NorthConnex

Trelawney Street Support Facility - Traffic issues

It is intended trucks will enter & leave the site at least one truck per minute. Trucks are supposed to enter via Loch Maree Avenue and exit directly onto Pennant Hills road. The lights at Loch Maree Ave are timed to give 20 Sec turn off to Pennant Hills road. The site will be operating 24/7 and would cause considerable disturbance in the neighbourhood. The additional traffic will also make it difficult for local traffic entering or leaving the area via Loch Maree Avenue signal lights. In addition to the operating vehicles, proposal is to have 100 car parking spaces for workers at the site. Our suggestion is that all vehicles related to the project should be banned from entering Loch Maree Avenue, Trelawney Street and Nelsons Street. DPE should take in to account the local topography noise and dust likely to travel a long way down into the valley.

1. As a long time resident of Gum Grove Place I am very concerned about the proposed NorthConnex project. The planned southern unfiltered ventilation stack is within a few hundred meters of my home and as I suffer from an Auto Immune Disease which, as it progresses attacks my lungs I fear that my health will be severely compromised. As well as that I am an asthmatic so you can understand my concerns .

2.The stack not only needs to be filtered but also moved away from residences.

3. Another major concern is the hundreds of trucks a day that will be using the local roads. These roads are very congested during both morning and afternoon peaks and the added burden of these trucks will be a nightmare for the area as well as a huge danger to all the residents.

4. At the moment as I look out my back windows I can't see the M2 as it is hidden by many tall trees. With the construction of the off ramp to the proposed tunnel how many of these trees will be lost and what are your plans to try and save some and revegetate the area?

Thank you for the opportunity to comment on the NorthConnex proposal. I support the project in its current form. My support for the project is subject to:
- the Trelawney Street tunnel support facility remaining as an emergency ventilation and fresh air intake facility
- road pricing mechanisms to encourage heavy vehicles to use the new tunnel
- consideration of opportunities for urban design improvements to Pennant Hills Road, including improved cycling facilities, following completion of the tunnel.

Importantly, my support for the project would be withdrawn if any change is made to the function of the Trelawney Street support facility.

I look forward to your assessment of the NorthConnex project.

Regards

I support the proposed NorthConnex project in its current form provided:
- the Trelawney Street tunnel support facility remains as an emergency support and fresh air intake facility and
- provision is made for bikes along Pennant Hills Road as dedicated bike lanes segregated from the traffic lanes.
I look forward to your consideration of these matters and improved local road conditions in the locality, especially for bikes.
Regards

Dear Director - Infrastructure Projects

NorthConnex Application Number: SSI 13_6136

This is my submission in response to the exhibition of the EIS for NorthConnex.

I would like to state that I object to the location of the northern ventilation stack and portal exit as described in the EIS.

I am a local resident of Wahroonga and I reside less than 50 metres away from your proposed location of the ventilation stack and portal exit. I am extremely concerned about the following issues, and request that these be considered by NorthConnex and the Department of Planning.

My concerns are:

1. That the proposed location of the stack and portal exit will adversely affect property values in Wahroonga. How can you guarantee that the houses surrounding the stack and portal exit will continue to sell at the value that they would be worth if there had been no stack and portal exit?

2. That the proposed location of the northern ventilation stack is in the centre of a densely populated residential area in Wahroonga. Vast medical research indicates that air pollution is extremely harmful to the health of human beings and that there are no safe limits for air pollution. Any extra pollution from the stack is purely unnecessary to Wahroonga, especially given the already existent pollution being produced from the Pacific motorway.

3. That the northern ventilation stack is only 15 metres tall, and is in a valley location, which will result in both poor dispersion of concentrated polluting air, as well as high levels of tunnel emission exposure to the surrounding community. In circumstances of low or no wind, the tunnel emissions will accumulate within the valley and raise the concentration of exposure levels significantly among the local community. In cases of strong winds, the low valley boundaries will allow pollutants to be easily blown to adjacent schools, aged care facilities, nearby hospitals and homes. Waitara Public School is one of the examples of this: given that it is only around 450 metres away from the proposed stack location and has a much higher altitude level, any strong winds can easily sent the tunnel pollutants to school grounds.

4. That the effects of emergency accidents possess the high likelihood of threatening lives, since the northern stack is situated in the heart of Wahroonga, surrounded by multiple schools, childcare centres, aged care facilities, hospitals, homes and businesses. When accidents such as fire and chemical leaks occur, their effects will be immediately ventilated through the stack, potentially risking the lives of many.

5. That the construction noise and dust will significantly add to noise and environmental pollution within local areas, especially since construction will last for more than four years. Children and adults alike will be unable to effectively study, work and rest under these conditions.

I request that the Department of Planning consider the issues raised above and disprove the proposed location of the northern ventilation stack and portal exit as described in EIS. Furthermore, I ask that they consider relocating the stack to a non-residential area, such as industrial or park land areas, much of which can be found approximately 2 kilometres north of the proposed location in Wahroonga.

I am writing to object to the placement of the exhaust stacks in residential areas.

The EIS rejects options for filtering of the tunnel exhaust on cost benefit grounds, however many medical professionals have expressed concerns about the impact of exhaust gases and pollution on those suffering from respiratory and bronchial illnesses.

The report makes much of the potential for an overall reduction in pollution from road traffic however, it does not consider the effects of concentrating the emissions from the length of the tunnel around communities near the exhaust stacks.

I am therefore requesting that the exhaust stacks be moved away from residential areas.

11 September 2014
Director- Infrastructure Projects
Department of planning and Environment
Number: SSI 13_6136
Major Projects Assessment
GPO Box 39
Sydney NSW 2001

North Connex Application Number: SSI 13_6136

Please find below my submission in response to the exhibition of the EIS for NorthConnex.

