Great Western Highway Blackheath to Little Hartley

I have attached a submission objecting to the comments in the EIS for the above project.

Please find submission attached

I object to the project until further investigations have taken place, as detailed in my submission.

My concern is about the impact the proposed tunnel and its construction might have on the World Heritage Area and is determined to ensure this is minimised, and that matters of national environmental significance are addressed.

I am concerned that the current piecemeal approach, dividing the upgrade into sections for review, is totally inadequate as it won’t provide a true understanding of the cumulative impact and long-term consequences for the World Heritage Area.
Aquifers supplying groundwater to groundwater-dependent ecosystems, and their dependent species, along both sides of the tunnel corridor, are at significant risk as changes to water flow is expected. A reduction in groundwater to the Commonwealth-listed Peat Swamps, particularly those near Blackheath, poses a real threat to their populations of Giant Dragonfly and Blue Mountains Water Skink, which are both endangered.
Despite this EIS being released, I want the Federal Government for a full EIS across the entire Great Western Highway project upgrade to ensure that matters of national environmental significance are addressed

Please see attached word document for details

The EIS is flawed as it does not include the environmental impacts that an upgrade will cause further along the GWH when further road widening and straightening is undertaken. And when hundreds of mature eucalypts are removed which will destabilise embankments next to the railway line.
And if the Blackheath bottleneck is removed, it will simply move that bottleneck to Katoomba and its busy 4 sets of traffic lights, at which point there are several back streets that the traffic will use that will cause environmental damage to these quiet back streets and adjoining bush. Not to mention accidents due to speeding motorists especially those who don't know the area and/or are challenged by the frequent foggy days.
The EIS also does not adequately address the polluted water (oils and concrete and spills and stormwater) that will flow into the upper Blue Mountains water catchment, the environmentally sensitive swamps and the world heritage national park.

Portal emissions or ventilation stack

Meeting the air quality goals

The EIS presents strong justification for portal emissions - in particular the significant reduction in energy costs. However the ongoing concern with portal emissions is how to monitor emissions (limits) at the portal. With ventilation stacks, emissions can be monitored for compliance to predetermined emission limits which in turn gives confidence in meeting ambient air quality levels near the closest receptors. However for portal emissions it is not clear whether measuring emissions from portals is practically possible. In this regard, for nearby receptors there is sole reliance on the air quality modelling that ambient air quality goals can be met. In addition, without setting emission limits at the point of emission from the tunnel (the portals) it does not address optimising the performance of the tunnel ventilation system - that is the operator can operate the tunnel in a suboptimal way (in terms of ventilation) result in “polluting up” to the ambient goals for the nearest receptors. By polluting up - meaning a potential significant change in air quality for closest receptors but still technically meeting the ambient goals. The community needs to be assured how monitoring of stack emissions will not only meet ambient goals but also optimise air quality outcomes for the community.

Design of the ventilation stack

Noting that ground level (portal) emissions are able to meet ambient air quality goal it is unclear why the ventilation stack needs to be 10 metres in height.

The current design of the ventilation stack could be improved. Whilst it is accepted this is a subjective issue - a more slender /less imposing design would have less visual impact. In addition it is assumed that far more dense screening could be provided such that with reduced height and dense screening it may not even be visible from public viewing locations

An alternative (and assuming a lower height can be achieved) could be to integrate the ventilation stack into the Motorway Control Centre.

The RtS should present the ventilation stack with more sensitve urban design outcomes (rather than presumably worse case) and could include denser screening options.

Motorway Control Centre

It is unclear why such a large area is required in comparison to all other motorway control centres currently operating in Sydney. In particular the extent of parking appears excessive. A major reduction in the size of the MCC would have considerable benefits in reducing impacts. Integration of the ventilation stack would also reduce the overall footprint of this site.

