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Environmental Assessment of proposed Enfield Intermodal Logistics Centre Strathfield District Historical Society Submission - February 2006
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This submission has been lodged with the NSW Department of Planning in February 2006
Planning Framework for Intermodal Terminals in NSW
In July 2005 a report by the Freight Infrastructure Advisory Board [FIAB] entitled ‘Railing Port Botany’s Containers’ was released. This report contained a series of recommendations for the development of a strategic framework for Sydney’s rail/truck infrastructure. The report made recommendations which relate to the Enfield site specifically and to wider infrastructure development in NSW. On page 16 titled ‘Servicing the Central West’, the FIAB report endorses the Enfield Intermodal Terminal.
In 2002, the Sydney Ports Corporation released a proposal for a 500,000 TEUs per annum Intermodal terminal on land it had acquired at Enfield. At the time, the Corporation envisaged Enfield as Sydney’s major inland terminal – it was to be Sydney’s inland port. Having withdrawn its original proposal and in light of the findings of an Independent Review, Sydney Ports Corporation now proposes a substantially smaller facility at Enfield, with capacity reduced from 500,000 TEUs down to 300,000 TEUs per annum. Sydney Ports Corporation has indicated that, should its new proposal be approved, it could be operational within three years and be available to provide capacity as a first step in achieving the Government’s 40 percent rail share target. Having considered this particular proposal, the Advisory Board believes Enfield should be supported as an early step towards developing new capacity to meet Sydney’s intermodal needs.
The strategic framework proposed by the FIAB report as this is the recommended strategic direction for managing transportation of containers by the State Government and industry stakeholders, therefore the proposal for the Enfield Intermodal Logistics Centre can not be separated from this strategy.
The FIAB report supported a network of intermodal terminals throughout Sydney, including Enfield, Moorebank and Eastern Creek, an expansion of the existing terminal at Minto and development of the planned facility at Ingleburn. The strategy for movement of container freight involves transportation by rail from Port Botany to the terminals, which would be located within major industrial precincts. Containers would be transported from the intermodals to warehouses and other destinations by rail. The rationale for the establishment of an intermodal network is the reduction of traffic congestion near Port Botany, reduction of container transport costs and removal of ‘hundreds of thousands of heavy vehicles off residential streets between Botany and Western Sydney’.
The recommendations which affect the Enfield site directly include:
Recommendation 3
• Sydney Ports Corporation’s Enfield site be developed as an integrated logistics facility to meet local and sub-regional requirements
• Enfield be limited in throughput size to 300,000 TEU’s per annum and be operational before the end of 2008
• Participation from the private sector be sought for the site’s development and the terminal’s ongoing operation
• The Roads and Traffic Authority review road improvements necessary to support the Enfield development with funding available from the Freight Infrastructure Charge to assist in these works
Recommendation 11
The development of the major, new terminals at Enfield, Moorebank and Eastern Creek include adequate provisions to allow common-user, open-access operations.
Recommendation 12
For new terminals, the following general principles should be adopted:
• Terminals be located adjacent to or close to key distribution and warehousing areas in metropolitan Sydney;
• Terminals be located adjacent to, and with good access to, key arterial road corridors, particularly the M4, M5 and M7;
• Terminal locations be adjacent to dedicated rail freight lines;
• Terminals have the capacity to receive, load and unload 600m push-pull unit trains for the import/export trades;
• Terminals be of sufficient capacity to load full trains either to or from a single stevedore;
• Terminals be of sufficient size to accommodate on site empty container parks and servicing, on site warehousing development, driver facilities including truck and trailer parking, rest facilities, and AQIS Inspection and Customs bonded areas;
• Terminals be available to operate 24 hours a day, seven days a week to maximise the return on investment in the sites and utilise the rail network to its maximum capacity; and
• Terminals be adequately buffered from residential areas in order to minimise noise and light spill.
The FIAB Board was chaired by former Federal Transport Minister Laurie Brereton and included representatives from government agencies [RTA, Railcorp, Sydney Ports and DIPNR], NSW Farmers Association, Transports Workers Union and shipping companies. Many of the recommendations for development of rail/truck intermodals is based on environmental benefits, yet for a strategy which purporting to make large improvements in the environment eg reduction of pollution etc, the Advisory Board does not contain any representatives of environmental agencies/organisations. Most members of the FIAB board have direct commercial interests in the development of this strategy.
There does not appear to be any genuine consultation with the local community regarding this report, which has direct impact on the proposed development. The copy of the FIAB report was found accidentally by an internet search engine, while researching the ILC Environmental Assessment, in order to write a submission. In contrast, Sydney Ports Corporation has made direct contact with community organisations such as the Strathfield District Historical Society in regard to the proposed development at Enfield and though, we are opposed to the development, we are grateful of the opportunity to provide comment.