I am very concerned about the following issues and request that these be considered by NorthConnex and the Department of Planning. In relation to the NorthConnex Tunnel, I am particularly concerned about:

1. the fact that this tunnel will result in huge amounts of unfiltered air pollution being directed into densely populated residential areas.

2. This concern needs to be considered carefully, as Wahroonga in particular, is home to Knox and Abbotsleigh- both schools which hold hundreds of children who will be exposed to toxic, dangerous fumes daily.

3. Large scale research studies have consistently drawn the irrefutable links between air pollutants and health issues, with findings showing that, among other things, there is an increased risk of lung cancer, asthma, and birth complications resulting from such exposure.

To address my concerns, I ask that the following actions be taken:

1. the Department of Planning does not approve the project in its current form;

2. the Department of Planning recognise that while this may be a short term fix to solve the traffic problems on Pennant Hills Road, the health and well being of the people who will live near the ventilation stacks must not be compromised. To do so would be morally reprehensible; and

3. other alternative transportation options must be canvassed to ease the high level traffic on Pennant Hills Road (for example, an orbital surface route).

XXXXX

11 September 2014

Director - Infrastructure Projects
Department of Planning and Environment
Number: SSI 13_6136
Major Projects Assessment
GPO Box 39
SYDNEY NSW 2001

NorthConnex Application Number: SSI 13_6136

Please find below my submission in response to the exhibition of the EIS for NorthConnex.

Firstly I would like to state I OBJECT to the project as described in the EIS.

I have major concerns regarding the following issues and request that these be considered by NorthConnex and the Department of Planning. In regards to the NorthConnex tunnel, I am concerned about the following:

1. Firstly placing the stack in the centre of a densely populated residential area in Wahroonga, where 9,300 school children will be exposed. As children will undertake greater physical activities at school in their backyards and in the parks and ovals, they will inhale more of the pollutants as well.

2. The emissions will also have adverse health impacts on the local families and the elderly living in the many aged care facilities in the area.

3. There are two of Sydney's biggest hospitals in the area, the Hornsby Hospital and The San Hospital in close proximity to the Wahroonga stack, where the sick and the recovering along with the staff will be inhaling the pollutants coming out of the Wahroonga stack 24/7.

4. The placement of the northern ventilation stack is in a valley in Wahroonga where there are often low wind speeds, which will mean the pollutants instead of dispersing will in fact be dumped on the residents of the area. Surely NorthConnex have to come up with a more practical plan for tunnel emissions rather than just hoping that the wind blows the right way.

5. I am highly concerned about the multiple large scale research studies that suggest the impacts of air pollutants on health are serious. These include increased death from heart disease, increased risks of lung cancer, stroke, poor lung growth in children, increased asthma, and recent research suggesting low birth weight for pregnant women, increased autism, and congenital heart defects. Under the current NorthConnex plan the residents of Wahroonga will be at risk of all these health problems.


6. NorthConnex's claim that there will no portal emissions in their current proposal. How can this be verified. In fact it cannot be verified. I am concerned about the project including future provisions for portal emissions in densely populated areas, which will result in emissions remaining at ground level, and hence exposing the local population to pollutants.


7. I am concerned about the large amount of diesel emissions which will be emitted from the NorthConnex tunnel, under the terms of the proposal trucks will be forced off Pennant Hills road and forced to use the NorthConnex tunnel. Diesel emissions have been classified as carcinogenic by the World Health Organisation, and also contain a larger number of fine particles which penetrate deep into lung tissue and remain there causing inflammation.

8. I am concerned about the air quality within the tunnel which is shown in the EIS to have exceeds above standards for pollutants such as NO2, and haze from particulate matter at the ends of the tunnel.

9. I am concerned about the multiple flaws in the air quality modelling of the northern stack in the EIS. These include:
a) Extrapolation of meteorological data from other weather stations which do not reflect the local meteorology, local topography, and the valley location.
b) The use of a coarse topographical model
c) The failure to consider polluted intake air from the Pennant Hills/M2 interchange as part of the project contribution to air quality at Wahroonga
d) The background air quality being based on air quality at Lindfield and Prospect and the lack of any actual data on PM2.5

10. I am concerned that a full and transparent options assessment process was not undertaken to assess alternative designs for the project. Unlike other tunnel projects in Sydney there are alternatives for locating the stack and portals in non-residential areas.

11. I am concerned that the justification for not providing filtration for the stacks is cursory and unconvincing. For example in Japan there are 55 traffic tunnels EVERY SINGLE tunnel has active filtration. Why has this been completely overlooked by NorthConnex.

12. The EIS does not have any studies on the impacts of a fire in the tunnel.

13. The projections NorthConnex have made in relation to traffic levels in the tunnel are not realistic. One only needs to look at the projected traffic levels for the M5 and the actual levels of traffic which is much higher. This will be the case again with the NorthConnex tunnel, meaning that the residents will in fact be exposed to much higher level of pollution than what NorthConnex is stating.


To address my concerns I request that the following actions are undertaken:

1. The air quality and human health impact assessment need to be revised to address the issues raised above. This is of critical importance given that once the tunnel is built then it is not only this but the future generations as well who will be exposed to 24/7 unfiltered pollution.
2. An independent options assessment process should be undertaken to assess alternative locations for the ventilation stack and portals. NorthConnex state that the cost to relocate the stack is too high. I was under the impression that I was living in Australia "allegedly" a first world country and not some tinpot third world country on the verge of bankruptcy. NorthConnex and the State and the Federal Government need to realise that we are not a Banana Republic that cannot afford to relocate a stack.
3. To undertake a Life Cycle Analysis and assessment for the provision of filtration again critical because the current and future generations' health is at stake.
4. A long term health study on children and residents in areas impacted by stack discharges be included as part of the conditions of approval.
5. A comprehensive air quality monitoring program is developed and implemented.
6. An independent review of the ventilation system is undertaken to ensure that NorthConnex's claim of no portal emissions is justified.
7. Portal emissions from NorthConnex in the future are banned.
8. The Submissions Report/Preferred Project be exhibited to allow the community to respond to the revised information contained in the report.
9. The Department does not approve the project in its current form as it clearly does not meet the principles of Ecologically Sustainable Development as required by the Environmental Planning and Assessment Act.

