Beaches Link and Gore Hill Freeway Connection

I object to the project for reasons contained in the attached submission

- lack of business case
- pollution of harbour as a result of dredging releasing contaminants. This may mean we no longer can safely use beaches such as clontarf, plus 428,000 litres of waste water pumped into Queenscliff each day may make this an unusable area also.
- destruction of habitat - there have been 23 species detailed as under threat in the EIS. Burnt Brudge Creek will probably dry up due to a potential 96% reduction in water flow!
- vibration and construction noise that residents will be subjected to over a 7 year period
- unfiltered stacks. Gladys herself objected to the use of these in the Lane Cove Tunnel, calling the filtration of stacks “ethically right in the interests of health”. Apparently she’s now changed her tune and they’re fine to use here on the northern beaches
- I want the environment to be more heavily considered and a detailed review of the plans to be completed prior to any action being taken
- build the tunnel, sure, but not in a way that has this much damage to the environment in the area

Please see objection submission attached consisting of:
Objection Summary dated 1st March 2021
Appendix A - GHD Report to DIPNR - Disposal of Surplus Govt land at Seaforth
Appendix B -Vegetation Assessment -North Seaforth from URS
Appendix C - Peer review letter from Hayes Environmental

Please find attached my submission.

As it seems you are going ahead with the beaches link here are some further points to consider regarding the protection of our local neighbourhood:
* Install a proper street side noise abatement programme for Brook St and Flat Rock Drive. How are people living in these streets or side streets going to cope with noise from the trucks?
* Limit all truck movement to weekday working hours 7am to 6pm and ensure trucks do not use their air brakes otherwise they will be fined.
and ensuring it does not impact homes etc?
* I run a business from home that requires peace and quiet and good access to our residential street. Am I going to be compensated for if I am forced to shut down because of the noise and poor access to our street? Or as I said in my previous submission if our property develops cracks in the walls from underground work?

I am not convinced that this project has taken into account viable public transport options to the Northern Beaches. In my view, there always has to be the best possible public transport options made available to residents before the kind of money that is being spent on this road project is undertaken. This is especially true when the disruption to local traffic, parklands, schools and community is so significant and where the local residents affected by these changes do not benefit in any way whatsoever. The air and noise pollution is also of immense concern.

I believe it is only fair, right and the responsible course of action for the government to provide evidence of the research done into the what public transport options were considered and what the business case is for the Beaches Link and Gore Hill Freeway Connection vs. public transport options such as the metro. Travel time savings and congestion benefits have been quoted in the EIS but the public have not seen any evidence of this. I would also be interested in seeing what public transport options were considered and the business case for rejecting these alternatives for increased road traffic.

I also sincerely believe that there needs to be greater engagement and consultation with the community in every stage of the process, particularly to explain the merit of this project versus any public transport alternatives.

Milson Precinct
PO Box 704
Milsons Point. NSW 1565

1 March, 2021

The Hon. Robert Stokes,
Minister for Planning Industry & Environment,
4 Parramatta Square,
12 Darcy Street,
PARRAMATTA NSW 2150

ATTENTION: Ms. Belinda Scott

Also via Dept. Planning, Industry & Environment, portal:
www.planningportal.nsw.gov.au/major-projects/project/10456

RE: OBJECTION to Beaches Link & Gore Hill Freeway (BL) Environmental Impact Statement (EIS)

This submission is distinguishable from those two following submissions identified in that it prioritises three of the issues already touched upon but are considered most relevant to the interests of the Milson Precinct
.
Milson Precinct concurs with the North Sydney Council officer’s report at the meeting held on 22 February, 2021 . Identified as item 8.6 Beaches Link and Gore Hill Freeway Connection EIS Submission. In addition we support the letter of Objection dated 26.2.2021, from Councillors Zoe Baker, MaryAnn Beregi and Tony Car, of North Sydney (NS) council.

However the following three matters are specifically of particularly grave concern to our community. These issues are considered sufficient grounds for refusal and at the very least constitute the need for revision before the application proceeds to determination.

1. Transport terminus oversight: North Sydney will become the terminus for 350 morning peak hour buses from the northern beaches, which will be using the BL tunnel, and coming out onto Warringah Freeway. Then NS roads at Alfred St., High St, to then cross over Pacific Highway to drop passengers to NS train station in Blues St followed by Victoria Cross Metro stations, in Miller street

These buses should not be adding to the already congested traffic of North Sydney and rely
simply on the use of the existing road system at grade.
This situation must be ameliorated by additional infrastructure works. , preferably via a tunnel direct to an underground bus terminus / transport interchange. It has been done before, similar for example to Tokyo city.
The imposition of this drastic public transport impact must be addressed if the objectives of an improved transportation network are to be achieved.