TBM operation

The decision to run both TBMs from the Little Hartley with all spoil removed to the west is commended and would be a fundamental aspect to the acceptability of the project. Accordingly, this should be locked in by way of an explicit condition of approval. Furthermore, DPE should consider whether this requirement could be conditioned by the Minister such that any change would result in a new Environmental Impact Statement rather than through a potential modification process.

I live in Faulconbridge and travel to Lithgow and further west from time to time along with traveling to Jenolan Caves with visitors to the Blue Mountains. I am looking forward to highway improvements that increase safety, improve the quality of journey, reduce speed zones and improve the environment for the local residents in the Blue Mountains.
I am in favour of a tunnel from Blackheath to Little Hartley. I would prefer a tunnel from Katoomba to Little Hartley, however, I have been informed that the proposed upgrading of the highway from Katoomba will only have one set of traffic lights at Medlow Bath and the rest of the highway will be realigned and built to a very high standard. Never the Less, I have concerns regarding the long term impact of the highway through Medlow Bath, both from a traffic and a locals point of view.
When building this tunnel and in fact all tunnels in NSW, provision should be made for running high voltage power distribution cables (330Kv). One of the major costs in under-grounding power is the cost of digging the trenches, by planning to use road tunnels would considerably reduce costs and have the additional advantages of reducing environmental impacts such as bush fires, aircraft accidents, and visual impacts, especially in national parks. Please consider this option for this tunnel and any future tunnels along with including provisions for telecommunications (fibre) cables.

Best regards,
Michael Parker

Why?
The need for the upgrade is questionable and seems out of proportion to the cost and damage that will be done.
Environment
A comprehensive EIS for the whole of the affected highway should be completed and made public. In particular there is no information on the effect of the tunnel on underground water and the ecosystems it supports.
Alternatives
The alternative of freight by rail should be investigated and reported on before this destructive option should be considered.

See attached PDF

Please see attached document.

The CNSWJO policy is that we are “solution agnostic” to a safe swift and secure link between Sydney and the Central West and the Board shares the Deputy Premier, The Hon Paul Toole’s vision for dual carriageway at 100km per hour for the Great Western Highway.
The Board thanks the Government for its commitment towards the project that will ultimately give an additional 67km of dual carriageway and greater safety especially for emergency vehicles. The Board understands the planning for tunnels to reduce the gradient down the western escarpment, with the current Blackheath to Little Hartley section on exhibition, and it is pleased to learn that dual carriageway is possible through this challenging terrain.
Further, the region is concerned that the congestion through the Blue Mountains not only impacts through traffic but has significant impacts on local communities and supports upgrades that minimises this congestion. This congestion has been exacerbated by landslips caused by the significant rain events through the past three years of La Nina.

1 March 2023

Director of Transport Assessments
Planning and Assessment
Department of Planning and Environment
Locked Bag 5022
PARRAMATTA NSW 2124