XXXXXX

11 September 2014

Director - Infrastructure Projects
Department of Planning and Environment
Number: SSI 13_6136
Major Projects Assessment
GPO Box 39
SYDNEY NSW 2001

NorthConnex Application Number: SSI 13_6136

Please find below my submission in response to the exhibition of the EIS for NorthConnex.

Firstly I would like to state I object to the project as described in the EIS.

I have major concerns regarding the following issues and request that these be considered by NorthConnex and the Department of Planning. In regards to the NorthConnex tunnel, I am concerned about the following:

1. Firstly placing the stack in the centre of a densely populated residential area in Wahroonga, where 9,300 school children will be exposed. As children will undertake greater physical activities at school in their backyards and in the parks and ovals, they will inhale more of the pollutants as well.

2. The emissions will also have adverse health impacts on the local families and the elderly living in the many aged care facilities in the area.

3. There are two of Sydney's biggest hospitals in the area, the Hornsby Hospital and The San Hospital in close proximity to the Wahroonga stack, where the sick and the recovering along with the staff will be inhaling the pollutants coming out of the Wahroonga stack 24/7.

4. The placement of the northern ventilation stack is in a valley in Wahroonga where there are often low wind speeds, which will mean the pollutants instead of dispersing will in fact be dumped on the residents of the area. Surely NorthConnex have to come up with a more practical plan for tunnel emissions rather than just hoping that the wind blows the right way.

5. I am highly concerned about the multiple large scale research studies that suggest the impacts of air pollutants on health are serious. These include increased death from heart disease, increased risks of lung cancer, stroke, poor lung growth in children, increased asthma, and recent research suggesting low birth weight for pregnant women, increased autism, and congenital heart defects. Under the current NorthConnex plan the residents of Wahroonga will be at risk of all these health problems.


6. NorthConnex's claim that there will no portal emissions in their current proposal. How can this be verified. In fact it cannot be verified. I am concerned about the project including future provisions for portal emissions in densely populated areas, which will result in emissions remaining at ground level, and hence exposing the local population to pollutants.


7. I am concerned about the large amount of diesel emissions which will be emitted from the NorthConnex tunnel, under the terms of the proposal trucks will be forced off Pennant Hills road and forced to use the NorthConnex tunnel. Diesel emissions have been classified as carcinogenic by the World Health Organisation, and also contain a larger number of fine particles which penetrate deep into lung tissue and remain there causing inflammation.

8. I am concerned about the air quality within the tunnel which is shown in the EIS to have exceeds above standards for pollutants such as NO2, and haze from particulate matter at the ends of the tunnel.

9. I am concerned about the multiple flaws in the air quality modelling of the northern stack in the EIS. These include:
a) Extrapolation of meteorological data from other weather stations which do not reflect the local meteorology, local topography, and the valley location.
b) The use of a coarse topographical model
c) The failure to consider polluted intake air from the Pennant Hills/M2 interchange as part of the project contribution to air quality at Wahroonga
d) The background air quality being based on air quality at Lindfield and Prospect and the lack of any actual data on PM2.5

10. I am concerned that a full and transparent options assessment process was not undertaken to assess alternative designs for the project. Unlike other tunnel projects in Sydney there are alternatives for locating the stack and portals in non-residential areas.

11. I am concerned that the justification for not providing filtration for the stacks is cursory and unconvincing. For example in Japan there are 55 traffic tunnels EVERY SINGLE tunnel has active filtration. Why has this been completely overlooked by NorthConnex.

12. The EIS does not have any studies on the impacts of a fire in the tunnel.

13. The projections NorthConnex have made in relation to traffic levels in the tunnel are not realistic. One only needs to look at the projected traffic levels for the M5 and the actual levels of traffic which is much higher. This will be the case again with the NorthConnex tunnel, meaning that the residents will in fact be exposed to much higher level of pollution than what NorthConnex is stating.


To address my concerns I request that the following actions are undertaken:

1. The air quality and human health impact assessment need to be revised to address the issues raised above. This is of critical importance given that once the tunnel is built then it is not only this but the future generations as well who will be exposed to 24/7 unfiltered pollution.
2. An independent options assessment process should be undertaken to assess alternative locations for the ventilation stack and portals. NorthConnex state that the cost to relocate the stack is too high. I was under the impression that I was living in Australia "allegedly" a first world country and not some tinpot third world country on the verge of bankruptcy. NorthConnex and the State and the Federal Government need to realise that we are not a Banana Republic that cannot afford to relocate a stack.
3. To undertake a Life Cycle Analysis and assessment for the provision of filtration again critical because the current and future generations' health is at stake.
4. A long term health study on children and residents in areas impacted by stack discharges be included as part of the conditions of approval.
5. A comprehensive air quality monitoring program is developed and implemented.
6. An independent review of the ventilation system is undertaken to ensure that NorthConnex's claim of no portal emissions is justified.
7. Portal emissions from NorthConnex in the future are banned.
8. The Submissions Report/Preferred Project be exhibited to allow the community to respond to the revised information contained in the report.
9. The Department does not approve the project in its current form as it clearly does not meet the principles of Ecologically Sustainable Development as required by the Environmental Planning and Assessment Act.

XXXXX

NorthConnex Application Number: SSI 13_6136

Please find below my submission in response to the exhibition of the EIS for NorthConnex.

