Horsley Drive Business Park Stage 2 – Building 1 State Significant Development Application (SSD 10404) Part of Western Sydney Parklands (Cnr. Cowpasture Road and Trivet Street, Wetherill Park (Lots 17-22 on DP 13961 & Lot 2 on DP 1212087)) Submitted to Department of Planning, Industry and Environment On behalf of Charter Hall 25 June 2020 | 2190880
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This document has been prepared by: This document has been reviewed by:
Roisin Cosgrave 25 June 2020 Angus Halligan 25 June 2020
Reproduction of this document or any part thereof is not permitted without written permission of Ethos Urban Pty Ltd. Ethos Urban operates under a Quality Management System. This
report has been prepared and reviewed in accordance with that system. If the report is not signed, it is a preliminary draft.
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1.0 Introduction 4 1.1 Overview of the Original Proposal 4 1.2 Amendments to the proposal 5 1.3 List of design changes 5
2.0 Overview of Submissions 7
3.0 Report Structure 7
4.0 Response to Submission 8 4.1 Department of Planning & Environment 8 4.2 Fairfield City Council (FCC) 17 4.3 Department of Transport for New South Wales
(TfNSW) 19 4.4 Heritage Council of NSW 19 4.5 WaterNSW 20 4.6 Environment, Energy and Science Group (EES) in
SSD 7664 is currently the subject of a Modification Application for which an updated BDAR has been prepared by
EcoLogical (dated 7 April 2020). The updated BDAR recognises that the EPBC Act establishes a process for
assessing the environmental impact of activities and developments where MNES may be affected.
Under the Act, any action which “has, will have, or is likely to have a significant impact on a matter of MNES” is
defined as a “controlled action”, and requires approval from the Commonwealth Department of the Environment and
Energy (DoEE), which is responsible for administering the EPBC Act.
A habitat assessment and Likelihood of Occurrence was completed for listed threatened species that represent
MNES. One MNES, Pteropus poliocephalus (Grey-headed Flying-fox), was assessed under the EPBC Act.
Given Matters of National Environmental Significance have been dealt with under SSD 7664 and the subsequent
Modification Application, further assessment as part of SSD 10404 is not warranted.
Provided the SSD-7764 modification is approved and the works undertaken in accordance with the approval, the
construction of Building 1 for SSD-10404 will have no biodiversity impacts.
13. confirm whether site access and amendments to Cowpasture Road and Trivet Street are being sought
under SSD-10404 or SSD 7664 Modification 1.
Applicant’s Response
Site access and road reconfiguration is subject of SSDA 7664 MOD 1.
14. provide a process description and illustration of how the development will operate.
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Applicant’s Response
As outlined in the Table 2 below and the attached architectural drawings (Appendix B), the proposed CFC Facility
processes have been designed with a considered approach to functionality, efficiency and safety.
Table 2: Process Description
Process Description
Traffic flow and good delivery to and from the site
Traffic flow around the site Traffic flow around the site will be aided by the following initiatives: -inbound truck management via reporting to the gatehouse.
-inbound van management via traffic signalised queue management
and audio connection to yard manager to direct vans accordingly. - all vehicles directed around the site via an extensive digital directional signage installation covering all areas of the site.
Traffic flow, bulk inbound bulk product Inbound goods from the distribution DC or direct from suppliers arrive
in B-doubles or 19m articulated semi-trailers.
These laden vehicles enter the truck entry driveway and report to the
gatehouse.
From the gatehouse they are directed to a delivery dock or truck
waiting bay, then to a delivery dock.
After unloading has taken place the empty vehicle then exits the site
through the Truck Exit driveway.
Traffic flow, bulk outbound bulk product Outbound goods from the CFC depart in 19m articulated semi-trailers, bound for smaller cross-dock distribution centres.
The unladen vehicles are waiting in storage bays within the hardstand and are directed to the relevant despatch dock for loading.
These laden vehicles exit the Truck Exit driveway after crossing the weighbridge for a load compliance check.
After delivering the unladen truck will return and enter the truck entry driveway and report to the gatehouse.
