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An EIS Community Liaison Group has been established by Thiess in relation to proposed works on the Government's former Union Carbide site and the strip of dioxin contaminated sediments in Homebush Bay. This process has limitation s as it is primarily concerned with a scope of works established without community consultation and does not deal with the contamination on the Peninsula and in the Bay on a holistic basis.

The comments below relate to the need for and promises of a broad "Homberg" Style Group concerned with the whole SREP 29 area, the impacts from the sites within that area on surrounding areas and the whole of Homebush Bay.

The process followed has had serious defects, only some of which have been addressed by the formation of the site specific EIS CLG referred to above:

Bias in supporting reports |No EIS |No real consultation | Changes after Exhibition of Draft REP | Virtually no Remediation consultation  

No broad Oversight Group with Community representation.

7 Feb 2001.  Waterways / DPWS have now agreed to formation of a committee with broad community representation. The proposed membership and the proposed terms of reference will be added when the file is received. While it took too long, this is a big step forward towards a more transparent process. See their suggested Terms for the Community Reference Group.

Waterways / DUAP / DPWS have failed to respond to the call at a public meeting  and by the City of Canada Bay Council for the formation of a HOMBERG style oversight group with community representation. HOMBERG was the oversight group for the Olympics remediation. The Rhodes remediation is expected to cost about 70% of the total cost of the Olympic remediation. The principles of the National Advisory Body on Scheduled Waste and of the National Environment Protection Council's Guideline on Community Consultation and Risk Communication are not being followed as they were by OCA. Neither DUAP nor the EPA have any local community representation about remediation.

Failure to include community Representatives on DCP Steering Committee

1 March 2001. DUAP now have Paul Hanly paulhanly@hotmail.com on the steering committee. The steering committee sees such a summary position that it does not have a full understanding of the weaknesess of the draft Transport Management Plan and the draft Community Development Plan.

DUAP did not appoint any community representatives to the Development Control Plan Steering Committee. DUAP  say they approached Concord Council who declined to appoint anyone.  DUAP did not advise the RPG that it was seeking community representation, nor did it appoint the previous nominees of Concord Council. Following a call by the City of Canada Bay Paul Hanly has been appointed with his first meeting after the close of the exhibition.

No information on practical implementation of proposed remediation process

7 March 2001. While the details of the proposed processes are not yet certain, partly because of the purchase by Meriton of the former Allied Feeds Site, EPA and DPWS / Waterways and Health have given a more meaningful overview of the regulation of the remediation, community consultation / oversight and some answers to questions.

A presentation by Dept Public Works & Services gave a background on why remediation was necessary, but in spite of a list of questions being lodged nearly 2 weeks in advance, there were virtually no answers to the resident's questions.

Timing of exhibition of draft Transport and development Control Plans

9 February 2001. The exhibition period was extended by only a further week to assist the Council of the City of Canada Bay, even though they asked for a month. It appears that all those who wanted to make submissions at least got their issues on the table.

The draft Transport Management PLan is dated September 2000. At a meeting in John Brogden's office DUAP declined to provide a copy. The draft was held back until early Decmber coinciding with the complete change in the local council and the absences over Christmas of residents, council employees, and public servants. The 8 week exhibition period ends as School returns.

Failure to respond to correspondence.

1 March 2001. DUAP has promised at a DCP steering committee meeting to provide detailed responses to the submissions by the Rhodes peninsula Group on the draft Transport Management and Community Development Plans

DUAP regularly fails to respond to correspondence addressed to its advertised project email address and to letters requesting specific information, or takes so long that the time for use of the information has effectively passed.

Bias in Supporting Reports

The Hassell Report of March 1998 shows a clear bias in support of high density development, even where it fails to meet long established planning guidelines
"The standard of 2.83 ha/1,000 people when applied to the potential population of the site, generates a somewhat excessive and impractical quantity of open space"

We would argue that higher ratios of open space are more important in developments with no private open space, like 10 storey apartment developments.

