Great Western Highway Blackheath to Little Hartley

Hi,
I'm broadly supportive of this project but I have concerns about the impact of the construction on the houses on Evans Lookout Road that will back onto the construction site. Reading through the EIS, it looks like those occupants are facing the prospect of eight years of almost non-stop heavy construction traffic, noise, pollution, light, dust and activity. I realise it's a small number of houses, and the construction site has to go somewhere, but I was wondering what the options are for organising that construction site so as to leave a larger buffer zone between the backs of those properties.
There are families with young children in some of those properties, and the adverse impact of noise pollution as well as other forms of pollution on the health of children is well studied. Eight years of it could have long-term adverse effects on the people in those homes.
I have seen some information suggesting there is the possibility for the construction site to be shifted slightly away from Evans Lookout Road. I also understand that some of those families weren't aware until recently of the potential impacts to them personally of that construction site. I would like to argue for more sit-down consultation with those specific householders to understand their concerns and see how they can be addressed.
Thanks,
Bianca

I support the project but am concerned that no decision has been made on the tunnel ventilation system. My main concern is the visual impact of the ventilation outlet option but also it's potential increased impact to noise sensitive biota. Also it is not clear to me how the decision on the tunnel ventilation system will be made.

I am very concerned about the environmental impact of this project on the fragile ecosystems of the upper Blue Mountains. I am particularly concerned that there has been no EIS on the whole of the upper mountains, including Katoomba and Medlow Bath. As a resident of Medlow Bath I am concerned about being trapped in the village during a disaster due to there being no alternative exit road.
POINTS FOR EIS SUBMISSIONS February 2023


Environment

• Catchment
o This site is wholly within the Blackheath Special Catchment area, which protects Greaves Creek Dam on Greaves Creek, and Lake Medlow on Adams Creek. Residents living between Medlow Bath and Mt Victoria depend on these dams for their water supply.
o The Blackheath construction site will be located right at the headwaters for Greaves Creek which flows through the Walls Cave Aboriginal Area, into Lake Greaves, on into the Greater Blue Mountains World Heritage Area, through the iconic Grand Canyon into Govetts Creek and then into the Grose River. These are areas in the World Heritage Area and will threaten its status.
o Roadheaders or special rock excavators will be used to dig a 250m tunnel from Soldiers Pinch to meet the eastbound tunnel. Top portion of this tunnel would be lined, bottom half would not and any groundwater would be drained into main tunnel water system.
o Lining for the TBM tunnels would consist of precast concrete segments, transported by truck to Little Hartley site from cement factory that will need to be built for this purpose. (Ch 5, Fig 5-12)
o TfNSW state that leaching of cement from the tunnel will change the pH of ground water and could affect the downstream swamps and endangered vegetation communities.

• Swamps
The threat of sedimentation (and weeds) entering the Blackheath Special Catchment Area and the downstream World Heritage Area from both the initial clearing of the site and the 9 years of road widening and portal/tunnel construction is very real. Current water flow through the catchment area helps feed hanging swamps which are nationally endangered and which are home to a unique range of fauna including the endangered Giant Dragonfly and endangered Blue Mountains Water Skink.

• Aquifers
Will the 11km tunnel be deep enough to avoid the aquifers?
No, because cut and cover tunnels will be dug by Roadheader machines for about 250m at each tunnel portal in Little Hartley to where Tunnel Boring Machines (TBMs) can begin digging the two tunnels, and as well as at the Blackheath end of the tunnels near Evans Lookout Road. (Ch 5, 5.4.2) These shallow trenches will be “covered” but will still intercept shallow aquifers feeding the hanging swamps that are the habitats of endangered flora and fauna. The impact of shallower tunnels on the aquifers, hanging swamps and creeks and waterfalls is unknown. Inflow into Greaves Creek is predicted to be reduced by up to 15-17% due to the tunnel portal diggings.

