MOD 3 - Iron Cove ventilation underground

Please see attached

I object to the proposed modification (MOD 3) because it is hugely different to what was approved in the EIS. The ventilation facility approved in the EIS for the Iron Cove Link/Rozelle Interchange (in the words of a John Holland engineer at an October 2019 community briefing) 'had hairs on it' and was 'unbuildable'. The proposed new ventilation facility is of a quantum/impact entirely beyond that which was approved. Many many more homes and lives in this tightly-packed corner of Rozelle would be impacted if it were to proceed.

Nor did the original EIS include any mention of there being an active spoil-removal site on Victoria Rd near Callan Street. This would be a massive additional impost upon the lives of hundreds of local residents for an unacceptably long period.

Changes of such magnitude must surely (legally) require that an entirely new EIS be drafted?

Over the past weeks Sydneysiders have been made critically aware of the disastrous health impacts of bushfire smoke. Begrudging acknowledgment that extreme weather conditions and unprecedented fires are linked to (government inaction on) climate change is swiftly 'snowballing'.

Whilst vehemently objecting to the massive 'modifications' being proposed, my underlying and most profound concern remains that the Rozelle Interchange and Iron Cove Link will disrupt the lives and impact upon the physical and mental health and well-being of residents across Sydney in an entirely unacceptable manner. Our experience of fine particulate pollution in Rozelle just last week (when air pollution reached 11 times the levels generally regarded as injurious to human health) has made us even more certain that Stage 3 of WestConnex is an insane and unnecessary multi-billion furphy which should be terminated.

It is not possible to believe that the NSW Government wishes to poison its own residents (despite the fact that a high proportion of the electorate are Greens supporters). Therefore - in light of recent air-quality events which demonstrate 1) the terrifying effects of climate change, and 2) that we must move swiftly to cut emissions - to proceed with a project which will bring MORE belching fossil-fuelled vehicles into urban areas is entirely unacceptable. Moreover, to refute and over-ride the crystal-clear findings of scientists and medicos at last year's NSW Upper House Parliamentary Inquiry into the Impact of WCX with regard stack filtration is, in our current (manifestly more alarming) predicament, criminal.

As a visual artist, environmental activist and long-time Rozelle resident, I would like finally to object to the Modification on aesthetic/spiritual grounds. MOD 3 exacerbates what is already extraordinarily-ugly, visually-disturbing urban planning. The bald-concrete cut-and-cover lanes, the bland portal, blunt stack and ghastly noise baffling all look as if they were designed in the 1950s. The massive underground intrusion of the proposed ventilation caverns is not only of concern to the hundreds of residents who own property and/or live above, but also to those of us who believe that we are merely contemporary custodians of these precious harbourside lands, and that wounds such as those proposed must not be brutally inflicted on ancient sandstone and its delicately filigreed watercourses. There is no quarter given to the fact that hundreds of thousands of sensitised human beings inhabit and travel through these zones, humans who, over recent decades, have begun to question modern notions of 'progress' and to understand the importance of place and 'country'. Not to mention fast, efficient and sustainable public transport.

As NSW Environment Minister Matt Kean stated just last week, the conditions under which we are now living are NOT NORMAL.

NSW should be placed on a war footing to combat climate change, and (as part of this enlightened and necessary push to cut emissions) WestConnex should be terminated. Residual lands - planted with mature-aged trees, should be returned to the (all suffering) local community.

In short... MOD 3 must NOT BE APPROVED.

I object strongly to the project proceeding with unfiltered ventilation stacks. This tunnel is too long to operate with just end stack ventilation and no filtration.

According to the design proposed for approval each one direction tunnel is to be ventilated with longitudinal end stack ventilation utilising an unfiltered stack at the exit end of each tunnel. The unfiltered Rozelle stack is within 300 metres of Rozelle public school and also close to countless homes, businesses and childcare/preschool children and will emit pollutants from vehicles emissions and tyre and brake wear accumulated in the tunnel all at this single point. Locating unfiltered stacks with sensitive receivers (people -especially the young , families and the elderly) in the downwash zone : 150 to 600 metres from the stack is irresponsible at best and likely negligent. It amounts to a large public health trial of deliberately adding air pollution collected from a large area and desitributing it over a small area. Depending on winds the affected area expected to have an increase in pollution is from 150 to 1200 metres form the ventilation stack. The pollution does not disappear. These are particles, they will fall out of the air at some point in this range. The EIS claims the increase in pollution is neglible but it is not neglibible when the background (ambient) particulate levels of pollution already reach the NEPM standard of 8mcg per cubic metre regularly and the Federal Government has revised this standard down to be 7mcg per cubic metre by 2024 when the tunnel will be operating. It is unconscionable to deliberately released unfiltered air exhausted from a long urban road tunnel, accumulated along the length of expected to be highly trafficked, over a densely populated area with existing background air pollution concerns. Given the recent weeks of of poor air quality from bushfires which we cannot prevent surely removing a significant proportion of the pollutants from the tunnel air before release is the only sensible thing to do. Filtration of the emissions collected in road tunnels is a golden opportunity to reduce harmful pollutants from the environment. This is why every other OECD country in the rare cases when they build long urban road tunnels are installing filtration or at least banning the most polluting vehicles form the tunnels.

