Great Western Highway Blackheath to Little Hartley

See attached submission

The Blue Mountains World Heritage Institute welcomes the opportunity to comment on the proposed works for the Greater Western Highway. As a research institute, our focus is on understanding and supporting an evidence base for decisions.

We are not able to support the project as it is currently proposed, there are a number of issues related to run off that have not been adequately addressed in the EIS. The project is situated within a receiving environment that is recognised as a World Heritage Area and is home to a network of Temperate Highland Peat Swamps on sandstone, listed as a threatened ecological community under the Environment Protection and Biodiversity Conservation Act 1999. The project as proposed will have a negative impact on the World Heritage Area and the Temperate Highland Peat Swamps.

The Institute has recently completed research in relation to the contamination of Upland Swamps and Waterways: Water from concrete leachate, outlining specific risks associated with potential contamination sources. The research concludes that concrete materials, particularly in the form of recycled concrete aggregates that become exposed to water, can rapidly modify water chemistry. This includes the dissolution of contaminants into water at concentrations that could be ecologically hazardous to aquatic and terrestrial species. Please find that research report attached.

This research project also included the development of a Decision Support Tool to provide high level graphic and spatial data on water flows in relation to the proposed highway expansion and the network of Temperate Highland Peat Swamps surrounding the catchment area.

Our concerns with the proposed project relate to soil contamination and degradation of the upland swamps, specifically;
- soils and contamination, the report does not adequately acknowledge the impact of the run off from the concrete from road infrastructure, nor does it address any issues related to construction materials.
- groundwater issues from run off from the highway that would indicate some considerable risk of degradation of endangered upland swamps in the world heritage area, including nearby flora and fauna.

We welcome the opportunity to discuss our concerns with you further and particularly how the Decision Support Tool can be used to mitigate negative impacts on the World Heritage Area, including the endangered Temperate Highland Peat Swamps.

Regards

Jane Powles

28 February 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,
Rebecca Hilder, resident of Little Hartley
(with many thanks to the Hartley District Progress Association for their detailed submission, with which my view align)


 

Please see attached submission.

Please see attached submission,

Firstly, what does someone have to do to get on the email list for updates from RMS about this project? I've nominated for emails a few times on the project website, been to community meetings and even rung the project team. Recently I was told that they 'were having problems with their mailing list'. It's Not Good Enough.
I have two primary concerns about this project.
1. The last minute change of route. When I was purchasing a property in 2021/22 the published route was under Station St Blackheath. Now it's been moved three blocks to be near my new home. Not happy, especially as RMS told us during the settlement period that it was not affected.
2. The discussion of potential property damage from tunneling is very vague and puts off all detail until the post-approval stage, into the CEMP and CNVMP. This issue has been analysed to death during Westconnex, so I'd have expected more detail to be available at this stage.
App. R states "Where the use of vibration intensive equipment within the relevant minimum working distance from a building or structure cannot be avoided, a detailed inspection of the building or structure will be carried out prior to the commencement of the vibration intensive work. A written and photographic report will be prepared to document the condition of building or structure, and a copy of the report will be provided to the relevant landowner or land manager."
A. What is the "minimum relevant working distance"? Is that from the centreline or outer boundary of the project tunnels? Is it to the property boundary or the edge of the structure?
B. When do landholders find out if they will be offered a report?
C. Who makes the decision that damage has been caused by tunneling? There should be an Independent Property Impact Assessment Panel.
D. Will landholders outside the 'minimum relevant working distance' be able to get reports done at their own expense and have possible damage assessed by the Panel?

Traffic Management during construction to manage the flow of vehicles from Katoomba up to Blackheath specifically. The traffic is heavy normally & it is difficult to enter and exit the GWH at Abbot Street, Blackheath. Also - the rh turn lights from GWH into Govetts Leap Road needs a green light to allow traffic to turn right into GL Road. This is due to increased traffic heading towards Mellow Bath. It is extremely difficult to turn right at any time and will be worse during construction.
I support the Portal preference for emissions.
Please ensure that signage is clear on the GWH well in advance of entering the tunnel at Blackheath. Also, ensure signage describes the exit/entrance opportunity at the tunnel entrance at Blackheath. Plus signage advising that this will be the only opportunity to exit the tunnel until Hartley.
Please ensure there is sufficient signage early enough to ensure drivers can visit Blackheath - ie. do not enter the tunnel.
I would like assurance that houses on the western side of the highway at Blackheath - in Abbot St, Bridges St, Lookout St and Jellico Street are assessed concerning potential damage prior to the tunnel being commenced.
Thank you for the opportunity to make comments.

