Beaches Link and Gore Hill Freeway Connection

BEACHES LINK TUNNEL Project ID SSI- 8862 - EIS SUBMISSION by John Berry -CHAPTER 15 ABORIGINAL CULTURAL HERITAGE

INTRODUCTION
The lower north shore area of Sydney area has a rich indigenous heritage dating back 4500. There is evidence of Aboriginal occupation throughout the study area. Aboriginal occupation focused on accessing resources from diverse ecological areas, seasons and conditions. Occupation sites, hunting, travel and inter-clan contact would have been associated with coastal areas, smaller rivers, creeks and swamps. Aboriginal people have left us with a rich cultural heritage, both tangible and intangible, which needs to be preserved. (1)

OBJECTION
I object to the potential damage or destruction to known and unknow Aboriginal cultural heritage within the construction footprint of the Beaches Link Tunnel project
The EIS identifies several know Aboriginal sites in the study area, within 50 metres of the construction zone ranging in significance from "low' to "moderate high". (2)

THE PROBLEM
The EIS states that the potential risk of damage to know terrestrial Aboriginal as "negligible". (3)
However large construction projects can be unpredictable. For example, during the construction of the Lane Cove Tunnel there was an unplanned partial collapse of a unit building which had to be demolished. A similar fate could await known (and unknown) Aboriginal heritage sites.

The construction zone can vary post EIS approval depending on problems and constraints encountered by engineers of the construction company. For example, tunnel depths, tunnel routes and dive site locations can all be altered post EIS approval.

Even minor variations to these could put know terrestrial Aboriginal sites at greater risk of damage or destruction.

RECOMMENDATIONS:
The potential for destruction or damage to significant aboriginal cultural heritage would be unacceptable to the community (particularly in light of recent destruction of aboriginal heritage by mining companies and others).

1)The project should be modified so that there is no risk to known Aboriginal heritage sites.
2) Management recommendations Section 9, Appendix L Pg 74 should be made a condition of consent.

3. Archaeological monitoring during construction by qualified archaeologists specialising in Aboriginal cultural heritage should be a codition of consentpresent. The proposed training of construction staff in cultural and heritage awareness alone would be grossly inadequate. (4)

If unexpected finds are located during works, an archaeological consultant should be engaged to assess the significance of the finds and the NSW Aboriginal Heritage office notified.

4) Real time vibration monitoring of known aboriginal sites should take place and construction should cease in the event that damage is detected so that it can be accessed by a qualified archaeological consultant.


5) Any variation to the EIS sought by the construction company once the EIS has been approved should not be granted until the risk to known and potential Aboriginal heritage has been reassessed by engineers and archaeologists.

OBJECTION
I object to the potential damage or destruction of unknown but highly probable terrestrial and submerged Aboriginal sites in the study area.

THE PROBLEM
The EIS acknowledges the likely existence of unknown Aboriginal sites - which could be damaged or destroyed by the project and it would be very difficult to mitigate against damage or destruction of these unknown sites. (5)
The EIS identifies several areas in the study area with the potential for Aboriginal sites “The lower North Shore portion of the study area includes several parks and reserves including St Leonards Park, ANZAC Park, Cammeray Golf Course, Artarmon Park and Artarmon Reserve, as well as the Flat Rock Reserve and the surrounding alluvial terraces and exposed sandstone outcrops. These parks and reserves have been subject to less intensive disturbance and may have increased potential for Aboriginal sites.” (6)
Destruction of unknown aboriginal heritage at these and other sites cannot be ruled out.
The study area is likely to have undiscovered submerged Aboriginal archaeology. "The pronounced rock outcrops at about 20 metres depth close to Seaforth Bluff are considered to have moderate to high potential for the presence and survival of inundated rock shelters. The possibility of unindated rock shelters requires further investigation and rock shelters at Seaforth be protected from damage or destruction. There is a moderate to high potential for submerged aboriginal heritage at Pearl Bay (west of Spit West Reserve) and the area between Clive Park and Beauty Point." (7)

RECOMMENDATIONS
The potential for destruction or damage to significant aboriginal cultural heritage, both known and undiscovered sites, would be unacceptable to the community (particularly in light of recent destruction of aboriginal heritage by mining companies and others). The project should be modified so that there is no risk to known and potential Aboriginal heritage.
1. The project should be modified so that there is no risk to potential Aboriginal heritage.
2. Further investigation of submerged sites prior to EIS approval is warranted.
3. Management recommendations Section 9, Appendix L Pg 74 should be made a condition of consent.
4. Qualified archaeologists specialising in Aboriginal cultural heritage should be present at all times at all constructions sites where known Aboriginal sites exist whilst work is in progress. Proposed training of construction staff in cultural and heritage awareness alone would be grossly inadequate. (3)
5 Any variation to the EIS sought by the construction company once the EIS has been approved should not be granted until the risk to known and potential Aboriginal heritage has been reassessed.