The lowest ratio of any LGA quoted by Hassell was 1.2 ha /1,000 people, but his was based on Marrickville where there is significant cumulative private open space in backyards. It is also a suburb that most people would regard as having insufficient open space.  There will be virtually no backyards at all in the proposed Rhodes development.  While Concord has 3.6 ha/1,000 people, virtually none of this is within walking distance for a mother with a stroller. The closest public playing field will be about 3 kilometres away. While Hassell talks about the McIllwaine/Brays/Rhodes parks, the discussion fails to acknowledge that they are regional parks, already densely occupied on weekends and that McIlwaine Park is regarded as unsuitable for family activity from late afternoon onwards.

Failure of to exhibit an Environmental Impact Study with the draft REP

7 March 2000. The DUAP Director General's Requirements for the EIS were issued over 12 months ago, probably before the REP had been gazetted. There was no community involvement in the formualtion of the DG's Requirements. Waterways, DPWS and EPA have indicated they would support community involvement in any review of the DG's requirements.

In spite of (or a cynic might say "because of"):

the gross scale of the development ($1.5 Billion)
the nature of the contaminants (Dioxins)
the location of the contaminants (within 20 metres of a gazetted Environmental Conservation Area (SREP24 gazetted the Homebush Bay Area Environmental Conservation Zone)
the potential impact on fish breeding grounds in local mangroves
the environmental sensitivity to water quality of the only 2 significant wetlands on the Parramatta River (Bicentennial Park and Newington)
the existence of 5 threatened species scheduled under the NPWS Act within the Environmental Conservation Area abutting the development
the existence of 27 species of migratory birds within the JAMBA and CAMBA treaties within the Environmental Conservation Area abutting the development
the risk of dust contamination to adjoining residents during remediation

no Environmental Impact Study was done and exhibited with the draft REP.

If this can be a proper exercise of the Minister's discretion (as claimed by DUAP) then when will the Minister be obliged to present an EIS?

Failure of DUAP to consult properly with the local community before Gazetting SREP 29:

No reply to most submissions on the initial plans
No display until 6 months after gazettal of summary of submissions 
No opportunity for persons making submissions to rebut responses, some of which are clearly of doubtful validity
No consultation on revised plans prior to Gazettal
Failure to provide information sought in writing by residents
Only 2 weeks notice of an intense 3 nights in one week consultation
Failure to ensure relevant information was available to residents, not only in time to allow review but not even before the consultation was completed.
No session yet on Contamination and Remediation issues on the riverbed, Union Carbide or Allied Feeds sites.

Failure of to re-exhibit draft REP in spite of significant changes:

Concord Council who objected to REP removed as Consent Authority
Roads and Traffic Authority no longer have to be satisfied with traffic management
Significant increase in building heights
 Removed protection of Mangroves
Deletion of draft aim re Traffic Plan
Deletion of requirement for a Development Control Plan

These changes to the REP were made without advice or consultation, and the REP should have been re-exhibited so that the community had an opportunity to comment.

DUAP has improved its performance in the mid 2000 round of community consultation,  instituting a small web site, http://www.duap.nsw.gov.au/rhodes.htm   with a link to the plan, and copies of the maps available. 

Copies of relevant documents can be obtained by emailing DUAP from there web site (click link above), or can be viewed at Concord Library, Concord Road, Concord West (between Yaralla Street and Strathfield North Public School) 

Virtually No 

7 March 2000. It appears that there will be a "Homberg Style" committee established. The terms of reference and proposed membership, subject to advertisement should be available shortly.

There has been no consultation on remediation to date. Just a presentation on the degree of contamination. The consultation process is not in accordance with the National Environment Protection Council Guideline on Community Consultation and
Risk Communication under the National Environment Protection
(Assessment of Site Contamination) Measure 1999. See: http://www.nepc.gov.au/cs/cs_shedules.html#measure 

If you have any information of relevance to this project or wish to advise of any corrections that need to be made, please advise the webmaster. rhodes@drive.to

If you become aware of later figures being available please provide copies of the relevant report so that it may be analysed and the pages updated.