Furthermore, Impact on NS roads especially the arterial traffic function of Berry Street, Pacific Highway, Miller Street & Falcon Street is of grave concern. NS Council has numerous adopted and draft strategies for NS CBD - public domain initiatives for Miller St., Berry St and Ward Street, The NS Integrated Transport Plan (NSITP) and the requirements being placed in the WHT & WFU Approval instrument by the DPIE should be upheld in these BL documents, but fails to be so. Being:

E162 TheCritical State Significant Infrastructure (CSSI) must not preclude the delivery of the objectives proposed by the North Sydney Integrated Transport Program (NSITP) in consultation with the Government Architect NSW and North Sydney Council.


2. If unfiltered stacks were to be built then they should be built, at the very least, so that they can be retro-fitted for air filtration purposes at any time in the future. Thereby addressing the technical arguments that favour significant further added precautions, said to be technically necessary but not accepted for inclusion so far

If the argument for shorter lengths of tunnel between stacks is not heeded then the nature of the exhaust systems, proposed as they are at extremely extended intervals, becomes of critical importance.

The tunnel as proposed is of extreme length by comparison with the current Sydney network. All the Sydney tunnels advise motorists to close windows and put recycled air on while driving through. This shows that the air quality exhausted from within tunnels is fundamentally not appropriate for human health. So why should the residents of NS be risking the contested health risks of these otherwise contested unfiltered stacks?
But even if the level of air quality was to be further improved by filtration, is that so extravagant as a result and enough to eliminate such provision in the future? Is our Sydney air quality that good that any improvement in its standard is altogether unwarranted?

More precaution applied to the operation of the stacks as proposed is an obvious compromise as far as the surrounding communities are concerned. The request to provide assurance that any required remedial work be anticipated in the initial construction to provide for additional works to be retrofitted is (at the least) a most reasonable suggestion and a constructive request by way of compromise.

3. With no public meetings to facilitate direct questions and review the details in person, vs online is a radical change and to compensate then the notification and community consultation times should be significantly extended. Outside of Corvid restrictions, lack of time for community consultation and engagement has been compounded due to the span of the intervening Christmas holiday period, insufficient to allow community time to assimilate the several thousand pages of very technical documents for this epoch public investment..

4. It would appear that there may also be a failure to meet the SEAR’s as a state significant infrastructure applicant. The EIS has failed to give analysis of “how alternatives to and options within the project were analysed to inform the selection of the preferred alternative / option”, which should have included Public transport options.

5. Regrettably there is said to be a ‘temporary’ loss of green open space for only up to 7 years, of nearly 29,000sq. meters of land in Cammeray at the golf course, along with North Sydney council’s renowned water harvesting facility for maintaining the watering of sports fields and parks. E157 The CCSI must result in a net increase in usable open space. Replacement space must be in the general vicinity of the loss, unless agreed to by the Planning Secretary.


We thank you for your further consideration of these matters raised in this submission, intended as they are to be constructive in the quest to achieve confidence in the finally considered outcome and the community awaits your response.


Yours faithfully,

Terence Byrnes
Co-convenor,
Milson Precinct

I object, only to having unfiltered stacks. The stacks clearly should be filtered!

Not only would this greatly reduce the overall objections to this proposal but it would reduce net air pollution.

Stacks by their very nature concentrate emission and although the pollution at ground level is predicted not to increase greatly it will have a negative effect and can be simply improved by filtering. The tunnel runs though a highly urbanised area where people are now living (and will be living) at different heights ins surrounding houses and apartments.

We already have pollution from the vast majority of drivers passing through on their way to the city, don’t increase this when you have the opportunity to reduce it.

I OBJECT to the Western Harbour Tunnel and Beaches Link Project on a number of grounds:
A. Local Traffic Considerations -
1. Public transport alternatives are not compared nor is public transport substantially benefited. There is no dedicated bus lane in the proposed tunnel despite the 'lie' being peddled by the brochure/marketing material.
2. Local Traffic will worsen appreciably and the project delivers even more traffic to the Northern Beaches.
3. Infrastructure NSW rates this project as a low priority project.
5. The need to feed cars into Westconnex should not be a key “driver”.
6. The modelling relies on pre-Covid data and is already outdated
7. Project cost ($14billion) is substantial and is not supported by the cost benefit analysis
8. There is an extensive list of under-scoped risks
9. There is a questionable Benefit Cost Ratio (BCR), it has not been released to the public
10. The Beaches have been waiting for mass transit solution for almost a century
11. The Inquiry into Westconnex found that business cases should be released prior to planning approval of future projects - WHERE IS THE BUSINESS CASE?
12. The public favour a public transport solution over a toll road which is not a sustainable option bu ar enot being offer that as an alternative.
13. The project will put homeowners under further financial stress post pandemic
14. The project transverses the largest school zone in NSW (WHT&BL approx 26 schools 500-1000 kids at each and many more pre-schools, kindergartens and sporting groups)