• Air quality
o Two main types of ventilation systems are being considered for the tunnels, one using fans and vehicle flow to expel vehicle emissions out the tunnel portal; the other using a 10m high ventilation outlet stack at end of each tunnel. The tunnel portal ventilation system will use 55,000 kWh/day of electricity, while the latter will use 73,000kWh/day more of electricity per day, but emissions are somewhat lower. The EIS is leaning toward the former but they are seeking input from stakeholders and the community before deciding (Chapter 3, Tables 3-11 and 3-12). Exhaust coming out of tunnel portals will negatively impact residents living nearby which is not acknowledged.
o The effects of fine particulates on photosynthesis of vegetation are not well understood; and there is not currently an established criteria for assessment of ecological receptors with regards to PM2.5 concentrations.
o The dispersion model uses regional meteorological data to predict the direction of travel and degree of dispersion for a pollutant from the point of emission. The study used less than 12 months of data from only one (of 3 possible) sites to ‘model’ the outcome: ‘As such no significant air quality impacts are predicted for the project for the ventilation outlet option.’ Blackheath and Soldiers Pinch construction sites are considered to have a high sensitivity to dust due to their proximity to the Blue Mountains National Park which is regarded as a highly sensitive ecological receptor due to its World Heritage and National Heritage listings.
o Slightly higher annual average Nitrogen Dioxide (NO2) concentrations are generally predicted for the portal and ventilation stack emissions. NO2 lowers the pH of water and soil, making it more acidic.
o A mitigation measure for dust is locating and managing dust generating stockpiles away from sensitive human and ecological receptors. The 5000 cubic metre spoil pile at Evans Lookout Rd adjoins residences, National Park, and water catchment.

• Threatened species
o Greater Gliders: A number of mature trees with hollows (20) will be cleared for the tunnel portals and the work site at Blackheath near GWH and Evans Lookout Rd, and these tree hollows will be saved, stored somewhere and then tied up into the new trees TfNSW will plant after the tunnel work is finished. As these trees will not be mature for at least 20 years the threat on this endangered species is very real.
o Large Eared Pied Bat is also a Threatened Species affected by the Project.
o A further 8 species are likely to have their habitat affected.

• Blackheath Construction site (corner of Evans Lookout Rd and GWH)
o The worksite will extend across 23 hectares and will back on to 9 homes.
o Worksite will be operational for 9 years and will include some permanent buildings for tunnel infrastructure.
o All vegetation will be cleared and the land will be levelled at the start of the Katoomba to Blackheath Duplication and used for that, and then for the Blackheath tunnel construction.
o During construction there will be truck and light vehicle movements up to 260 times per hour or 790 movements per day (est.).
o Blackheath worksite will have parking for about 100 vehicles, including construction vehicles; but construction workers may choose to use available on-street parking which may impact on-street parking for nearby residents and visitors.
o Plans for this site have changed from the East Section Review of Environmental Factors (REF) Submissions Report (Oct 2022) to release of EIS (Jan 2023). However, the EIS states it has already been assessed and approved as part of the REF.

Trucks
• The introduction of 26/30/36m trucks affects the whole of the Great Western Highway ‘Freight Corridor’ in what is currently the only local road for many villages. TfNSW states that the GWH Duplication is about giving local roads back to locals. This is clearly not happening. A 36m truck is 2.5 times longer than a 40 seater bus, and these trucks when loaded can weigh between 84-91 tonnes). Many Blue Mountains Villages will have these trucks driving right through the centre.
• There has been no consultation with any of the Blue Mountains residents about the introduction of these 36m trucks. Only 26m and 30m trucks have been mentioned in the REF’s to date. This is an example of TfNSW misleading the public as the REF Submission Reports were released less than 5 months ago.
• What is the impact of trucks of this size in the Tunnel for all road users?
• What issues have been assessed for 26/30/36m Trucks using the GWH through other mountains villages such as Blaxland, Faulconbridge and Wentworth Falls and Medlow Bath where the highway is narrow?
• What other impacts from these larger trucks are expected and have they been assessed?
• A full assessment of the introduction of 36m trucks, as well as community and stakeholder consultation throughout the Mountains is needed immediately about this proposed change.
• A 30% increase in freight through the Blue Mountains poses significant (high) impact for road users including residents and tourists. What Socio-economic studies have assessed this?
• The Cumulative Impacts of the introduction of 26/30/36m trucks has not been assessed in any of the REF’s. There must be a pause on all construction while these are assessed, as this is a requirement of the division of the GWH Duplication into 4 separate projects.