REFERENCES

(1) 15.3.1 Ethnographic and archaeological context. The Sydney area has a rich indigenous heritage. Aboriginal occupation focused on accessing resources from diverse ecological areas, seasons and conditions. Occupation sites, hunting, travel and inter-clan contact would have been associated with coastal areas, smaller rivers, creeks and swamps.(7)
(2) EIS CH 15Aboriginal cultural heritage Table 15-6 Pg21
(3) Table 15-7 Assessment of potential impacts to known Aboriginal cultural heritage sites Pg24

(4) EIS Ch 15 15.5 Environmental management measures - AH6ConstructionAboriginal heritage –impacts
Cultural and historic heritage awareness training will be carried out for personnel engaged in work that may impact heritage items before commencing works for the project. (31)
(5) EIS Ch15, Pg's 7,8
15.3Existing environment
15.3.1Ethnographic and archaeological context
“There is evidence of Aboriginal occupation throughout the study area, with areas of plentiful food resources associated with shorelines, riparian zones and adjacent areas including Clive Park, Burnt Bridge Creek and Flat Rock Creek. During urban development, many of these areas have been covered by fill, concealing original formations. Some evidence of Aboriginal occupation may also be present along movement pathways, meeting and camping sites, which were often associated with ridgelines.”
(6) EIS Ch 15 15.3Existing environment
15.3.2Environmental and landscape The lower North Shore portion of the study area includes several parks and reserves including St Leonards Park, ANZAC Park, Cammeray Golf Course, Artarmon Park and Artarmon Reserve, as well as the Flat Rock Reserve and the surrounding alluvial terraces and exposed sandstone outcrops. These parks and reserves have been subject to less intensive disturbance and may have increased potential for Aboriginal sites.
“in areas of remnant landscape, Aboriginal sites, where present, may be relatively undisturbed.”
5.3.2Environmental and landscape context
“At the Wakehurst Parkway landscape region, there are sections of undisturbed remnant landscapes in two locations within or in close proximity to the project (Garigal National Park and Manly Dam Reserve)….. The Wakehurst Parkway landscape region is particularly significant because of the Hawkesbury Sandstone and its association with known Aboriginal rock engravings.”

(7) 15.3.4 Potential submerged Aboriginal sites Pg 17

I request the state government reconsider the northern beaches tunnel and re consider the option of improved public’s transport. To me, it makes no sense to increase the amount of cars on the road and therefore extra pressure on parking within the city. It horrifies me to think we will lose our local creek (near Balgowlah golf club) and the impact on our local bird and animal life around the Manly Dam area. My other concern, my property will become an island, surrounded by highways and smoke stacks - please reconsider this decision.

Concerns around local schools:
As a local Balgowlah resident, I fear for the abundance of traffic and congestion that the construction will bring surrounding the school on Wanganella and White Streets, St Cecilia's. My children go there, and having extra traffic surrounding this already congested area where 270 primary school students are having to be dropped off, needs to be closely respected and draw traffic AWAY from the Southern side of Sydney road towards White Street. This area was listed as a place of worship, not a school. With 270 primary students, plus several hundred secondary students one block West of it at Balgowlah Boys High, congestion needs be removed, not added to this area. Careful consideration needs be placed on the use of Maretimo, Wanganella, and Condamine South of Sydney Rd, to not create a 'rat run' on this densely populated area to Ethel and Cutler Streets / Roads. Children, especially primary that bring infant siblings often in prams, need be respected and isolated from workman, work vessels, and the like, associated with constructing this said tunnel.
Concerns about commuters and toll expenses:
I would like to see a 'toll concession' applied for local residents, not unlike the old Bob Carr inspired exemption from the Wollongong Canberra freeways, whereby residents of the beaches get a capped weekly toll, to not allow for excessive billing.
Local sporting amenities:
The Balgowlah Oval, and Golf Club, specifically, should these be used for work stations of the area, then adequate relocation of cricket nets and the like etc, so our children have access. Perhaps use some of the public grounds for all to enjoy on other area's to allow for all rate paying and school paying families to enjoy the area during the construction of the tunnel. This area is a wonderful community, sharing and kind, but the pressures of construction and impacts on schooling can be devastating for the lifestyle of the area, of any area.
Thank you for considering my opinions.
Respectfully, Sam

I object to the Beaches Link and Gore Hill Freeway Connection for many reasons.

