|Channel Nine News video featuring Mayor Ned Mannoun was presented by Lizzie Pearl about Liverpool City Council push to have intermodal terminal relocated from Georges River Moorebank site to Badgerys Creek Airport site.|
Credit: Footage courtesy of Channel Nine's News, nightly at 6pm, and at 9news.com.au Promotional video of Moorebank Proposal is third party.
Councils submission to Moorebank Intermodal Company public exhibition.
For a copy of Councils submisison please click here.
Badgerys Creek –The Ideal Location for an Intermodal
The announcement of the Badgerys Creek International Airport is a game changer for Western Sydney. A Deloitte report estimated that up to 28,500 jobs alone will be created as a result. It is a significant piece of infrastructure that demands a revisiting of the existing strategic framework for Sydney and New South Wales. As we speak, NSW Planning and Environment are updating the draft Metropolitan Strategy for Sydney to 2031 to incorporate the opportunities of the second airport at Badgerys Creek.
The intermodal requirements of Western Sydney are a key consideration when discussing Sydney's second airport. The Badgerys Creek airport freight traffic would enhance existing land freight activity in Western Sydney. There are substantial efficiency opportunities when intermodals and international airports are co-located. This would create a strategic intermodal transportation hub connected to the outer Sydney Orbital and the rail network, and would potentially provide world-class global logistics to international and domestic transportation companies, while also being more cost effective. An intermodal would generate economic activity at the airport site from its first day of operation.
It is important not to limit the vision for the Badgerys Creek precinct to just these traditional activities. The precinct has the capacity to provide a catalyst for industry innovation that can drive implementation of new technology in both services and manufacturing. The convergence of industry sectors across technology platforms means that the airport precinct and its links back to the Liverpool City Centre can assist a new concentration of knowledge intensive industries in South West Sydney.
SIMTA Intermodal Approved by Planning Assessment Commission
On 29th September 2014 the Planning Assessment Commission (PAC) released its determination in relation to the SIMTA intermodal terminal facility. The PAC have granted the project conditional approval, meaning that there are conditions and requirements that the applicant needs to meet before they can proceed with construction.
The draft environmental assessment (EA) for the SIMTA intermodal terminal was publicly exhibited as required by NSW Planning and Infrastructure. The first draft of the EA exhibited from March to May 2012 was not adequate and a review of the EA and second exhibition period was undertaken in September and October 2013. Both times Council provided a comprehensive submission, prepared by the consultant Cardno, to the exhibition. Throughout this process, Council has maintained its objection to the SIMTA intermodal at Moorebank.
Despite Councils objections, NSW Planning and Infrastructure provided Council with a draft conditional concept approval for the SIMTA intermodal terminal project in April 2014.
The application was referred to the PAC for determination. The PAC held a public meeting as well as a meeting with Council officers in July 2014.
The key condition to note is contained within the Schedule 2 titled "Limits of Approval". SIMTA have applied for approval to move 1 million containers per year with this concept approval. The conditions require that the operation not exceed 250 000 containers per year, with a potential to increase this to 500 000 containers subject to a further application. More details is contained in conditions 1.6 and 1.7:
"1.6 Projects carried out under this this Concept Plan must be operated with the objective of not exceeding the capacity of the transport network, including the local, regional and State road network. The container freight road volume must not exceed 250,000 TEUs, subject to the exception identified in 1.7, which may only be considered after the facility has been in operation.
1.7 The movement of container freight by road may exceed the 250,000 TEU limit by up to a further 250,000 TEU, if the consent authority of a subsequent Development Application is satisfied that traffic monitoring and modelling of the operation of the facility demonstrate that traffic movements resulting from the proposed increase in TEU will achieve the objective of not exceeding the capacity of the transport network."
It should be noted that should the Concept Approval does not give approval for works to commence on site, rather it provides limits and a framework for future staged project applications for construction and operations of the facility.
Freight Terminal Facts
Moorebank Freight Intermodal Terminals
Two intermodal freight terminals have been proposed in Moorebank, on either side of Moorebank Avenue.
The proposed intermodal terminal to the east of Moorebank Avenue is a private intermodal terminal. The proponent of this project is SIMTA. SIMTA is a joint venture, formed in 2007, comprising of Qube Logistics and Aurizon (formerly QR National).