From the gatehouse they are directed to a storage bay or despatch dock accordingly.
Traffic Flow; Vans Vans deliver multiple customer orders based on a geographic ‘delivery run’.
After a previous delivery run, Vans enter the site through the dedicated Van Entry driveway and queue at the signalised queuing bay.
They communicate with the yard manager via audio intercom and are directed according to their requirements including
- refuelling - washing - internal cleaning
- repairs or direct to the Van Random Access bays.
When required Vans will move from the Random Access Bays to the Vehicles inspection bays for quality checking.
Upon passing inspection the Van will move to the relevant van dock, or Van Pen Parking then the relevant van dock; for loading.
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Process Description
Upon loading the Van will return to the Van Pen Parking then/or exit the site via the Van Exit driveway after crossing the Van weighbridge for a load compliance check.
After deliveries are complete the van will re-enter the site as previous and the cycle repeats.
Goods flow within the building
General System The warehouse operating system generally comprises an ambient (temperature controlled) and refrigerated ’hive’ for storage of
consumer grocery product in stacked plastic storage totes.
Bulk palletised product is broken down and inducted into the hive for medium term storage, sent to picking stations for order collation into
delivery totes.
The remaining bulk product is re-inducted into the system, whilst the order is inducted into the hive in delivery totes for short term storage.
Upon requirement for despatch, the order comprising multiple delivery totes is collated into delivery frames and loaded into a van for despatch on a delivery run of multiple orders in similar geographic
locations.
4.1.4 Hazards and Risk
15. it is noted that there is a wide variety of dangerous goods listed in the Dangerous Goods (DG) Assessment,
please provide the representative products that may represent DG Class 1.4s and DG Class 5.1 and
describe how these products are being handled in the proposed development.
Applicant’s Response
Class 1.4s products include party poppers, sparklers and general birthday party goods in small containers. These
products are considered to be low risk, with only a minor quantity of explosive in each component.
Class 5.1 products are typically hydrogen peroxide-based hair dyes which contain between 8-12% hydrogen
peroxide. These are also considered low risk as the hydrogen peroxide will only decompose into oxygen and
hydrogen when dried and exposed to a high temperature.
16. confirm the location of the diesel storage.
Applicant’s Response
The diesel storage is proposed in a packaged fuel tank/dispensing facility nominated as "Van Re-fuel" on the overall
site plan (DA 020). Please refer to the Architectural plans attached at Appendix B.
17. clarify whether the forklifts are fuelled by LPG, diesel or electricity. Please also indicate the forklift filling or
charging location.
Applicant’s Response
All forklifts are intended to be fuelled by LPG using small refill bottles. Gas (bullet) is located external to the facility in
hardstand and only handled during re-fill.
18. confirm whether all DG products to be handled within the proposed Automated System warehouse are
household packaged product.
Applicant’s Response
It is confirmed that all DG products to be handled within the proposed Automated System warehouse are household
packaged retail products.
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The following ancillary products are not stored within the proposed Automated System warehouse:
Diesel for van re-fuel is handled within the van re-fuel location in hardstand external of the facility.
Gas (bullet) is located external to the facility in hardstand and only handled during re-fill.
Ammonia for refrigeration is handled within the plantroom, not located within warehouse.
19. how will the DG products be categorised within the distribution centre? Is there the potential for
incompatible substances to be stored together?
Applicant’s Response
The storage logic can be programmed to dedicate particular storage areas to a DG class. Only DG classes which
align with that designation can be stored within that location.
The separation table from AS 3833 will be used to guide the DG separation within the automated warehouse
system to minimise the potential for co-location.
In addition, the DGs are stored in self-contained totes; hence any spillage from a package would be contained
within a tote and unlikely to mix with other products during storage.
Only undamaged products are introduced into totes so the potential for damage to occur once located in a tote is
minimal.
20. it is stated in the Preliminary Hazard Analysis that Ammonia/Glycol is low charge with 500g. Where will this
refrigeration unit and the associated ammonia storage be located?
Applicant’s Response
In review of the Preliminary Hazard Analysis, the appointed refrigeration contractor has confirmed that the
Ammonia/Glycol will be low charge with 300g and is to be stored in the plant room.
