Advocating Against Cemetery Construction
REJECT
DOUGLAS PARK CEMETERY AND CREMATORIUM
JULY 2026 UPDATE:
On 18 June 2026 the exhibition period for the State Significant Development application ended and the Department of Planning, Housing and Industry (DPHI) received 101 submissions, only one of which supported the cemetery (and it wasn't our resident wallaby here)
Endangered Gang Gang Cockatoo
Our excellent Minister, Judy Hannan, authored a comprehensive submission covering the many problems with the DA including traffic impacts, geological and hydrological site constraints, acoustic noise impacts, lack of European and Aboriginal heritage impact assessment, and potential for perceived bias in relation to the Social Impact Assessment, authored by a member of the Metropolitan Memorial Parks board. The Minister notes the "many site specific reasons including geology, geotechnical issues, natural landscapes (Nepean River) and ecological values on and surrounding the subject site" to disqualify any merit for the proposed crematorium. While intimating that crematoriums are better placed in industrially zoned areas, the Minister seeks clarification regarding the ability of a stand-alone crematorium to meet the definition of a State Significant Development, and that should it not, it will return to the Wollondilly Council for assessment. Importantly, the Wollondilly LPP did not authorise the use of the Site for a crematorium six years ago because of its incompatibility with RU2 zoning rural amenity objectives.
The Wollondilly Councillors and specialist staff have demonstrated, in their submission, a steadfast commitment to the objectives of planning instruments and protection of the environment and rural amenity. They have also submitted an extensive submission detailing all of the key issues about which they hold significant concerns including "environmental, ecological, wastewater, contamination and design issues". They have assessed the traffic study to be deficient and that impacts related to safety, the environment and rural amenity, together with non-compliance with relevant statutory requirements, lead them to formally oppose this development.
The NSW Department of Climate Change, Energy, the Environment and Water (DCCEEW) has identified, amongst other issues, the inadequacy of the developer's hydrological assessment in order that a confident decision can be made regarding the "separation between burial depths and groundwater levels...[and]... whether this separation can be achieved under all conditions including wetter periods or localised groundwater mounding...[and]...it is unclear how site works may affect water movement, and whether groundwater impact conclusions are consistent with the overall site water regime". Despite this, the DCCEEW decided a "post-approval" system of groundwater monitoring wells is a sufficient safeguard. Weighed against the Department of Primary Industries and Regional Development's assessment, that "the cumulative impacts of shallow groundwater intercepting burial plots...pose a high risk of sub-surface leachate transport into the adjacent Mitchell Place and potentially into the Nepean River catchment, local agricultural bores and irrigation dams", the DCCEEW's suggestion seems grossly inadequate. This system of post-approval promises resulted in the concept approval for the original cemetery. It is with relief that the DPHI stipulates in its Request for Further Information that any assurance plans be submitted "for a thorough review" before approval this time.
As stated above, the DPIRD noted that "Site investigations reveal a highly constrained geological profile, characterised by a shallow soil depth of generally less than two metres sitting directly above a low-permeability sandstone bedrock shelf...groundwater is less than one metre below the proposed burial depths in several zones of the site...[so that]...there is a high risk that the interred remains will interact with the water table...generat[ing] necro-leachate...that ha[s] a high potential for groundwater contamination." Further, it notes that "[t]he proponent's proposal to artificially increase soil depth via fill placement does not offer a viable mitigation strategy" and "[c]umulatively, these hydrogeological factors indicate a high baseline vulnerability and physical lack of suitability for this proposal at this site. "
On 8 July, the DPHI added to the portal their request for additional information which included, amongst other issues, the need for the developer to provide contemporary and accurate traffic flow information, this time including the vehicles arriving from the gorge and at times outside of the school holidays, as well as the likely origin of visitors, distance travelled and a comprehensive study of the effects on Douglas Park Drive. An assessment of the ability of the Douglas Park gorge to handle such increased traffic is also to be undertaken.