The proponent for the proposed intermodal terminal to the west of Moorebank Avenue is the Australian Government Department of Finance and Deregulation. It is known as the Moorebank Intermodal Terminal (MIT).
The freight intermodals will be a destination for freight containers transported from the port via rail. From this terminal the freight containers will be distributed by trucks to their various destinations.
The development is categorised as heavy industrial and is prposed to be operational 24 hours a day 7 days a week.
The SIMTA intermodal has a maximum capacity of 1 million twenty foot equivalent unit (TEU) containers per year and the Moorebank Intermodal Terminal proposal is expected to have a maximum capacity of 1.2 million TEU containers per year. The proposals both also include warehousing and distributions facilities associated with the intermodal terminal.
Intermodal terminals currently operating in Sydney
- Enfield – 300 000 TEUs per year
- Chullora – 300 000 TEUs per year
- Minto – 45 000 TEUs per year
- Yennora – 115 000 TEUs per year
- Villawood – 15 to 20 000 TEUs per year
Total Maximum Capacity – 780 000 TEUs per year
These sites are too small and too constrained to be able to move the forecast container demand. This is why the Government has identified a number of proposed sites for the development of additional intermodal facilities.
If these freight intermodals are constructed, Moorebank will have more than double the total containers compared to the remainder of Sydney.
It is considered that the distribution of containers should be more equitably spread across Sydney to better reflect the ultimate destination of the goods in the containers.
Impacts of the Intermodals
The two intermodal terminal proposals will result in 2.2 million TEUs being processed at Moorebank, which far exceeds the expected demand for the South West Region including Liverpool, Camden, Campbelltown and Wollondilly Local Government Areas.
The SIMTA documentation does not adequately address how the cumulative impacts of two freight terminals with a throughput of 2.2 million TEUs will be mitigated.
SIMTA claims that as there is only demand for 1 million TEUs to be processed in this region and the IMT will develop on a needs basis that two terminals will only ever develop to process 1 million TEUs. Therefore, there is no need to address the impacts of two terminals with 2.2 million TEU throughput per year.
Detailed documentation for the IMT has not been released at this time.
Casula Powerhouse Arts Centre and Georges River Casula Parklands
The proposed rail link from the Southern Sydney Freight Line to the MIT crosses over the Georges River Casula Parklands area. Council has exhibited a master plan for the Georges River Casula Parklands redevelopment as a recreation area.
The same rail access is likely to limit access along the newly road built for the Casula Powerhouse Arts Centre.
The proposed rail link from the Southern Sydney Freight Line to the SIMTA proposal runs over the Glenfield Waste Facility, adjacent to the river, across the river and through pristine bushland.
Rail links either side of CPAC, along and over Georges River and its foreshore will be a detriment to the outlook and setting of CPAC and the river. The public enjoyment of CPAC and the river will be lost forever if the rail links are constructed.
CPAC would be severely impacted by the Freight Terminal and would be a significant loss to the community and the arts across South West Sydney. The Casula Powerhouse is a vital community asset that must not be lost.
Traffic and Transport
The SIMTA intermodal terminal is designed to have a throughput of 1 million TEUs per year. This equates to 2740 TEUs entering the site on 21 trains per day. SIMTAs documentation states this will generate 2638 truck movements per day.
Cardno have extrapolated that SIMTA traffic could add up to 84% of the additional trucks on the Hume Highway, 350% of the additional trucks on Moorebank Avenue and 22% of the additional trucks on the M5 west of Moorebank Avenue (SIMTA Intermodal Terminal Proposal Peer Review of Environmental Assessment, prepared by Cardno, dated June 2012, page 35). This represents significant increases in traffic on major roads and will lead to congestion and increase commute times through the region.
Detailed documentation for the MIT has not been released at this time.
Due to the arterial road layout and location of industrial developments in the Liverpool LGA, Council has a number of industrial and local streets that are used by heavy vehicles with the associated concerns about road traffic noise, impact on residential amenity, road maintenance and road safety. The roads that will require works as a result of the intermodal proposals include:
- Moorebank Avenue,
- Newbridge Road,
- Milperra Road,
- ANZAC Road,
- Cambridge Avenue,
- Governor Macquarie Drive,
- Nuwarra Road,
- Cumberland Highway,
- Hume Highway,
- Hoxton Park Road.
