NorthConnex

I endorse the attached SCAPS Group submissions.

I object to the M1-M2 Project

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Please find attached our submission in response to the exhibition of the EIS for NorthConnex.

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I endorse the attached SCAPS Group submissions

12 September 2014.
Director - Infrastructure Projects
Department of Planning and Environment
Number: SSI 13_6136
Major Projects Assessment
GPO Box 39
SYDNEY NSW 2001
Submission by Bryan Johnson,
23 Gipps Street Drummoyne, N.S.W. 2047
Via online form:
http://majorprojects.planning.nsw.gov.au/index.pl?action=view_job&job_id=61
36
NorthConnex Application Number: SSI 13_6136
Please find below my submission in response to the exhibition of the EIS for
NorthConnex.
I would like to state that I object to the project as described in the EIS.
Introduction
My name is Bryan Johnson. I am a grandfather. Three of my grandchildren live with
their parents in Wahroonga. Their family home is located only 25 metres from the
base of the proposed northern exhaust stack for the NorthConnex tunnel. They will
be living in very close proximity to the proposed northern portal.
Two of these children, twins now two years old were premature babies. As such, they
are at higher risk of respiratory disease from particle and other forms of pollution than
average children, who in turn are at greater risk, during their formative years than
adults in the population. This is unfortunate, but widely accepted medical opinion.
Prior to retirement I was a career public servant, working in the then N.S.W.
Department of Public Works and Services and then in N.S.W. Treasury, Office of
Financial Management. I was associated with infrastructure provision throughout my
career.
I am concerned that the currently proposed unsolicited proposal by NorthConnex
exposes the State of N.S.W. to possible risks to its credit rating, significant risks to
liabilities for ongoing adverse health outcomes suffered by the community in
proximity to the tunnel infrastructure, significant risk of financial burden from future
community class action for specific damages from this project and from similar
projects currently proposed. I am also concerned at the unfair burden of health,
wellbeing and financial impacts that appears to be imposed on particular individuals
and communities from this and similar projects where overall benefits claimed for the
community at large are achieved at the extreme detriment and cost to communities
often in proximity to the projects.
NorthConnex EIS Submission
2
I have read the submission in response to the NorthConnex Environmental Impact
Statement by CAPS (Community Against Polluting Stacks) and Ku-Ring-Gai Council
and I fully endorse both submissions.
Concerns
I have great concern regarding the following issues and request that these be
considered by NorthConnex, Roads and Maritime Services and the Department of
Planning and Environment.
In regards to the NorthConnex tunnel, I am concerned about:
Local community health.
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.
The base of the stack is located at an R.L. of approximately 170metres above
sea level. This compares with an R.L. of 190 metres on the Pacific Highway at
Wahroonga. Locating the exhaust stack in this valley reduces the likelihood of
wind flows dispersing the stack pollutants.
Wind flow predictions for the stack site at Wahroonga show only one percent of
days are still at this site. Yet no weather data close to this location have been
used. Instead, data from sites as far away as Prospect and Sydney Airport have
been used. The data used by NorthConnex suggests that Wahroonga is the
windiest suburb in Sydney. This is in stark contrast to local knowledge that fogs
not infrequently hang in Wahroonga for several hours of a morning. Pictures
taken by Prof. Richard Chard, from upper floors of the San Hospital at
Wahroonga last week clearly shows fog in the valley.
Such lazy weather and pollution dispersal predictions appear to me to be
incompetent or deliberately misleading.
If the one percent figure for still air conditions has been understated which seems
from all other wind speed data quoted in the EIS most likely, then the dispersals
predicted will not be achieved, leading to higher levels of pollution spill onto the
community in the vicinity of the proposed stacks.
The EIS predicts sufficient mixing and disposal of stack emissions to minimize
dangers to health of people at ground level. There does not appear to be any
consideration that many people in the vicinity of the northern stack will be living
well above the level at the base of the stack. This is not only due to the fact that
the stack is proposed to be built in a valley but that 6 story medium density
housing located within 200 metres of the proposed stack is currently under
construction and will be completed before the NorthConnex project is completed.