4.1.5 Inconsistencies
21. there are a number of inconsistencies within the EIS and specialist reports – for instance:
• Section 4.3 of the EIS states that the detailed design guidelines under the concept plan have a
nominated building height of 15 metres, whereas Condition A10 of the concept plan provides a
maximum building height of 16 metres. The development controls of SSD 7664 have not been
adequately addressed; and
• Appendix H – Civil Engineering Report SSD 10404 – Section 6.2 states that “Indoor and outdoor water
demand and rainwater tank sizing will be based on individual site requirements and form part of
separate future development applications…”. Clarification as to what future development applications
would submit this level of information, rather than SSD 10404 is required. Alternatively, it would be
expected that this detail would be provided as part of this development.
Applicant’s Response
Chapter 4.3 of the EIS makes an incorrect reference to the maximum building height approved under SSD
7764.
In accordance with Condition A10, Table 1; Development Controls under Schedule 2 Conditions of Consent for
Concept Development (SSD 7664), the maximum building height is 16 metres.
The proposed CFC facility sought under SSD 10404 proposes a maximum building height of 15.7 metres in
accordance with the Concept Approval.
A 250,000L rainwater capture and reuse system is proposed for installation to offset the sites water usage for
washdown, cooling towers, toilet flushing and irrigation. This system is expected to offset the majority of the
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sites potable water usage with initial calculations showing that up to 70% of potable water consumption could be
avoided (Please refer to the amended ESD Report prepared by Northrop at Appendix D)
Appendix F – Civil Engineering Report SSD 10404 has been updated to reflect indoor and outdoor water
demand and rainwater tank sizing for the development.
4.2 Fairfield City Council (FCC)
FCC provided comment on the proposed application and identified the following matters for consideration:
Traffic management
Biodiversity Assessment Development Report
Heritage
Landscaping requirements
Catchment management
Environmental management (noise, odour)
Dangerous goods storage
Applicants response:
A detailed response to the matters raised by Council has been provided within the Response to Submissions Table
provided at Appendix A.
Council’s submission specifically raised the proposed access arrangements at Trivet Street and Cowpasture Road
and that the owners of the following lots be should consulted and their agreement provided in relation to the revised
access arrangements:
105 Cowpasture Road, Wetherill Park.
109 Cowpasture Road, Wetherill Park.
115-119 Cowpasture Road, Wetherill Park.
121-123 Cowpasture Road, Wetherill Park.
As outlined within the EIS, a letter was prepared and provided to nearby stakeholders and community members
most likely considered to be impacted by the development. The letter provided the following elements;
details of the proposed development.
details of changes to the surrounding road network.
details of changes to the Concept Masterplan per SSD 7664.
details of the proposed CDC facility.
Following the lodgement of SSD 10404, the Applicant has undertaken the following additional consultation in
response to Fairfield City Council’s request.
Table 3: Stakeholder Consultation
Address Comment
105 Cowpasture
Road, Wetherill Park
Tuesday 9/6/2020
Applicant had an onsite meeting with Owner to discuss the proposed access
modification.
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Address Comment
The Applicant and Owner discussed the proposed realignment of Cowpasture
Road and Trivet Street.
Owner noted that they did not have any major concerns as long as B-Double
access to and from his site is not impacted by the modified arrangement;
Owner mentioned that some heavy vehicles will have concerns with the extra
stop start on the uphill section but acknowledged this as unavoidable.
Owner acknowledged that the proposed arrangement would resolve safety
concerns he has previously raised with trucks coming down Cowpasture Road
(north to south).
Applicant issued the Owner with a follow up email including link to the
Department website and civil diagrams indicating changes to the crossover.
The Owner has not responded any further to the email correspondence.
109 Cowpasture
Road, Wetherill Park
Friday 5/6/2020
Applicant called the Owner to discuss the application and query any potential
concerns.
No immediate concerns were raised by the Owner but highlighted that they
were not fully across the detail.
Owner noted the crossover to Cowpasture Road is to be an exit to their
proposed depot only.