The documentation provided by SIMTA and the MIT does give a guarantee that the road upgrades will be provided and that the increases in traffic will not impact on the accessibility of the Liverpool City Centre, Moorebank, Wattle Grove and the surrounding areas, however the extent and design of road upgrades is not yet provided.
The increase in trucks, trains and other traffic will result in increases in emissions in South Western Sydney.
Western Sydney suffers from poor air quality due to the topography of the Sydney basin. The Sydney basin is a closed basin, bounded by high ground to the north, west and south, and by the difference between land and ocean temperature on the eastern side. Trapped pollution accumulates and circulates inside the basin for several days and therefore increases the level of localised air pollution.
These proposals may increase the air pollution in a localised area that already has poor air quality.
Council and the community are concerned that the quality of air in Western Sydney will continue to decline and that higher concentrations of pollution will be trapped with the development and operation of the intermodal terminals. Exposure to poor quality are leads to respiratory problems, cardiovascular problems, problems with lung development in children, low birth weight of babies, and a variety of cancers.
The Approvals Process
Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act)
The EPBC Act is the Australian (Federal) Government's central piece of environmental legislation. The EPBC Act comes into play when a proposal or action has the potential to have a significant impact on a matter of national environmental significance. Both the SIMTA proposal and IMT proposal require approval under this Act due to potential impacts on threatened species and communities and impacts on Commonwealth land.
As part of the EPBC Act process, the Minister or delegate (in this case a delegate) has determined that the intermodal proposals are to be assessed by an Environmental Impact Statement (EIS). This means the applicant must prepare a document titled "Environmental Impact Statement." The Minister has issued guidelines as to what the EIS must include.
In terms of public exhibition, the Minister or delegate directs the applicant to undertake the public exhibition/consultation process themselves.
Elton Consulting was engaged by SIMTA to undertake their public consultation. The EIS was on public exhibition from 19 June 2013 to 13 August 2013.
You can view all the information relating to the EPBC Act process for SIMTA here:
You can download Councils submission here:
The MIT is being publicly exhibited now.
You can view all the available information relating to the EPBC Act process for the MIT here:
Once the exhibition period is over, the applicant must finalise the EIS, including consideration of any comments received in the exhibition period. The EIS must also contain a summary of the comments and how they have been addressed. The applicant must then submit their finalised statement back to the Minister, including a copy of the comments received, for the Minister to make a determination.
NSW Environmental Planning and Assessment Act 1979 (EP&A Act)
Planning and development in NSW is carried out under the EP&A Act and Environmental Planning and Assessment Regulation 2000.
In 2011 the NSW Government repealed Part 3A of EP&A Act and announced that it will stop accepting any new projects in the Part 3A assessment system. This system has been replaced by the State significant development and infrastructure assessment systems.
The SIMTA intermodal terminal proposal is being assessed as a Transitional Part 3A Application and the MIT is being assessed as a State significant development (SSD).
The SIMTA intermodal terminal proposal was placed on public exhibition from the 28 March 2012 to 28 May 2012.
Following the exhibition the applicant (SIMTA) is required to review all the submissions and provide responses. This process is still ongoing.
You can follow the progress of the Transitional Part 3A application for SIMTA here:
You can download a copy of Councils submission to the SIMTA exhibition here:
The SIMTA Intermodal Terminal proposal was re-exhibited from 4 September to 21 October 2013. Council's submission to the revised documentation can be downloaded here.
Difference between the EPBC Act and the EP&A Act
|EPBC Act||EP&A Act|
|Relevant Part of the Act||Chapter 4||SIMTA - Part 3A (now repealed) |
IMT - Part 4, Division 4.1
|Level of Government||Commonwealth government||State government (NSW only).|
|Objectives||Environment protection and biodiversity, national heritage.||Planning administration, assessment of development.|
|Authority||Australian Government Department of Sustainability, Environment, Water, Population and Communities.||New South Wales Department of Planning and Infrastructure.|