Moorebank Intermodal Terminal

Those interested in a non-government assessment of the Moorebank Intermodal Terminal proposal are encouraged to read this report immediately.

In December 2015, the NSW Department of Planning and Environment (DPE) recommended to the NSW Planning Assessment Commission (the Commission) approval of an application by Moorebank Intermodal Terminal Company (MIC) for an intermodal terminal at Moorebank with capacity of 1.55 million containers (TEU) per year. The proposal is for 1.05 million containers (TEU) per year to be railed between Port Botany and Moorebank and 0.5 million containers per year to be railed between regional areas of NSW and Moorebank.

The Moorebank intermodal terminal proposal is founded upon adequate capacity in the rail network between Port Botany and Moorebank. As this does not currently exist and there are no government or private commitments to create this capacity, there can be no approval of this proposal. Additionally, the proposal is founded on removing 3000 container truck movements per day from the M5 between Port Botany and Moorebank. Should the proposal proceed, container truck movements on the M5 are estimated to increase from 2700 per day in 2014 to 6900 – 9900 per day in 2045.

In 2014, there were 2.3 million container (TEU) movements through Port Botany. The land transportation of these containers was 2 million carried by truck and 0.3 million carried by rail (NSW Ports). The average number of containers carried per truck was 1.93 TEU as at September 2013. There were 1 million container truck movements in 2014, averaging 2700 per day.

NSW Ports estimates that in 2045, Port Botany container throughput could reach 8.4 million, with land transport comprising 5.4 million carried by truck and 3 million carried by rail.

NSW Ports has as an objective to rail 3 million containers (TEU) between Port Botany and sundry intermodal terminals by 2045. NSW Ports has not demonstrated how this increase will be accomplished and the source(s) of funds for major projects. These include: building the Western Sydney Freight Line at an estimated cost of $1 billion; building a second rail freight line between Port Botany and Mascot; building improvements to the Southern Sydney Freight Line (SSFL); and, linking Port Botany to the proposed WestConnex motorway, including a dedicated truck lane.

The Moorebank intermodal terminal proposal relies completely on availability of rail freight capacity between Port Botany and Moorebank. Existing capacity is inadequate because the Port Botany rail freight line connects to the SSFL and NSW Ports estimates the existing capacity of the Port Botany rail freight line to be 1 million containers per year “based on realistic productivity levels”. The capacity of the line may be less than that claimed by NSW Ports. NSW Ports further identifies a need to increase capacity of the SSFL to cater for the growth of the Moorebank intermodal terminal proposal.

NSW Ports page 52:

The existing rail infrastructure at Port Botany has capability to handle one million TEU based on realistic productivity levels. Allocation of additional equipment and labour to rail operations, together with the required improvement in rail operation performance, will allow this capacity to be realised.

… Capacity improvements on rail beyond the Enfield Intermodal Logistics Centre, for example passing loops near Warwick Farm on the Southern Sydney Freight Line, will also be required to cater for the growth of the Moorebank Intermodal Terminal and future intermodal terminals in western Sydney.

In its recommendation to the Commission, DPE said (page 31):

Additionally, the Department is satisfied that there is sufficient capacity available on the SSFL to accommodate the proposal.

There is not sufficient rail freight capacity available to accommodate the Moorebank intermodal terminal proposal.

Rail freight capacity was a primary issue when the NSW Department of Planning approved expansion of Port Botany in 2005. Matters concerning the Department were reported by the Sydney Morning Herald on 18 February 2005:

Expanded cargo terminal too big, say planners

By Darren Goodsir, Urban Affairs Editor
Sydney Morning Herald February 18, 2005

The state’s top planners have cast adrift an ambitious plan to massively expand cargo facilities at the Port Botany container terminal – arguing its size should be reduced by 25 per cent to avoid traffic gridlock.

The Sydney Ports Corporation is arguing at a commission of inquiry for a 63-hectare boost to the existing terminal, which it claims would allow 3.2 million container movements a year by 2025.

This would increase the size of the stretched cargo area by nearly 30 per cent – with a potential impact on air-traffic control radars.