Please find submission attached

I object to the project to build a tunnel from Little Hartley to Blackheath.
The tunnel will do nothing to ease congestion on the Great Western Highway and a better and more cost effective solution should be found to facilitate traffic movements.
Infrastructure on this scale is completely out of character for the Hartley valley.

Thank you for the opportunity to comment. I object to the proposed tunnel for the following reasons:
• Firstly, the EIS is a preliminary concept design and subject to change, asking for comments on the proposal and then having the ability to change the design does not seem like a fair and equitable process!
• There has been no Benefit Cost Ratio (BCR) addressed in the EIS and a project of this magnitude should at least be able to justify to the taxpayers who are ultimately paying for it why it is considered a viable project, on numerous occasions it has been cited as a project that doesn’t stack up economically from more than one source .
• The proposed design is completely out of character for the historic Hartley Valley, the construction process will have a significant impact on the valley for years to come and when completed the portal and infrastructure needed to support operation of the tunnel will have a significant detrimental visual impact and will have significantly altered the sense of place of the area.
• The upgrade and tunnel proposal is designed to facilitate movement of heavy vehicles to and from the central west with no regard to residential areas along the corridor, a speed limit of 100 km per hour is unacceptable and add to that the scenario of allowing B-Doubles to travel on the highway and through the tunnel makes it even worse. Heavy vehicles will still have to contend with and travel through the linear residential villages of the upper and lower Blue Mountains dealing with high pedestrian traffic, school zones, traffic lights and various speed limits and as such the tunnel and associated upgrade do nothing to expediate travel times. Traffic modelling has shown a saving of around 10 mins of travel time between Medlow Bath and Little Hartley, any time saved is immediately lost in having to travel up or down the Great Western Highway as it snakes its way through the Blue Mountains.
• There is no entry or exit points in the tunnel for Mt Victoria or Blackheath for that matter and this should be addressed not only for the residents and businesses, but also, should there be an accident or an emergency in the tunnel people should be able to exit immediately. Emergency vehicles would be hampered by this omission.
• The proposed construction phase of the tunnel is designed to have minimal impact on the eastern end and residents of the Blue Mountains whereas the western portal and Little Hartley and therefore the Hartley Valley bears the brunt of construction and adverse impact to the environment for years to come. The EIS acknowledges the beauty, heritage value and rural residential qualities of the Hartley Valley and yet the construction phase (years) and completed project design does nothing to enhance those qualities, actually the area will be completely spoilt with a project that is over engineered and overpriced, offering no real benefit to the community.
• The proposed works operating 24 hours per day seven days a week will have a significant adverse impact on the residents and businesses in the valley.
• The EIS recognizes that ventilation stacks would not be suitable in a highly sensitive and unique environment ie the Blue Mountains National Park, there doesn’t seem to be the same acknowledgement given to the historic Hartley Valley though, a tunnel and project of this magnitude has no place in this valley. Our history should be preserved.
• The 2 options for ventilation that are being considered both come with significant risk to human health, vehicles could well be stuck in the tunnel in the event of an accident/emergency for a considerable amount of time, additionally the EIS states that the carriage of dangerous goods through the tunnel will be determined as the design progresses. I can personally recall a situation when a truck carrying chemicals overturned at the bottom of Victoria Pass, the crew attending the accident and clean-up operation wore Hazmat gear and the Pass was closed for a considerable time, the driver trapped in his truck was overcome with toxic fumes and sadly died at the scene of the accident. The toxic smell lingered in the area for some days and nearby residences were advised to close their windows and avoid being outside if possible. Imagine a scenario like that with people trapped in an 11km tunnel without ventilation stacks. The option that forces emissions out with the flow of traffic would do nothing to disperse emissions in the event of traffic not moving, also not far from the western portal there is a proposal for a parking bay with access to Berghoffers walking track and a cycle /walking track down into Hartley historic village people could be potentially exposed to emissions that are being forced out at concentrated levels as they have had no opportunity to disperse into the atmosphere along the length of the tunnel.
• There is also a potential health risk for construction workers, it is well documented that tunneling poses a real risk, Silica and some silicates are some of the most common and hazardous dust particles found in tunnel construction. Given the recent media coverage about possibly banning certain building materials due to the health risks to workers I would like to think that this matter has been addressed adequately to ensure safety, silicosis is a lung disease that can be fatal. The spoil from the tunneling would then be transported via road through the Hartley Valley and Lithgow posing a further health risk enroute.
• The western portal is to be situated within close proximity to the convict stockade, the proposed Little Hartley worksite and tunnel is just not acceptable for an area of such historical significance.
• Water for the project if bores are sunk to enable work will possibly have an adverse impact of valley residents who have bores for house water and fire fighting and with due acknowledgement to climate change this places them in very real danger. Additionally I note that the construction site is situated right along side one of the valley dams (the middle one) and this feeds into the larger western one, there is a potential for contamination of the water.
Pauline Worthington
27/2/2023