Firstly I would like to state I object to the project as described in the EIS.

I have a high level of concern regarding the following issues and request that these be considered by NorthConnex and the Department of Planning.

In regards to the NorthConnex tunnel, I am concerned about:

1. Placement of the northern ventilation stack in the centre of a densely populated residential area in Wahroonga.

2. The placement of the northern ventilation stack in a valley in Wahroonga where there are often low wind speeds, which will result in poor dispersion and exposure to community to
high levels of tunnel emission.

3. I am highly concerned about multiple large-scale research studies that suggest the impacts of air pollutants on health are serious. These include increased death from heart disease, increased risks of lung cancer, stroke, poor lung growth in children, increased asthma, and recent research suggesting low birth weight for pregnant women. These studies confirm air pollutants have inflammatory effects on humans which cause the above health problems.

4. I am concerned about future provisions for portal emissions in densely populated areas, which will result in emissions remaining at ground level, and hence exposing the local population to pollutants. I am also concerned that NorthConnex's claim
that there will no portal emissions from current proposal cannot be verified.

5. I am concerned about the large amount of diesel emissions which will be emitted from the NorthConnex tunnel, as it is being designed for heavy freight to bypass Pennant Hills Rd. Diesel emissions have been classified as carcinogenic by the World Health Organisation. They also contain a larger number of fine particles which penetrate deep into lung tissue and remain there causing inflammation.

6. I am concerned about the air quality within the tunnel.

7. I am concerned about the multiple flaws in the air quality modelling of the northern stack in the EIS. These include:
a) using meteorological data from weather stations which do not reflect the local meteorology, topography, and valley location.
b) The failure to consider polluted intake air from the Pennant Hills/M2 interchange as part of the project contribution to air quality at Wahroonga.
c) the background air quality being based on air quality at Lindfield and Prospect and the lack of any actual data on PM2.5.

8. I am concerned that alternative designs for the project haven't been properly assessed. Unlike other tunnel projects in
Sydney there are alternatives for locating the stack and portals in non-residential areas.

9. I am concerned that the justification for not providing filtration for the stacks is unconvincing.

To address my concerns I request that the following actions are undertaken:

1. The air quality and human health impact assessment need to be revised to address the issues raised above.

2. An independent options assessment process should be undertaken to assess alternative locations for the ventilation stack and portals.

3. To undertake a Life Cycle Analysis and assessment for the provision of filtration.

4. A long term health study on children and residents in areas impacted by stack discharges be included as part of the conditions of approval.

5. A comprehensive air quality monitoring program is developed and implemented.

6. An independent review of the ventilation system is undertaken to ensure that NorthConnex's claim of no portal emissions is justified.

7. Portal emissions from NorthConnex in the future are banned.

8. The Submissions Report/Preferred Project be exhibited to allow the community to respond to the revised information contained in the report.

9. The Department does not approve the project in its current form as it clearly does not meet the principles of Ecologically Sustainable Development as required by the Environmental
Planning and Assessment Act.

SSI 13_6136

I received the Community update 5 from the Northconnex last night and I hope the SCAPS could explain to the concerned residence and not to be fooled by these seemingly scientific explanations.

a) Northconnex quote some vague statements in the what they called Key facts:

"There will be air quality monitoring stations in locations like schools operating 24/7... " but do not mention where the schools are within 1 km of the stack, entries and exits or not.

"By reducing the travel times vehicles and trucks are spending in this community, our modelling predicts air quality improvements of up to 38 per cent (for particle matter 2.5 microns and less for Pennant Hills Road" and again do not mention which part of the Pennant Hills Road where the reduction of the 38 per cent are.

If Northconnex are clean, they will mention the locations of the monitoring stations which will be installed and which parts of Pennant Hills Road where their modelling is based on.

What we concern about are the residence, schools etc within 1km of the Northern and the Southern stacks if the stacks are not filtered. You don't need to be a scientist to understand if the whole of the pennant hills road traffic exhaust are all discharged into the atmosphere by these 2 stacks, the traffic pollution in those areas around 1km of the stacks will significantly increase. Anyone with half a brain will know those who live far away from the stacks (e.g. Pennant Hills Road, Thornleigh) will benefits significantly from the tunnel because all the trucks will be in the tunnel and the trucks exhaust are not released into the air around Thornleigh (fyi, trucks will be fined if they do not use the tunnel, ABC 7.30 report noted this point).

b) Northconnex use the cross harbour tunnel stacks as the aerial photo again is trying to mislead the community because there will always be (i am almost certain) sea breeze at the sea shore because the air temperature at the sea surface and at the land surface are always different (secondary school physics).

As the sea breeze disperse the stacks pollution almost immediately when they reach the outside, pollution of course will be significantly less in areas around the stacks.

c) Northconnex quoting why filtration system are required for the tunnels in Japan. "In Japan they are required to address the combination of a high fraction of diesel powered cars and a very high percentage of heavy goods vehicles"

This is exactly the scenario for the Northconnex tunnels which are mainly used by uphill and downhill trucks and Northconnex are still trying to bend the fact of not providing filtration. Hence filtration for the Northern and Southern stacks are required based on the Japan experience.

NorthConnex Application Number: SSI 13_6136

Please find below my submission in response to the exhibition of the EIS for NorthConnex.

Firstly, I would like to state I object to the project as described in the EIS.

I have a high level of concern regarding the following issues and request that these be considered by NorthConnex and the Department of Planning.

In regards to the NorthConnex tunnel, I am concerned about:

1. Placement of the northern ventilation stack in the centre of a densely populated residential area in Wahroonga, where 9,300 school children will be exposed to pollution, as well as multiple aged-care facilities, hospitals, businesses and homes.