But the Department of Infrastructure, Planning and Natural Resources has been spooked by predictions by the stevedores Patrick Corp and P&O that the expansion could lead to 8 million container movements a year. In a reversal, the department said yesterday it would only support a 47-hectare expansion, and that it should be built in stages.

In a last-minute submission to the commission of inquiry, the department said the foreshore area should also be reduced by 70 metres – widening the mouth of the nearby Penrhyn Estuary and improving tidal flows.

It said a smaller terminal expansion would still allow a third player to enter the freight market, and also allow planners enough time to gauge the impact of increased traffic.

Under the department’s plans, a proposed fifth berth would be put on hold, and only approved after another detailed environmental analysis. The submission, presented to Commissioner Kevin Cleland, argues that “any increase in container throughput over and above 3.2 million … must therefore be the subject of a further environmental assessment”. This was “to ensure that such throughput can be accommodated on the surrounding road and rail networks and beyond”.

Last year the Herald revealed leaked cabinet papers showing that, even if incentives were provided to increase rail freight, semitrailer movements would leap by 300 per cent by 2021, clogging all road arteries near Sydney airport.

In response, the Planning Minister, Craig Knowles, raised the prospect of a levy of up to $30 per container being placed on freight vehicle movements to encourage more rail freight. He set a target of doubling to 40 per cent the proportion of cargo carried by train within six years. Mr Knowles also created a new body, chaired by the former Labor politician Laurie Brereton, to look at ways to accommodate the increased traffic.

First opened in 1976, Port Botany currently has 1.2 million container movements a year, with movements rising by about 7 per cent a year.

In earlier evidence yesterday, Patrick’s managing director, Chris Corrigan, rubbished the Carr Government’s embryonic freight strategy. He said plans to establish a rail-truck interchange at Enfield, only 18 kilometres from the port, were questionable. It made more sense to create a facility further away, on the city’s outskirts, to improve costs and efficiencies.

Mr Corrigan has been frustrated in his attempts to build a large transfer station on Sydney’s south-western fringes, at Ingleburn, which is in Mr Knowles’s electorate. After a series of bitterly contested court battles, the matter has again gone to the Land and Environment Court for a decision.

However, Mr Corrigan said yesterday he supported the planned construction of a freight-only rail line from the port, saying it would be enough to tilt the balance more favourably to rail freight.

On 13 October 2005, the Minister for Planning, The Hon. Frank Sartor MP, approved a $1 billion expansion of Port Botany. A container throughput cap of 3.2 million per year was imposed under the “Port Botany Determination”:

[Section A1.4] Port throughput capacity generated by operations in accordance with this consent shall be consistent with the limits specified in the EIS, that is, a maximum throughput capacity at the terminal of 1.6 million TEUs per annum and a total throughput at Port Botany of 3.2 million TEUs. These limits may not be exceeded by the development without further environmental assessment and approval. Sydney Ports Corporation shall prepare, or have prepared on its behalf, such further environmental assessment for the determination of the Minister.

The limits on expansion specified in the 2005 conditions of approval were abolished by the government in 2012 prior to the port being leased to NSW Ports on 12 April 2013.

“Further environmental assessment” will not be conducted for expanding container throughput beyond 3.2 million containers per year.

An environmental assessment will be provided as part of the EIS for stage 2 works of the Moorebank intermodal terminal proposal. This EIS will include an assessment of demand distribution and capacity within the freight network.

DPE page 30:

An assessment of demand distribution and capacity within the freight network would be provided as part of the EIS for stage 2 works.

It is not possible to provide “an assessment of demand distribution and capacity within the freight network” as part of an EIS without including works required to increase rail freight capacity at Port Botany.

The government’s treatment of the Moorebank intermodal terminal proposal is incompatible with the government having abolished a requirement for environmental assessment of expanding Port Botany capacity beyond 3.2 million containers per year.

The Moorebank intermodal terminal proposal requires 45 train paths per day on the SSFL. At present, there are 16 train paths on the Port Botany rail freight line.