No other OECD country is building long (5km or over) urban road tunnels with this ventilation system intended for short road tunnels (4km and under) and allowing diesel heavy vehicles to use it without installing filtration ideally within the tunnel aswell to protect tunnel users but certainly to clean the polluted air before it is emitted from the ventilation stack. The recent CWB Bypass opened in Hong Kong in April 2019 with full stack filtration - built by Leightons Asia with FILTRONtec filters. The M5 East trial proved that the filters removed up to 80% of particulate matter form the air put through the filter. The project should have measured quantity of particles removed rather than weight as PM2.5 and PM 10 should be measured by quantity not weight. The smaller particles, that weigh less are actually the most dangerous carcinogens, reaching deep into the lungs and able to cross into the bloodstream. As acknowledged in countless studies over the past 10 years, fine particle pollution, especially PM2.5 is implicated in law birthweight & premature births, heart attacks, strokes, aswell as causing or worsening respiratory illnesses such asthma, ephsema, COPD and lung cancer. The fastest growing cases of lung cancer in Australia are in women who have never smoked - air pollution is the most likely cause.

The unfiltered E4 Stockholm tunnel has many more exhaust stacks along the route and also air exhange units to insert fresh air form height into the tunnel. Its ventilation system design also mandates that there must not be a distance of 5000m or more between exhaust stacks. The proposed M4M5 breaches this important design rule. The CTEU reports on tunnels also make clear that the length of the tunnel and distance between exhaust stacks significantly affects the level of pollutants accumulated in the tunnel and for dispersion.

If you do not provide additional air exhausts and inserts you must ban diesel heavy vehicles from using the tunnels. This is what the rest of the world does if they build a longitudinal ventilated long (4.5 - 5km plus) road tunnel with end stacks without filtration. Turkey bans diesel vehicles larger than a minibus and motorcycles from the 6km + Eurasia road tunnel opened in Istanbul in 2016. The French ban diesel vehicles from the nearly 5km long Duplex tunnel in Paris. They installed Aigner filtration when the Mon Blanc tunnel was retrofitted after the tragic fire.

Other countries use filtration to clear the air before it is emitted: the 2019 Hong Kong CWB bypass tunnel. the Madrid Calle 30 network of tunnels, the Yamate tunnels in Tokyo, the Cesaena tunnel in Italy all have filtration of fine particles (using electro static precipitation ESP filters) and gas filters (NOX filters) to remove nitrous dioxide and related gases. Air filtration is well established technology worldwide and there are established providers (CTA - Norway, Aigner - Austria used in Madrid, Italy & France (Mont Blanc road tunnel), Panasonic - Japan used in Japan and Europe and FILTRONtec - Germany used in Madrid and Hong Kong.

Either ban the diesel vehicles from the M4M5 tunnels or add filtration to the ventilation stacks or change the ventilation design. Fully transverse ventilation where a separate air tunnel washes fresh air across the tunnel for its length is also used in some countries. Having such a separate air tube system is more expensive, If you don;t want to spend the money, ban the diesel vehicles or add reliable stack filtration to the ventilation stack systems. The USA and UK do not even have any urban road tunnels longer than 5km. They put electric trains in their tunnels producing no vehicle emissions.

Why are the lives of the people and children of Sydney not worth the same protection as the citizens of all other OECD countries?
At the very least full baseline health studies of the local population, especially children, should be undertaken before construction begins, during construction (to assess health impacts of increased truck movements and construction dust if mitigation measures are not sufficient) and every 2 years after the tunnel opens. Air quality monitoring must be on going and commence now from at least 12 months before construction begins - a baseline established in the 2 years before the tunnel opens as mandated in the approval conditions of Northconnex and earlier Westconnex tunnels is inadequate and misleading as it captures the increased dust and vehicle emissions generated int he construction process creating an inflated baseline level of pollution.

Please check your project assumptions against what is really happening around the world. No other comparable countries are building long urban road tunnels with such a second rate venitlation system design. The Madrid Calle 30, Tokyo Yamate tunnels and Hong Kong CWB tunnel all have ESP filtration for PM 2.5 and PM 10 particles and also gas filters. The E4 Stockholm 18 kms tunnel network has many more exhaust stacks and also fresh air intakes (exhanges) to maintain better in tunnel air - making the design like a series of short Sydney Harbour tunnels for which unfiltered longitudinal ventilation is acceptable. The Stockholm tunnel exhausts are also mainly located in forested areas and none are 5000m or more apart.