Other apartment projects up to 10 stories are likely within 500 metres of the
proposed stack. There are also several four story residential blocks in the area.
The Minister for Planning has alerted the north shore that it will be the location for
an influx of multi-story residential development. The current NorthConnex
northern ventilation proposal could make such development unhealthy and
unviable.
NorthConnex EIS Submission
3
2. that the exhaust stack beside the southern portal is located alongside residential
areas. This is despite the location of Pennant Hills Golf Course across Pennant
Hills Road. There has been no attempt to locate the exhaust stack within and to
the centre of that open space by way of a horizontal offset to the stack from the
tunnel. This would have provided at least some protection to surrounding
communities from exhaust pollution from the stack. When NorthConnex project
staff were asked at the community pollution forum at Hornsby RSL Club in
August 2014, about this extraordinary stack location alongside a residential area
they stated that RMS already owned land at the proposed site yet they assured
incredulous attendees that this was not a cost saving measure. This once again
flies in the face of the Minister for Roads and Maritime Services' claim that this is
a gold standard proposal. Then it came to light that RMS already own a site of
some 4000m2 within the golf course.
3. NorthConnex Publications that state "there are a number of tunnel ventilation
outlets located within and near urban and residential areas in Sydney and
Australia. These include the Cross City, Eastern Distributor, M5 East and Lane
Cove tunnels in Sydney". This is misleading as most of these exhaust stacks are
in commercial precincts (as in Darling Harbour with residences several hundred
metres from the stack), or in industrial areas (as is the case with the Lane Cove
stack). The NorthConnex proposal is for stacks located among residences. What
makes this proposal even more outrageous is that NorthConnex is more than
twice the length of any other tunnel, thus exhausting more than twice the
pollution load of any other tunnel. The NorthConnex tunnel design uses only one
stack at the exit end of each tunnel. The Ku-Ring-gai Council submission has
suggested investigating the use of several exhaust stacks to at least distribute
the pollution from such a long tunnel and so few stacks. While this may make
public health sense it would cause great political pain for government, and
community anxiety, the suggestion highlights that the two stack solution has
public health problems. NorthConnex has at least limited the public health
problem to two sources (dismissing for the moment the significant problem of
portal emissions). It suggests the importance of locating these two pollution
sources so as to eliminate the public health risk. Having horizontal offsets to
each of the proposed stacks, in the south to Pennant Hills Golf course and in the
north to Ku-Ring-gai Chase, would allow discharge further from surrounding
homes and make it more politically possible to make each stack higher to
achieve the dispersion required.
4. NorthConnex publications that also state "The continuing reduction in vehicle
emissions has enabled NorthConnex to design a ventilation system that would
not have been possible a decade ago" One of the main stated aims of
NorthConnex project is to remove 5000 trucks daily from Pennant Hills Road.
NorthConnex project team stated at a NorthConnex community forum in Pennant
Hills that heavy trucks produce 30 to 50 times the overall pollution of a passenger
car. Most such vehicles are also diesel fuelled. NorthConnex traffic modelling has
been based on particular mixes of vehicle types and loadings. This mix and the
modelled speed of these vehicles will have a significant effect on the predicted
level of pollution exhausting from the stacks. I am concerned that the
NorthConnex may be underestimating pollution levels. Diesel emissions have
been classified as carcinogenic by the World Health Organisation, and also
NorthConnex EIS Submission
4
contain a larger number of fine particles which penetrate deep into lung tissue
and remain there causing inflammation.
The emissions from the NorthConnex project will be significantly different to the
emissions from other tunnels. Considered together it seems misleading to liken
the exhaust stacks from NorthConnex with any other Sydney tunnel.
NorthConnex project have publically stated that the tunnel will be built to
accommodate three lanes of traffic but will initially be lane marked for two lanes.
Thus there is a 30 percent extra capacity built into the tunnel's capacity. I
understand that tunnel exhaust modelling is based on initial traffic flow capacity,
not full flow. I believe this understates pollution fallout by a similar amount.