I want to see new public transport infrastructure to support the sustainable future growth of the Northern Beaches, not a motorway that locks us into car dependency. Toll roads do not solve congestion. Sydney is already riddled with urban motorways that destroy the fabric of the city and create huge traffic jams.
In order to make this a livable city for the future, you have a once-in-a-generation opportunity to make the correct long-term decision and provide public transport, preferably by rail, as other progressive cities around the world have done.
I object that Transport for NSW has failed to consider other options to achieve a reduction in congestion and improved travel times for the relevant communities.
In addition, there is plenty of evidence that WFH will continue. A number of large employers (including TfNSW itself and many government departments) have officially adopted a hybrid form of WFH. However, TfNSW have evaluated the movement to WFH as “temporary” in relation to the Northern Beaches. This must be re-assessed.

An independent cost-benefit analysis must be conducted for all transport options and publicly released. The must include a full evaluation of the option of Western Harbour Tunnel without the Beaches Link, an extension to the Metro, the use of trackless trams and driverless electric buses and proper BRT systems.

My sons are students at NBSC Balgowlah Boys Campus. The school sits directly south of the Balgowlah Construction site. The students and staff will be impacted by noise, dust, traffic congestion, safety issues, parking problems and the probable loss of the Balgowlah Oval.
The school has grown rapidly over the last few years due to its excellent academic results. This upward trajectory is in jeopardy from over 6 years of very disruptive construction that threatens to send boys and teachers to other schools.

The EIS states that 495 heavy truck movements will occur every day at the Sydney Road entrance to the construction site, noise levels will exceed Noise Management Levels consistently and dust will be a serious health hazard.

The NBSC Balgowlah Boys Campus must be listed as a ‘Community Receiver’ to ensure noise and air quality monitoring. This is a serious omission in the EIS.

The mitigation measures requested by the school must be included in the Scope of Works for the contractor and be regularly reviewed/monitored by a Working Group which includes representatives from P&C and the school.
Penalties must be imposed on the contractor(s) when acceptable air quality, noise and vibration levels are exceeded.

If the Beaches Link proceeds, the future amenity of the area around the school must be considered at the outset of the project:
• Northern Beaches Council and the NSW Government must collaborate with NBSC Balgowlah Boys Campus to design future facilities for the new open spaces to maximize benefits for the school. The open space development, if executed well, provides an opportunity to expand school’s existing campus.
• I would like TfNSW to install new bus stops for the B-Line and other express buses at the Sydney Road junction with the Burnt Creek Deviation. Space could be created for a proper bus interchange around the entrance to Dudley Street. This would dramatically improve access to the bus network for Balgowlah Boys students and local Seaforth and Balgowlah residents.

Finally, I am shocked by the environmental impacts of the project such as:
• Wakehurst Parkway will be a 4-6 lane freeway across a narrow escarpment, causing ongoing pollution into sensitive creeks and waterways at Manly Dam and Garigal National Park. 39 football fields of bushland will be cleared as well as 2,000 trees. The road will be raised several metres in some areas - making it audible and visible, day and night, for miles around.
• The Burnt Bridge Creek will die as its flow is to be reduced by 96%, destroying a delicate ecosystem that supports threatened species including the flying fox colony.
• During construction, 425,000 litres of waste water will be washed into Manly Lagoon at Queenscliff every day.
• At Middle Harbour, toxic chemicals in the harbour sediment will be disturbed during dredging, posing a major threat to the marine environment and the amenity of Clontarf and Sandy Bay.
• Balgowlah Golf Course site will be completely cleared of vegetation and native habitats during construction to allow for parking for some of the 3000 workers daily, enormous road headers, a concrete batch plant, rock crushers and acoustic sheds.

The contractors must be locked into all mitigation commitments with large fines for breaches. It is essential that due diligence is taken to protect the waterways and native habitats during and after construction. Restoration of construction sites must occur under the watch of independent experts to ensure that biodiversity is not lost forever.