I object to this project unless you follow recommendation 13 of the December 2018 NSW Parliamentary Inquiry into Westconnex report that filtration systems be installed for the ventilation stacks. If law suits follow the NSW Government, the Planning Minister and the operator of the tunnels (Sydney Motorway Corporations) cannot claim not to have this information about what to do and how the rest of the world is designing these tunnel ventilation systems. Encouraging electric vehicles would also be a help - at the moment more EVs are purchased in New Zealand each year than in Australia. Until Sydney has an entirely EV fleet filtration must be installed for the ventilation stacks or diesel vehicles banned from using the tunnels.

Thank you for reading my submission. I can provide copies of the technical documents in relation to the international tunnels mentioned on request.

I object to the modification because it it bears no resemblance to the ventilation facility that was approved by the EIS. The initial proposal was for an above ground facility and sub station this proposal is for an underground facility, surely this alone is reason to require that another EIS must be undertaken.
The addition of of the tunneling site with it's associated spoil removal creates a raft of potential hazards that must be addressed through an EIS.
Surely changes of this scope cannot be legal without a new EIS.

The following two conditions must be included in the new design prior to approval:
1. The EIS and the approval of the Rozelle interchange preceded the Parliamentary Inquiry into Westconnex. The recommendations of this Inquiry should inform the Department of Planning, Industry and Environment (DPIE) in its decision to approve the proposed changes. The Parliamentary Inquiry stated: “That the NSW Government install, on all current and future motorway tunnels, filtration systems in order to reduce the level of pollutants emitted from ventilation stacks”. Therefore the ventilation stack on Victoria Road opposite Callan Street and the 3 ventilation stacks in the Rozelle Goods Yard must include filtration as a condition of the approval for the proposed changes.

2. All residual land along Victoria Road at the Iron Cove Link should be used for community based amenities, such as planting, parks and playgrounds. Specifically the residual land on Victoria Road between Callan and Springside Streets should be planted with mature size trees and become a park for all residents to enjoy. Since our community has been ravaged by the destruction of historic homes and the removal of all vegetation, including mature aged trees along Victoria Road, this would help reinstate some of what has been lost.

It is important to note that this is consistent with the DPIE’s Place, Design and Public Spaces policy, which states: “We create great places and experiences for all, plan for a changing and thriving NSW, inspire strong and resilient communities and regions, and ensure the responsible and sustainable use of NSW’s resources.”

SUBMISSION REGARDING WESTCONNEX M4-M5 LINK MOD-3
I would like to submit the following concerns in relation to the Iron Cove Ventilation Undergrounding Modification proposal - application number SSI 7485:

Concern: Design of Proposed Ventilation Tunnels and Caverns
Key design concerns include:
1. Operational noise and vibration impacts for residents directly above or adjacent to the caverns
• The modification report fails to specifically address the impact on residents located directly above or adjacent to the caverns of long term ongoing noise and vibration associated with the operation of the ventilation fans and equipment. Ongoing noise and vibration will have a significant, negative impact on residents’ long term health and wellbeing and must be a key consideration for any modification design.
• At a residents’ forum held on 3rd October 2019 specifically to address this Iron Cove Link modification, Westconnex/Contractor Project Team experts provided contradictory answers as to what the exact noise and vibration impacts for residents located directly above the caverns would be. This indicates that insufficient or inadequate noise and vibration modelling was done prior to finalising the design modification. Residents were advised to go and stand next to the above ground ventilation facility near Bunnings in Haberfield to gauge for themselves the likely impact – a totally unacceptable response and clearly not based on hard data given the design of the Haberfield ventilation facility is very different to what is being proposed for Iron Cove.
• The report fails to address what preventative measures will be put in place to ensure residents above or adjacent to the caverns are not impacted by noise or vibration once the fans are operational.
• The report also fails to address what controls will be put in place to monitor and assess noise and vibration levels associated with the operation of the ventilation equipment on an ongoing basis.
• Similarly, the report does not adequately address potential mitigations measures if noise and vibration levels are found to be unacceptable to residents once the equipment is operational.

2. Depth, size and location of the ventilation tunnels and caverns
• The proposed modification to build ventilation tunnels and caverns and move some ventilation facilities underground will, in its current form, subject a significant additional number of residents to shallow tunnelling with associated disruption, risks of property damage and loss in property value.
• The size of the underground caverns appears to be significantly larger than the approved above ground buildings, and raises questions about the size of the underground footprint of the caverns. A larger than absolutely necessary footprint increases both the level of risk (of damage, ongoing noise & vibration) and the numbers of residents potentially impacted.
• Increasing the depths of the tunnels and caverns would help mitigate these risks, as would reducing the size of the caverns e.g. configure the equipment within the caverns in line with what was approved for the above ground facilities.
• It is disappointing that the alternative design option to locate the ventilation facilities underground within a ventilation building at a depth of 40 metres was dismissed. It is also disappointing that other alternative designs, impacting fewer residents, were not considered by this modification proposal. It would appear that relatively short-term construction impacts and project deadlines/profitability have been prioritised over the long-term impacts on those additional residents who will be directly affected by this proposed modification.
The ventilation facility undergrounding modification should be redesigned to address the serious long term impacts on residents wellbeing outlined above.