5. that NorthConnex proposes to monitor pollution levels from exhaust stacks for a
period of only twelve months from the opening of the project. This will coincide
with a period of possibly lower patronage as motorists become used to
incorporating the tunnel into their travel. It will also not track the predicted growth
in patronage over time and will not give the tunnel operators data on which to
determine more efficient and healthy operations. Independent air monitoring at
critical points along the corridor for the life of the tunnel and real time electronic
distribution of this data to the general public, and the linking of this data to the
pollution license under which the project will operate is necessary for the safety of
the community, the protection of both State and Federal Governments against
future class actions for damages and to encourage the tunnel operator to
optimize the effectiveness and efficiency of operations.
6. the many respected 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.
7. portal emissions, some level of which are unavoidable because of the piston-like
effect of exiting vehicles from the tunnel, being emitted from all proposed tunnel
openings. This will result in emissions remaining at ground level, exposing the
local population to pollutants without even the benefit of higher level dispersion
from a stack. The jet fans proposed to be installed on the tunnel ceiling cannot be
located closer than 300 metres from the portals because of the noise impact on
surrounding residential properties. The north and south portals have exhaust
stacks located in close proximity to the portals to exhaust polluted air drawn from
along the entire length of the tunnels and to draw back whatever air they can into
the tunnel exit portal, to reduce portal emissions. No exhaust stack is proposed
for the portal at Pierces Corner thus making it very difficult not to have high levels
of portal emission at that location. This would require the reader of the EIS to
believe that sufficient air flow will be achieved by fans not closer to the portal than
300 metres and that that air can be effectively drawn back down the tunnel to the
stacks at either end.
NorthConnex EIS Submission
5
8. I am also concerned that NorthConnex claims that there will no portal emissions
from current proposal cannot be verified.
9. that the air quality within the tunnel which is shown in the EIS to exceed at times
the standards for pollutants such as NO2, and haze from particulate matter at
the ends of the tunnel.
10. about the many 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
e) the lack of any actual data on PM2.5. Peer reviewed medical and scientific
literature is becoming more concerned at the health consequences of such
fine particles and of very fine particles down to PM0.1. This so called asbestos
of the twenty first century should not be dismissed so easily that it is simply
measured as part of the PM10 count. Such poor science leaves the
community open to potential health risks in the future and NorthConnex, the
N.S.W. Government and Commonwealth Government as joint participants in
this infrastructure proposal, exposed to future class action for damage
caused to the community. As James Hardie was liable for damages because
of their knowledge of the dangers of asbestos, with the current knowledge of
fine particles on health and the direction in which continuing research
appears to be heading, it would seem likely that those authorities who
presently took a cavalier approach to potential health consequences would
be held to have acted in bad spirit and recklessly. The precautionary
principle should apply in this situation, especially given the very long life of
such infrastructure projects.
f) the financial cost burden on government should it be forced to retrofit the
NorthConnex tunnel to improve air quality in the future. The community
remembers the financially and politically expensive retrofit of the M5 tunnel
stacks. Government I presume is also concerned that such a debacle might
be repeated. The Minister for Roads and Maritime Services stated on the
A.B.C. Stateline program on Friday 5 September 2014, that the NorthConnex
proposal was a gold standard design and that no short cuts were being
taken. This does not appear to me consistent with much of the approach set
out in the project EIS.
11. 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 no alternatives for locating the stack and portals in non-residential
areas. The current location of the northern portal and its associated exhaust
stack changed from the nominal proposal that came out of the 2004 and 2007
Government enquiries into the road infrastructure requirements in this area of
Sydney. The current proposal appears to have used lazy engineering design that
has led to major health and amenity concerns for communities located around
NorthConnex EIS Submission
6
this project. It appears to be a cheap and nasty response to Government's
expressed road transport needs.
12. that the justification for not providing filtration for the north and south exhaust
stacks is cursory and unconvincing. NorthConnex publications and its project
team have dismissed filtering as not being "cost effective". There has been no
discussion of the capital cost of filtering or its ongoing operating costs, its
effectiveness in reducing specific pollution products or its use alongside other
pollution control proposals. On the face of it this appears to fly in the face of the
Minister for Roads and Maritime Services attestations on the gold standard of
the proposal.