The EIS is a long and complicated document and the community has not had time to review it properly in consultation with council and elected representatives. I urge you to press 'pause' on the procurement process NOW so that all stakeholders can develop a truly sustainable plan for the the development of Sydney.

My submission is attached.

I am a father of 2 school aged children and have serious concerns about many aspects of the beaches link tunnel project. Given the state governments recent declaration of a net zero emissions target by 2050, I find that building a new motorway in a built city environment goes against this. Public transport options give us the best opportunity for the generations to come having a liveable climate like we currently enjoy. Every little bit counts for our future. See my points below to expand further.

Air quality and pollution –the impact on the environment and to my community from the increase in truck movements on local roads is completely at odds with the 2050 target. RMS Air Quality team have already confirmed it one of the biggest risks, causing potential cancer and fatality impacts in children, is the diesel emissions from the high levels of trucks. Hydrogen-fuelled trucks instead must be made mandatory if this project proceeds. The location of the unfiltered ventilation stacks nearby to schools is morally wrong also. Are the health risks to our next generation acceptable? I don’t think so when increasing and improving public transport is the way of the future.

Noise and traffic – The huge increase in truck traffic will cause unacceptable levels of noise, vibration, dust and diesel fumes that even the RMS team themselves have identified as highly toxic and dangerous. Having no time restrictions on certain types of truck movements is hard to believe. Previous objects to this have been ignored so far. Permanent noise abatement walls should be installed around the site as well as adjacent to those who are subject to significantly increased traffic noises due to truck movements, both during and outside of work hours ie along Flat Rock Drive and Brook Street and the south facing streets of Northbridge
Pedestrian road safety. Large numbers of pedestrians, particularly school children cross Brook Street every day. Installing traffic lights at the intersections of Grafton and Slade Street on Brook Street will somewhat improve this situation. If truck drivers need traffic lights to leave site for their safety surely our school children need to same protection also.

Waterways – we are blessed with an incredible harbour in Sydney and the risk of damage caused by dredging around the point in Northbridge unnecessarily puts this ecosystem at risk. Thousands of people enjoy this part of the harbour every week, many travelling from out of area to do so. Is this risk worth the so-called reward?
Bushland – The bush corridor that flat rock gully is part of is an important link for wildlife and recreational users. These corridors are part of what makes Sydney such a unique city. Thousands of people and animals use this corridor every day. Given that this area is a remediated tip site, it is quite astonishing that tunnelling through such a former site was even considered in the first place. How will you control the release of toxic gases and the removal of asbestos from this former tip? No indication is given as to how this will be controlled and or monitored.

Aboriginal sites of significance – There are known sites in the area dating back at least 4500 years. How will they be persevered and protected? These sites are important part of our pre-European history and need to be protected for our future generations.

In summary I feel the negative impacts of this tunnel project far outweigh the so-called benefits.

I object to the proposal on a number of grounds. First, the EIS indicates that this project will result in the clearing of more than 350 trees from parkland around Flat Rock Gully. This area is home to a range of native wildlife and it also provides valuable green spaces for local residents. As someone who lives and works nearby, it would be a real shame if this beautiful part of the Lower North Shore was lost or permanently damaged. The impact this will have on the regions biodiversity would also be considerable. Flat Rock Gully also has considerable Aboriginal Heritage which should be protected - the waste generated by this project has the potential to cause harm to this Heritage. Furthermore, the EIS suggests there will likely be significant pollution coming from unfiltered tunnel stacks. This will impact not only the local environment, but potentially the health and wellbeing of those who live and work nearby. This risk is not acceptable - the impact is too great.

I also object to the proposed tunnel because there is not enough evidence that this will improve traffic congestion. Building new toll roads is simply not a sustainable approach, it won't relieve congestion and it will make hitting our emissions targets harder. What we need is to invest in more public transport infrastructure. This will help remove congestion from our roads while also protecting our green spaces, and helping us collectively reduce our carbon emissions. The Government should commission a full options analysis that looks at alternatives including public transport infrastructure that could have a smaller footprint on the local area.

I am also deeply concerned that despite community requests, the business case for this project has not been made publicly available. In the interest of full transparency, the business case should be published and the public consultation period re-opened with new opportunities for residents to consider the proposal and provide their input.

