PAC Presentation on behalf of the Georges River Environmental - - PDF document

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

• f 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

• ccurs. (Cardno, July 2015, p121)

⦁ The proponent was supposed to consider storm water management with the

• bjective of maintaining or improving existing water quality. Cardno’s comment is

2

that no discussion occurs surrounding the maintenance and ongoing management

• f 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

Concerns around Storm Water Mitigation Strategies With regard to SIMTA, we have additional concerns about the adequacy of the strategies chosen to manage storm water impacts. The proposal has a limited internal demand for water and will produce a very large amount of runoff, due to the expansion of on-site paving. The proposed on-site detention basins are intended to function also as rain gardens, however it is not clear how they can perform both functions adequately or that the water quality targets will be met by the proposed measures under all conditions. We endorse Cardno’s expert opinion that “The evident risk is that a combination of rain gardens and OSD basins could result in the large scale release of accumulated pollutants during a large storm event. This does not appear to have been considered and no mitigation measures are proposed” ( Cardno, 2015, p79). Whilst our criticisms have been specific in regard to SIMTA, it is the MIC proposal we fear has the potential to do the greatest degree of quite catastrophic damage to the adjacent

• river. Given its far grander scale in terms of paved and impervious surfaces, its more

vulnerable and proximate site closer to the Georges River, and the apparent small scale of its On-site detentions basins, its storm water impacts on the Georges River simply will not, and cannot, be contained. The cumulative impacts of both the MIC proposal and future Stages of SIMTA on flooding, water quality and water balance have not been discussed. This should occur and provide for a precinct wide water balance assessment to ensure that shared infrastructure can cope. Bank stability is a key risk for long term water quality in the Georges River and has not been adequately addressed. Cumulative surface flows to be achieved, should any development

• ccur, should mimic natural conditions, so as to not increase the erosional pressure on

fragile riverbanks. With regard to flood management as a result of both SIMTA and MIC proposals; Overall there are many complexities and interactions around these infrastructure developments, associated with increases in paving, rail line and bridge impacts, and even the functioning of proposed storm water mitigation measures that will potentially change and even worsen flood patterns and behavior. These have not been adequately considered, modelled or assessed. Finally, in terms of biodiversity Overall the GREA position is that we reject any break in riparian connectivity, and we do not accept the validity of the Biodiversity off-sets as proposed. We believe that a 40 metre buffer zone, fully vegetated should be maintained between any development and the Georges River, without it being compromised. In regard to the MIC proposal we view the Riverside Conservation Zone Conservation as far too narrow to 4

provide for both adequate conservation and aesthetic screening to protect views from the river and opposite shorelines. There should be a further buffer zone of protective vegetation re-planted to protect and extend this existing foreshore zone of the existing

• lder growth riparian vegetation. The onsite detention basins should be set back further

away from this existing vegetation and the river, rather than encroach upon it, as is proposed. Any rail bridge structures over the river and its foreshore bushland and any rail line in close proximity needs to take account of the 40 metre buffer zone standard. This has been a long held standard to protect both environmental integrity and water quality of rivers, firstly in the Rivers and Foreshore Act, 1948 and later re-iterated in the GRREP 1999. In other parts

• f the Liverpool LGA, at Voyager Point, the development set-back is far more than that.

(References for buffer width https://jade.barnet.com.au/Jade.html#!a=outline&id=276907 http://www5.austlii.edu.au/au/legis/nsw/consol_reg/gmrepn2rc715/s11.html ) To state the absolute obvious, and the very least, the MIC and SIMTA rail links should be shared rather than duplicated to minimize impacts. GREA has serious concerns about the impacts of rail links situated on the western bank of the Georges River. They are partially situated within the specified riparian setback zone (the Georges River the riparian setback is comprised of a 40m Critical Riparian Zone and a 10m Vegetated Buffer). They need to be assessed for soil and water management, soil stabilization and re-vegetation works post construction of the rail links. We are particularly disgusted that the SIMTA rail route cuts through the middle of the Anzac Creek bushland and wonder why it does not run along its edge adjacent to Moorebank Avenue, to minimize impacts on habitat connectivity? Since it is acknowledged that endangered woodlands and species will be lost, such a deficit should be off-set by a “like for like” provision. This is to ensure that the project “will not contribute to the community and species being placed at risk of extinction” (Cardno, 2015, p 130) Further, we would add that it is a nonsense that the SIMTA Biodiversity Off-Set Strategy proposes to use Commonwealth Land to offset the proposed development. There is indication that this land will be approved by the Commonwealth for this purpose. Conclusion It is important that both the MIC and SIMTA proposals are considered together for their impacts on the Georges River, and its natural remaining lands in this precinct, species and ecological communities it supports, and cumulative downstream impacts. It is also essential that equally both are subject to the same stringent level of scrutiny, and the imposition of statutory conditions and controls to enable a far greater level of environmental protection and enhancement, that is proposed by either of them at this time. Thank You again. 5

Major References; PAC website; SMIC and SIMTA Projects Cardno Ref: 8201511201-01/Report 001 Ver 1: SIMTA Intermodal Terminal Project – Stage 1 EIS – Peer Review, July 2015, available at; file:///C:/Users/Owner/Downloads/Liverpool% 20City%20Council%20Submission%20(SIMTA%20Stage%201%20EIS).pdf 6