Vibration impacts
• Tunnel Boring Machines (TBMs) dig tunnels 24/7 at rate of about 70-90m/week with the deepest point being about 200m below Mt Victoria.
• However, the tunnel would only be 25m below ground at Evans Lookout Rd and at Hartley.
• The TBM will take 5 to 6 days to pass below a single business or residence . It has been stated that while residents in the nearby area can expect to experience vibration impacts, no damage is predicted. What studies have assessed these vibration impacts? What comparisons are there with tunnels through sandstone in other areas, such as, where blocks of flats have collapsed during the construction of a tunnel?
• The roadheader machines are constructing the 90-120 cross tunnels for safety routes. Could we have some confirmation of the noise impact of construction for these? Due to the distance underground, I think noise would be minimal, but I’m no expert
• ‘Effective noise mitigation and management measures would need to be developed by the contractor to minimise the potential noise Great Western Highway Blackheath to Little Hartley impacts from these works’. When will these be developed? What are they?
• How will you ensure that the contractor will adhere to noise management and what oversight will TfNSW have on the measures the contractor develops?
• The EIS predicts a 2dB increase from construction traffic. I assume this is just the movement of construction workers vehicles, not the actual noise generated by construction machinery. If this is so, surely a whole of project EIS to predict increased noise and vibration along all of the Blue Mountains GWH (BMGWH) is ne

There needs to a full environmental impact assessment of the GWH from Lithgow to Penrith. If there is to be a predicted 16 - 30% increase in road transport over time the entire Blue Mountains transport network and its environs will be impacted by increases in noise, air pollution, traffic congestion and road safety from the predicted increases in road freight using the road.
Offsetting credits for fauna or flora needs to be independently audited and published to prevent green washing.
Alternative habitat should be provided as close as possible to disturbed areas to allow for displaced wildlife to relocate. This includes providing water, hollows, rock and log habitat and other forms of shelter needed for fauna protection.
Rail transport should be included in the EIS as an alternative to road transport with the necessary upgrades.

Please see attached document entitled "EIS Attachment (Final Lodged)" which comprises my de-identified submission objecting to the project.

I object to the project on the basis of comments in my submission as attached document. I call for an EIS for whole of project Katoomba to Lithgow rather than the piecemeal REFs that TfNSW have done. I agree with Catherine King MP for Transport to call to pause the GWHUP project until a whole of EIS can be conducted. It is obscene and pork barrelling (of particular ministers) of the state government to push through duplication of 1.2km for Medlow Bath just prior to the state election. It will be another 9 years if and before the 11km tunnel is completed. the state government needs to find another way to carry freight rather than via the GWH. I also wish it be known that this process of submitting feedback has been very clunky and not straight forward negotiating DPE website. I can only imagine those who are less tech savvy able to navigate website or get their submissions in on time.

Please see the submission from the Hartley District Progress Association

I would like to make a submission to the planned GWH Upgrade Tunnel. I object to this plan as the historical Hartley Valley would loose a lot of its character during construction and on completion of the tunnel. The tunnel and the proposed infrastructure would be out of character to the historical village.
As an individual who travels to the greater west if the construction is estimated to take 10 years to complete then travelling on the GWH would take a great deal longer during the construction.
Also there would be an environmental impact on native animals in this area.
The tunnel is primarily being planned for the accommodation of larger 36 meter b double trucks. This will add stress to the everyday commuter or tourist driving next to a large 36 meter truck especially in a long tunnel. Why not upgrade the Bells Line of Road to accommodate these trucks and leave GWH to lighter vehicles to travel on.
Overall I do not feel the upgrade of the GWH tunnel is the answer to the proposed population increase in the greater west.
Thank you for your time.
Regards

I strongly object to this project on the grounds that it jeopardises the integrity of the BM National Park and its contained World Heritage areas.