Castlecrag Progress Association (CPA) supports and endorses the submission made by Willoughby Environmental Protection Association (WEPA) in objection to the project. We have read the WEPA submission and find its arguments sound and compelling.

For this reason we oppose the Beaches Link Tunnel until such time as:
1. the business case is released for public consideration;
2. the need for the project, and its superiority over public transport alternatives has been demonstrated by way of a transparent process involving informed public engagement and consultation, noting that the EIS process has to date failed to evaluate the relative merits of public transport alternatives.

yours faithfully
Dr Paul Stokes
President, CPA

Please find attached our submission.

Please find attached a document outlining my objection to this project

Updated submission to include a paper I authored on rail(Sydney Heads Rail Tunnel...). Other than that, no change from previous upload.

My husband and I moved to Naremburn 3 years ago to provide a better lifestyle for our two children now aged 5 and 6.5 years by being close to the bush, water, good schools as well as easier public transport access to the city. We live 50m from Brook Street in Naremburn. I can see little benefit of this tunnel for us in Naremburn. I think investing in our public transport system would be a far better use of these funds, a better way forward for future generations and would mean that our bushlands, waterways, air quality, flora and fauna and our children are not impacted and are allowed to thrive rather than be thwarted. I have many concerns about this project’s impacts on my family’s lifestyle and on our environment should be it be approved. Below are my main issues:

1. Air quality – If this project goes ahead, our community needs proper filtered ventilation stacks in line with world standards. Our health and our children’s health is paramount. In line with this, diesel trucks that are known to have harmful emissions on local children in particular should not be permitted to operate. The RMS Air Quality team have already confirmed that one of the biggest risks, causing potential cancer and fatality in children, is the diesel emissions from the high levels of trucks. Surely using hydrogen-fuelled trucks instead is a better option.

2. Noise and traffic - Thousands of heavy vehicle trucks will be added to roads. I’ve read that for Brooke Street there could be more than 1 truck a minute causing significant noise, vibrations, potential dust, diesel fumes that even the RMS have identified as highly toxic and dangerous. This traffic will continue for over 8 years. It seems the council hasn’t put any defined limit on when some trucks will be driving in and out. Trucks containing ‘fill’ might be limited, but other trucks could travel 24 hrs a day. The safety and traffic issues on a road already with enough safety concerns could easily lead to injuries and fatalities. Proper street-side noise abatement walls (not just timber) should be installed for those around the site as well as those who are subject to significantly increased traffic noises due to truck movements, both during and outside of work hours ie along Flat Rock Drive and Brook Street and the south facing streets of Northbridge.

3. Road safety for school kids and other pedestrians– If this project goes ahead, we need safety crossings for children and residents offering residents the same safety measures that workers and truck drivers are being offered and need. The intersection between Rosalind Street and Miller Street, where significant numbers of primary children from Anzac Park Public School in an already dangerous area, with 6 directions of traffic and the threat of heavy vehicles, known to significantly increase the risk of accident and death; Sailors Bay Road toward the dive site; and on Brook Street where the road does not currently take the extent of heavy vehicles and has significant safety issues. The Cammeray Public and Anzac Park Catchment areas cross Brook Street and many children walk to school and are in danger. It seems this issue was ignored at the RMS community meeting. I’d like to see the speed limit reduced to 50 km/h, traffic lights installed at key intersections and proper protocols in place (eg the installation of speeding cameras on Brook St) so that accidents and fatalities don’t occur. Even before this project proposal and the associated traffic concerns were raised, I phoned and wrote to Willoughby Council on several occasions requesting traffic lights be installed across Slade Street after having to help motorists that had been involved in serious accidents when attempting to right from Slade onto Brook Street. Traffic lights will help to protect residents and school children who live in the area and/or cross over Flat Rock in order to get to school.

4. Waterways - Dredging around Northbridge will be highly toxic and potentially stop my children using the waterway (eg sailing, kayaking, fishing, swimming at Northbridge Baths which we do weekly in summer) for the duration of the project and well beyond. I’ve read that Tunks Park river ecosystem is a ‘drainage’ line but is so much more than that – it is an established creek (or river when it’s flooding) which we often walk along to get to from our home to Tunks Park. Thousands of locals (and their dogs) use this area for daily exercise and to escape into the tranquility of the bush.