2. I am highly concerned about the multiple large-scale research studies that suggest the impacts of air pollutants on health are serious. These include increased death from heart disease, increased risks of lung cancer, stroke, poor lung growth in children, increased asthma, and recent research suggesting low birth weight for pregnant women. Increased autism, and congenital heart defects. These studies confirm air pollutants
have inflammatory effects on humans which cause the above health problems.

To address my concerns I request that the following actions are undertaken:

1. Due to the significant health concerns of the current project design, I request the department of planning does not approve the project in it's current form.

2. I also request that alternative transport options to ease congestion on Pennant Hills Rd be considered, such as an orbital surface route.

1. Placement of the northern ventilation stack in the centre of a densely populated residential area in Wahroonga, where 9,300 school children will be exposed, as well as multiple aged care facilities, hospitals, businesses and homes.

2. The placement of the northern ventilation stack in a valley in Wahroonga where there are often low wind speeds, which will result in poor dispersion and exposure to community to high levels of tunnel emission.

3. I am highly concerned about the multiple large scale research studies that suggest the impacts of air pollutants on health are serious. These include increased death from heart disease, increased risks of lung cancer, stroke, poor lung growth in children, increased asthma, and recent research suggesting low birth weight for pregnant women, increased autism, and congenital heart defects. These studies confirm air pollutants have prothrombotic and inflammatory effects on humans which cause the above health problems.

4. I am concerned about the project including future provisions for portal emissions in densely populated areas, which will result in emissions remaining at ground level, and hence exposing the local population to pollutants. I am also concerned that NorthConnex's claim that there will no portal emissions from current proposal cannot be verified.

5. I am concerned about the large amount of diesel emissions which will be emitted from the NorthConnex tunnel, as it is being designed for heavy freight to bypass Pennant Hills Rd. Diesel emissions have been classified as carcinogenic by the World Health Organisation, and also contain a larger number of fine particles which penetrate deep into lung tissue and remain there causing inflammation.

6. I am concerned about the air quality within the tunnel which is shown in the EIS to have exceedences above standards for pollutants such as NO2, and haze from particulate matter at the ends of the tunnel.

7. I am concerned about the multiple flaws in the air quality modelling of the northern stack in the EIS. These include:
a) extrapolation of meteorological data from other weather stations which do not reflect the local meteorology, local topography, and the valley location.
b) The use of a coarse topographical model
c) The failure to consider polluted intake air from the Pennant Hills/M2 interchange as part of the project contribution to air quality at Wahroonga
d) the background air quality being based on air quality at Lindfield and Prospect and the lack of any actual data on PM2.5

8. I/we am concerned that a full and transparent options assessment process was not undertaken to assess alternative designs for the project. Unlike other tunnel projects in Sydney there are alternatives for locating the stack and portals in non-residential areas.

9. I am concerned that the justification for not providing filtration for the stacks is cursory and unconvincing.

I object to the project as described in the EIS.
The northern ventilation stack will emit pollution from a very long tunnel. The pollution will be concentrated and emitted in a densely populated residential area. The surrounding area also includes a number of schools educating thousands of children.
Hospitals and nursing homes are also located nearby.
Multiple large studies suggest the impact of air pollutants on health are serious.
The northern exhaust stack should be relocated.
The inclusion of extra exhaust stacks along the course of the tunnel would help avoid concentration of the large amount of pollution emission at just two exhaust stack locations. This should also be considered.
Furthermore, the stack should be filtered. The cost of this filtering should be included in the cost of the project. It could be recovered from the tolls charged to users of the tunnel.
We have an obligation to protect people from obvious and forseeable injury caused by this source of pollution.
Due to the significant health concerns, I request that the department of planning does not approve the project in its current form.

Dear Sir/Madam,

I have significant concerns about the Northconnex motorway as proposed as it completely ignores the potential to repair communities along Pennant Hills Road and provide more sustainable transport choices.

One of the project objectives and benefits is nominated as:
"Provide opportunities for improved public transport in the area around Pennant Hills Road. "

The EIS also notes that:
"A number of bus services currently operate along Pennant Hills Road between the M1 Pacific Motorway and the Hills M2 Motorway, with bus stops at regular intervals in both directions. Efficiency of these services is currently limited by high levels of congestion along this section of Pennant Hills Road, particularly during peak commuter periods. "

And

"With the exception of a short section around the Pennant Hills Road / Castle Hill Road intersection and the Pennant Hills Road / Hills M2 Motorway interchange, there are no dedicated cyclist facilities along this section of Pennant Hills Road. Peak congestion, heavy traffic flows and the presence of large numbers of heavy vehicles reduces amenity and in turn reduces use of Pennant Hills Road by cyclists and pedestrians."

Pennant Hills Road is one of Sydney's Rapid Bus routes as identified in Sydney's Bus Future. This places it in the same category as major bus corridors such as the North West Transitway, Victoria Road and the M2 motorway (all of which have bus lanes). Bus priority measures are promised by Sydney's Bus Future along several sections of Pennant Hills Road including between Hornsby and Pennant Hills.

Despite the strategic alignment of the project objectives, benefits, problems of existing bus congestion and NSW Government plans to introduce bus priority, the Northconnex EIS fails to include any improvements for public transport. While several extremely limited opportunities to improve bus services are canvassed (signal retiming, relocating bus stops etc), these are specifically excluded from the project. Similarly there are no planned improvements for pedestrians and cyclists on Pennant Hills Road.

The Northconnex project as proposed completely ignores the potential to improve the safety, amenity and efficiency of modes of transport other than private cars and trucks. Without changes to existing surface routes, the additional capacity offered by the Northconnex motorway (of four to six lanes of traffic) will quickly be filled by induced traffic and the opportunity for returning Pennant Hills Road to the community will be lost.