I am objecting to the ventilation proposals as described in the January 23 Community Update. One proposes a ‘Ventilation Outlet’ option, the other a ‘Portal Emissions’ option.
The tunnel is to be 11 km long and ascend 220m, a gradient of 1/50. All the emissions from vehicles making this West to East climb will be locked in the tunnel until released at the Blackheath portal or vent, and the very large number of heavy trucks in particular will contribute to unacceptable levels of pollution. This will be exacerbated by slower moving trucks making the climb, which will lead to an accumulation of vehicles in the tunnel, also in the winter months in particular by climatic conditions in the Mountains.
I appreciate the significant additional cost that will be incurred if a number if intermediate vents are constructed to release pollutants along the length of the tunnel, but failing to provide these looks like inadequate planning foresight.
To a lay resident in Blackheath familiar with the sight of heavy vehicles labouring up the mountains, the prospect of all the exhaust fumes of perhaps 50 heavy trucks and large numbers of cars, stuck in the tunnel for typically eight minutes, being pumped out constantly within the local community is unacceptable.
I spoke to the very helpful officer leading on pollution at the Blackheath briefing on 11 February, but am not convinced by the stats! I live in Evans Lookout Road, and we can frequently smell emissions from the Highway. What it would be like being on the receiving end of 11 km worth of pollution does not bear thinking about, and more to the point will be a danger to health.
Please can we see a justification for the lack of intermediate vents, or their inclusion in the plan.

I do not agree with this proposal.
It’s a waste of money
I see zero benefit
And the stress it has put on local homeowners and residents who are being forced to relocate has been horrendous.
It is also infringing on Indigenous cultural grounds
Absolutely appalled by this entire project.

I object to the project because the level of environmental impact consideration is not adequate for the size and complexity of the the project.
The project will have vast impacts on a World Heritage Area, National Park and drinking water catchments. The depth of the environmental assessments is not adequate for level of risk to such valuable natural assets and resources.
This project should be put on hold until an independent review has been done.

Please see attachment for objection to this proposed project.

Regards
Jan and Wayne Hatton

Please see attachment- protection of the climbing amenity and involvement and communication with climbing stakeholders has not been considered. The proposed development has potential impacts on rock climbers and other users of the escarpment in the vicinity of the Western Portal

See attached submission

All of my comments are within the word doc attached. I have taken a lot of time to look through the EIS and the Eastern and Medlow REFs. Please consider my comments and the comments from anyone else with the utmost respect, as we live in the Blue Mountains and respect and understand its value.

See attached

The proposed location of the Blackheath portal will result in unacceptable impacts to human health and amenity for many residents of Evans Lookout Road.

Air emissions
The proposed location of the Blackheath portal is almost directly west of numerous residential receivers on Evans Lookout Road. The prevailing winds at this location are westerly, and can be extremely strong for several hours at a time, several days a week, depending on the season. The Air Quality Impact Assessment (Appendix E) notes that under the ventilation outlet option, NO2 and PM2.5 emissions will increase for residents east of the portal, because of these prevailing westerly winds (see Fig. 8-4 and Fig. 8-10 in the AQIA, respectively).

The AQIA states that these increases are “small in magnitude” (pg. 449). However, over the life of the project, these increases in air emissions are highly likely to negatively impact the health of residents on Evans Lookout Road. Placing the health of large numbers of residents at risk is totally unacceptable for a NSW Government project in the 21st century. Although the modelled air emissions are lower under the portal option, all potential risks to human health from increases in air emissions can easily be mitigated by moving the portal location south by 500 metres, as the prevailing westerly winds would not intersect any residential dwellings. Any additional costs incurred by slightly repositioning the Blackheath portal 500m further south would be negligible relative to the total cost of the project.

Noise emissions
Unlike the AQIA, the Noise Impact Assessment (Appendix G) does not appear to adequately consider prevailing winds at the Blackheath portal. As noted above, these winds are generally always westerly and can be extremely strong. Residents halfway down Evans Lookout Road already experience significant noise from traffic on the Great Western Highway when westerly winds blow, to the point that sleep patterns can be impacted. Further, at several points south of the Blackheath portal entry/exit location, the roadway is proposed to be elevated several metres above the surrounding landscape (see Fig. 5-79, Appendix N). Traffic noise from such an exposed location will carry for many hundreds of metres with the prevailing westerly winds, with resultant increased impacts on residents located east of the portal. For the Noise Impact Assessment to conclude that operational noise from the Blackheath portal would have minimal impact on residents located east of the portal seems grossly optimistic.

As with air emissions, the likely increases in noise impacts could be easily addressed by moving the portal location south by 500 metres, as the prevailing westerly winds would not intersect any residential dwellings.