5. Bushland – If this Project is approved in its current state, a large portion of Flat Rock gully will be destroyed yet there are no plans for rehabilitation or redevelopment (not that I’ve seen). My family use this bushland almost every day – we walk, cycle, run through it, admiring how things are growing, how the creek is flowing, how the moss and ferns at the bottom are thriving. We’ve seen so much wildlife there – all sorts of birds, wallabies, echidnas, snakes, goannas, skinks etc. We, along with our neighbors, would be devastated if such a peaceful patch of bushland is taken away from us and all those animals that reside in the flora there were also destroyed. All this growth has happened despite Flat Rock Gully being established on an old tip site (which my parents still remember when they grew up in Northbridge over 50 years ago). The Gully is known to contain asbestos that will be dug up if this project goes ahead. Current plans indicate it will be kept on site – if so, what are the containment measures? While being dug up how will we be protected? How are the asbestos fill ends being measured? If anything is trucked out, how will dust be contained and how will the toxicity (dust and air) be measured? What is the risk of these to locals? What independent testing is being undertaken and who will the results be released to? How are you ensuring this risk doesn’t transfer to the southern slopes of Northbridge where homes are incredibly close to the dive site, to Basketball, Netball courts and other community areas? There are so many unanswered questions!

6. Aboriginal sites - And what is become of the known Aboriginal sites in this region? How will they be preserved and protected? I’ve not seen or heard anything substantial on this front. Our Aboriginal heritage is so important to our country, our children and to those who value our forbearers, which my family certainly does. To simply ignore these traditional sites and artworks, as well as their beliefs throughout this project is so disappointing.

In summary, I oppose this project due to the impacts it will bring - contamination, destruction of biodiversity, traffic, health and safety of our residents and school kids. We love our home and our community and don't want it to be destroyed by removing our bushland and it's fauna and flora, by polluting our air with dust, toxins and noise, polluting our waterways and preventing us to fish, swim, sail, canoe etc, by damaging our children's health and the health of future generations. We want to preserve this rare ecosystem we have so close to an international city for our future generations to enjoy as much as we already have. Improved public transport is the way to achieve this, not the tunnel system and all it encompasses.

Please find attached my submission for the BLT.

I refer to the project documents for the Beaches Link and Gore Hill Freeway Connection, which are currently on public exhibition.

I object to the project, on the grounds of its environmental impact and subsequent impact on the local residential area. The questionable benefits for traffic congestion are negligible and other options including more accessible public transport are more environmentally friendly solutions. The pollutive impact of the Beaches Link is significant. Unfiltered stacks in the proximity of my place of residence where my family, including my children, are living is unacceptable and ill advised.

The project documents do not recognise the changing nature of work patterns in a post covid environment. Many are now working from home and the previous need for more roads is now no longer evident.

A further issue with the project is the construction impacts of the Link and Freeway Connection. Heavy gauge trucks carrying earth and landfill will severely impact the residents of Naremburn and surrounds. 24 hour truck traffic will shake foundations and pollute our streets. They will also endanger pedestrians, most particularly school students walking to Cammeray Public, Anzac Park and Cammeraygal High School. The dive site is in the midst of reclaimed bushland at Flat Rock Creek. Disturbance of this bushland will bring up high levels of toxicity dating back to the earlier decades when the area was used as a dump.

Flat Rock Creek reserve is a sanctuary for many within this area and is one of the most attractive aspects of our suburb. Destroying this natural haven for little purpose is short sighted and disturbing. Again, the pollution resulting from the unfiltered stacks that will result will further impact the natural attributes of this area.
The ventilation approach proposed will ensure that the bulk of the tunnel emissions from the western half of Beaches Link will be concentrated and emitted over Naremburn and Artarmon (pushing particulate concentrations closer to the limit). On the basis that no concentrated tunnel emissions is clearly preferable to local receptors than this, if the project is to proceed there is clearly good sense in moving the ventilation point away from these receptors and imposing conditions to ensure the high vertical discharge velocities from ventilation outlets.

This project is not what residents want and it's long term benefits for traffic and urban development ignores the greater needs of an environmentally friendly solution to population density. Pollutant, disruptive, dangerous. It must not be approved.