RE: GREAT WESTERN HIGHWAY BLACKHEATH TO LITTLE HARTLEY
ENVIRONMENTAL IMPACT STATEMENT
I would like to lodge my submission response to the above nominated project. My response includes the Hartley District Progress Association’s response as they have clearly articulated the significant and appalling omissions by the EIS, and I wish to show that I agree with their points. A summary of our joint position is provided below, with a more detailed response provided in the Attachment.
From a personal point of view, the environmental impacts on the Hartley Valley will be enormously debilitating for residents, local business, and wildlife, and it doesn’t appear that these impacts have been taken into account by the EIS. The 24hr / 7day week noise and extra-bright night lighting of drilling and heavy machinery in an inhabited valley with tourist operations is just the start of the problems. There is an almost complete lack of information about population numbers of the severely at-risk populations of endangered birds and animals, let alone the impacts of dust, noise and poisoned wastewater on flora and fauna. As this EIS is based on a ‘preliminary’ design, the impacts of anything actually to be implemented are not able to be specified or examined in detail, and this leaves us open to very significant changes being made after the EIS is approved, with no oversight (as has happened with the REF for the Little Harley to Lithgow section, where a THIRD truckstop has been added after the REF approval, without communication or consultation of the local community). Alongside the fact that the Little Hartley to Lithgow part of the project doesn’t have an EIS, but simply a REF, an in-house assessment of the enormous impact of the West section of the project, and the fact that a large number of built structures to be housed in the Valley and up to Lithgow have been excluded from the EIS just ‘because’, then we have a deeply concerning situation about the environmental impacts not being properly assessed over almost the entire distance of the project. There is almost nothing about the impact on Hartley Valley of noise, poisonous dust, loss of water, gaining of poisoned wastewater, the venting of gas from the completed tunnel – the list of things ignored or not dealt with seems endless, and the impacts locally to be so deleterious as to make life in the Valley untenable. This project appears to be being rushed through without proper detailed assessment of impact, while the local population will bear the ongoing impacts for the rest of our lives. Loss of clean air, loss of tourist amenities of Valley life, destruction of heritage character – all gone forever, with no care given in the project design and assessment phase.
Alongside my personally noted impacts, I agree with the positions articulated below by the Hartley District Progress Association (HDPA). The HDPA believes there will be unacceptable environmental impacts on the Hartley Valley community from both the construction and operation of the tunnel proposed in the Blackheath to Little Hartley Environmental Impact Statement (EIS). The EIS has failed to adequately assess the full impacts on the Hartley Valley, especially in relation to the cumulative construction and long-term operation impacts on the Hartley Valley. The EIS also does not fully address the economics of the project as it fails to include any discussion about the Benefit Cost Ratio (BCR). This in a context where both the capital and operating costs of the project will be enormous, with operating costs being intergenerational.
In particular:
• The EIS is based on a ‘preliminary’ concept design, one that is subject to substantive change and as a result, the true impact on the Hartley Valley community will never be known since the assessment is based on fiction and not reality.
• The Hartley Valley community will experience untold construction fatigue stretching over at least 10 years of daily construction related works – from early 2023 through to 2032. In our view, the EIS is negligent in grossly understating the construction impact on the Hartley Valley.
• It is also negligent in not considering the funding pause by the Federal Government which has created a construction delay. If this project is approved, it will result in construction of the tunnel commencing at the same time as major construction works of West (and East) sections of the GWH Upgrade. In other words, the 34km corridor will be ‘in construction mode’ for at least a decade, not just the ‘11km tunnel’.
