The Morebank Intermodal Export (IMEX) development includes the construction of an intermodal freight terminal, a number of state and interstate rail links, multiple warehouses and road entry and exit points. Fulton Hogan Construction was required to perform a number of utility service termination and diversions on behalf of Telstra, Sydney Water and EssentialEnergy.

The challenge

Fulton Hogan approached Circulr for assistance with an urgent and critical approvals issue. The existing EIS approval for the overall project did not permit the installation of utilities, which fell to the responsibility of the contractor.

Various structures of cultural heritage significance were identified at the site, and while the majority had been relocated, the heritage registers had not yet been updated. This meant navigating the planning approvals was particularly difficult.

The solution

We investigated approval requirements for the utility works under the Commonwealth Telecommunications Act 1997 and local and state planning instruments.
We identified and advised on the appropriate approval pathway through the legislation relating to EIS approval.
We developed a Review of Environmental Factors and Construction Environmental Management Plan.


After a period of ‘tools down’, Fulton Hogan were able to commence the telecommunications and other utilities works, some of which were found to be exempt from planning approval requirements. This meant we were able to save Fulton Hogan a significant investment of unnecessary costs and time on the project.

Fulton Hogan went from not knowing how to proceed in a state of urgency, to having clarity and pushing forward within a matter of weeks.

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