• The project is economically negative: the cost of investment is larger than expected benefit. The money would better spent on excellent public transport.
Overall design
• Beaches Link is a 6 lane underground highway. It is 50% wider than the Harbour Tunnel but with much less traffic. Is this width necessary?
• No dedicated bus lane.
• There is not enough parking in the Northern Beaches already. The tunnel will add to the traffic. We need better public transport first.
• Commitment to carbon neutrality by 2050 (30 years away) may see great changes in the way we travel. The tunnel could be obsolete soon after finishing.
• There are no side exits off Beaches Link along the Lower North Shore. This will mean some traffic for Mosman etc will travel to the Northern Beaches and return West to avoid Military Rd peak hour
traffic.
• Entrances and exits to the tunnel are too wide: Crows Nest 20 lanes, Balgowlah 12 lanes, Seaforth 6 lanes.

Direct impact on Manly Dam Reserve
• Wakehurst Parkway cannot be widened to 4-6 lanes without destroying the bush at the top of Manly Dam and Garigal National Park. The ridge is simply too narrow for such a wide road.
• Light from the road will be visible all through Manly Dam and Garigal National Park. The road is on a ridge, so light from the road will be visible for miles around.
• Encouraging articulated trucks and construction vehicles to use Wakehurst Parkway could result in accidents and spills that will have significant environmental impacts on Manly Dam and Garigal
Construction will destroy a large area of bushland at the top of Wakehurst Golf Course around the two water tanks. This area was declared by Sydney Water to be rich in endangered plant and animal species and worthy of conservation.
• The Aboriginal carvings along Engravings Trail will be under threat from road runoff, construction debris and possible blasting impacts.

Hello,

I am an advocate of well-designed infrastructure projects that benefit the wider community. I’m a resident of North Balgowlah and have no issue with such projects being undertaken near where I live.

I do however have some major reservations over the proposed Northern Beaches Tunnel as follows:

• Economic viability of the tunnel: The estimated cost is $14 billion, prior to any tender process so is likely to increase when the final scope of works is finalised. In the State Infrastructure Strategy 2012-2032, INSW concluded that the Northern Beaches Link was a lower priority for Government funding support than other projects because of lower traffic volumes, lack of through traffic, limited population growth etc. Other projects such as Western Sydney Airport and rail and road projects in Sydney’s population growth corridors must still be a much more suitable investment by the Government and make more economic sense.
• No dedicated public transport dedicated lane in the tunnels: The Government is targeting 30% reduction in private car commuting by 2038. There is no incentive offered to residents to catch public transport if there are no dedicated bus lanes. So providing a tunnel for cars is counter-intuitive to the reduction in private car usage.
• Lack of filtration of ventilation outlets: Errors in air quality assessments in projects such as West Connex do not provide confidence over modelling outcomes. Whilst the Department of Planning has engaged the NSW Chief Scientist in assessing the risk of air pollution to the population near air stacks, my uneducated suspicion is that the passage of time will show those assumptions to be incorrect by which point there could be irreversible health consequences for individuals affected.
• Location of the Balgowlah smoke stack: Based on the proposed tunnel exit point in Balgowlah, there needs to be a stack nearby. However, the result is that the stack ends up being situated at a low point in a residential catchment. This means that any air pollution either won’t disburse as easily as it should or means that the stack itself needs to be much higher than its surrounds to ensure extracted air is vented higher into the atmosphere, thereby potentially creating an eyesore. It results in an imperfect solution in either scenario. It should bring into focus how essential a new tunnel is at all, particularly in lieu of the success of the B-line bus route as a means to increase movement of commuters whilst simultaneously reducing the number of cars on the road.
• Side effects of increase in visitors to the Northern Beaches: Whilst this is likely to be beneficial to local businesses, there are already parking challenges around Manly and other beaches which will only be exacerbated if more people drive to the beach on the weekend instead of catching public transport there. Impacts will therefore not be felt just around the tunnel entry points but also in surrounding suburbs.

These issues need to be carefully considered now when assessing the merits of the project and should not be rushed under any circumstances.

Thank you

I object because of the impact to the Environment, the creek will dry out over the next few years, as well as you will pump untreated water into the creek which will go into Manly lagoon and then at Queenscliff beach into the ocean more than 100000l of untreated water a day. Also the exhaust vents which reach into the air which will put toxic unfiltered gases into the air is not ok. The Bally boys school will see a lot of traffic and pollution and noice and the pollution is meant to stay a certain distance from a school is not given. So I am not ok to build a tunnel with what kind of impact this has on the environment. The tunnel should have at least a public transport lane with current plans not having one.
Please take the plan and amend it.
Kind regards