• The EIS categorically states that construction of the tunnel project and the adjacent Upgrade projects will be undertaken consecutively. In reality, it is likely that all elements of the GWH Upgrade will be under peak construction at the same time and as a result, the EIS has grossly understated the impact of construction works, especially on the Hartley Valley.
• The EIS is negligent in allowing key construction facilities and works, including the powerline construction to the proposed substation, TBM precast segment plant, concrete batching plant and supply and sourcing of water for the project to be assessed outside this EIS and undertaken as part of the West section upgrade or separately – again an unacceptable situation especially given the magnitude of what is proposed and the fact there is no definitive information about these facilities;
• We cannot see how the concept design is an ‘environmentally-led design’. This may be the case for the communities of Blackheath and Mt Victoria. It certainly is not the case for the Hartley Valley community. Despite recognising the Hartley Valley for its unique beauty, its heritage and its rural residential character, the EIS states the project during construction and operation will significantly change the landscape character of the Valley and the impact will be adverse’ – in other words, the effect of the project on the Hartley Valley even when completed will be permanently adverse and therefore entirely inconsistent with the heritage, character and environmental significance of the Hartley Valley.
• The EIS illustrates the negative impact of the project on the local Hartley businesses during the operational phase, with a real threat to their future viability creating a potential long-term and permanent loss for the local Hartley Valley community. The EIS also fails to address the capital and operating cost of the project and, the BCR assessment. These matters need to be included in the EIS in order to give a balanced view of the proposal’s potential value to the local and broader communities which presently appears to be grossly and selectively overstated.
• The Hartley Valley will become the ‘dumping ground’ for all things construction and bring with it associated adverse environmental impacts. In this vein, it is somewhat bizarre to read in the EIS that reducing the impacts on Blackheath and Mt Victoria is far more important and a priority compared to the Hartley Valley.
• The EIS views the adverse amenity impact on the Hartley Valley as being low, a statement that is untrue given the anxiety and stress health impacts already within the local community arising from the Little Hartley to Lithgow Upgrade which has been dealt with under a less rigorous and independent environmental assessment – a Review of Environmental Factors (REF). Adding the impact of the tunnel project only exacerbates the impact on the Hartley Valley, a position the EIS fails to understand or appears designed to avoid.
• Using an EIS process for the tunnel but relegating the works in the Hartley Valley to a REF is political, lacks scrutiny and is motivated by the perception within Transport for NSW (TfNSW) and Government - that the REF process is quicker than the independently assessed and more rigorous EIS and involves self-assessment by TfNSW and self-determination of its own proposal.
• Nowhere in either the Little Hartley to Lithgow REF or the EIS for the tunnel section does TfNSW address why it is that the lesser REF is suitable at all or suitable now given that an EIS process was used in relation to the Concept Design 2011/2013 and that Concept Design was far less environmentally impactful than the most recent Concept Designs addressed in the REF.
• The EIS is deficient in firstly not informing communities spread across the Mountains that the primary purpose of the tunnel is to facilitate 36-metre long B-double trucks using the GWH through the Mountains and, secondly, in considering allowing such trucks on a road system in the lower Mountains that is neither fit nor safe for use by such large vehicles.
• We believe the EIS is wholly deficient in view of the heritage significance of the Hartley Valley, Little Hartley and heritage in general. We believe the precautionary principle should be applied to redirect the Western tunnel alignment away from its proposed route directly under the hugely significant 1832 convict causeway on Victoria Pass.
I and the HDPA are strongly of the view the EIS has failed its prime objective of assessing the full environmental impact on the Hartley Valley and because of that, it has under-stated the impact quite severely. The EIS should not be approved in such circumstances.
Yours sincerely,
Matthew Hilder , resident of Little Hartley
(with many thanks to the Hartley District Progress Association for their detailed submission, with which my view align)