The Department notes the concerns of the Department of Primary Industries and Regional Development, The Water Assessments Team from the NSW Department of Climate Change, Energy, the Environment and Water and Wollondilly Council, regarding the "limited soil depths and shallow bed rock requiring significant excavation and fill to accommodate burial plots...[as well as]...[t]he potential for groundwater impacts arising from the development [being] evident."
Adequate attention is to be given to the "highly noise affected level" that will result from the construction of the cemetery, particularly the extent of rock breaking required. Clarification regarding the staging of construction is requested as it is unclear whether this noxious activity will be carried out over the life of the project.
MAY 2026 UPDATE:
The exhibition period has begun on 13th May 2026 and it is now time for the council and community to lodge submissions on the NSW Portal BEFORE THE 18th OF JUNE:
https://www.planningportal.nsw.gov.au/major-projects/projects/douglas-park-memorial-park-concept-plan-and-stage-1 or SCAN THE QR CODE BELOW.
Residents of Douglas Park and members of the Reject Douglas Park Cemetery and Crematorium group have been cognisant of the many obstacles to the proposal for many years now:
Numbers of deceased for the entire of Wollondilly Shire number between 200 and 300 per year, and these are well catered for. The developer is seeking clientele from all over Sydney to try to make the project viable. There is a strong belief that this will SHUT DOWN THE GORGE as navigation apps guide people over it as the fastest route to and from the Site, which is just at the top of the river causeway on Douglas Park Drive. The other route involves the already heavily congested Picton Road, also believed to be incapable of supporting funeral corteges which can involve hundreds of cars. Douglas Park is a small village of 1,300 people - a massive state facility will overshadow and define it, in an effort to cater for the Sydney Metropolitan area where burial space is ACTUALLY running out in the future. This is a very lucrative venture, generating huge profit at the expense of Douglas Park which will become known as the Cemetery Town. The developer appears to have emulated the marketing ploys of other cemetery proposals which profess to be providing "parklands" for the community to enjoy but Douglas Park already has the popular Nepean River and would prefer to keep it safe and unsullied by pollutants from a cemetery and crematorium above. Who would choose to travel to a graveyard, where people are grieving as their loved ones are being buried or cremated, to have a picnic or ride their bikes?
Six out of the ten guidelines set by Cemeteries and Crematories NSW are not met and should have cancelled the project when the developer devised it years ago after other attempts to develop the property failed due to lack of sewerage:
1/ adjacent to residences
2/ not easily accessible
3/ affected by Hume Highway noise
4/ is in high bushfire zone
5/ insufficent soil depth;
6/ contains critically endangered ecology;
Calling local knowledge and expertise
We know our community includes people with valuable experience and skills.
If you have a background in:
* environmental science or ecology
* engineering or geology
* traffic or transport planning
* emergency services or risk management
* planning, policy, or infrastructure
Your knowledge could make a difference!.
Even a short contribution, perspective or review can help.
You don't need to be an expert to participate! Contact us on our facebook page and we can arrange private messaging: https://www.facebook.com/groups/2577682095581395/
What does this Development Mean for Douglas Park and Wilton ?
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Disposal of thousands of dead bodies into a sandstone rock shelf and sustained crematorium pollution threatening our river ecology. The federal government has declared the project a "controlled action" meaning it will be undertake special scrutiny for approval because of the critically endangered Shale Sandstone Transition Forest and Cumberland Plain Woodland
In 2020, a Local Planning Panel appeared to disregard the pleas of the community and their council representatives, by passing a "concept" for a cemetery servicing the local area. This opened the door for the developer to expand the project into a huge state facility. However, it was noted in the LPP decision that "to ensure the development and associated activities/operation are acceptable in terms of the amenity of the neighbourhood and the public interest...this consent does not authorise the use of the site for a crematorium."