Applicant issued the Owner with a follow up email including link to the
Department website and civil diagrams indicating changes to the crossover.
The Owner has not responded any further to the email correspondence.
115-119 Cowpasture
Road, Wetherill Park
Friday 5/6/2020
Applicant called the Owner to discuss the application and query any potential
concerns.
Owner noted they were not objecting to the amendments but was interested in
discussing the layout further.
Applicant and Owner agreed to meet on site to discuss the proposal.
Owner noted they are purchasing the rear lot (121-123 Cowpasture Road).
Tuesday 9/6/2020
Applicant had an onsite meeting with owner to discuss the proposed access
modification.
Owner noted he had no objections, as long as crossovers are reinstated and
that B-Double access to both 115 and 121 Cowpasture Road are maintained.
Owner acknowledged left out only from slip road.
Owner requested that landscaping to nature strip between slip road and
revised Cowpasture Road alignment be minimal to not reduce exposure for his
properties.
121-123 Cowpasture
Road, Wetherill Park
Friday 5/6/2020
Applicant called the Owner to discuss the application and query any potential
concerns.
No concerns raised.
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Address Comment
Owner agreed that having a separate slip road to service 2/3 lots is an
advantage.
Owner noted that they were selling parcel to neighbour at the front (115-119
Cowpasture Road).
As demonstrated above, the affected stakeholders have now had an opportunity to provide formal comment during
the public notification period and further, to discuss the application directly with the Applicant and at no stage have
any objections to the proposal been raised.
4.3 Department of Transport for New South Wales (TfNSW)
The TfNSW submission notes that the majority of impact of the proposed development will be at the intersection of
Cowpasture Road and Trivett Street, Wetherill Park. The TfNSW submission suggests extra capacity or alternate
access onto The Horsley Drive should be considered.
Applicant’s Response:
The SIDRA analysis indicates that the resulting development’s traffic would cause Cowpasture Road / Victoria
Street roundabout to decrease from Level of Service (LOS) B to LOS C. This decrease in LOS occurs for the AM
peak right turn movements from Cowpasture Road to Victoria Street as a result of a 9-10 second increase in delay
from 20.9 to 30.2 seconds. The worst delay of 34.1 seconds occurs for the U-turn movement with only 2 vehicles
per hour projected to utilise this movement.
Under the RMS Guide, LOS C occurs between 29-42 seconds of delay. As such, the primary right turn movement is
only 1.2 seconds higher than a LOS B which indicates that the resulting LOS decrease is only marginal. This is an
acceptable outcome as it indicates that the roundabout would still operate satisfactorily. We note that The Horsley
Drive upgrade would be undertaken in the future which would provide additional capacity along The Horsley Drive
and reduce the future PM peak hour delays at the existing roundabout.
4.4 Heritage Council of NSW
The Heritage Council of NSW submission recommends that the conditions of the Historical heritage advice
prepared by Biosis (22 January 2020) be implemented to avoid impact on the heritage significance of the Upper
Canal System. The submission also recommended the if unexpected archaeological deposits or relics are
discovered on the site, work should cease in the affected area(s) and the Heritage Council of NSW be notified.
Applicant’s Response:
The Applicant notes the recommendation from the Heritage Council of NSW that the conditions of the Historical
heritage advice prepared by Biosis (22 January 2020) be implemented to avoid impact on the heritage significance
of the Upper Canal System.
Further, the recommendations outlined in the Historical Heritage Advice prepared by Biosis (Appendix I) will be
addressed (as relevant) by the applicant prior to commencement or during construction phases.
The CEMP prepared by Charter Hall incorporates an Unexpected Finds Procedure to ensure that all actual or
potential heritage items uncovered during construction are protected. This includes Aboriginal objects, Historic (non-
Aboriginal heritage items) and Human Skeletal remains.
Additional mitigation measures have been identified to ensure any unexpected archaeological deposits or relics
discovered on the site are protected and these have been included within the Updated Mitigation Measures outlined
in Section 6 of this report.