Enfield Intermodal Logistics Centre Environmental Assessment
The proposal for the Enfield Intermodal Logistics Centre can not be separated from the strategic framework proposed by the FIAB report as this is the recommended strategic direction for managing transportation of containers by the State Government and industry stakeholders.
Comments on information provided to the community on the Intermodal Logistics Centre at Enfield:
Road Traffic and Transport.
Our highest concern is in regard to the proposed development is the increase of traffic, particularly heavy vehicles on roads surrounding the Enfield ILC. We are concerned that increased amounts of heavy vehicles will be using the same roads as motorists and increasing congestion, pollution and compromising motorist safety. In addition, we fear that light traffic will increase throughout Strathfield Municipality by motorists trying to avoid arterial roads such as Centenary Drive, Roberts Road and Liverpool Road. There has been a noticeable increase in traffic in Strathfield in the last ten years, particularly due to major residential developments in areas such as Homebush, Homebush West, Liberty Grove, Rhodes and so on.
Centenary Drive including the overpass across Liverpool Road took many decades to be completed. This opening of this road had the effect of moving some through traffic from Strathfield’s residential streets and expediting traffic movement between key arterial roads and motorways. With the increased use of Centenary Drive with heavy truck vehicles, increased amounts of light traffic will use Strathfield Municipality’s residential streets in preference to avoid heavy traffic and delays caused by increased use.
If this development proceeds, the State Government should investigate minimising intersections by building of overpasses or underpasses at intersections such as Centenary Drive/Arthur Street.
Centenary Drive, which is part of the roadways of Homebush Bay Drive and Roberts Road/King George Road, connects much of the traffic from the north shore to the west and south west. The development of the Rhodes Peninsula, Sydney Olympic Park, Liberty Grove and proposed development in the Parramatta Road corridor rely on these roads to facilitate traffic movement, particularly small vehicle.
Many of the areas targeted under State Government Urban Consolidation programs rely on these roads for transport. According to the NSW Planning website, Rhodes Peninsula is considered a key development area with targets for 3000 dwellings, 1500 office jobs and 850 retail jobs. Road access from this site is via Concord Road to the north and Homebush Bay Drive to the west and south west. The ‘Parramatta Road corridor’ is also a key target area for increased residential/commercial development. The increased use of these roads for truck movement will have a detrimental impact on these proposed residential and commercial developments, which also depend on reasonable road access.
Motorways
It is obvious that heavy truck traffic on motorways will increase with this proposal. Due to conflicts with light traffic, has the government considered building dedicated heavy vehicle lanes on these roads to minimise traffic conflicts, wear and tear and shift cost of such arrangements to the industries which use the roads? The reports state there is a need for efficient movement of containers to have dedicated goods rail lanes, why not have dedicated road lanes for similar reasons?
Access to facilities including local business.
The proposed Intermodal terminal at Enfield will involve road access points into the site at Cosgrove Road and Roberts Road. Despite the claims by Sydney Ports that there will be no access from the southern point of Cosgrove Road, trucks will still enter into Cosgrove Road from Liverpool Road at the north end. The proposed entry on Cosgrove Road involves turning from Liverpool Road. Access to Cosgrove Road by heavy truck vehicles will have detrimental impact on both residential and commercial properties in Strathfield and Strathfield South.
If entry to the site from Cosgrove Road is open, trucks will enter Cosgrove Road from Liverpool Road. It is likely many trucks entering the Cosgrove Rd entry will travel along Liverpool Rd from an eastern direction, rather than from the Centenary Drive/Liverpool Road intersection, because trucks on Centenary Drive would logically enter from Roberts Road [eg Roberts Road is the continuance of Centenary Drive]. If trucks travel along Liverpool Road from an eastern direction, this will have a serious impact on residential areas.
It may have escaped the notice of Sydney Ports but Liverpool Road is mixed commercial and residential. Liverpool Road near the entrance of Cosgrove Road contains some commercial business eg mainly food [McDonalds, KFC], a motel [Formula One] and a Shell and Mobile service stations. Strathfield South High School is located on the corner of Liverpool Rd and Hedges Avenue and is bounded at its rear by Centenary Drive.
The increase of truck traffic on Liverpool Rd will discourage residents from using these shops or services. It should be noted that the service stations on Liverpool Road are some of the few service stations still in existence in Strathfield Municipality. Urban consolidation has resulted in the redevelopment of many service stations into medium density residential development. Urban consolidation which is primarily focused on increasing residential dwellings, can result in the reduction of commerce and industry, which provide services and employment to the local and regional community.
Most of Liverpool Road at the east of the proposed Enfield ILC is residential, mainly home units and townhouses.
Many residential areas of Strathfield and Strathfield South are accessed from Liverpool Road. Streets such as Hedges Avenue, Wallis Avenue and Homebush Road intersect with Liverpool Road.