Community amenity
1. that absolutely no regard has been paid to the impacts the proposal has on the
community amenity. The northern portal has been configured as an industrial
object some 4 stories in height and some hundred and fifty metres in length, with
a substation, pump room, and close by, 2 large water tanks. The NorthConnex
publications show a photo montage of this industrial structure located in an
industrial area. This is deliberately misleading due I presume to NorthConnex's
embarrassment in having to more accurately show that the industrial structure is
to be erected into a currently sylvan residential street setting directly opposite
significant heritage listed houses. It again appears that lazy engineering and an
attempt to produce only the cheapest solution is the only reason for the decision
to create this industrial scaled solution. This would be unnecessary had the pump
room, substation, and water tanks been located below or partly below ground
level, or below the level of the sound walls. There is no need to locate such
infrastructure in the immediate vicinity of the portal. Moving the portal further
north, or moving the infrastructure further south are obvious solutions. Locating
the infrastructure below ground level and beside the tunnel corridor could also be
examined. As long as the water tanks are above all points along the length of the
tunnels, they will still flow under the force of gravity. This lazy engineering is
apparent throughout much of the NorthConnex proposal.
2. that the southern portal and exhaust stack site have been located with insufficient
consideration for the amenity of surrounding homes. The water treatment plant,
substation and switch station (located on adjoining Coral Tree Drive) are not
proposed to sit above the portal, as on the northern portal but are still proposed
to be above ground level. While a noise wall appears to be proposed to separate
only part of the site from adjoining homes there has been no attempt to minimize
visual impact on these homes. Extending the noise walls along workshop storage
areas and other areas subject to site traffic and maintaining the height of the
treatment plant, substation and switch station below the noise wall, by
constructing them as necessary below ground level would appear an easy way to
minimize the visual and noise impact on community amenity. Effective vegetation
screening around service yards, storage areas and workshops appears on
NorthConnex publications and should be mandated by Department of Planning
and Environment to minimize visual impact to surrounding homes.
NorthConnex EIS Submission
7
3. that the operating noise of the pumps, substation, jet fans within the tunnel and
exhaust fans within the stack will have a significant and intrusive acoustic impact
on homes located close to the exhaust stacks. While at the northern portal the
portal and the substation and pump room located above it, will be behind a sound
wall, the height of the equipment will locate it up to 10 metres above the top of
that wall. Should an attempt be made to increase the escape velocity of the
pollution being emitted from the exhaust stack, in an attempt to increase mixing
and dispersal, this is likely to result in higher fan and air flow noise.
4. that the exhaust stacks which are currently proposed to be some 15 metres
above the existing ground level will be a major visual intrusion especially at the
northern portal where it intrudes in a heritage precinct. Should the stack height be
raised to accommodate better dispersion, the visual intrusion will increase and its
visibility will affect most of Wahroonga. This suggests the proposed location is
difficult and a better siting would alleviate both public health and community
amenity difficulties.
5. that existing tree cover will be removed as part of the construction of the portals.
This is critically important in that if the response to the loss of tree cover is to
replant replacement trees it will leave the four story blight with no visual
screening for many years. As the blight is within 25 metres of surrounding houses
the visual intrusion on the streetscape and amenity of the area is very significant.
6. that large swathes of blue gum high forest will be removed at the site of the
northern interchange to erect a compound for the storage and loading of
excavated material from the tunnel. Some 1.41ha of forest will be removed of the
remaining 170ha of remnant forest in the Sydney area. The project is designed to
remove a total of 2.81ha of forests and tree cover. While the EIS does not give
definite information on any environmental offsets or biodiversity credits for this
quite shocking deforestation, the value of remnant forests and tree cover in the
Sydney area is not just their effects on global carbon levels but the effects they
have on their immediate microclimate as well as their important visual impact on
an increasingly dense and hard landscaped city. Thus any offsets must take into
account how such swathes of forest can be removed and this impact on this area
be offset without waiting 30 to 50 years for any reforestation to be effective.
Proposing to process excavation material in this way is not acceptable and is yet
another example of lazy engineering, completely dismissing the value of
community amenity and flying in the face of the Minister for Roads and Maritime
Services statements.