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4.5 WaterNSW
WaterNSW acknowledges that the key issues relating to environmental management practices required during the
physical construction and operation of the facility have been assessed and the EIS considers WaterNSW’s SEARs
comments. The submission requested several conditions relating to stormwater management, earthworks, erosion
and sediment controls, vibration, bulk water supply infrastructure, fencing, heritage and consent.
Applicants response
The applicant has reviewed the recommendations and appreciates that several of these can be addressed by way
of a condition of consent. Accordingly, the applicant is prepared to address these (as relevant) prior to
commencement or during construction phases.
4.6 Environment, Energy and Science Group (EES) in the Department of Planning, Industry and
Environment (DPIE)
EES provided commentary on the Aboriginal Cultural Heritage Assessment Report (ACHAR), BDAR waiver and
flooding. ABHAR and BDAR waiver issues have been resolved and the department advised the submitted
documentation regarding flooding is considered adequate for the management of local drainage and flooding
problems within the development site and the downstream areas.
4.7 Endeavour Energy
Endeavor Energy raised no issues with the proposed development. The submission included advice regarding
potential connections for the proposed development, noting that the development may require existing overhead
powerlines to be moved underground. The submission also requested a condition of consent that requires
satisfactory arrangements have been made for the connection of electricity to the proposed development, prior to
the release of the Construction Certificate / commencement of works.
Applicant’s Response:
A submission for power will be made to Endeavor Energy prior to commencement of work.
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5.0 Proposed Amendments
The SSDA package, as amended during the Response to Submissions phase of the project, relates to construction
of a light industrial warehouse facility to operate as a customer fulfilment centre with the Horsley Drive Business
Park Stage 2 – Building 1. The application proposes the following:
• a light industrial warehouse facility to operate as a customer fulfilment centre. This will include ambient and
chilled warehouse space, freezer chamber, bakery, plant, data centre and energy areas and ancillary office.
• a total gross floor area of 45,305m2 is proposed over 2 storeys – an upper and lower mezzanine;
• 539 car parking spaces (including 10 accessible spaces);
• service vehicle parking, including:
- 306 van parking spaces;
- 21 trailer parking spaces;
- 25 truck waiting spaces;
• a total of 20 bicycle and 29 motorcycle parking spaces;
• 2 maintenance parking bays are located at truck entry and loading areas;
An amended set of Architectural Drawings prepared by Leffler Simes Architects is submitted with this response at
Appendix B. The scope of the application has not changed; however, the following amendments have been made:
Fire Sprinkler tanks and pump room relocated to north-west corner of site
Extra fire sprinkler tank added
16 trailer parking bays along north boundary relocated for sprinkler tank
CCR1 communication room relocated
Van Entry driveway widened
Van Hardstand parking layout altered
Truck & Van driveway exits combined
Extra lane added to Staff car park driveway
Covered pedestrian awning added from street to main office
Truck weighbridge setback off northern boundary
Fuel Bay location layout altered in van hardstand
Van Wash Bays location and layout altered
CCR2 communications room relocated from southwest corner of site to northwest corner
Battery Disposal Cage shifted south
Truck trailer parking and truck waiting bays along western boundary rotated 45 degrees
Waste room on west façade deleted and altered to waste finger dock
6 trailer bay parking spaces added to northwest corner of building
VI Hut, Data Room 1, external access stairs and ramps altered on north façade
Outdoor dining area off main office shifted south
First Floor Main Office façade altered above main entry to provide weather protection
Loading bay added to staff car parking northern end
Security turnstiles and access gate added separating van hardstand from pedestrian walkway
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Pedestrian covered way added along west side of staff car park
Covered bicycle parking added
Covered smokers hut added
LPG Bullet added. Located between staff car park and east boundary truck driveway
Gas Bullet refuel parking bay added
4 truck waiting bays added along east boundary truck driveway
Energy Centres 1 & 2 layout and configuration altered
Truck driveway gradient along southeast corner boundary altered to keep height of retaining wall on south
boundary to 3m maximum
Data Centre 2 relocated from east façade to south façade
Rainwater harvest tanks added along buildings south façade
4 truck waiting bays deleted from southern driveway adjacent building
2 truck waiting bays added along south boundary truck driveway
Extent of canopy extended in southwest corner of building to shelter pallet storage area
6.0 Updated Mitigation Measures
The collective measures required to mitigate the impacts associated with the proposed works have been updated to reflect the amended design and updated technical studies. The Updated Mitigation Measures are detailed in Table 4 below. These measures have been derived from the previous assessment the EIS and those detailed in appended consultants’ reports.