Concern: Reclassification of the Iron Cove Site as a Tunnelling Site
The modification proposes to reclassify the Iron Cove site as a tunnelling site to excavate the ventilation tunnels and caverns. If approved this will impose additional impacts including truck movements, noise and disruption on residents living in an area which will already be heavily impacted by the major Iron Cove Link works.
This modification should not add additional impositions onto residents living in that area in addition to what has already been approved through the EIS.

Concern: No Guarantee Residual Land Will be Returned to the Public
By moving some ventilation buildings underground, the size of the above ground ventilation facilities will be reduced. Accordingly, residual land will be available upon completion of the project.
In addressing the claims the modification design will have the benefit of increased greenspace – it is noted that WestConnex has no responsibility for, nor can it deliver on this. That lies with the Residual Land Management Plan and in fact it seems unlikely parkland is in the future given that:
“In relation to the Proponent’s intent for the land fronting Victoria Road between Springside Street and Byrnes Road to be returned as passive open space, once construction is completed. Whilst the Department encourages open space delivery in urbanised contexts, in this particular case, the Department does not support the use of any remaining land in this location for the purposes of pocket parks in lieu of any other design solution being found.” M4-M5 Link EIS p84
Any residual land arising from this modification should be released to the public via increased greenspace once work is complete.

In Summary, the assessments and assurances in the EIS for the M4-M5 Iron Cove Link were based on an original design which contained a significant error i.e. the lack of ventilation tunnels to take the polluted air from the road tunnels to the air vent. The solution set out in this modification contains a number of significant design issues and appears to have expediency and project profitability as the key assessment criteria at the expense of long-term community wellbeing. This is evidenced by the multiple issues outlined above; limited considerations given to alternative design options; and supported by statements such as:
“Commissioning of the entire project would begin at Iron Cove Link. Tunnelling of the proposed new ventilation tunnel and caverns from Iron Cove would work to potentially allow the project to commence commissioning two to three months early. Starting commissioning earlier would give the project more opportunity to finish early and more certainty that it would finish on time. “(P.67 M4-M5 Link Mod 3 Main Report)
The ventilation facility undergrounding modification should be redesigned to address the serious long term impacts on residents wellbeing outlined above.

Since the erasure of 27 houses and businesses along Victoria Road for the Iron Cove Link, the public are obliged to walk/cycle/run in extremely exposed conditions. The houses used to provide shade and shelter. The 'footpath' is now a barren wasteland, and it is hell on earth to linger in the blistering sun. Given that NSW is experiencing unprecedented high summer temperatures, I would hope that the mooted urban-design elements for the residual space in the MOD 3 might consider what has been lost by the local residents. How about some immediate shade and shelter - an urban forest of mature trees for the general public - instead of selling it off to the highest bidder? The drawings in Appendix F show trees in 5 to 10 years time (too late!). We'll have been struck down with heatstroke by then.

Also, given the increased traffic predictions in your modifications and the fact that the extra trucks/service vehicles will be exiting into Victoria Rd (Appendix B), it is a pretty sure bet that RMS will change traffic-light phasing to favour the Victoria Rd traffic, and not local pedestrians trying to cross the road. This will be so annoying for locals who are already circumnavigating their suburb due to WCX roadblocks. When Moodie St was closed with initial WCX diggings, the traffic was unbelievable - backed up, as predicted, along Darling St to Orange Grove School. I disapprove of this modification for the simple fact that the local area cannot sustain the extensive traffic build up and disruptions you are planning. Pensioners who normally take the back roads to whip up to the local shops now find themselves sitting in a traffic jam for 30 minutes. Others who are physically challenged would be forced to walk hundreds of metres further uphill to the re-assigned city bus stop. Some locals can't even get a grocery delivery! And what about the ambulance that was forced (by a road closure, just last month) to stop a street away from a local resident suffering a heart attack - luckily he survived, but minutes matter!!!! It is just poor planning. Can you not put the new ventilation chambers under a less-traffic-congested area - how about on the northern side of Victoria Road (under Bridgewater Park)?

I strenuously object to the NSW Governments Road Project Plans for the entire Rozelle Interchange in its entirety.
This modification while appearing beneficial to some extent to some sections of the local residential community will impose onerous conditions on other sections. Any amendments to the plans we believe are more for the benefit the RMS Planners & their contracting partners implementing and constructing the Works and not the community itself who have not been respectfully consulted or listened to on any real level. Experience with prior NSW Government RMS projects has shown that any promise to supply a proper replacement of Trees to community did not occur so we are doubtful this will be any different.

I strongly object to the lack of filtration on the proposed stack so close to Rozelle Public School, Sydney Secondary College Balmain and a number of residential developments and preschools.
All these schools and educational facilities should be given double glazing to mitigate noise, shade cloths in playgrounds to prevent spoil and dust falling on children, and air conditioning to prevent toxic lead, dioxins and particulates from contaminated spoil entering classrooms and developing lungs during construction.
The use of imagery depicting the development after 10 years' of use, with few cars, is also misleading, as Victoria Road, the Rozelle Goods Yard, the Crescent and White Bay will continue to look like the dusty, treeless, apocalyptic moonscape that this NSW Government have now made it.
I therefore am completely distrustful about the 2038 picture being painted of this Project works .

