely 200m from the proposed entry / exit point, will be a major traffic management problem. Dump trucks bank up along Lee Holm Rd from both directions waiting to enter the Hi-Quality site. Also, they have very poor dirt removal processes on site, so trucks exiting the site carry a large amount of dirt onto the road. So they have engaged road cleaners and street sweepers to continually wash down the road all day long. This creates a highly localised precarious section that every truck entering and exiting the proposed Freight Hub facility must pass through.
Should the truck drivers wish to avoid this section, they must drive in the opposite direction along Lee Holm Rd towards Wordoo St / Forrester Rd intersection. This intersection is not currently proposed for an upgrade. It is already heavily congested, especially during afternoon peak times when factory workers finish work. Traffic banks up at Wordoo St and along Forrester Rd down to the Glossop St intersection.
So with a container every 1.75 minutes, this will become an extremely volatile area. Please consider tired workers leaving their jobs after a long day only to be hit with traffic as soon as they leave their work.
Please review the overhead power lines along Lee Holm Rd near the entry / exit location, which seem too low and require a major upgrade. They are located right along the edge of the kerb increasing risk of an accident with high volume truck movements.
Upon reviewing the Traffic & Transport Assessment Figure 7.4 showing the required swept path at the proposed entry / exit location it appears that every single truck that enters and leaves the facility must go onto the other side of the road. Given the high volume of road transport through the proposed facility, this would result in excessive interference and stoppage of other vehicles using Lee Holm Rd. It would create traffic build up. Also, given that this is near a blind bend (only 100m away) there would inevitably be a rear end accident as vehicles come around the bend to be met with a traffic jam, waiting for the truck to enter / leave the proposed facility every 1.75 minutes!
I also find it dangerous that the proposed "Heavy Vehicle Access Rd" leading from Lee Holm Rd to the facility just misses a very big steel electricity transmission tower.
It seems evident to me that the location of the entry / exit is not ideal and that there must be better alternative.
By "better" I mean one that does not impact the local workers and businesses so heavily. Does not heighten safety risks along Lee Holm Rd at numerous locations. Does not require every single truck to go onto the other side of the road and impact all other users of Lee Holm Rd. Does not have adverse flow on effects to other ends of Lee Holm Rd as an avoidance consequence of the area.
To mitigate all the above-mentioned issues, I propose that entry / exit for the facility be relocated to run along the Existing Siding and come out at Christie St, with new traffic lights installed. At this point it is far away from existing businesses and facilities, there is sufficient space to widen the driveway and allow low impacting truck swept paths. The proposed duplication of Christie St may even be brought forward (at Werrington Rd intersection).

In summary, I support the proposed St Marys Freight Hub to cater for the growing Sydney metropolis, with the whole basis of this facility being to relieve "the regional and state road network of heavy vehicle and container traffic" as stated on page v of the EIS. Whilst relieving other areas throughout Sydney of this traffic, the offset it seems is that Lee Holm Rd will be burdened with the increased heavy vehicle and container traffic. There are way too many local adverse effects with the current proposed entry / exit at Lee Holm Rd. A safer, more efficient, less impacting alternative must be sought. Hopefully, with further analysis, my proposal may prove suitable.

Based on the matters discussed in the attached, it is recommended that SSD 7309 not proceed in its current form. Given the construction and operational impacts which would occur for the Charter Hall landholding at 10 Forrester Road, St Marys (2220 DP1172926), it is considered that the assessment prepared so far for SSD 7309 is lacking in some respects.

These concerns of Charter Hall primarily relate to consistencies with the quoted Construction Program and timeframe, the lack of consideration given to Medium-Sensitive Receptors to dust generated during the construction of SSD 7309, lack of transparency regarding potential construction-period traffic impacts, the lack of consideration to human discomfort impacts during the use of vibration-intensive equipment during construction works, the validity of conclusions made in the Flood Impact Assessment about SSD 7309 not increasing flooding impacts to surrounding properties, and the suitability of locating a Dangerous Goods store so close to the Charter Hall site.

It is considered prudent for DP&E to request the matters identified in this Objection be addressed so that a decision can be made in the public interest.

Please find attached submission letter.