Table 4: Mitigation Measures
Mitigation measures
Traffic and transport
• The Transport Assessment recommends the Preliminary CTMP, provided for information purposes, would be further
detailed in consultation with the relevant authorities at CC stage in response to the expected condition of consent.
Noise and Vibration
The Acoustic Report recommends the drafting of a noise management plan outlining all reasonable and feasible
methods for the reduction of noise impact including:
• Briefing the work team and contractors to create awareness of the proximity of noise-sensitive residential receivers
and the importance of minimising noise emissions.
• Using ‘quiet’ work practices to minimise noise, where possible.
• Use of less noise-intensive equipment, where feasible and reasonable.
• Adjusting reversing alarm volume on heavy equipment to make them ‘smarter’, by limiting the acoustic range to
immediate danger area, where acceptable under the relevant safety procedures.
• Enclosure of outdoor fixed plant (such as mechanical plant) where practicable
• For equipment with enclosures, ensure door and seals are well maintained and kept closed when not in use.
• Vibration screening criterion of 50 mm/s is applicable for the Upper Canal structure.
• The proposed construction works near the Retaining Wall 2 at the western boundary of Lot 1 has a minimum slant
distance of less than 15 m to the Upper Canal visible structures.
• Where vibration intensive construction activities are proposed within the minimum working distances, these works
will be confined to less sensitive periods where practicable.
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Mitigation measures
• In general, mitigation measures that should be considered are summarised as follows:
• Relocate vibration generating plant and equipment to other areas within the site in order to lower the vibration
impacts.
• Investigate the feasibility of rescheduling the hours of operation of major vibration generating plant and equipment.
• Use lower vibration generating items of plant and equipment where possible e.g. smaller capacity vibratory rollers.
• If vibration intensive works are required within the safe working distances, vibration monitoring or attended vibration
trials would be undertaken to ensure that levels remain below the cosmetic damage criterion.
• Where buildings are located within the minimum working distances for cosmetic damage, building condition surveys
would be completed both before and after the works to identify existing damage and any damage due to the works.
Soil and Water
The following recommendations were made in the Civil Engineering Report as part of the Soil and Water Management
Plan:
• Clearly visible barrier fencing shall be installed as shown on drawing Co11492.18-DA20 and elsewhere at the
discretion of the site superintendent to ensure traffic control and prohibit unnecessary site disturbance. Vehicular
access to the site shall be limited to only those essential for construction work and they shall enter the site only
through the stabilised access points.
• Soil materials will be replaced in the same order they are removed from the ground. It is particularly important that
all subsoils are buried and topsoils (landscaped areas only) remain on the surface at the completion of works.
• The construction program should be scheduled so that period of time from starting land disturbance to stabilisation
is minimised.
• Notwithstanding this, schedule works so that the duration from the conclusion of land shaping to completion of final
stabilisation is less than 20 working days.
• Land recently established with grass species will be watered regularly until an effective cover has properly
established and plants are growing vigorously. Further application of seed might be necessary later in areas of
inadequate vegetation establishment.
• Where practical, foot and vehicular traffic will be kept away from all recently established areas
• Earth batters shall be constructed in accordance with the Geotechnical Engineers Report or with as law a gradient
as practical but not steeper than:
- 2H:1V where slope length is less than 7 metres
- 2.5H:1V where slope length is between 7 and 10 metres
- 3H:1V where slope length is between 10 and 12 metres
- 4H:1V where slope length is between 12 and 18 metres
- 5H:1V where slope length is between 18 and 27 metres
- 6H:1V where slope length is greater than 27 metres
• All earthworks, including waterways/drains/spillways and their outlets, will be constructed to be stable in at least the
design storm event of 1 in 2 year ARI (Q2).