I recommend that the Department of Planning and Environment requires the proponent to implement meaningful changes to Pennant Hills Road as a core part of the Northconnex proposal. This would follow the precedents of the Eastern Distributor and Land Cove Tunnel, which have established lasting value for local communities by introducing bus lanes, cycle paths and traffic calming. As a Rapid Bus route and key cycling desire line (along the ridge line) I would suggest that bus lanes are established on Pennant Hills Road if not in a 24 hour configuration, at least between 7am-7pm daily. A secondary benefit of the bus lanes will be better access for cyclists, taxis and motorbikes. Off road shared paths could offer less experienced cyclists and pedestrians an improved experience.

Without these elements as a component of the Northconnex proposal, the project risks generating a significant increase in traffic, degrading the local and global environment, and limiting transport choices for residents of Sydney's northern suburbs.

I am writing to you with regard to my concerns arising from the proposed M1¬M2 NorthConnex Tunnel.

North Connex Premise

I understand that the argument is that the dilution of the pollution through propelling it high into the atmosphere will ensure that the ground level concentration of particles etc will be negligible.


Queries

1. Can it be moved to a new location?

I am extremely concerned about the pollution which is likely to impact those in close proximity to the stack. Studies have shown that those with asthma, the elderly and other predisposed people are most at risk. My two young children have asthma and I am exceedingly apprehensive that they will be adversely affected by the introduction of the stack. My son going to Waitara Public School and so he will be impacted by the pollutants at all times.

Similarly, the stack is in close proximity to the hospital. Smoking is prohibited in the grounds of the hospital and therefore it seems counter-intuitive to have an increased amount of carcinogens in the form of air pollution so near to patients at this major hospital. I understand that the government is spending $120 million on redeveloping this hospital and increasing its capacity. This furthers the reason why all should be done to prevent negative impact to the purity of the ambient air.

I understand that it would be best practice, backed by research, for the stack to be located away from fully residential areas, as well as areas close to schools and childcares. The preference would be in industrial/parkland areas. I understand that there is light industrial area which could be accessible if the tunnel is extended by a further 1.6 km. The land is owned by RMS and in a forested area. Surely this land could be used for the stack instead?

Recommendation: Northconnex should make a detailed assessment of the proposed extension and relocation of the stack and portal and comparison made, especially in regard to air quality, to the current application.


2. Fans

Will the fans be on the whole time or just during peak times? How will this affect the air quality around portals and through the ventilation stacks?


3. Could filtration be reconsidered?

It has been said that many other tunnels do not have filtration and that many filtration systems have been turned off.


There was a trial of the M5 stating that it was not cost effective to use filtration.


However:

Norwegian and German experts in filtration equipment showed that the dangerous components of vehicle pollution could be economically removed from the M5 East tunnel by using electrostatic precipitators and other new gas treatment systems. This equipment could more than halve the overall cost of ventilation by enabling the use of simpler ventilation systems. Currently electrostatic precipitators are in use in tunnels in Norway, Japan and South Korea and planned for Germany, Vietnam and in the reconstruction of the Mont Blanc tunnel. Their effectiveness was vouched for by all the international experts.


In addition, saying that filtration is not cost effective is not the same as saying that the filtration did not work. Indeed, it did work for the M5 trial, however, not to the high parameters apparently required to justify the filters. This means, by turning off the filters or not having them present in the stacks, a needless amount of pollution is going into the atmosphere and concentrating in one area.


I also find it unacceptable for the RMS to rely solely on trying to reduce emissions at the source (ie through targeting and fining high-polluting vehicles) rather than also on the emissions that are going to be generated. Given there is no minimum at which air pollution is 'safe', it is key that it is minimised wherever possible. To facilitate this, filtration should be mandatory for the stack. Northconnex argues that the modelling and risk assessment says that the risk is negligble and therefore filtration is unnecessary. The doctors such as Dr Nassar who recently held the forum disagreed and provided evidence to the contrary.


I am also concerned that it has been consistently said that the M5 stack has not had a discernible impact on air quality according to monitors, however, there has been reports that this is because the monitoring was not done effectively. For example, the first monitoring was done when emissions were coming from the portals, not the stack, rendering the survey of people around the stack irrelevant. The second monitoring was done in a closed question study which was highly criticised and leads many to believe that it did not adequately monitor the effects of the stack. Please refer to this article:http://ecologynow.wordpress.com/enviro-politics/toxic-exhausts-force-sydnyers-to-move-away/


It therefore cannot be relied upon that the M5 Stack has been successful.

Recommendation: Make filtration mandatory.


4. Modelling

a. Three lanes
Is the modelling of the impacts for the EIS taking into account that the tunnel is being built for 3 lanes but only marked for two? This arrangement means that there is the distinct probability that three lanes of traffic will flow through the tunnel in the future and the stack/emissions need to be calculated to deal with this level of traffic. A study which takes this into account is appropriate to ensure that the true health, air quality and noise effects are considered.

b. Appropriate monitoring stations
More time needs to be taken to have data from monitoring stations located close to the proposed stack. OEH monitoring stations at Prospect and Lindfield are not appropriate and the other air quality monitoring stations eg. At James Park, are still too far away to give a fair indication of whether the modelling used is correct. I also understand that this data was not even incorporated into the calculations!

Recommendation: It should be a requirement of the approval process that new monitoring stations close to the stack are installed and this data used to recalculate the air quality assessments and the design of the stack.

c. Modelled wind speeds
The wind speeds used assume only 1% of calm conditions. This is not reflective of Lindfield (up to 60% calm), let alone Wahroonga.

Recommendation: monitoring of windspeeds in appropriate locations near the proposed stack should be undertaken for an appropriate period of time, such as a minimum of 6 months, to ensure that the appropriate weather patterns are used for the modelling and subsequent design of the stack/analysis of air quality etc.