7. that no assessment has been made on ground water and its management
throughout the infrastructure corridor. Without such modelling there is no way of
identifying the porosity of substructure rock and soils. This could lead to changes
to the water table during construction or permanently, with impacts on runoffs and
the creation of sink holes. The embarrassing loss of much of a multi-story
residential building into the Lane Cove tunnel could be replicated by
NorthConnex. Widespread damage to homes undermined or close to the tunnel
corridor is also possible.
NorthConnex EIS Submission
8
Tunnel configuration
1. that tunnel gradients are steeper than they need be. Despite the NorthConnex
project team rhetoric at community forums that the NorthConnex tunnel would
provide very low gradients which would lead to fuel savings to motorists and
reduction in exhaust levels, an investigation of RLs at the south and north ends of
the tunnels indicates the following problems. RLs at the southern end are about
115 metres above sea level. At the northern portal, RLs are about 170 metres.
Further north along the M1 freeway, RLs fall to 100 metres some one Km from
the proposed portal. A portal located 1 to 1.5Km north would allow an almost flat
run along the tunnel. Entering and exiting at a high point at Wahroonga appears
to cause many of the problems of this proposal. Tunnel levels also fall to 75
metres to go under the railway tunnel. Having the road tunnel pass above the
railway tunnel, even if this requires more careful excavation, would permit more
level gradients to be maintained.
2. While the Kur-Ring-Gai Council submission on the NorthConnex EIS questions
the quantum of pollution generated from a longer tunnel because of difficulties
with gradients (which I fail to understand) the alternative which is to leave the
northern portal as proposed and pipe the stack by a trenched pipe to a relatively
safe location north of North Wahroonga or preferably to Ku-Ring-Gai Chase and
allow a higher stack to obtain the necessary dispersal.
3. that the tunnel operating license may not require the operators to continue
operations over the total service life of the tunnel with compliance to external
operating noise levels, pollution levels, runoff levels and other operating
parameters the tunnel is claimed to achieve or to improve these performances as
community knowledge and expectations change.
4. that the operator may not have to maintain for the service life of the tunnel,
infrastructure aimed at ameliorating the tunnel impact on surrounding
communities. This would include but not be limited to vegetation, noise walls,
berms and embankments.
5. that construction impacts on surrounding communities appear to have been
treated with arrogant dismissal by NorthConnex. The heavy vehicle route
proposed at the southern interchange which uses currently residential streets
appears not to have considered tunneling under Pennant Hills Road to allow
access from the south to the construction site. Continuing use of this underpass
should be considered as part of the tunnel's operation. The Minister for Roads
and Maritime Services' promise of a gold standard project once again looks to be
at odds with the proposal.
6. the lack of detail as to where the massive amount of excavated material is to be
disposed. Risk management plans calculate the risk of death and injury resulting
from a project. The plan then attempts to minimize such risk. An obvious risk is in
the transport of excavated material. It will obviously be a function of the distance
it has to be relocated. There is no information on this. This suggests a level of
oversight by NorthConnex within the realm of criminal negligence or a veil of
secrecy to minimize public appraisal. It also allows the NSW State Government to
abrogate its responsibilities for making decisions on levels of risk beyond which
NorthConnex EIS Submission
9
the community would not be asked to endure. Suggestions by the Mayor of
Hornsby that Hornsby Council could accept a major portion of the excavation
material to fill its Quarry in the Asquith area should be considered as it would
reduce transport distance, risk and probably cost. These proposals included
transporting material by tunnels allowing quick access to the quarry, which would
then become on / off ramps from the M1 to Hornsby.
7. the NorthConnex team's common advice to the community on matters ranging
from locations for disposal of excavation material to vehicle access to homes
during construction. This appears to give NorthConnex unnecessary discretion
without effective overview of a wide range of important decisions that could
significantly change project risks, construction and operational impacts on
communities. While day to day decisions must be made on any project during the
course of their construction, effective independent review of detailed design
decisions must be implemented to protect the community interest.
8. the heavy toll this project has already taken on the mental health of individual
members of affected communities. Much of this has been due to the very
incompetent (or perhaps it seems to me, deliberately dishonest) communication
by NorthConnex with the community. This includes letters to property owners on
whether their properties were noise affected or to be reclaimed, going to wrong
addresses or not being sent. (NorthConnex puts this down to it identifying
properties on Google. I know this beggars belief but it was admitted by project
staff.) NorthConnex, aware of the significant effects its actions had caused,
instigated a mental health referral and support system. This should continue to
operate until at least the end of the construction period as distress from intrusive
construction activities is likely.