• During windy weather, large, unprotected areas will be kept moist (not wet) by sprinkling with water to keep dust
under control. In the event water is not available in sufficient quantities, soil binders and/or dust retardants will be
used or the surface will be left in a cloddy state that resists removal by wind.
Stormwater
The design of the proposed development aims to ensure that adverse impact on stormwater quality or quantity does not eventuate. Given this, the main mitigation measures associated with stormwater relate to the regular maintenance and monitoring of the systems in place, including the water quality treatment train. An indicative maintenance schedule has been included in the Civil Engineering Report (Section 3.5) for reference.
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Mitigation measures
Hazards and risks
Dangerous goods
• The site shall be designed to contain any spills or contaminated water from a fire incident within the boundaries of
the site.
• The warehouse and/or site boundaries shall be capable of containing 612 m3 which may be contained within the
warehouse footprint, site stormwater pipework and any recessed docks or other containment areas that may be
present as part of the site design.
• The civil engineers designing the site containment shall demonstrate the design can contain at least 612 m3.
• A storm water isolation point (i.e. penstock isolation valve) shall be incorporated into the design. The penstock shall
automatically isolate the storm water system upon detection of a fire (smoke or sprinkler activation) to prevent
potentially contaminated liquids from entering the water course.
Bushfire
• The warehouse site is to have a defendable space between the building and the site boundary including the
following:
- A minimum 6 m wide carriageway fire access road located between the warehouse and the boundary.
- Continuous thoroughfare for fire pumpers between the warehouse and site boundary linking back to the internal access road.
• The defendable space is to be clear of vegetation.
• Vegetation and landscaping across the business park is to comply with the performance objectives of an Inner
Protection Area (IPA) standard as described by PBP.
• The site requires fire hydrants to be installed to comply with AS 2419.1 – 2005 Fire Hydrant Installations - System
Design, Installation and Commissioning (AS 2419) so that all sides of a building envelope are within 70 m of a
hydrant by lay of the hose (or 90 m with a tanker parked in-line maximum 20 m from the hydrant).
• Any gas services are to be installed and maintained in accordance with AS/NZS 1596-2014 The storage and
handling of LP gas.
Biodiversity
A Biodiversity Assessment Development Report (BDAR) that assess the impacts of the civil works is in preparation and will be submitted with the modification application to SSD-7764 for Horsley Drive Business Park Stage 2. Please refer to Appendix H – Biodiversity Waiver for more information.
Heritage
• Ensuring that no physical impacts occur within the curtilage of the Upper Canal (Lot 1 DP 596354).
• Building envelope setbacks from the western edge of the lots to ensure that the current development and future
applications do not have an adverse impact on the heritage significance of the Upper Canal.
• Developing a landscaped area along the canal as a soft barrier to protect its setting.
• If possible, effort should also be made to ensure that buildings along the frontage do not present blank high walls.
• The proposed works should comply with the Guidelines for Development Adjacent to the Upper Canal and
Warragamba Pipelines (WaterNSW 2018).
• Further assessment of any alterations to the design to determine whether it would impact the Upper Canal.
In addition to the above, the following general mitigation measures for unanticipated discoveries include:
• Should any Aboriginal objects be encountered during works associated with this proposal, works must cease in the
vicinity and should not be moved until assessed by a qualified archaeologist. If the find is determined to be an
Aboriginal object the archaeologist will provide further recommendations. These may include notifying the OEH and
Aboriginal stakeholders.
• Should any historical relics be discovered during the project, work in the vicinity must cease and an archaeologist
contacted to make a preliminary assessment of the find. The Heritage Council will require notification if the find is
assessed as a relic.
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Mitigation measures
• If any suspected human remains are discovered during any activity, the project team must:
• Immediately cease all work at that location and not further move or disturb the remains
• Notify the NSW Police and OEH’s Environmental Line as soon as practicable and provide detail of the remains and
their location
• Not recommence work at that location unless authorised in writing by OEH.
Waste
Waste management strategies which will be implemented during the construction and operational phases of
development include:
• During construction: the stockpiling of construction materials waste (likely in a skip) to be transported off Site for
recycling or disposal
• During operation: the storage of waste in designated areas, pallets/crates or compactor and collected on a regular
basis (daily, 1-2x per week or weekly) by a specific contractor.
