Sunday, April 22, 2012

NWRL - BCCT Submission

North West Rail Link – Site 3 Proposed Cheltenham Services Facility.

This submission deals specifically with the proposed Services Facility. The EIS has recommended for the facility to be located next to Cheltenham Oval and identified in the EIS as Option 6.  This submission critically analyses options 6 as presented and recommends what we believe to be the best design that minimises environmental impact, construction costs, compensation, visual impact, future maintenance costs and maximises operational efficiency.
The Beecroft Cheltenham Civic Trust was formed by the residents of Beecroft and Cheltenham in 1964 to help preserve the best qualities of the two suburbs. The Trust maintains an active role in representing the views of the 3000 local residents. 
At the recent Pre-EIS briefing, the Trust was advised about the NWRL intentions regarding access for emergency services in the event of a fire or derailment in the tunnel between Epping and Cherrybrook rail stations. The Trust was advised that the subject EIS focuses mainly on the construction phase and another EIS will be released soon that deals with the operation of the NWRL.  We believe the construction and operating phases are linked and both must be assessed concurrently in order to achieve a comprehensive environmental assessment under the provisions of the EPA Act 1979. So this submission may be deficient if additional information comes to light in the second EIS.
The EIS has considered 19 possible locations for the services facility and the Trust acknowledges that the Cheltenham Oval location (option 6) appears to be the best of the 19 presented. We note that there are no details of the other 18 options in the EIS so this submission will focus on option 6 adjacent to Cheltenham Oval. We believe the main issues that need assessing are location, ecological impact and access. In addition the short term impact during the construction phase and the long term impact during operation must also be assessed concurrently.
The main advantages of option 6 is its very close proximity to the M2 motorway and its minimal impact on ecology and residential amenity.  The recommendation to locate the completed facility and acoustic shed for the extractor fans behind the houses facing Castle Howard Rd is questioned. Surely these types of noisy operations and the completed facility would be better positioned closer to if not abutting the M2 boundary. Noise impact will be minimised and visual amenity of having a facility building next to the M2 noise walls would be less visually intrusive. Also the vegetation behind the houses can eventually by remediated once the compound is removed. Permanent access for light vehicles off Castle Howard Rd could be designed into any reconstruction of the bushland or netball courts.  Having the facility closer to the M2 will also suit direct access on and off the M2 for emergency vehicles.
The key benefit in using option 6 is making both short and long term use of direct access to the M2.  If the M2 is not used then any financial or ecological benefit is lost and option 6 will not stand up to impartial scrutiny. The proposed access from Kirkham St involving the destruction of almost one hectare of pristine indigenous bushland cannot be justified.  The total cost of such a road will be in the order of $3mill if traffic lights, construction and vegetation compensation is taken into account.  The visual amenity will be severely comprised as well.
The M2 is currently being widened and in the vicinity of the proposed facility the M2 carriageway is virtually at grade with the netball courts.  This offers a huge opportunity to satisfy the needs of the project at minimal cost.   There is also ample width within the M2 lease boundary to widen the break down lane even further then what is currently being constructed to allow for vehicles to enter and leave the service facility and its temporary compound.  This solution appears to be so simple to design, so efficient in terms of quick access and so cost effective that any cost benefit analysis would clearly support this access option.  Admittedly there may be the matter of where to take the fill once the trucks enter the M2 eastbound lanes. But we believe this can be resolved and would be a minor issue compared to the advantages of directly accessing the M2 and avoiding the Kirkham St route. 
 Ecological impact
As mentioned above any road whether temporary or permanent through the pristine bushland to Kirkham St would be a disaster for the local community as well as Hornsby Council who are responsible for  managing  the bushland in this area. If access onto the M2 cannot be secured for any reason then option 6 for a service facility should be abandoned and another location investigated. The destruction of one ha of bushland for a 'white elephant' road that may never be used is simply not acceptable and would not stack up to any impartial assessment using all the standard assessment criteria.
Short term requirements      
The EIS estimates that heavy vehicle access during construction will be about 1000 truckloads of fill over about a year. As stated above the advantage of this option 6 location is the close proximity of the M2 for direct access.  The alternative access that is being considered being the building of an industrial grade 2 lane all weather road to be used for just a year and may never be used again just does not compute.  There is no environmental or financial benefit to such a proposal. In fact it would become a long term liability. So unless short term haulage of material does not use the M2 then any benefit of option 6 is lost and another location for the service facility should be considered.   
Long term requirements
The EIS says that the service facility will need efficient access for all types of emergency vehicles. The key advantage of this location is its proximity and direct access to the M2. The probability of the service facility being used as part of an emergency may be once in a lifetime. Say once in 30 years. The construction of a purpose built access road through the pristine bushland to used once in a lifetime cannot be justified in any environmental assessment. Periodical service vehicles such as cars can use the local road network.
In summary option 6 Cheltenham Oval for a service facility will only be supported by the community if direct access to the M2 is supported. Otherwise another site must be investigated  

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