5. Monitoring

The NorthConnex material states that the tunnel's ventilation system will meet the NEPM standards. However, the NHMRC report issued in 2008 states: "the NEPM explicitly does not apply to localised impacts such as emissions from road tunnel stacks. Current approaches may under-represent the impacts on health of ultrafine particles and the effects associated with the short-term experience of odour".

Recommendation: hold the stacks and monitors to a higher standard which does apply to localised impacts such as a stack.

NorthConnex have also stated that it will monitor for at least 12 months but this does not form part of the EIS and so is not compulsory.

Recommendation - monitoring should be made compulsory with the effect that if it does not meet appropriate levels, ventilation will be implemented.

6. CAPS submission

I fully endorse the CAPS submission.

I have a number of issues with the proposed project:

1. I disagree that a tunnel under Pennant Hills Rd is the best response to traffic issues on Pennant Hills Rd and feel that a second crossing of the Hawkesbury River plus an extension of the M7 and M9 would be more appropriate rather than bringing traffic into this suburban area and then back out again.

2. With the current M1-M2 proposal I am concerned primarily about the ventilation stacks and the quality of the air in the surrounding areas. I do not believe that enough modelling of the local conditions has been done to ensure the long term health and safety of residents living in the vicinity of the ventilation stacks. Assurances that the air quality will be better defies belief as how can it be when fumes from the entire length of the Pennant Hills Rd tunnel will be ejected in only 2 places? Assurances that the tunnel air will be warm and rise do not seem to have taken into account what happens on a hot, calm, summer's day when the air temperature may be warmer than that in the tunnel.

3. I am concerned about the location of the southern stack. If it is more efficient to put the stack as close as possible to the portal, then why has that not been planned for?

4.West Pennant Hills recently endured the upgrade to the M2 which was noisy at night time, dusty, and damaged the local creek and cycle track. Moreover our fast access to the city was severely impeded (15 minutes to the bridge became 35 mins for months), TransUrban gave no concessions in tolls for that inconvenience.

5. Our local neighbourhood roads (especially Aiken Rd, Eaton Rd, Oakes Rd and Murray Farm Rd) will become even more congested as residents of nearby suburbs as well as us locals have to travel along them to access the new tunnel.

6. I am very concerned about the noise, dust, and traffic congestion of construction vehicles using our local roads. These are 50km/hour neighbourhood roads not zoned for heavy traffic. Construction vehicles should be limited to using roads which are designed for heavy vehicle use - in this case the M2, and Pennant Hills Rd. Widening of any of these roads will turn them into duplicate Pennant Hills Rd and will adversely affect our quiet, local community.

7. There is confusion in our local community of West Pennant Hills regarding this M1-M2 Project. The new Rail project currently under construction on Castle Hill Rd immediately to our north is very visible and many people have the 2 projects confused. Even our local community newspapers seem to be confused when they have headlines of "Residents Rail against Roadwork Plans" (Hills News Aug 7th 2014 Pg 5.) implying the prtests were about the rail project and not the tunnel project. The newspaper certainly has not helped to clarify the project confusion, so even though the community information has been available, many people in our community are still not aware of it and how it will affect them.

NorthConnex Application Number: SSI 13_6136

Please find below my/our submission in response to the exhibition of the EIS for NorthConnex.

Firstly I would like to state that I object to the project as described in the EIS.

I/We have a high level of concern regarding the following issues and request that these be considered by NorthConnex and the Department of Planning. In regards to the NorthConnex tunnel, I am concerned about:

1. Placement of the northern ventilation stack in the centre of a densely populated residential area in Wahroonga, where 9,300 school children will be exposed, as well as multiple aged care facilities, hospitals, businesses and homes.

2. The placement of the northern ventilation stack in a valley in Wahroonga where there are often low wind speeds, which will result in poor dispersion and exposure to community to high levels of tunnel emission.

3. I am highly concerned about the multiple large scale research studies that suggest the impacts of air pollutants on health are serious. These include increased death from heart disease, increased risks of lung cancer, stroke, poor lung growth in children, increased asthma, and recent research suggesting low birth weight for pregnant women, increased autism, and congenital heart defects. These studies confirm air pollutants have prothrombotic and inflammatory effects on humans which cause the above health problems.

4. I am concerned about the project including future provisions for portal emissions in densely populated areas, which will result in emissions remaining at ground level, and hence exposing the local population to pollutants. I am also concerned that NorthConnex's claim that there will no portal emissions from current proposal cannot be verified.

5. I am concerned about the large amount of diesel emissions which will be emitted from the NorthConnex tunnel, as it is being designed for heavy freight to bypass Pennant Hills Rd. Diesel emissions have been classified as carcinogenic by the World Health Organisation, and also contain a larger number of fine particles which penetrate deep into lung tissue and remain there causing inflammation.

6. I am concerned about the air quality within the tunnel which is shown in the EIS to have exceedences above standards for pollutants such as NO2, and haze from particulate matter at the ends of the tunnel.

7. I am concerned about the multiple flaws in the air quality modelling of the northern stack in the EIS. These include:
a) extrapolation of meteorological data from other weather stations which do not reflect the local meteorology, local topography, and the valley location.
b) The use of a coarse topographical model
c) The failure to consider polluted intake air from the Pennant Hills/M2 interchange as part of the project contribution to air quality at Wahroonga
d) the background air quality being based on air quality at Lindfield and Prospect and the lack of any actual data on PM2.5

8. I/we am concerned that a full and transparent options assessment process was not undertaken to assess alternative designs for the project. Unlike other tunnel projects in Sydney there are alternatives for locating the stack and portals in non-residential areas.

9. I am concerned that the justification for not providing filtration for the stacks is cursory and unconvincing.

10. I am concerned that there was no consideration for traffic jams, breakdowns, complete halt of traffic and accidents within and nearby the tunnel.
 