To whom it may concern,
I wish to lodge my objections to the beaches link tunnel based on the following:
- Non-filtered emission stacks where there is a high concentration of preschool, primary and secondary schools. This is unacceptable particularly given the increased car and diesel truck exhaust fumes containing extremely toxic substances including tiny particles that are hazardous for human respiratory and circulatory health.
- Lost opportunity in not filtering/ treating stack pollution – although the EIS suggests PM2.5 levels will not be significantly changed with the construction and operation of unfiltered stacks, we are already living in an environment where levels of PM2.5 and PM10 is above the level of what is considered safe and the EIS demonstrates that this will continue well past the tunnel opening. Would filtering stacks reduce PM 2.5 levels to acceptable levels? Or could a public transport alternative address our growing PM levels. The government has a duty of care to do what it can to reduce these levels now that it has monitored and confirmed the issue.
- Flat rock gully as dig site unsuitable due to known contamination of site containing asbestos, toxic gases and other unknown items that were legally allowed to be dumped there last century. flat rock gully is home to a range of species including small bird populations, rock wallaby, powerful owl, lizards and many more and disruption to this site would disrupt the environment and endanger this wildlife. The risk to the flat rock gully native wildlife corridor is unacceptable. In addition to this the risk to downstream contamination of other sites is unacceptable.
- The EIS states that the area North of the golf course in Cammeray will experience noise above limits across the duration of the project. Anzac Park School, Anzac Park, Cammeray Oval and KU Preschool (Green Park) will be noise affected above limits across various stages of the project. With my child due to attend Anzac Park, I have grave concerns about the impact this will have on children.

The project will have a significant direct impact on Manly Dam Reserve, specifically in terms of it's freshwater ecology. The Reserve is a critical refuge for endangered species that are already under threat from increased fire frequency, drought, freshwater pollution. The banks of trees currently adjacent to Wakehurst Parkway are critical wildlife corridor for a number of endangered and threatened species and the only significant urban reserve acting as a buffer for the adjacent national park network. These corridors become increasingly important. With more people working from home going forward, the widening of this roadway, instead of alternative planning solutions, represents an ill thought out approach to infrastructure planning which should now be reconsidered in the context of COVID and ongoing demographic shifts away from centralised work, especially due to the local heritage, natural and social values of this significant strip of vegetation.

It will threaten the last remaining population of the Galaxias brevipinnis in the Sydney area, together with multiple threatened species such as the red crowned toadlet that lives in the habitat adjacent to the Wakehurst Parkway.

• Wakehurst Parkway cannot be widened to 4-6 lanes without destroying the bush at the top of Manly Dam and Garigal National Park. The ridge is simply too narrow for such a wide road.
• The road is too wide to have adequate runoff water treatment. Untreated water from the road will pour through the bush, scouring the land and filling streams below with sediment every time there is heavy rainfall. This will essentially eradicate small freshwater populations of invertebrates including threatened frog species. The proposed drainage processes from the EIS are inadequate.
• Street lighting along Wakehurst Parkway will cause light pollution which will affect the life cycles of nocturnal animals, causing them to die out from that area. The Reserve supports a population of the Eastern Pygmy Possums will be affected.
• Light from the road will be visible all through Manly Dam and Garigal National Park. The road is on a ridge, so light from the road will be visible for miles around.
• Encouraging articulated trucks and construction vehicles to use Wakehurst Parkway could result in accidents and spills that will have significant environmental impacts on Manly Dam and Garigal
National Park. A spill of toxic liquid will pour downhill directly into the bush and be extremely difficult to clean.
• There will be a lot of traffic on Wakehurst Parkway. Heavy construction vehicles going 80km/h will dominate the road for the next 30 years. Traffic noise will be heard all across the bush, particularly
at night. Truck movements for the key construction site on Wakehurst Parkway will have about a truck pre minute entering or leaving.
• Construction will destroy a large area of bushland at the top of Wakehurst Golf Course around the two water tanks. This area was declared by Sydney Water to be rich in endangered plant and animal species which are already threatened by climate change and increased bushfire frequency.
• The Aboriginal carvings along Engravings Trail will be under threat from road runoff, construction debris and possible blasting impacts

The environmental impact statement for this project by nature is so damaging and extensive that this project should not proceed .
The recent changes in work practices with Covid show that technology not polluting outdated modes of transport are the future.
I object to this project on moral ethical and cultural grounds and it is beyond comprehension that this government thinks they have the right to destroy this irreplaceable land forever and for generations to come for a time saving exercise today