Given previous breaches by WestConnex contractors in spoil removal and truck movements in Haberfield and St Peters, I am extremely concerned about provisions for safe spoil removal through residential streets and so close to schools, and there is little detail about how this is proposed, or where residents can lodge complaints or reports of these breaches.
The impact of 24 hour noise as being akin to "a truck idling next to your house" sounds horrific and distressing — perhaps project managers, the Planning and Roads Ministers and the Premier might consider having a concrete mixer outside their homes 24/7 in solidarity with affected families? The suggestion that there will be no structural damage to homes, given the extensive damage to homes in Beverly Hills, St Peters, Strathfield, Concord and Haberfield by drilling and construction is fallacious.

As a local resident of Rozelle in Cambridge St, I seek further clarification / explanation into the short and long term impacts of Ventilation Cavern to be to be constructed as part of the Mod 3
Works.
1. Figure 7-4 in the EIS forecasts the preliminary settlement caused by the ventilation cavern will be in excess of 15mm to an upper end of 20mm. Can explanation please be provided to why this cavern cannot be constructed at a greater depth to mitigate foreseeable damage to surface structures and residential properties caused by considerable settlement for the ventilation cavern?
2. If it is not feasible to construct the ventilation tunnel deeper, can an alternate fan arrangement be considered to limit the overall width of the cavern and thus corresponding surface settlement? For example a 2x2 arrangement?
3. The EIS does not investigate the possible long term vibrations caused by having up to four fans simultaneously running during an emergency event or 3 fans during normal operations. It is understood there will be attenuators and dampeners, however can clarification please be provided to what will be done to eliminate long term vibration as a potential issue? Has this been modelled to ensure vibrations at the surface is zero? The immediate residents are concerned that long term vibrations into residential properties will be a significant impact into residential quality of life;
4. In order to construct the 15m high, 25m wide Ventilation Cavern, can an excavation rate for production please be provided to allow residents to understand the duration it will take for the cavern to be excavated?
5. It was mentioned in the EIS that other options were investigated to enable the Mod 3 works. Has a site adjacent to the existing Rozelle substation in Callan Park been considered? Much of this park is abandoned and unused, thus locating the ventilation fans and structures there would seem best for residents due to distance from homes and project outcome as it would also eliminate the requirement to build the additional proposed substation, as the proposed ventilation fans could feed off the already built Rozelle Substation?
6. Ventilation tunnels do not have the same grade and alignment constrictions as the road tunnels, can a reasoning into why these tunnels could not be constructed predominantly underneath exisiting streets and roads instead of underneath residential properties please be provided? As this would be a popular outcome for local residents if this could eventuate.

Dear Minister, dear Councillors, dear Project Designers,

I wish to object to the Project in its current form due to my following concerns:

• Visual impact of the tunnel entries, which look like a huge gaping hole
 I propose to
o rethink the design of the tunnel entries/exits
o introduce sympathetic landscaping around the entries to blend into the community. After all, this is a community where people live and not an “Autobahn” or Freeway.

• Impact on the community of Rozelle, which will further separate the community, due to development’s increased width of roads in Victoria Rd (existing lanes plus the width of the tunnel entries)

 I propose to
o reduce remaining lines by 1 on either side (see Epping Road)
o include plenty of native landscaping to ameliorate the visual impact
o ensure safe pedestrian crossings are easily accessible for the elderly, disabled and cyclists

• Location of the exhaust stacks – it is currently situated within metres from a school and kindergarten, as well as from community hubs, like the Rozelle markets

 I suggest to
o push exhausts out underneath Iron Cover bridge, above the water;
o this can be done with multiple, smaller exhausts, horizontally, underneath the bridge;
o apply state of the art filters to the exhaust stacks, serviced regularly.

• No unfiltered exhaust stacks – scientific evidence has proven that car exhausts are cancerogenic. Nowhere else in the world are unfiltered exhaust stacks being built except in Australia. This is a complete disrespect for residents’ health in favour of developers’ profit, and just pushes the issues down the line: to the already with rising costs overburdened health care system.

Please refer to Dr. Raymond Nassar’s* INQUIRY INTO IMPACT OF THE WESTCONNEX PROJECT of 30 August 2018 and his recent findings (see below and attachment)

=> I urge decision makers to
o ensure only state of the art, properly filtered exhaust technology is used in Sydney and Australia.
o Ensure operator services these filtered exhausts regularly.

• Visual impact of the exhaust stacks – I appreciate that the detailed design will be developed later; however, it is essential to think about it already now. I refer to the exhaust stack in Haberfield/Parramatta Rd/at Bunnings: it looks like a huge, ugly industrial complex – and that next to people’s homes

=> I propose:
o Choosing multiple, smaller stacks;
o Running them along underneath Iron Cover Bridge;
o Filter them with state of the art filters;
o Covering them in plenty of landscaping;
o Choosing an Australian artist for the design / decoration.