(Wollondilly Shire LPP meeting 28/05/20)
By the proponent's own admission:
"Utilising the existing approval on the site is not viable nor does it establish a sustainable business model for the cemetery." (Scoping Report 29/02/24 Strategic Context 2.1)
It is unfair to burden the Douglas Park community in order to improve a developer's "business model"?
* 7-days-a-week, 6am to 6pm funeral and cremation services and processions. The majority of clientele has been secured from areas all over metropolitan Sydney which may SHUT DOWN THE GORGE and further block the Picton Road and M31 interchange
* Our little country village will be overshadowed and defined by a huge, state significant funeral facility
Why is the Community Angry ?
Four years ago, following community outrage, a cemetery DA for 430-490 Douglas Park Drive, was referred to a Local Planning Panel to consider. Taking advantage of Covid lockdowns, community consultation was online and very brief; the very troublesome facets of the proposal seemed to be glossed over, and approval for a cemetery "concept" was granted for land where "the depth of soil is significantly too little over the whole site" (Red Earth Geosciences 25/09/18) for cemetery development. It was decided that pulverising multiple hectares of a sandstone rockshelf right beside residents and the Nepean River is a tolerable use of the Wollondilly landscape in order to accommodate 27,000 dead bodies. The developer immediately put the block on the market for 20 million dollars but failure to sell it has resulted in the size of the DA being trippled and a crematorium added, elevating it to the State Government for consideration. Rate-paying residents are unable to compete with expensive consultancy firms that appear to diminish and dilute the many obstacles with this location. A system which allows those obstacles to be dealt with at later stages of a DA's implementation should not be permitted when that proposal is problematic, offensive, potentially toxic, and met with fierce and unrelenting objection from community and councillors alike. Our MP, Judy Hannan, has been of enormous assistance introducing a notice of motion that saw the Mayor and councillors vote unanimously to ensure that the State Planning Panel are well informed of the fatal lack of soil, sewerage, adequate drainage, road infrastructure, community and council support, or market for a facility of this nature, in this location.
The Site is located above the Nepean River with residential properties in between. Climate change has caused a big increase in intense weather events with stormwater over flow from the Site gushing through four tributaries to the river below. The community is very concerned about the polluting effects a state wide cemetery and crematorium will have on the health and safety of the river ecology.
Flooding on Site
Audio
Across the road
Through properties
through the gullies
and into the river
Reality is different from
promises made...
On the developer's website, the promise BEFORE approval is granted, is to provide a "sanctuary" that will "minimise any impacts on biodiversity..."
However, THIS is the image the developer chose to use to advertise on the Sydney property market immediately after the original "concept approval" passed:
BIG difference !!
Access is a huge problem...
Many of the directions from which to travel to the proposed site involve travelling over either the Douglas Park or Appin causeways - both of which are very narrow, winding, one-way in some sections, and subject to flooding and rockfalls. The council has installed portable traffic lights to manage the one-way section of the Douglas Park Gorge and is attempting to raise millions of dollars for the necessary repair to this essential thoroughfare for the community. This is not expected to be completed before 2031 and is dependant upon the requisite funding being raised or granted.
The 28 May 2020 LPP minutes included the claim that visitors may be encouraged not to travel over causeways with measures that "largely involve notifying vistors of access arrangements prior to attending the site through website notices, management plans and the like" A marketing representative admitted that they "can't control google" when challenged with the certainty that GPS services would, indeed, direct visitors over Douglas Park Gorge as the fastest travel route to and from the Site from many locations, increasing car numbers on the causeway by hundreds of vehicles a day.
Welcome visitors to your site with a short, engaging introduction.
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From the Council...
Deputy Mayor Matt Deeth: "...there are significant infrastructure issues that are unresolved and I hope that the planning panel that will be assessing this will certainly take all of that into consideration because there is no way we could possibly have that style of cemetery in that position without significant impacts on our community out there...the Douglas Park Drive down to the gorge is not satisfactory for traffic right now and needs significant investment, we are talking millions of dollars and you know that...is just not going to be done in time for this"
Councillor Briggs: "...my belief is that if [Transport NSW] are not aware of it I think it would probably hit a wall as soon as they became aware of it...those roads are not capable of dealing with significant amounts of traffic..."