I have attached my submission below.

As a longtime member of the Upper Blue Mountains community, I feel I have a responsibility to protect, and act as a custodian to the magnificent Greater Blue Mountains World Heritage Area (GBMWHA), not only for those of us privileged to be living here, but for all of Australia and the world. Therefore I cannot support the Katoomba to Lithgow GWH Upgrade, nor can I support the plans to build an 11-km tunnel from Blackheath to Little Hartley as described in the EIS.

I am opposed to this project as set out in the EIS. My reasons for this are set out in the attached submission. Thank you for providing me with the opportunity to express my concerns, and thank you for taking the time to read them.

Major issue here. I can ONLY "comment" or "Support"---which is silly as I want to do BOTH.
Reading the Health Dept. Report it seems to say that as the Entrances & Exits are NOT near populations then no additional exhaust outlets are required. Clearly when the Tunnel is finished the population will seek to build / live CLOSE to the new road & you can consult me later if you need this explained about the nearness of people. Safety to all needs to be at the forefront of all such decisions & remember that many are demanding more people to live in Sydney, which includes the Blue Mountains. Thank you for reading this far. Regards, BobM.

Please find attached MS word file.

1 March 2023

Director of Transport Assessments
Planning and Assessment
Department of Planning and Environment
Locked Bag 5022
PARRAMATTA NSW 2124

RE: GREAT WESTERN HIGHWAY BLACKHEATH TO LITTLE HARTLEY
ENVIRONMENTAL IMPACT STATEMENT
I would like to lodge my submission response to the above nominated project. My response includes the Hartley District Progress Association’s response as they have clearly articulated the significant and appalling omissions by the EIS, and I wish to show that I agree with their points. A summary of our joint position is provided below, with a more detailed response provided in the Attachment.
From a personal point of view, the environmental impacts on the Hartley Valley will be enormously debilitating for residents, local business, and wildlife, and it doesn’t appear that these impacts have been taken into account by the EIS. The 24hr / 7day week noise and extra-bright night lighting of drilling and heavy machinery in an inhabited valley with tourist operations is just the start of the problems. There is an almost complete lack of information about population numbers of the severely at-risk populations of endangered birds and animals, let alone the impacts of dust, noise and poisoned wastewater on flora and fauna. As this EIS is based on a ‘preliminary’ design, the impacts of anything actually to be implemented are not able to be specified or examined in detail, and this leaves us open to very significant changes being made after the EIS is approved, with no oversight (as has happened with the REF for the Little Harley to Lithgow section, where a THIRD truckstop has been added after the REF approval, without communication or consultation of the local community). Alongside the fact that the Little Hartley to Lithgow part of the project doesn’t have an EIS, but simply a REF, an in-house assessment of the enormous impact of the West section of the project, and the fact that a large number of built structures to be housed in the Valley and up to Lithgow have been excluded from the EIS just ‘because’, then we have a deeply concerning situation about the environmental impacts not being properly assessed over almost the entire distance of the project. There is almost nothing about the impact on Hartley Valley of noise, poisonous dust, loss of water, gaining of poisoned wastewater, the venting of gas from the completed tunnel – the list of things ignored or not dealt with seems endless, and the impacts locally to be so deleterious as to make life in the Valley untenable. This project appears to be being rushed through without proper detailed assessment of impact, while the local population will bear the ongoing impacts for the rest of our lives. Loss of clean air, loss of tourist amenities of Valley life, destruction of heritage character – all gone forever, with no care given in the project design and assessment phase.
Alongside my personally noted impacts, I agree with the positions articulated below by the Hartley District Progress Association (HDPA). The HDPA believes there will be unacceptable environmental impacts on the Hartley Valley community from both the construction and operation of the tunnel proposed in the Blackheath to Little Hartley Environmental Impact Statement (EIS). The EIS has failed to adequately assess the full impacts on the Hartley Valley, especially in relation to the cumulative construction and long-term operation impacts on the Hartley Valley. The EIS also does not fully address the economics of the project as it fails to include any discussion about the Benefit Cost Ratio (BCR). This in a context where both the capital and operating costs of the project will be enormous, with operating costs being intergenerational.
In particular:
• The EIS is based on a ‘preliminary’ concept design, one that is subject to substantive change and as a result, the true impact on the Hartley Valley community will never be known since the assessment is based on fiction and not reality.
• The Hartley Valley community will experience untold construction fatigue stretching over at least 10 years of daily construction related works – from early 2023 through to 2032. In our view, the EIS is negligent in grossly understating the construction impact on the Hartley Valley.
• It is also negligent in not considering the funding pause by the Federal Government which has created a construction delay. If this project is approved, it will result in construction of the tunnel commencing at the same time as major construction works of West (and East) sections of the GWH Upgrade. In other words, the 34km corridor will be ‘in construction mode’ for at least a decade, not just the ‘11km tunnel’.