• Shallow tunnelling – again the proposed, in parts shallow tunnelling represents a complete disrespect for affected residents’ health and well-being and pushes the problem down the line to benefit the profit of developers: to individual residents – frequently elderly, longterm residents of the community, who do neither have the financial means nor the psychological stamina to take up the fight with a big developer and / or influential governments.

=> I propose to
o increase the depth if tunnelling
o expand the zone of influence to 250m
o include a local community representative on the RMS independent property assessment panel
o Ensure there are legally enforceable provisions with set compensation amounts for residents who are negatively impacted.

• Overall, Sydney needs more, and more frequent, and more reliable public transport.

Thank you for the opportunity to voice my concerns.
With best regards

*Dr Ray Nassar is a Sydney-based specialist anaesthetist who has compiled authoritative new research into the serious health effects of vehicular air pollution. He emphasises the dangers of particulates – PM 2.5s and PM 10s – tiny, often carcinogenic particles invisible to the naked eye. Dubbing particulates ‘the new asbestos’, Nassar warns that COMPLACENCY = APPROVAL. About a third of all lung cancer deaths, stroke deaths and pulmonary deaths worldwide are due to air pollution. Worryingly, Nassar’s research reveals that ‘there is no safe level of exposure’… and that although ‘most countries around the world have guidelines… the majority of cases of health impacts occur when people have exposure to the so-called ‘safe’ level – i.e. people living in normal communities where the air quality is within the guidelines are still having a lot of these problems.’

I want to express serious concerns about:
- The unfiltered air outlets being a point of contention is unimaginable. The introduction of underground ventilation tunnels creates an opportunity to use air filtering technology. It should be mandatory and on condition of implementing an air filtering system that this modification can be approved. Especially in an era where the negative impact on health from air pollution is scientifically proven and acknowledged even by The World Health Organization. The vicinity of schools, childcare , dense residential areas with families and children makes it look like total negligence to have unfiltered air from the outlet stack. It is a let down to the community and health system.
Solution: implementation of technology filtering the air.
- Ventilation tunnels need to be more than 7 meters below the surface to avoid home damage, ground noise and vibration.
To consider: deeper tunelling
- To show some regards to residents by offering vibration monitoring at homes within the zone of influence.
- Deploy ground movement detection technology to avoid further damage to properties if sign of damage occur.
- Need for a commitment to compensate compulsory substrata acquisition.
- Need for detailed design NOW in the modification proposal in regards to urban design, landscape plan and residual land
- Location of the stack being very close to 2 schools, kindergarden, community ... & visual impact
To consider: redesigning and repositioning of the stack and for the visual impact a more detailed proposal needed with the opportunity for a hanging garden and and many more trees around the stack and along Victoria road. The artist's impression in figure 6-7-7a-9 looks rather grim and has plenty of space for aesthetic improvement.

Conclusion: The EIS needs to reconsider a proposal that is sound, more specific and shows more concern about the negative impact and possible solutions of the modification.

I trust this submission to be read and be taken into consideration in a serious manner.

With thanks for the opportunity to express my concerns.
T Dhuyvetter

Dear Sir, dear Madam,

I wish to object to the Project in its current form due to my following concerns:

• Visual impact of the tunnel entries, which look like a huge gaping hole
 I propose to
o rethink the design of the tunnel entries/exits
o introduce sympathetic landscaping around the entries to blend into the community. After all, this is a community where people live and not an “Autobahn” or Freeway.

• Impact on the community of Rozelle, which will further separate the community, due to development’s increased width of roads in Victoria Rd (existing lanes plus the width of the tunnel entries)

 I propose to
o reduce remaining lines by 1 on either side (see Epping Road)
o include plenty of native landscaping to ameliorate the visual impact
o ensure safe pedestrian crossings are easily accessible for the elderly, disabled and cyclists

• Location of the exhaust stacks – it is currently situated within metres from a school and kindergarten, as well as from community hubs, like the Rozelle markets

 I suggest to
o push exhausts out underneath Iron Cover bridge, above the water;
o this can be done with multiple, smaller exhausts, horizontally, underneath the bridge;
o apply state of the art filters to the exhaust stacks, serviced regularly.

• No unfiltered exhaust stacks – scientific evidence has proven that car exhausts are cancerogenic. Nowhere else in the world are unfiltered exhaust stacks being built except in Australia. This is a complete disrespect for residents’ health in favour of developers’ profit, and just pushes the issues down the line: to the already with rising costs overburdened health care system.

Please refer to Dr. Raymond Nassar’s* INQUIRY INTO IMPACT OF THE WESTCONNEX PROJECT of 30 August 2018 and his recent findings (see below and attachment)

=> I urge decision makers to
o ensure only state of the art, properly filtered exhaust technology is used in Sydney and Australia.
o Ensure operator services these filtered exhausts regularly.