DPE page 30:

The Applicant has stated that at full operation, 317 train movements per week (45 per day) would use the rail link connecting the site to the SSFL. This would require 45 train paths to be available on the SSFL being 22.5 movements each way (on average). The EIS explains that the SSFL has capacity constraints that may influence the number of trains being able to access the site per day and that consultation would continue to occur between the Applicant, ARTC, TfNSW and other stakeholders on the rail freight network. An assessment of demand distribution and capacity within the freight network would be provided as part of the EIS for stage 2 works.

NSW Ports page 52:

Moving three million TEU per year by rail will require up to 56 port shuttle trains over a 24 hour period arriving and departing the Port via the Port Botany Freight Line. Currently about 16 trains per day use this line.

We understand from work conducted by ARTC that the Port Botany Freight Line will have capacity to cater for the forecast port shuttle volumes once the line has been duplicated between Port Botany and Mascot and operational improvements on the line have been implemented.

NSW Ports page 5:

Increasing the movement of containers by rail to and from Port Botany will assist the Port to maximise its throughput capacity. In this way, forecast container growth can be accommodated in a cost-effective, efficient and sustainable manner. We have set a target to move three million TEU per year by rail by 2045. Achieving this target requires action by all stakeholders involved in the container rail supply chain. The operation of intermodal terminals will be essential for achieving this target. The Enfield Intermodal Logistics Centre and Cooks River Intermodal Terminal will be part of this solution, with both being inland extensions to Port Botany.

NSW Ports page 57:

Port Botany is serviced by trains from the Cooks River, Minto and Yennora intermodal terminals and, from 2015, intermodal terminals at Chullora and Enfield.

Collectively, these intermodal terminals do not have sufficient capacity to meet the forecast freight task. Future intermodal terminals at Moorebank, Eastern Creek and Badgerys Creek, all with dedicated freight rail access, will be critical to meeting future rail demand.

In relation to road transportation, 6 per cent of container trucks use the M5 at Moorebank (NSW Bureau of Transport Statistics, February 2014 Release, Heavy Commercial Vehicle Forecasts for the Sydney Greater Metropolitan Area). The Moorebank intermodal terminal proposal will reduce container truck movements on the M5 at Moorebank by 162 per day (6 per cent of 2700).

MIC estimated that 5522 heavy vehicle movements per day would be generated by the proposed intermodal terminal and approximately 3000 heavy vehicles per day would be removed from the M5 Motorway between Moorebank Avenue and Port Botany (DPE, page 22). The reduction in container truck movements at Moorebank is not 3000 per day it is 162 per day. The net increase in heavy vehicle movements at Moorebank is 5360 per day with the intermodal terminal proposal.

In addition, the Moorebank intermodal terminal proposal will increase passenger vehicle trips by 5724 per day. Road congestion at Moorebank, already severe, is forecast to significantly increase over the next 20 years, due to natural growth. The proposed intermodal terminal will add to future road congestion, with less road capacity than Port Botany. At the same time, road congestion at Port Botany will worsen because container truck movements are estimated to increase from 2700 per day to between 6900 and 9900 per day in 2045.

Container trucks are a significant user of the M5 East tunnels. The (former) RTA reported that a container truck using the M5 East westbound tunnel is the equivalent of six passenger cars and the equivalent of three passenger cars using the eastbound tunnel.

Container trucks are 2 per cent of vehicle use on the M5 East (NSW Ports). This equates to 6 per cent of capacity in the westbound tunnel and 3 per cent of capacity in the eastbound tunnel. For many years these tunnels have been operating at more than rated capacity. In 2045, when container trucks will require 4 per cent of M5 East capacity, this will equate to 12 per cent of the westbound tunnel and 6 per cent of the eastbound tunnel.

Expansion of container throughput at Port Botany will further intrude into the “Obstacle Limitation Surface” (OLS) at Sydney Airport. Intrusions will occur due to bigger cranes, bigger ships, more trucks and more trains. Approvals will be required from government for these additional intrusions. NSW Ports discloses that it does not “foresee” penetration of critical protection surfaces associated with the “Procedures for Air Navigation Services – Aircraft Operations (PANS-OPS)”.

NSW Ports page 55.

Port Botany is located close to Sydney Airport. Port operations and developments must consider the regulatory environment related to airport operations. All current quay cranes at Port Botany have appropriate approvals in place to intrude into Sydney Airport’s protected airspace known as the Obstacle Limitation Surface (OLS).

