Advocating Against Cemetery Construction

REJECT
DOUGLAS PARK CEMETERY AND CREMATORIUM
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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 9TH OF JUNE:
https://www.planningportal.nsw.gov.au/major-projects/projects/douglas-park-memorial-park-concept-plan-and-stage-1
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:
* 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;
* there is a very high likelihood it will cause the Nepean River gorge to shut down and further congest the already severe peak-hour bottleneck of the Picton Road/M31 interchange. Most clientele have been sourced from the Sydney metropolitan area over forty kilometres away and GPS services will guide them over the gorge as the fastest route, potentially one hundred cars for each of the referenced six services a day, arriving and leaving at the same time.
* the soil depths over the entire site fall far short of the required depth to ensure 900mm between top of coffin and surface. The developer has to crush hectares of sandstone rock to manufacture the bare minimum but that still places thousands of cadavers on top of a rock shelf that has been subject to micro fracturing from mine subsidence. This will logically be made worse by extensive excavation and cause decomposing body remains to leach into tributaries and aquifiers and ultimately the Nepean River.
* Crematoriums are highly emitting toxic facilities that should be carefully and intentionally located well away from residences, home to small children, the ill and elderly, as well as endangered ecologies and a 70m elevation drop may well cause pollution to settle in the river and village valley
* Marketing the facility as a "park" for locals to enjoy is a misleading and cynical ploy in our opinion. Residents already have the river banks to enjoy a swim and canoe ride and prefer to retain this location as a pollution-free venue over a fantastical suggestion that riding a bike around a graveyard and crematorium is in any way a desirable substitute.
* There is no public transport which disadvantages large sectors of the population without access to a private vehicle. The suggestion that shuttle buses from the nearest train stations is not viable as there is a 3-tonne limit on the gorge and Picton train station is 14 kilometres away on the other side of the congested interchange. References to orbital 2 are also invalid as it is multiple years away with funding yet to be allocated. "Not in my lifetime" was the estimation of the Minister.
* Alarmingly, the Social Impact Assessment has been authored by a board member of the Metropolitan Memorial Parks, an organisation whose aim aligns with that of the proponent, who has engaged her services for this development. This represents an irreconcilable conflict of interest, in our opinion, evidenced in the perceived positive impacts for stakeholders from far afield, over the devastation felt by local residents, summarised as "somewhat emotional" and arising from "general superstition". This contribution is entirely at odds with the Social Impact Assessment Guideline for State Significant Projects and it is our fervent view that a severe injustice would be visited upon the tax-paying residents of the region if it is permitted to persuade consenting authorities.
* The only real justification relied upon for the development is the oft-quoted findings of the 2021 11th Hour Report which outlines a modelled shortfall in burial capacity for Sydney Metropolitan areas, specifically, Central Sydney, Northern Sydney, the Eastern Suburbs, and then Southern Sydney in that order. The Minister for Wollondilly has referenced an interment figure of approximatley 54 for our region per year, a figure well-catered for with our own facilities. This rural, remote and difficult-to-access Site is simply the wrong location, on all possible measures, to solve any future problems experienced in the city of Sydney.
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 demonstrated gross negligence, in our opinion, by ignoring the pleas of the community and their council representatiaves, and passing a "concept" for what they supposedly assumed would be a small cemetery servicing the local area. This mistake has opened the door for the developer to expand the project into a huge state facility. However, a condition was imposed on the developer for the original DA 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)
Nothing has changed in this regard except the perception of the viability of the project, 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)
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Why should Douglas Park residents suffer to improve a developer's "business model"?
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* 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 will 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 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 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.
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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)
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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