• Visual impact of the exhaust stacks – I appreciate that the detailed design will be developed later; however, it is essential to think about it already now. I refer to the exhaust stack in Haberfield/Parramatta Rd/at Bunnings: it looks like a huge, ugly industrial complex – and that next to people’s homes

=> I propose:
o Choosing multiple, smaller stacks;
o Running them along underneath Iron Cover Bridge;
o Filter them with state of the art filters;
o Covering them in plenty of landscaping;
o Choosing an Australian artist for the design / decoration.

• Shallow tunnelling – again the proposed, in parts shallow tunnelling represents a complete disrespect for affected residents’ health and well-being and pushes the problem down the line to benefit the profit of developers: to individual residents – frequently elderly, longterm residents of the community, who do neither have the financial means nor the psychological stamina to take up the fight with a big developer and / or influential governments.

=> I propose to
o increase the depth if tunnelling
o expand the zone of influence to 250m
o include a local community representative on the RMS independent property assessment panel
o Ensure there are legally enforceable provisions with set compensation amounts for residents who are negatively impacted.

• Overall, Sydney needs more, and more frequent, and more reliable public transport.

Thank you for the opportunity to voice my concerns.

Regards.

*Dr Ray Nassar is a Sydney-based specialist anaesthetist who has compiled authoritative new research into the serious health effects of vehicular air pollution. He emphasises the dangers of particulates – PM 2.5s and PM 10s – tiny, often carcinogenic particles invisible to the naked eye. Dubbing particulates ‘the new asbestos’, Nassar warns that COMPLACENCY = APPROVAL. About a third of all lung cancer deaths, stroke deaths and pulmonary deaths worldwide are due to air pollution. Worryingly, Nassar’s research reveals that ‘there is no safe level of exposure’… and that although ‘most countries around the world have guidelines… the majority of cases of health impacts occur when people have exposure to the so-called ‘safe’ level – i.e. people living in normal communities where the air quality is within the guidelines are still having a lot of these problems.’

Not withstanding my objection to the Westconnect project I make the following submission on the MOD 3 Iron Cove Ventilation underground modification.

The yellow area between Callan Street and Springside Street marked residual land should be retained as open space and included in the Urban design and landscape plan.

Alternative designs should be sought for the intersection of Clubb Street and Victoria Road. King George park is a busy park for the area and the main road access for this park should not be only via Callan and Toelle Streets. Both of these streets are narrow and only accommodate traffic in one direction at a time. Cars traveling in opposite directions on these two streets need to pull over to allow the other car through. It should be possible for road surface levels at the Clubb Street / Victoria Road intersection to be altered so that Clubb Street remains open.

The ventilation outlet should be filtered so that the air quality in the surrounding area is not negatively impacted. If this is not to occur then the design of the ventilation system should be built in such a way that air filtration can be easily retrofitted at a later stage without the need for significant alteration of either the buildings or supporting utilities.

Due to the traffic levels and narrow nature of the streets the maximum speed in surrounding streets such as Clubb & Toelle Streets should be decreased to 40 KPH or lower. Maximum speed limits in Callan and Springside Streets should be even lower as these streets and footpaths are even narrower.

The design of the Electrical and Operations Management buildings between Toelle and Callan Streets should be minimised in size as much as possible and open to full and meaningful public consultation during the design process and prior to being finalised. This structure should also be sympathetic and blend in with the surrounding buildings and landscape.

I am writing to strongly object to the proposed changes to the design of the Westconnex Rozelle Interchange.

Below are the key reasons for my opposition:
1. The proposed change is to the ventilation system associated with the tunnel. Since the contractor is no longer adhering to the original approval, all aspects of the tunnel and ventilation design should be on the table for consideration.

We have just experienced what it’s like to be exposed to 34 times higher than the World Health Organisation’s recommended safe level of 2.5 particulate pollution. This is caused by the ongoing bush fires and our government tells people to stay indoors to avoid ill health effects. The unfiltered ventilation stacks in this project will deliver concentrated 2.5 particulate pollution directly over and around the inner west and in particular to those like me, living within a 100M radius of the stack. This too will exceed the W.H.O. recommendations for safe levels. Given the fact that diesel fuel creates the most carcinogenic 2.5 particulate pollution of all sources and that numerous diesel vehicles will be travelling though these tunnels, people’s lives will be put at risk if the ventilation system is not filtered. The justification for non-filtration in the original approval is flawed. Equal comparisons to other 'best practice'tunnels around the world were not fair comparisons, with differences in number of exhaust stacks, length of tunnels and system design not being appropriately considered. The fact is that these tunnels are exceedingly long and have very limited inputs for fresh air and outputs of exhaust, only occurring at the portal openings. Therefore, the scope of work in the proposed change must include the addition of filtration for the ventilation system to deliver the ‘best practice’ result that our government has promised.

2. The proposed change puts my property at great risk of damage due to the new underground ventilation tunnel being within 50M of my home and being constructed at a depth of only 10-15M below the ground surface. In the current approved design no tunnels are within 50M of my home.