I CALL for the following:
1. That the business case be released for public consideration. Why has this been kept from the public? What is there to hide?
2. The business case should evidence the travel time savings quoted, the congestion benefits quoted, should include a revised and fully scoped assessment of impacts to local roads model various tolling implications and surface road impacts, should include all under-scoped risks (ie contamination, utilities etc), include the costs to mitigate and remediate multiple contaminated sites and in so doing accurately cost the project.
3. That the need for the project, and its superiority over public transport alternatives is 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.

B. Tolls and Traffic Considerations -
1. The EIS confirms the Beaches Link is a Toll Road but there are no costings as yet. Costing and placement of toll gantries is essential to modelling traffic flows and predicting toll avoidance. Toll avoidance could become an issue as per the Inner West - tolling strategy yet to be confirmed however all other contracts have been 40-50 years with min. annual % increase in tolls.
2. A very low level of induced demand has been included in the modelling - research demonstrates that a higher level of induced demand is generally used for new expressways (up to 10%) which calls the modelling into question
3. The only local entry points for the Beaches Link are via Artarmon and Berry St North Sydney – no local time saved: 10mins to get to entry, 10 mins in tunnel, 10 mins to Dee Why or Manly = 30 min journey time.
4. The EIS makes it clear that this is not a local congestion solution – several local intersections fail or will experience a worse level of service both during and after construction as a result of the project.
5. Does not achieve goals – only 10% reduction in short term on Military Rd based on FUTURE predicted traffic growth not today’s levels. The growth model is not made available in the EIS so the travel time savings and congestion reductions are unable to be verified. Where a road is already at capacity it is self limiting ie) future growth cannot overreach the ceiling capacity of the road and therefore a travel time saving or reduction cannot be claimed on this basis.
6. Traffic differential modelling in the EIS shows increased traffic flows around the Warringah Freeway and on the Beaches exit roads. The project appears to transfer pinch points to alternate locations rather than solving congestion.
7. Confirmed as a capacity solution not a congestion solution – the EIS prioritises freight and through traffic as a goal of the project above local congestion
8. No dedicated bus lane in tunnel so is not a public transport solution – express buses aren’t express if they are going at the same speed as cars and don’t have their own lane.

I CALL for the following:
1. Release the business case for the Beaches Link and Gore Hill Freeway connection that has never been made public. This will tell us whether the Beaches Link is the most efficient, cost effective infrastructure to reduce congestion to and from the Northern Beaches
2. A full reassessment of the traffic flows to and from the Northern Beaches needs to include data collected after 2016, data also needs to be collected on the number of Northern Beaches residents who work in the area and how many work from home.
3. A re-assessment of surface level traffic with all major local roads included in the operational modelling. The surface road traffic assessment should then inform the pollution impact of the project as the pollution contribution is not only limited to the stacks.
4. A comparative public transport options analysis to be published (via a reissuance of the EIS for public consultation) that compares the traffic implications both during and after construction of a mass transit solution.