There needs to be further investigation, clarification and assurances surrounding
1. The threat to water catchment, quality and pollution as a result of cement leaching, construction works and flow interruption.
2. Air quality and particulates affecting nearby residents and the environment, in particular the 90% silica content of sandstone.
3. The quantity of water, in potentially drought years, needed in the construction process.
The Blackheath construction site of 23 hectares backs onto 9 homes, clearing, construction, vibration and truck movements will interfere with the enjoyment of their homes and effect resale should they with to sell/rent. What compensation will be provided to these occupants?
What assurances can be provided re the level, duration and hour of operation compliance of noise associated with the project regarding truck movements/braking, TBM vibrations, road header machines and construction traffic?
Will a sound shed be constructed over the spoil pile at the Blackheath construction site to reduce noise and downstream sedimentation to surrounding houses?
What is the prediction duration of construction for the Katoomba to Balckheath and Blackheath tunnel portals as this slowing/stopping of traffic, dust and general inconvenience will affect the tourism industry in Blackheath and Mt Victoria.

In October 2022 I raised concerns with the route of the proposed tunnel. Looking at the proposed route shown on the EIS - Chapter 4 - Project Description figure 4-9 on page 4-17 I can see my concerns with the routing have been ignored. As shown by your (not to scale) diagram the proposed routing of the tunnel will be very close to the surface of Fairy Bower ravine and associated escarpment. Your rough diagram shows significant depression at this point and is likely to be less than the approximately indicated 25m. The sandstone escarpment in this area is extremely unstable as shown recently by the recent rail subsidence close to this location. Furthermore, being so close to the surface will have an impact on the natural water movement through the sandstone affecting the Fairy Bower environment and below. The routing of the tunnel needs to more closely align with the existing highway that has proved to be stable with minimal watercourse impacts over the last 150+ years.

Below is the body of the email that I first sent on 6/10/2022 raising these same concerns. From the EIS I can see these concerns were not considered.

Looking at the map it is clear that the tunnel is not aligning with the central ridge as used by both the highway and the railway from Blackheath to Mt Victoria. The tunnel passes close to the escarpment, particularly from Mount Boyce to Mount Piddington and the area around Sunset Rock. As shown by the recent major railway landslip, it is clear that the escarpments continue to be unstable on a large scale. As we know, the escarpments were formed by regular landslips, landslides and fracturing of the edges which occurs on regular basis and may be clearly seen at multiple locations. The western side of the escarpment appears to be particularly vulnerable around the NW Blackheath and Mt Victoria areas with ongoing falls around the Mount Boyce, Mount Piddington and Pulpit Rock areas. The ongoing falls are evidenced by the large number of substantial boulders below the plateau on the escarpment and the general instability