Councillor Rogers: "...even if they don't go through the gorge they are going to have to come up to Picton Road... Anyone who has been on Picton Road in recent times, and it doesn't matter which way you turn, whether you turn back to Menangle Road or in through Wilton, we have got all sorts of issues with the Almond Street overpass, all these other issues, it's really interesting that the State Government have a vision zero for road toll. This would proably increase the road toll..." (Wollondilly Shire Council Meeting 23/04/24)
Bodies Buried in Sandstone Rock!
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From the Red Earth Geosciences Site assessment:
"The Site has insufficient soil depth over its entire surface in order that a conventional cemetery can be developed. Residual soil depths are typically 0.7-0.9 metres deep and variously overlay weathered sandstone bedrock. The most weathered bedrock at the Site is of highly variable form and thickness and because of its nature (being jointed Hawkesbury Sandstone which has potentially been subject to micro-fracturing due to mine subsidence) should not be relied upon to provide adequate cemetery function." (Dent, Boyd B. Red Earth Geosciences, Preliminary Review Study and Site Assessment 25/09/18)
The May 2020 LPP meeting:
"As the ripping of rocks will result in deceased persons literally being laid on top of a rock layer, it is recommended that groundwater wells are placed in strategic locations, and regularly monitored to ensure that there is no migration of body exudates along the rock platform and offsite." (emphasis added)
Burying bodies in sandstone rock
From the Council...
Councillor Suzy Brandstater:
" ...it comes down, to me, as absolute environmental vandalism...it is huge and it is going to destroy the environment and it is so close to the waterways..." (Wollondilly Shire Council Meeting 23/04/24)
Mayor Matt Gould:
"...I hope that we can stop it because it is a terrible, terrible idea in pretty much solid rock which is a terrible place to put a cemetery to begin with." (Wollondilly Shire Council Meeting 23/04/24)
Indigenous Heritage
Cubbitch Barta:
"I do not agree with the assessment for Cultural reasons. We were not included in this assessment, and would have provided a Cultural perspective rather than just the perspective that was given...The geo tech testing only proved that there is a soil deposit that has the potential to contain sub-surface materials. It also proves that it is not a good spot for burials, as the rock layer is quite shallow, making it unsuitable for burials. For Cultural reasons, it is an unsuitable location for burials and if this project is to proceed then it should have a full Aboriginal Cultural Heritage Assessment." (LPP meeting minutes13/02/20)
The site is within a study area which "is dominated by surface and sub-surface artefactual material generally found within 200m of the larger river systems within the region. Distances of sites up to 500m away are documented...[and]...there is high potential for Aboriginal objects/site to occur along the banks of the Nepean...River(s)". (AHMS report for GMIA by DP&E, 2017)
From our MP, Judy Hannan: "...there is a site test for Cemeteries and Crematories in NSW and none of this proposal actually sits well in those criteria...it is opposite a residential area. It's poor access and it's from both directions...we inter 54 locals a year or something, so these 80,000 people that are being interred are not going to come knowing what the local roads are like. There is drainage issues and it all drains down to the Nepean River...we have insufficient soil depth. They are going to rip the rocks, I don't know if they blast first, to a depth of three metres to be able to actually allow burials and the Site has potential Aboriginal and Cultural heritage significance and probably some flora and fauna as well...the people of Douglas Park need to know that this council is standing firm with them, not only on what
the concept plan that was
approved but the State
Significant, so both things,
our council will say are
unacceptable for us."
A last word from our most important residents...
Audio
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Don't forget to lodge your objection submission on the NSW portal by 9th June 2026:
and lobby your local representatives:
matt.gould@wollondilly.nsw.gov.au