I do not support the full plan for this tunnel upgrade as I have concerns about its environmental and visual impact and on the potential for de-stabilisation of the fragile landscape of the World Heritage listed Blue Mountains.
I am concerned about destabilisation of the ground beneath the Villages of Blackheath and Mount Victoria and of all the surrounding World Heritage Landscape.
As has been evidenced at The Gardens of Stone, mining below the surface can have structural impact on the fragile landforms above despite the best intentions and planning of the mining contractors. Not all water courses and fault lines can be detected to prevent such ‘accidents’.
So I personally would err on the side of extreme caution when dealing with this significant landscape.

As for a safer town centre for cyclists and pedestrians in Blackheath, we are talking about a village, not a metropolitan centre, and these are not present risks and not worth building a road diversion tunnel for.

Whilst I acknowledge that there can be large traffic backlogs coming over the Victoria Pass and into Mt Victoria and Blackheath on weekends and public holidays, I am concerned that such a huge and long tunnel project, added to many underway in and around Sydney, can have detrimental effects and also can increase our reliance on motor vehicles and trucks and the sole means of transport and freight from the West into Sydney. This leads us inescapably into future reliance on this infrastructure system.

To bring us into line with other world standards what is preferable for me is a fast rail system.
The cost for families employing current internal combustion engines and paying ever increasing road tolls makes it prohibitively costly to travel.

Tunnel Ventilation : Exhaust Towers option:
Visually I am concerned about the tunnel exhaust towers planned proposed in relation to the size of the local communities, the scale of the landscape, height of existing buildings, and disjuncture with the landform.

Tunnel Ventilation : Portal emissions option:
The Longitudinal Ventilation option seems highly risky and unproven for the and rescue/ emergency options for this more isolated area are sketchy given the scale of this project and relative isolation of the area.

The tunnel will only make a major difference to overall traffic flow on weekends and public holidays and the tolls would be anticipated to be high cost for many years to come beyond the viable use of fossil fuel vehicles. Will new infrastructure need to be added as soon as 3-5 years down the tracK?

By personal choice I do not use the M4 tunnel into Sydney. The time saving is negligible and the cost adds up. I wonder if offered the choice families will pay for the proposed tunnel ? Rather it is a freight diversion that will ease traffic congestion.
I would prefer to see an upgrade to railway infrastructure.

In terms of the ongoing construction period, and likely delays, I’m really concerned about the ongoing disruption to normal life, further and potentially extreme traffic delays and backlogs caused by the construction, visual impact over several years of the construction sites, infrastructure and increased heavy duty vehicle traffic that is involved. Evidence of such disruption is evident all over Sydney, for example at the approach the Victoria Road and Anzac Bridge from the Western Distributor.

Is this kind of visual carnage really something that is suitable to impose upon the still relatively pristine Blue Mountains environment?

The EIS is deficient in not fully examining the impact on the residents of Hartley especially during the long, 8 years of tunnel construction. The Hartley community will have to endure some 10 years+ of construction with in all likelihood the tunnel project (if approved) will coincide with the Upgrade works from Hartley to Lithgow. The EIS is required to articulate and consider the cumulative impact. That in my view has not been done in a fashion that is objective or adequate. The Hartley community will bear the brunt of the construction impact but the EIS seems to infer that is only temporary and possibly okay given there is a lesser impact on Blackheath and Mt Victoria. Some 8 to 10 years of construction activity is not temporary. There are glaring omissions, notably the separate approvals of infrastructure directly needed for this project - what is the point of having an EIS when bits and pieces can be carved off and assessed separately. The Hartley community has been through the REF process for the West section and despite overwhelming opposition, the REF was approved and then subsequently, the design was modified which added more pain for the locals. It seems a similar path is again being trod by Transport - this should not be allowed. Communities should be informed about the full impact and not left wondering what could happen. I support the position taken by the Hartley District Progress Association - their submission details the various matters which are deficient and in need of redress.
Both this EIS process and the REF process has involved a huge amount of reading (thousands and thousands of pages) and much of it being technical. Communities cannot be expected to sit, read and absorb so much data - the opportunity for group based Q&A was not existent - communities get more out of Q&A sessions than just rocking up and seeing maps on tables and expecting to understand the situation. That process for such large infrastructure projects must change.
In conclusion, I do not support the project as the EIS is grossly under-estimating the environmental, social, heritage and economic impact on Hartley Valley.