C. Health & Wellbeing Considerations -
1. Pollution - Particulate Matter is already higher than what is recommended or considered “safe” - PM2.5 and PM10 levels are already above the guidelines for both the 24-hour average and the annual average (including the 2025 goal set by NEPC (2016).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.
2. Contamination Risks - The main temporary dive site in the area is earmarked for Flat Rock Reserve which is confirmed as being part of the old tip site at the top of Flat Rock Gully. Currently there is inadequate information in relation to health impacts (secondary to landfill gas and odours) of proposed tunnelling works at Flat Rock Drive. A Phase 2 assessment is needed to check for contaminants and quantify risk. Approval should not proceed until the risks are known and mitigation possibilities scoped. Testing around the freeway and at Cammeray site has also confirmed contamination. Serious consideration of the cost/benefits of the project in light of the risk to residents and children as well as the cost to mitigate and remediate sites should be given.
3. Safety - The sheer volume of additional vehicle movements which will be on the road around a dense area of schools and children's sport presents a significant safety risk. Close to 5000 additional vehicle movements will be required across the route during construction. Heavy vehicles should not be permitted to marshal or transport loads on residential roads or within school zones. Over 1200 additional daily vehicle movements will be required to/from the Balgowlah Construction site - this is a key transport corridor for children accessing Northern Beaches schools and school sport.
4. Noise
5. Loss of Green Spaces
6. Community fragmentation - The local area has already been fragmented by the Warringah Freeway and Gore Hill Expressways. Communities have worked hard to regain a sense of place however these projects again create barriers bit during construction and after. Local communities should not be considered in the planning process and the best outcomes for both commuters and local communities found. A mass transit alternative should be considered.
7. Financial Stress - The Health risk assessment acknowledges construction fatigue, increased traffic and uncertainty as significant stress factors for the population. There are a large number of plans yet to be finalised, testing to be completed and known geological challenges across this project. The uncertainty created is and will create stress within the community.Substratum acquisition (uncompensated) is likely to cause financial stress particularly given economic uncertainty following Covid. Both the Westconnex Inquiry and recent reports demonstrate issues with the process as well as well as pressure on housing prices and the ability to sell homes during the period of construction and sometimes beyond. Given the economic situation post Covid the stress associated with uncertainty and acquisition is likely to be heightened.

I CALL for the following:
1. Local background data about current Particulate Matter levels to truly assess impact
2. An alert style monitor near children’s playing fields that sporting groups and parents can subscribe to to determine if playing sport is a safe option given the potential for contaminated dust and heavy vehicle emissions to be high around existing greenspaces.
3. Modelling of levels of particulate matter/other air pollutants in the environment if the stacks were filtered.
4. Landfill gas investigations should be carried out within these areas to assess the potential presence or absence of gas which could potentially impact upon construction and/or operation of the project if not managed appropriately.

There is not sufficient public transport capacity on this program of works. The reliance on cars as a sustainable method of transportation in 8 years is out dated and at odds with reducing carbon emissions. This project must include a mass transit system to meet the needs of the growing (geographically as well as populously) city .
I cannot support it in its current state

Please find attached submission from Save Manly Dam Catchment Committee objecting to the project.

I am distressed by the effects that the proposed Gore Hill Tunnel/ Northern Beaches Link on the health of all residents due to unfiltered stacks. My child will be going to Anzac Public which is in direct line with these unfiltered smoke stacks. The use of places like St Leonard’s Park during construction will destroy this very important recreational facility in my local area. We need a better solution!

Please see my attached Objection document. Many thanks

Josie Taylor, 6 Ryan Avenue, Mosman 2088
Ph (02) 99699074

Please see attached a detailed list of objections.

To Whom It May Concern,
I am writing in objection to application SSI-8862, specifically chapter 9 page 31 in regard to removing approx 6 motorcycle parking and 10 car parks at the intersection of Dickson Ave and Pacific Hwy Artarmon. There are more than 20 businesses which employ over 200 people in this area that will be dramatically affected by the removal of these spots. Parking for employees is already scarce at best with most employees carrying running shoes with them daily to cope with the already long walks to and from their places of employment.
Removing these spots would create a dire situation not only for employees but customers of these businesses who we field many complaints from daily of lack of parking already. Not only are retail customers the lifeblood of my current business Northside Motorcycles Artarmon but also support the local cafes, auto body shops, paint stores, and even doggy day cares in the area. I have recently bought this business which has been a hub for motorcycling enthusiasts for over 30 years, by removing these spots would negatively impact a great proportion of these businesses who are already suffering due to covid and lock down restrictions. This will not only have an impact on myself but also the widespread economy and availability of these specific services in the local area. We service over 1500 customers a year who would be driven over 25 kms away to be able to secure these services.
In this application it states this parking can easily be absorbed by local areas. I challenge to poll local businesses to gain a reality on the parking situation in Artarmon.
I would suggest as an alternative to install a set of lights at the corner of Dickson and and Clarendon which is currently a four way stop and could then create a primary route which would divert traffic through to Hotham Pde or Campbell St which already has sets of lights. This would also allow traffic to be diverted without adding another set of lights to an already existing crowded Pacific Hwy.

In closing this single set of lights would create havoc in an already congested area, this is supported by the fact we have already received over 425 signatures on our petition in less four days. The community is speaking and less parking is not something they can cope with.