The Enfield Industrial Area
Though Strathfield Municipality is primarily residential, there are dedicated industrial areas in parts of Enfield and Homebush. The industrial estates of Enfield, located around Cosgrove Road, emerged with the development of the Enfield Marshalling Yards in the early 20th century. Streets such as Madeline St, Pilcher St, Cleveland St and Hope Street are zoned industrial. Road access to these streets, which contain many industrial and commercial businesses is via Cosgrove Road. As Madeline Street continues into a residential area, traffic devices have been installed by Council to prevent commercial vehicles from entering the residential areas.
While there are larger businesses in Cosgrove Road such as Toyo Tyres, one of the businesses identified by Sydney Ports as a ‘key business’ in the Enfield Catchment area, there are many smaller businesses on Cosgrove Road such as smash repairers, auto repairers, transmission, paving companies etc. These businesses service the local and regional community and depend on access and on-street parking for their customers.
Has any consideration been given to the impact of a substantial increase of heavy vehicle traffic to these businesses? With increased traffic, there will inevitably be a demand for on-street parking on Cosgrove Road to be abolished?
Noise minimisation
One of the highest concerns regarding this proposed development is noise, particularly from rail and traffic, particularly to nearby residential areas.
As discussed, the Society is concerned about the viability of the Enfield Industrial area due to the impact of heavy vehicle traffic. The ILC proposal states that ‘Commercial and light industrial activity at the southeast of the site on Cosgrove Rd will act as a buffer for residents’. If the Enfield industrial area becomes less viable for a range of businesses, the likely occupiers of land will be business associated with the ILC eg trucking companies. It is possible that the ILC or similar operations may explore future expansion on the southeast of Cosgrove Road.
Operational Hours
The Environmental Assessment states that ‘peak activity for truck movements would be between 6am and 5pm Monday to Friday with a weekday average of total of 1160 vehicle movements per day on the roads. One third of these would be by light trucks.’ The FIAB report states that the Enfield site would be operational 24 hours a day, seven days a week. The actual proposal for the operations of this site by Sydney Ports appears to be the 24 hours per day, seven days a week, despite the statement about ‘peak activity’ which may imply restricted hours of use.
This proposal is unacceptable. There is little regard to the impact on residential areas. Even Sydney Airport hours of operation are restricted and a curfew imposed.
Heritage
The Enfield Marshalling Yards has important heritage significance and it is disappointing that this site will be so dramatically altered in future, with little reference to its past and importance in the local community.
In reference to the heritage assessment, the Strathfield District Historical Society does not agree with some of the recommendations of the report in particular:.
The Administration Building, built c.1940s appears to be in good condition. This style of building is rare in Strathfield Municipality, which has few historic industrial buildings in existence. The former Ford Factory on Parramatta Road Homebush and the Weston Milling site on Braidwood Avenue Enfield are the only industrial buildings which have heritage status. We do not agree that this building has no heritage status, it is certainly locally significant. This building could be reused or readapted for other uses such as administration, café for workers onsite etc.
The Yard Master’s Office has lost some of its features but restoration of this building or reuse would be not difficult as the building is substantially in-tact. We do not agree that this building has no heritage status, it is certainly locally significant. Further, the building appears to be in reasonable condition and there would be no reason not to maintain and reuse this building.
The retention and reuse of these buildings would provide aesthetic enhancement in the proposed development of this site. It would also provide a visible link with the site’s history.
The Tarpaulin Factory on Cosgrove Road is in a deteriorated condition [see photographs]. This is not the original site of this building as the factory was relocated and reassembled to the site on Cosgrove Road. There are concerns regarding the deteriorated state of this item and the cost of its restoration and whether there are funds available for its maintenance.
These heritage items are owned and managed by the NSW Government, yet most are deteriorated and have not been maintained. It is remarkable that items which the Government refers to as ‘Assets’ are in such poor condition and worse, that the few items which appear to be in good condition and could be easily reused such as the Administration Block, have been assessed as having no heritage significance.
According to Project Newsletter Issue 3 January 2006, Sydney Ports intends to make this a gift to the community. If Sydney Ports intends to ‘gift’ these to the community, Sydney Ports should finance restoration, maintenance and determine a genuine use for these sheds. If a viable and sustainable use can not be determined, the sheds should be moved and reassembled to another site. The burden of restoration and maintenance should not fall to the community and local Council, when this is the clear responsibility of the current owners.