3. The proposed change will result in excessive noise and vibration due to the construction. My house is shown below circled in red and is identified as one where noise levels will be high during construction. (please refer to the attached copy which shows the reference mentioned, since photos would not copy here)

4. To date the contractor has not been consistent in performing work as per community notifications. Nor have they been consistent in their community consultation. In fact one item shown in their proposal under section 6 : Community Consultation did not occur: the information session noted as occurring on 20 November 2019, was cancelled only 2 hours prior to its proposed start, with the contractor stating that there weren’t enough RSVP’s. I understand that at least 5 people, including myself, RSVP’d to this session. Given this lack of commitment to the consultation process, I wonder what other aspects of this proposal will not be carried out if it is approved. I severely doubt the integrity of this contractor and believe that should this proposal be approved, additional inspections by the EPA and DPIE should be required.

5. The ‘residual land’ shown in the proposal is not included in the scope of the project, when previously this area was included. Although the use of this land may change, it must be included in the scope of work. All residual land should be given back to the community as green public space and it should be within the project scope to implement an appropriate design that delivers this.

Should the DPIE determine to approve this proposal, the following two conditions must be included in the new design prior to approval:

1. The EIS and the approval of the Rozelle interchange preceded the Parliamentary Inquiry into Westconnex. The recommendations of this Inquiry should inform the Department of Planning, Industry and Environment (DPIE) in its decision to approve the proposed changes. The Parliamentary Inquiry stated: “That the NSW Government install, on all current and future motorway tunnels, filtration systems in order to reduce the level of pollutants emitted from ventilation stacks”. Therefore the ventilation stack on Victoria Road opposite Callan Street and the 3 ventilation stacks in the Rozelle Goods Yard must include filtration as a condition of the approval for the proposed changes.

2. All residual land along Victoria Road at the Iron Cove Link must be used for community based amenities, such as planting, parks and playgrounds. Specifically the residual land on Victoria Road between Callan and Springside Streets must be planted with mature size trees and become a park for all residents to enjoy. Since our community has been ravaged by the destruction of historic homes and the removal of all vegetation, including mature aged trees along Victoria Road, this would help reinstate some of what has been lost.

This residual land should not be used for residential or any other type of commercial development. The proposal specifically refers to the benefit of moving facilities underground being the reduction of overshadowing. To reinstate any built structure on the residual land would negate this benefit. Noise reduction seems to be a concern and could be achieved through the design of a park with dense foliage, mature trees and 'green walls' at the Victoria Road edge of the park.

It is important to note that making the residual land a green space for the community is consistent with the DPIE’s Place, Design and Public Spaces policy, which states: “We create great places and experiences for all, plan for a changing and thriving NSW, inspire strong and resilient communities and regions, and ensure the responsible and sustainable use of NSW’s resources.” Our community would expect the DPIE to apply these principles universally when assessing the proposal.

Thank you for your consideration and I would be eager to discuss my concerns directly and in person with planners prior to approval if possible.

Respectfully submitted;

Brian Gorman

As the owner of a property that will be positioned above the proposed ventilation channels AND Rozelle Interchange tunnel, I would like to express serious concerns in regards to the MOD 3 .

I was never informed about the above. Door knocking and letter drops proof inefficient when not living at the property. I would appreciate to receive further communication by post or email.

- Under the MOD3, air quality/pollution of the stack outlet is unchanged. These underground tunnels should be able to accommodate modern technology filtering the air before getting released in the open. Outlets with unfiltered air are not acceptable in an era of scientific evidence of the carcinogenic impact of car exhaust. It illustrates a total disregard for people's health and indirectly burden on the healthcare system. Let's not put profit before health.

- As stated in your documentation 'Residents living above or near the tunnels may be temporarily impacted by noise and vibration from tunnel excavation' and 'vibrations caused by tunnel excavation are not expected to result in structural damage'. Tunnelling under my property will come from 2 different directions and make a junction between the ventilation tunnels and the Rozelle Interchange. I am concerned about structural damage to the 100 year old cottage. Besides a free property condition survey, vibration monitoring at properties within the zone of influence should be installed and satellite technology used and made available to the public. Expansion of the zone of influence to 250m.

- Deeper tunnelling. 7 meter is unacceptably shallow and shows no regards for residents and their properties.

- Compulsory substrata acquisition needs compensation or concessions in land tax where applicable. It is my understanding that the Rozelle interchange will attract a toll and is generating business in the substratum of my property.

- Location of the exhaust stacks. Unfiltered exhaust near 2 schools, kindergarden and dense population.

- The visual impact of the entrance to the tunnel, the stack and area around needs much improvement.

- It is time to start thinking of people movers instead of motorways accommodating the movement of cars. Sydney urgently needs a reliable and frequent public transport system.

The MOD3 is a substantial modification 'rising up from the soil' that is very different from what was originally approved in the EIS.

Considering all of the above, I object tot the MOD3.
James Wickramasuriya

Inner West Council's submission.

Attached.