Objection.
This correspondence is AGAIST the Northern Beaches Tunnel.
I object to the Northern Beaches Tunnel and I will actively work against its planning approval and construction due to the following reasons:
1. The enormous cost of the proposal makes it financially unfeasible.
2. The EIS has demonstrated there are numerous environmental degradation issues as a direct and indirect result of the Tunnel.
3. The Tunnel will need to be funded and this will undoubtedly result in an increase in the cost of commuting from the Northern Beaches to the city and other areas of Sydney.
4. Due to Covid and the resulting work-from-home directions, traditional working arrangements have changed and this change in work location may continue for some time. This will result in a reduced level of road usage.
5. There are far superior options that would improve travel to the city, such as, expanding bus services like the B1 and fully utilising the existing three lanes of roadway rather than have the road taken up for parking.
6. The Tunnel proposal will force high density living onto suburbs that do not have sufficient local road networks to support higher usage.
Please do not build the tunnel!
Shaun Austin

I object to the Beaches Link and Gore Hill Freeway Connection due to Biodiversity Objections raised and Climate and Sustainability Objections which have been put forward.

My husband myself and our two children have been residents of North Balgowlah for 28 years. One of the key reasons we live here is because of the beautiful natural setting it offers including the flora and fauna. Manly Dam catchment area needs to be protected from the tunnel project.
As stated by the EIS.
The Beaches Link will negatively impact significant wildlife corridors, including Flat Rock Drive and Manly Dam bushland, and marine ecosystems at Middle Harbour and the Spit.

23 threatened species will be negatively impacted. Hundreds of other species will also lose their habitat, be cut off from bushland, or be driven away - birds, frogs, reptiles, mammals and aquatic animals.

Potential contamination of creeks and the harbour threatens land and marine ecosystems.

Mitigation measures are inadequate - most animals cannot be moved, and biodiversity offsetting will not stop local wildlife extinctions.

Sydney’s bushland saved us during COVID. Now it is time for us to save it.

Please reconsider the location of the tunnel or scrap it altogether.

Linda Norman
Resident of North Balgowlah of 28 years

I wish to lodge my objections to the Northern beaches link tunnel based on the following points ; -

1. the EIS is not current and much of it was written before COVID, therefore the facts and data it contains are irrelevant to current situation eg with respect to travel time data, post covid - there is much less dependency on peak hour travel. Also more people are working from home and will continue to do so as workplaces have become more flexible. Thus a new, up to date post-covid EIS needs to be written and re submitted for community consultation.
2. the 'beaches tunnel' has been declared "worlds best practice', however, this is untrue, as 'world's best practice' would include filtration of the tunnel ventilation/emission stacks. As identified in the EIS these will NOT be filtered, therefore this plan for beaches tunnel is NOT worlds best practice and should NOT go ahead until it can demonstrate it will be world class
3. The negative impact on the communities of the lower north shore will be immense throughout the construction period and post completion. The environmental damage alone to flat rock gully will take generations to repair and the pollution from the unfiltered stacks is unacceptable when you look at the climate change issues we are already facing.

This project needs to paused while the EIS is reworked and all objections are considered in a fair and equitable manor.

Please do the right thing and stop and reassess all alternative sites and options for the project.

Regards
Concerned Northbridge Resident

Please increase the deadline for submissions!!!

The deadline for reading through these ‘scientific’ documents is too short.

Is the Government desperate to build this tunnel? for political reasons? We have been lead to believe our journey time will be a few minutes shorter, but at what cost to the environment? Is this something to be proud of for your children and grand children? Why should you care about us as boat users? (I am a boat user btw) The sediments in Middle Harbour will be disturbed by the construction of two huge coffer dams. I understand that the sediment contains toxic waste which has run off from the numerous water catchments that feed into Middle Harbour. How will this be handled? The toxic waste is from historic industrial pollution and residential development. The toxic plume could spread as far as the swimming beaches of Clontarf and MHYC beach (so many children swimming) Aquatic life will be affected. Transport for NSW say they will provide filtration curtains around the coffer dams to prevent spill. I understand that these are been scientifically proven to be ineffective. So what can you do? PLEASE PLEASE look into this further. We are so proud of our home here in Australia and we have been working to clean the waterways. What is our future to be?
I understand the spoil extracted from the tunnel dig will be loaded on to barges via the coffer dams. These will be transported to sea where the spoil will be dumped. There will be numerous barges every day for 7 YEARS!!! passing though the narrow passage outside the marinas and our club. Imagine that lot ploughing through a Wednesday race start line!
PLEASE DO NOT BE PRESSURED INTO DOING THIS INCORRECTLY. I am not against a tunnel but we are responsible for our water and land and our futures. so make the hard but good choices please.

I object to this proposal on the basis of the environmental impacts to support further cars and zero public transport. Thank you.