Future ownership and management of the site
The FIAB report [Recommendation 3] states ‘participation from the private sector be sought for the [Enfield] site’s development and the terminal’s ongoing operation’. While this does not state that the site may be sold to private interests, there is some concern about whether the site will continue to be government operated and managed. If future ownership and management of the site is not maintained in government control, assurances about future use may be irrelevant. Since Sydney Airport was privatised, use of the site is constantly intensifying with local councils and residents fighting against site intensification and proposed developments. It should be noted the original Port Enfield proposals in 2002-2003 involved capacity of 500,000 TEU per annum as opposed to the 300,000 TEU proposed in 2006. However, limits can be varied and is there any genuine guarantee that limits on rail transport movements will not be increased, particularly if site ownership is privatised or management transferred to private interests?
Benefits of the ILC
The Environmental Assessment claims that the proposed ILC would result in reduction of carbon dioxide emissions within the Sydney basin. However, the increased amount of truck traffic and resultant pollution in Strathfield Municipality and adjacent areas will be substantially increased.
The Environmental Assessment claims that the proposed ILC will create 840 direct and indirect jobs during construction and further 850 direct and indirect jobs during operation. It could be argued that other uses of this site eg development of commercial or business centres would also create employment. It could be assumed that most jobs ‘created’ would involving shifting existing work from other sites eg Port Botany, otherwise the additional cost of labour in handling the transfer and management of goods at Enfield would add substantially to the overall cost of transportation. It should be noted that the development at Rhodes Peninsula is creating at least 1500 office jobs, 850 retail jobs and 3000 dwellings on a site of 43 hectares. In comparison, the Enfield site is 60 hectares.
The Environmental Assessment claims that the proposed ILC would significantly increase the number of containers delivered by rail close to where the importers and exporters are, thereby reducing the number of truck kilometres traveled. Certainly, this would occur if the final point of delivery was located in close proximity to the Enfield intermodal terminal. However, in the diagram ‘Key businesses within the Enfield ILC market catchment area’ many businesses are located over 20 kilometres from Enfield, which will require road travel for the distance between Enfield and their final destination. These include sites at Huntingwood [25 kms from Enfield], Prestons [28km from Enfield], Wetherill Park [24km from Enfield], Seven Hills [26 kms from Enfield]. It should be noted that most of the Enfield ‘catchment area’ is the outer Western Suburbs. Transportation from the Enfield site would still require the majority of trip from Port Botany to be via road, not rail.
Conclusion
While it is fashionable to criticise local opponents of large scale development as parochial, Sydney Ports and the Minister for Planning may wish to consider the adverse impacts on residents and small business of the Strathfield Municipality and other areas affected by this development.
In 1916 when the Enfield Marshalling Yards were established, there was minimal residential development in areas close to this site such as Belfield, Strathfield South, Enfield and even parts of Strathfield West. The establishment of the Marshalling Yards provided local employment and encouraged residential development in areas close to the Yards. Early subdivision posters use the Marshalling Yards as an incentive for residential development. Residential development commenced in the 1920s but most occurred post WWII.
In 2006, the former Enfield Marshalling Yards site is located close to many residential areas. This development will affect many residential homes in Strathfield and Bankstown Municipality, which are located close to the site. It will also affect homes located near the railway lines to and from the site. It will further affect any residential area located close to the roads where containers will be transported.
The roads surrounding the site which are targeted for massive increase in truck traffic are already clogged with existing traffic, particularly during peak hours. Strathfield is increasingly suffering from increasing ‘through’ traffic, caused by motorists trying to avoid traffic bottlenecks at Centenary Drive/Arthur St intersection, Parramatta Road and Liverpool Road. The proposed ILC will fully utilise these arterial roads, highways and motorways with trucks and will push local and car traffic into local residential streets.
Our members have expressed a genuine concern for road safety for motorists, when they are competing with trucks on local roads. It may shock Sydney Ports but we, the resident, have the right to use public roads such as Centenary Drive, Homebush Bay Drive, Liverpool Road and Motorways. We pay for roads, through taxes, vehicle registration, petrol taxes and tolls. The increasing proliferation of heavy trucks on our local roads is a cause of concern, particularly if it denies residents of Strathfield Municipality fair and safe access to roads, nearby suburbs and local/regional services and facilities because of a State Government development that is not supported by the local community.
Increased noise and air pollution and reduced access to roads and services will devalue the amenity of Strathfield and possibly may result in declining property prices. Many Strathfield residents shop at the Chullora Marketplace, Rhodes Shopping Centre, Roselands or Bankstown Square Shopping Centres. All the roads leading to these shopping centres will be difficult to access as roads will be clogged with heavy vehicles.
Sydney Ports and the Freight Infrastructure Advisory Board claim environmental benefits to support the development of these projects. However, the environmental impact on suburbs in the vicinity of the proposed development is negative. The proposed development will increase noise and air pollution, it will dramatically increase the numbers of heavy vehicles on local roads and it will make roads unsafe for motorists who compete with heavy trucks on local roads.
The submission is in PDF form - download submission.