To address my/our concerns I request that the following actions are undertaken:

1. The air quality and human health impact assessment need to be revised to address the issues raised above. There are several existing tunnels which can be took for better modeling
2. An independent options assessment process should be undertaken to assess alternative locations for the ventilation stack and portals.
3. To undertake a Life Cycle Analysis and assessment for the provision of filtration
4. A long term health study on children and residents in areas impacted by stack discharges be included as part of the conditions of approval.
5. A comprehensive air quality monitoring program is developed and implemented. E.g. monitoring stations deployed in the appropriate locations for 3 years prior any construction can begin and all data to be easily available to public at all times.
6. An independent review of the ventilation system is undertaken to ensure that NorthConnex's claim of no portal emissions is justified.
7. Portal emissions from NorthConnex in the future are banned.
8. The Submissions Report/Preferred Project be exhibited to allow the community to respond to the revised information contained in the report.
9. The Department does not approve the project in its current form as it clearly does not meet the principles of Ecologically Sustainable Development as required by the Environmental Planning and Assessment Act.

NorthConnex Application Number: SSI 13_6136

Please find below my/our submission in response to the exhibition of the EIS for NorthConnex.

Firstly I would like to state that I object to the project as described in the EIS.

I/We have a high level of concern regarding the following issues and request that these be considered by NorthConnex and the Department of Planning. In regards to the NorthConnex tunnel, I am concerned about:

1. Placement of the northern ventilation stack in the centre of a densely populated residential area in Wahroonga, where 9,300 school children will be exposed, as well as multiple aged care facilities, hospitals, businesses and homes.

2. The placement of the northern ventilation stack in a valley in Wahroonga where there are often low wind speeds, which will result in poor dispersion and exposure to community to high levels of tunnel emission.

3. I am highly concerned about the multiple large scale research studies that suggest the impacts of air pollutants on health are serious. These include increased death from heart disease, increased risks of lung cancer, stroke, poor lung growth in children, increased asthma, and recent research suggesting low birth weight for pregnant women, increased autism, and congenital heart defects. These studies confirm air pollutants have prothrombotic and inflammatory effects on humans which cause the above health problems.

4. I am concerned about the project including future provisions for portal emissions in densely populated areas, which will result in emissions remaining at ground level, and hence exposing the local population to pollutants. I am also concerned that NorthConnex's claim that there will no portal emissions from current proposal cannot be verified.

5. I am concerned about the large amount of diesel emissions which will be emitted from the NorthConnex tunnel, as it is being designed for heavy freight to bypass Pennant Hills Rd. Diesel emissions have been classified as carcinogenic by the World Health Organisation, and also contain a larger number of fine particles which penetrate deep into lung tissue and remain there causing inflammation.

6. I am concerned about the air quality within the tunnel which is shown in the EIS to have exceedences above standards for pollutants such as NO2, and haze from particulate matter at the ends of the tunnel.

7. I am concerned about the multiple flaws in the air quality modelling of the northern stack in the EIS. These include:
a) extrapolation of meteorological data from other weather stations which do not reflect the local meteorology, local topography, and the valley location.
b) The use of a coarse topographical model
c) The failure to consider polluted intake air from the Pennant Hills/M2 interchange as part of the project contribution to air quality at Wahroonga
d) the background air quality being based on air quality at Lindfield and Prospect and the lack of any actual data on PM2.5

8. I/we am concerned that a full and transparent options assessment process was not undertaken to assess alternative designs for the project. Unlike other tunnel projects in Sydney there are alternatives for locating the stack and portals in non-residential areas.

9. I am concerned that the justification for not providing filtration for the stacks is cursory and unconvincing.

10. I am concerned that there was no consideration for traffic jams, breakdowns, complete halt of traffic and accidents within and nearby the tunnel.
 

To address my/our concerns I request that the following actions are undertaken:

1. The air quality and human health impact assessment need to be revised to address the issues raised above. There are several existing tunnels which can be took for better modeling
2. An independent options assessment process should be undertaken to assess alternative locations for the ventilation stack and portals.
3. To undertake a Life Cycle Analysis and assessment for the provision of filtration
4. A long term health study on children and residents in areas impacted by stack discharges be included as part of the conditions of approval.
5. A comprehensive air quality monitoring program is developed and implemented. E.g. monitoring stations deployed in the appropriate locations for 3 years prior any construction can begin and all data to be easily available to public at all times.
6. An independent review of the ventilation system is undertaken to ensure that NorthConnex's claim of no portal emissions is justified.
7. Portal emissions from NorthConnex in the future are banned.
8. The Submissions Report/Preferred Project be exhibited to allow the community to respond to the revised information contained in the report.
9. The Department does not approve the project in its current form as it clearly does not meet the principles of Ecologically Sustainable Development as required by the Environmental Planning and Assessment Act.

Decision makers must exercise the "Precautionary Principle"

In Leatch, Stein J took this starting point and described the precautionary principle as a 'statement of commonsense'. He continued: It is directed towards the prevention of serious or irreversible harm to the environment in situations of scientific uncertainty. Its premise is that where uncertainty exists concerning the nature or scope of environmental harm (whether this follows from policies, decisions or activities), decision makers should be cautious.

The Honourable Justice Paul Stein (1996) "The Role of the Land and Environment Court in the Emergence of Public Interest Environmental Law" 13 Environmental and Planning Law Journal 179.

The Honourable Justice Paul Stein AM (2000) "Are Decision-makers too Cautious with the Precautionary Principle 17 Environmental Planning and Law Journal 1 at 3 left to join Court of Appeal in 1997

There seems to be a clear case for caution here. There is a mountain of scientific evidence to indicate that there will be considerable serious and irreversible harm to the environment (in this case the people).