The MICL EIS is open for comments. The information below will help you preparing a response. You should submit a response because you have a right to have input into what is approved for your local area. If there aren't enough comments MICL will get an easy approval without protection for residents.

THE FACTS

EIS Documents are found on this link (and you can make a submission there too):

NSW Department of Planning

Submissions Close: 08/12/2014

8,160 heavy vehicles per day

5,724 cars per day

Sample Submission

This attachment will help residents who don't know where to start with their submission:

New: Sample Submission

Original: Sample Submission

Write your own Submission

Even better, use following information to develop your own submission.

Submission Style & Length

Be frank, open and honest. You have a right to express your concerns, but should also be respectful. 

You don't need to use a lot of words or complex technical jargon. If complex technical jargon is comfortable for you and appropriate for what you want to say, use it. If you have a lot to say, use as many words as you need, but unnecessarily  inflating the word count won't make your submission any more persuasive.

SUBMISSION TIPS

There are many concerns with the proposal, the following are some points to help you frame your thinking.

The Planning is deeply flawed

The site is surrounded by residential and is river front land and objectively is more suitable for residential or commercial development. Analysis by Western Sydney Parklands "Market demand analysis has determined a shortage in business /retail floorspace within the region" Liverpool City Champion 5/11/2014 p4 advertisement 

MICL's analysis shows that there is only modest need for additional capacity locally, and that the main target for containers that would come to Moorebank are 30KM or more away to the north or north-west.

The site is only barely long enough for current requirements of interstate freight rail and the facility would have the effect of preventing future efficiency improvements in interstate rail transport by limiting future train lengths.

There is no whole-of-precinct plan. The cumulative impacts of the two proposals have not been adequately explained or addressed by the proposals. Since the PAC has already approved a sufficient number of containers for the demands of the region in response to the SIMTA EIS, no further capacity should be approved.

Badgerys Creek is a better plan

Badgerys Creek is a truly greenfield site with no surrounding houses and space to develop the necessary infrastructure without costly retrofitting. 

Funds from the sale of the Moorebank site could fund the necessary infrastructure at Badgerys.

Noise from Badgerys Creek Airport will lock up a lot of land for industrial use, so it will be a major destination for containers.

Badgerys Creek is further from the centre of Sydney and is much cheaper land.

The distance from Badgerys Creek to the container destinations identified by MICL is about the same as the distance from Moorebank.

Asciano has stated that it can increase capacity at Chullora (up to 800,000 TEUs), so there is no need to develop an Intermodal urgently (refer SMH). it would be better to carefully consider all options and come up with the best solution, one that is integrated with other developments underway.

The proposal is incompatible with the local area

Some residents are as close as 400m to the site, closer than Botany residents shown to have been impacted by similar activity at Port Botany. At the community information session MICL disclosed that they have followed the same approach to calculating the noise impact as would have been used for Port Botany and that they certainly did not take into account the recent findings from Botany.

Noise from the terminal will reduce resident's ability to enjoy their outdoor living space.

Large sealed areas such as hard stand areas will absorb heat and reflect it back making the local area hotter in hot weather.

Freight terminals have crime problems. This is not a good neighbour for a residential area.

Locating a large industrial complex adjacent to sensitive ecology and large residential areas significantly increases the costs to establish and operate the facility.

Local roads are too congested. The impact on residents travel time to work has not been calculated.

The river should be protected. The portion of the Georges River adjacent to the terminal is contained by Liverpool Weir, so pollution and runoff will be trapped and could accumulate.

Military heritage on the site should not be destroyed.

The Casula Powerhouse is important to the region and could not continue to deliver theatre with that many locomotives rumpling past.

The development is incompatible with the council's vision for the Liverpool waterfront.

No-one knows how many trees would be destroyed by the proposed development, but other more sympathetic development could be built without destroying areas of native vegetation.

Since the operator of the SSFL cannot prevent very serious noise impacts on adjacent residential areas, no project should be approved that increases SSFL traffic.

The local infrastructure is insufficient to meet existing demands

Numerous local intersections are already overloaded.

The "weave" as traffic entering the M5 from Moorebank Ave crosses traffic exiting at the Hume Highway is already dangerous and would be made quite frightening by adding thousands of trucks each day.

The cost to refit the local infrastructure to meet the terminal's needs negates any perceived advantage.

Despite being adjacent to rail on two sides, the site has no access to passenger rail, significantly exacerbating the traffic problems it causes to local infrastructure, as staff will be forced to drive to work.

Major planning decisions should not be rushed. Asciano's statement that they can increase capacity at other intermodals means that necessary infrastructure should be planned, funded and in built before any heavily intensive project is approved.

There is no plan to up-skill or resource the local police command to handle port related crime.

The local Fire Station is not equipped to handle HAZMAT emergencies.

The kinds of locomotives doing the local haul freight work are old (eg 60 years old) and very polluting. It is incorrect to assume they are in good order or are well maintained or modern.

Employment

The local area has a deficit of jobs and needs more employment, but especially professional jobs.

Other land uses would provide more employment and better employment.

The Intermodal proposal is a jobs sucker. It will transform adjacent light and medium density industrial into warehousing. The result is that many small businesses employing 10 to 20 each will give way to large warehouses that will employ only a few.

Equity Issues

It is inequitable to impose another major undesirable infrastructure on the South and South-West. The region already has most of Sydney's undesirable infrastructure and should not be seen as Sydney's easy solution for ugly projects. Examples of past abuses include: relocation of port facilities from the inner city to Port Botany, consideration of only south-west locations for a second airport, the location of all intermodal facilities in the south or south-west.

MICL has a significant consultant workforce at its disposal with both large numbers and a wide range of skills. Local residents don't review EISes for a living and are at a disadvantage due to the large number of technical concepts that must be understood to respond in detail. Similarly, residents have a job and a family and simply could not devote enough time read the huge volume of the EIS even if they were already experts in all of the fields. While MICL has made a significantly greater effort to engage with the community than SIMTA did, the scale of the proposal introduces a significant equity issue that has not been addressed.

MICL has no measures proposed or in place to ensure that the standards and assurances it gives won't decline over time. There is no plan to police the agreed control measures and no reporting framework.

Residents have been locked out of their riverfront by 100 years of military occupation. It is unfair to lock them out for another 100 years by locating a container terminal on the Liverpool waterfront.