For the Port to accommodate forecast container trade growth and for port operations to remain cost effective and competitive, there will be a need to install more, and in some cases higher, quay cranes. Future vessels, depending on their physical height, their loading utilisation and the tidal levels, may also intrude into the OLS when operating in the Port’s navigational areas.

We therefore foresee further intrusions into the OLS but no penetration of the critical protection surfaces associated with the Procedures for Air Navigation Services – Aircraft Operations (PANS-OPS).

We will work with Sydney Airport, stevedores, Commonwealth aviation authorities and the Port Authority of NSW to address interface issues relating to larger vessels and quay cranes. Appropriate aeronautical assessments will be undertaken and approvals sought to ensure that the port and airport can jointly grow to their full potential supporting the Sydney and NSW economy.

Trucks travelling around Sydney Airport on Qantas Drive and trains on the Port Botany Freight Line currently penetrate the OLS. With growth in both truck and train volumes required, we will work with government and airport stakeholders in relation to interface issues.

In relation to intermodal terminal capacity, NSW Ports discloses that there is insufficient capacity to meet the forecast rail task and “future intermodal terminals at Moorebank, Eastern Creek and Badgerys Creek, all with dedicated freight rail access, will be critical to meeting future rail demand”.

NSW Ports page 58:

The transportation of containers by rail to the Enfield Intermodal Logistics Centre is cost competitive against road transportation within a catchment extending from Enfield, west to Penrith, north to Baulkham Hills and south to Campbelltown. Currently 430,000 TEU have been estimated as being contestable for rail transport via Enfield and this is forecast to grow to 1.7 million TEU by 2045.

NSW Ports page 61:

The Cooks River Intermodal Terminal has eight sidings with a total length of 4.5 kilometres. It currently handles 330,000 TEU per year, which could increase to about 500,000 TEU subject to some site reconfiguration, increased use of port shuttle trains and optimisation of the average container storage time on site.

NSW Ports estimates that intermodal terminals at Enfield and Cooks River will have combined capacity for 2.2 million containers. Railing containers to these terminals leaves only 0.8 million rail capacity available for all other terminals, assuming rail capacity of 3 million is attained in 2045.

Container throughput at Enfield of 1.7 million will require about 850,000 truck movements per year. At Cooks River, container throughput of 500,000 will require around 250,000 truck movements. Transferring truck movements from Port Botany to these two locations by using rail capacity would defeat the purpose of using rail.

Although an EIS is required for increasing heavy vehicle movements at Moorebank, no EIS is required for increasing heavy vehicle movements at Enfield or Cooks River by the significant additional amounts disclosed by NSW Ports.

Intermodal terminals at Eastern Creek and Badgery’s Creek will require building the Western Sydney Freight Line, between Chullora and Eastern Creek, costing around $1 billion. There are no funds allocated for building this line. Furthermore, there are no funds allocated for a new freight line between Port Botany and Mascot, or for improvements to the SSFL.

The economics of a $1 billion investment in the Western Sydney Freight Line would be maximised, obviously, by railing 3 million containers to intermodal terminals, at locations such as Eastern Creek and Badgery’s Creek. However, railing 1.05 million containers to Moorebank and up to 2.2 million containers to Enfield/Cooks River would mean not building the Western Sydney Freight Line, due to lack of capacity, should the 3 million capacity of the Port Botany Line be used for other locations.

It is possible to rail 100 per cent of containers to intermodal terminals at Eastern Creek and Badgery’s Creek. This is accomplished by building a rail freight bypass of Sydney, between Glenfield and the Port of Newcastle, and building a container terminal at the Newcastle port. The southern section of this line – between Glenfield, Eastern Creek and Badgery’s Creek  – would be built first to enable use of existing Port Botany rail capacity of up to 1 million containers per year. A container terminal at the Port of Newcastle would also reduce Port Botany container throughput by around 25 per cent by servicing the northern NSW market. Once the bypass line was completed, freight would be removed from the Sydney rail network. An intermodal terminal would be built at Eastern Creek, not Moorebank.