Air Quality
• Air pollution control devices may be implemented to further reduce emissions where complaints are received in
relation to nuisance odour or where prolonged smoke is visible during normal or peak operations (i.e. not during
start up or shut down).
• Good housekeeping be maintained on all areas of the Project Site, including regular cleaning of all internal and
external areas
• Physical controls (including ventilation fans, exhaust stacks, extraction hoods, grease traps, air pollution control
devices etc.) should be designed to allow for easy and safe cleaning and maintenance. It is recommended that
regular cleaning of physical controls be undertaken as per manufacturer’s requirements.
• All generated waste is identified and separated into common material streams or categories at the point of
generation for separate collection.
• General environmental awareness training be provided to relevant staff and contractors.
Ecologically Sustainable Development and Energy Efficiency
• Changing Surface Temperatures will be addressed through the;
- Use of high reflectivity roofing to minimise heat gain and heat island effects
- Integration of solar panels to provide shading to areas of the roof and provide increased power to the site when
peak energy use for cooling is required.
- Incorporation of heating, ventilation, air conditioning (HVAC) systems designed to modulate in the event of
changing outside air temperatures. Equipment will be rated to continue operating during higher temperatures.
- Use of waterless heat rejection system to reduce increased demand for water as a result of increased average
temperatures.
• An increase in rainfall intensity will be managed through the;
- Inclusion of rainwater and stormwater storage systems to modulate flows exiting the site
- Ability to provide increased finished floor level (FFL) designed to be 0.30 m above freeboard requirement to account for increased flooding potential at the site.
- Inclusion of awnings to the entry access points to promote allow continued operation during adverse conditions.
• An increase to wind speed intensity will be addressed through;
- The metal deck roof design incorporating roof bracing to fasten the roof onto the building structure to account for south-easterly winds on site and prevent damage to the roof due to prevailing winds.
- Improved structural integrity to ensure that the building is not significantly impacted in the event of high intensity wind loads. This includes wind loading on the façade of the office spaces.
• Decrease in humidity and increased drought conditions will be addressed through;
- Increased capacity within the fire safety systems to assist in the management of bushfire risk associated with dryer conditions
SSD 10404 Horsley Drive Business Park Stage 2 | Response to Submission | June 2020
Ethos Urban | 2190880 26
Mitigation measures
- Additional non potable water supply for irrigation needs and, the integration of native and drought tolerant vegetation.
SSD 10404 Horsley Drive Business Park Stage 2 | Response to Submission | June 2020
Ethos Urban | 2190880 27
7.0 Conclusion
This Response to Submissions has been prepared to satisfy the provisions of Section 4.39 of the EP&A Act and
Section 85A of the EP&A Regulation. Each of the submissions received during the public exhibition period have
been collated, analysed and addressed through the provision of additional information and design amendments.
A majority of the issues raised within the submission are proposed to be addressed by way of conditions of consent
which will monitor and ameliorate impacts during the construction and operational phase.
The mitigation measures provided within the EIS have been updated where necessary to respond to the
submissions received, and these updated measures will further reduce the overall environmental impacts during
both the construction and operation of the proposal.
Having regards to biophysical, economic and social considerations, including the principles of ecologically
sustainable development, the carrying out of the project is justified for the following reasons:
The built form and density proposed for the site in consistent with that approved Horsley Drive Business Park
Stage 2 under the Concept Plan Approval (SSDA 7664) and subsequent MOD approval;
The building is considerate of its surrounds and complements it setting through articulation of the built form and
sympathetic choice of good quality materials;
It has been demonstrated that the proposed works will result in minimal environmental impacts, all of which can
be managed or mitigated through the recommendations outlined in the relevant specialist reports;
The proposal involves the provision of approximately 45,305m2 of warehouse floorspace and will contribute to
achieving the anticipated employment growth for the Fairfield LGA, without a discernible impact on overall
capacities across the Greater Western Sydney region.
Given the merits described above it is requested that the application be approved.