Dear Friends,
This may be of interest to you in one way or another
Submission on Lot 4128 121 Amy Johnson Drive D/A Crematorium
From: Margaret Clinch
Date: 31 January 2009 2:57:29 AM
To: das.dpi@nt.gov.au
Subject: Submission on Lot 4128(121 Amy Johnson Drive D/A Crematorium
PLan: the Planning Action Network, Inc
PO Box 2513, Darwin, NT 0801
The Manager,
Development Assessment Services,
Department of Planning,
PO Box 1680,
Darwin, NT 0801
Lot 4128(Town of Bagot)
121 Amy Johnson Drive, Marrara
Dear Sir/Madam,
Our organisation is entirely opposed to the siting of a new crematorium in the Northern suburbs, or in the CBD. If there is a need for a new facility it should be located at the Thorak Cemetery.
We are also aware of strong and well researched opposition from residents in the Northern suburbs. Not all of those concerned public will be able to respond in terms of a written submission. This reaction should not be underestimated.
We make the following points:
1. The land is zoned for COMMUNITY PURPOSES. The schedule does not mention crematoriums at all. Even light industry is a prohibited use. The land is situated in an established suburban area.
2. Actual land use in this zone, in this area, consists of various community clubs, built up gradually over many years based on a combination of government and community effort, and an independent school, similarly built up over years of community effort. Across the road is a main residential area, established in the aftermath of Cyclone Tracy.
3. Building a crematorium in an established residential suburban area, amongst established family homes, is a different situation from suburbs spreading out around an existing crematorium. Homes are the major investment for most people, and a crematorium would be expected to reduce the attractiveness and value of properties in the area.
4. The commercial proponent is presuming that an extension, including a crematorium, is acceptable in the zone. However the proposed crematorium is a completely different land use from the functions currently performed in the existing buildings. Zoning principles mean that different functions within a business must be assessed according to appropriateness for the site.
5. Most people view crematoriums as an unpleasant reminder of death, and sad experiences. They should be out of sight, and only visited when essential. This how they are sited in cities like Sydney and Canberra. Those working in the industry may possibly not be sensitized to this. If the logic is that all a business’ functions should be together, then why not in Woods Street, in the CBD. This proposal is just as wrong.
6. This application makes reference to an “approval” by the former Minister for Local Government, subject to final approval by the DCA. Inclusion of a copy of the approval looks highly prejudicial.
On what was this “approval” based ? How can an unbiassed assessment be made when the DCA does not know what was involved in it.
In some ways a new crematorium may be a good thing, but the DCA needs to know what the criteria were, who was consulted, and how the decision was made. The public, which is most affected, certainly does not know, and is rejecting the proposed siting.
7. Similarly, we are told that no environmental assessment of the present and future impact of the crematorium is required. On what basis was that decision made, and by what process ? The public are fearful about emissions pollution, present and future, especially as this is an area where young children play. States and territories have environmental guidelines for crematoriums.
The ACT lists the crematorium as one of its four pollution emitters.
More information relevant from:
(www.environmentcommissioner.act.gov.au/soe/2003actreport/indicators03/airemissions03)
www.brisbane.qld.gov.au/bccwr/environment/documents/crematoria operators.pdf.
www.oseh.umich.edu/OSEH%20Presentations/Air%Presentation2003.pdf
8. Questions need answering about hazardous emissions from chemicals such as formaldehyde (Ref. National Pollutant Inventory), and from chrome and mercury in incinerated bodies.
9. The DCA is required to take matters covered by the clauses of Section 51 of the Planning Act into account.
Particularly relevant here are:
Clauses (d) (g) (n) (p) (r) and we require specific and impartial responses on these in the matter of the application.
10. There are several specific questions about the handling of emissions.
What is the permitted height of the chimney ?
Is the proposed chimney tall enough to disperse hazardous emissions ?
What is the purpose of the grill ?
Is a grill sufficient to deal with sub – particulate matter ?
What is the cumulative effect of emissions pollution ?
What are the prevailing winds ?
11. Are there power considerations to be addressed in the operation of the crematorium in the Northern suburbs which already has its electric generation and distribution systems stressed ?
12. We are concerned about the impact of depending on one commercial firm to provide a crematorium. Does this mean that other firms will need to build and operate further crematoriums ?
CONCLUSIONS
It is our view that building a crematorium on the proposed site is not in the public interest. There are too many uncertainties about pollution close to established living areas.
The amenity of the area will be changed regardless of immediate landscaping.
One option would be to lease land at Thorak Cemetery for a crematorium, perhaps with tenders, and a condition that the facility be shared. Another option might be to upgrade the existing facility.
Concentrating the incinerator function at Thorak would have basic advantages:
The amenity of the Northern suburbs would not be adversely affected.
The community purposes zoning would remain in tact.
The facilities could be shared, even on a contract basis.
Pollution would not be funnelled into residential and school areas.
With Thorak was zoned for all potential crematoriums, emissions pollution could be more efficiently managed and monitored.
The facility would be better placed to serve the various local government areas.
Yours sincerely
M A CLINCH
Convener
30.1.2009