I would have expected that to avoid instability the best location of the tunnel should align with the flatter ridge area as used by the highway. This would provide an increased buffer distance between the tunnels and the escarpment. However looking at the proposed map of the tunnel, the primary driver appears to minimise the length of the tunnel through using a flatter arc rather than a more appropriate smaller radius curve. The proposed arc results in a closer proximity to the western escarpment than is appropriate. Using the CMA topographic map 8930-1N, in the region of Fairy Bower the cliff edge is around 1000m in elevation with the escarpment at 900m and less. The tunnel is shown going through this section. If the tunnel depth varies between 90m at Blackheath and 150m at Sunset Rock at 150m, this mid point would be approximately 130m deep (based on a constant slope), at an elevation of 870m (Sunset Rock elevation @ 1000m - mid point @ 130m). This elevation of 870m is very close to the highest point of the escarpment at 900m, which decreases by at least 50m in the area where the route is marked. This would result in the tunnels being unreasonably close to the surface which would be certain to create problems with stability and drainage. As you know the sandstone is very porous so the proximity of the tunnel would also be likely to affect natural subterranean watercourses.

I note that there have been ongoing geotechnical surveys as published in a letter from the NSW Government in August 2022 titled 'Geotechnical investigations from Blackheath to Little Hartley continuing'. This letter highlighted that the major focus was 'on or near the Great Western Highway'. Does this geographic focus around the highway indicate that the proposed tunnel will closely align with the location of the highway rather than what is shown conceptually on the map at https://caportal.com.au/tfnsw/great-western-highway/central/map? ie decrease the radius of the curve. Referring once again to the Fairy Bower area, it can be seen that the highway alignment traverses the highest elevation in this area at approximately 1030m. Using the estimated depth from before this would ensure the tunnel is 1030-870 = 160m below the surface at the approximate middle of the ridge in an east west direction. This is far more appropriate than the indicated routing under the Fairy Bower valley and escarpment.

See attached letter

I object to the proposal and have provided reason in the attached document

Please find attached my submission.
I am very familiar with website applications but this website is extremely difficult to navigate and I believe that many people who may have submitted would be put off by trying to work out what to do next. I suggest that this site be reviewed before you request further submissions from the public.
Thank you for the opportunity to comment.
Debra Brown

The only reason for this project is to allow large B Double3 trucks access from the western side of the Blue Mountains to the Eastern side of the Blue Mountains. The GWH from Katoomba to Penrith will become an accident waiting to happen as the original design of the GWH from Katoomba to Penrith was never designed for B Double trucks.
The signage which has been erected saying this present construction will ease congestion is utterly false as the section of road from the bottom of Mount Victoria to the other side of Hartley fresh has never seen congestion.
Blackheath lights are the problem!
This Government is hell bent on this project which they cannot fund themselves. The Federal Government has even seen fit to withdraw funding as the do not agree with the project.
The tunnel project when and if it gets funded is lacking entry and exits at Mt Victoria and Blackheath.
The air pollution needs to be addressed as the air exiting the tunnel will be exiting too close to existing properties.
Air extraction stacks should not be considered as this whole project is aesthetically ruining our valley.
Truck stops really don't need to be in our valley when only kilometres away they could be placed in forests.
The idea of piping water from Lithgow is absurd when a pipeline from Mt Victoria down to the construction site would require far less money and would be gravity fed.
This road is over engineered and does not need to be constructed to allow 100KLM and hour speed limit when a tunnel speed will be 80KPH and Fortyt bends is 90KPH then Lithgow is 70KPH.
Good speed trap one would think.

Hi,

I noticed that the current alignment of the tunnel in the area of Mount Victoria goes right underneath parts of the western escarpment.

Of particular concern is the cliff line next to Mitchell Ridge Lookout. This area is used by rock climbers and abseilers for recreational purposes. It is also used by the guiding and training private sector.

The area of Sunset Rock is also visited regularly by many locals and tourists alike.

There is no mention in the EIS of the potential impact on the cliff stability during construction of the tunnel or during normal operations. Would it be possible to review the alignment and set it back sufficiently to remove those concerns? Or would it be possible at least to mitigate risks during construction by reducing boring rate etc?

Thanks

I support the project, but with strong reservations.

I wish the project to proceed and quickly. I want the Blackheath crossing to be improved as part of the project. I endorse the attached submission from BAG