• The EIS categorically states that construction of the tunnel project and the adjacent Upgrade projects will be undertaken consecutively. In reality, it is likely that all elements of the GWH Upgrade will be under peak construction at the same time and as a result, the EIS has grossly understated the impact of construction works, especially on the Hartley Valley.
• The EIS is negligent in allowing key construction facilities and works, including the powerline construction to the proposed substation, TBM precast segment plant, concrete batching plant and supply and sourcing of water for the project to be assessed outside this EIS and undertaken as part of the West section upgrade or separately – again an unacceptable situation especially given the magnitude of what is proposed and the fact there is no definitive information about these facilities;
• We cannot see how the concept design is an ‘environmentally-led design’. This may be the case for the communities of Blackheath and Mt Victoria. It certainly is not the case for the Hartley Valley community. Despite recognising the Hartley Valley for its unique beauty, its heritage and its rural residential character, the EIS states the project during construction and operation will significantly change the landscape character of the Valley and the impact will be adverse’ – in other words, the effect of the project on the Hartley Valley even when completed will be permanently adverse and therefore entirely inconsistent with the heritage, character and environmental significance of the Hartley Valley.
• The EIS illustrates the negative impact of the project on the local Hartley businesses during the operational phase, with a real threat to their future viability creating a potential long-term and permanent loss for the local Hartley Valley community. The EIS also fails to address the capital and operating cost of the project and, the BCR assessment. These matters need to be included in the EIS in order to give a balanced view of the proposal’s potential value to the local and broader communities which presently appears to be grossly and selectively overstated.
• The Hartley Valley will become the ‘dumping ground’ for all things construction and bring with it associated adverse environmental impacts. In this vein, it is somewhat bizarre to read in the EIS that reducing the impacts on Blackheath and Mt Victoria is far more important and a priority compared to the Hartley Valley.
• The EIS views the adverse amenity impact on the Hartley Valley as being low, a statement that is untrue given the anxiety and stress health impacts already within the local community arising from the Little Hartley to Lithgow Upgrade which has been dealt with under a less rigorous and independent environmental assessment – a Review of Environmental Factors (REF). Adding the impact of the tunnel project only exacerbates the impact on the Hartley Valley, a position the EIS fails to understand or appears designed to avoid.
• Using an EIS process for the tunnel but relegating the works in the Hartley Valley to a REF is political, lacks scrutiny and is motivated by the perception within Transport for NSW (TfNSW) and Government - that the REF process is quicker than the independently assessed and more rigorous EIS and involves self-assessment by TfNSW and self-determination of its own proposal.
• Nowhere in either the Little Hartley to Lithgow REF or the EIS for the tunnel section does TfNSW address why it is that the lesser REF is suitable at all or suitable now given that an EIS process was used in relation to the Concept Design 2011/2013 and that Concept Design was far less environmentally impactful than the most recent Concept Designs addressed in the REF.
• The EIS is deficient in firstly not informing communities spread across the Mountains that the primary purpose of the tunnel is to facilitate 36-metre long B-double trucks using the GWH through the Mountains and, secondly, in considering allowing such trucks on a road system in the lower Mountains that is neither fit nor safe for use by such large vehicles.
• We believe the EIS is wholly deficient in view of the heritage significance of the Hartley Valley, Little Hartley and heritage in general. We believe the precautionary principle should be applied to redirect the Western tunnel alignment away from its proposed route directly under the hugely significant 1832 convict causeway on Victoria Pass.
I and the HDPA are strongly of the view the EIS has failed its prime objective of assessing the full environmental impact on the Hartley Valley and because of that, it has under-stated the impact quite severely. The EIS should not be approved in such circumstances.
Yours sincerely,
Margaret Hilder, resident of Little Hartley
(with many thanks to the Hartley District Progress Association for their detailed submission, with which my view align)

A very experienced structural engineer, Peter Rochlin, has assisted me with understanding the design issues in this project and he maintains that you do not need a TBM as it is expensive and its proclaimed advantage of minimising environmental damage is not correct. Just as roadheaders were used in North Connect with 3 incision points to expedite the project, the same could be used in this Blackheath to Hartley tunnel, reducing the time taken from 8 to 3 years. Freight carriages could be used to remove soil rock etc from the mid incision point.
Also the portal method of emissions reduction should be used or lateral ventilation shafts.
The houses that may be affected by soil subsidence should be detailed.
Overall the project is highly commendable with a Benefit Cost ratio of 3:1 and should be commenced immediatley.