To address my concerns I request that the following actions are undertaken:
1. 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.
2. Wind speed estimates at both the north and south portals be reviewed. That
weather data most appropriate to the sites be used. That weather data from
privately operated local weather stations, which are believed to exist be sourced
and independently assessed, and if considered credible, be used as part of
revised weather modelling.
3. In view of revised weather modelling, review the pollution dispersal models
including stack heights and exit velocities to ensure the long term safety of the
community. Review stack noise predictions to minimize nuisance to surrounding
residents.
4. Ensure that pollution dispersion modelling takes into account that a 6 story
building is currently under construction some 200 metres from the northern
exhaust stack, that there are several 4 story residential buildings in the same
NorthConnex EIS Submission
10
area and that it is probable that there will be an influx of 8 to 12 story residential
buildings in the area according to the advice of the Minister for Planning and
Environment. Furthermore, ensure that dispersion modelling uses suitably
detailed topographical data to ensure accurate assessment of fallout on areas at
higher elevations around the proposed stacks.
5. Consider alternative placement of both the northern and the southern exhaust
stacks to locations that lessen the danger from stack fallout on surrounding
communities. Specifically consider location of the southern stack in a central part
of Pennant Hills Golf Course which would provide several hundred metres of
protection around the stack and allowing higher stack heights than would be
politically acceptable in residential areas. Specifically consider location of the
northern stack some 1.6Km north of its presently proposed, along the M1
freeway. Consider piping the exhaust below ground over this distance. This
would locate the stack in a largely industrial area of Asquith, providing some
protection to surrounding residences and allowing higher stack heights than
would be politically acceptable in residential areas. Also specifically consider
relocation of the northern portal some 1.6Km north along the M1 freeway and
piping the exhaust to a stack located in Ku-Ring-Gai Chase, again allowing
higher stack heights. Specifically consider the possibility of reclaiming the land
currently occupied by the M1 freeway for use as medium density housing to
offset any additional cost in relocating the stacks. This idea was first proposed by
Peter Georgiadis. It also appears to align with the State Government policy for
increasing urban population density. That all siting alternatives be subjected to
independent engineering assessment.
6. Consider the current tunnel gradient running from a RL of about 115 metres in
the south, then dropping to a RL of 75 metres to pass under the railway tunnel,
exiting at an RL of about 170 metres at Wahroonga. Consider tunneling above
the railway tunnel to reduce tunnel gradients, vehicle fuel use and resulting
pollution. This reduced gradient would work whether the northern portal was
located as presently proposed or moved northward to exit at a reduced RL.
7. Review the proposed location of tunnel infrastructure above the northern portal.
Location of pump room and substation above the portal is not operationally
necessary as is demonstrated by the location of such equipment other than
above the southern portal. The resulting 10 metre industrial complex is an affront
in a heritage area. Reconfigure this infrastructure to keep it below ground level or
at sufficient height below the sound walls for it not to be visible from surrounding
homes. Consider minor relocation of the portal or the associated infrastructure so
that the infrastructure can be located below or partly below ground while still
above the line of the portal. Consider the integration of water tanks below ground
on land with RLs much closer to that of Pearces Corner, say up to 30 metres
higher than the site selected.(Note the RLs of the proposed tanks are about 170
metres. THIS IS NOT THE HIGHEST POINT ON THE PROPOSED TUNNEL
ROUTE. Pearces Corner has an RL of about 200metres) It would make better
hydraulic sense to locate the water tanks and water pumps to a below ground site
in close proximity to Pearces Corner. This would save purchase of at least one
property in Bareena Avenue Wahroonga and reduce the visual intrusion into a
heritage residential environment. Also consider location of several water tanks
NorthConnex EIS Submission
11
along the tunnel route, possibly on the site of fire dampers, depending on visual
impact to surrounding areas. This could increase fire safety overall.
8. A groundwater assessment completed to consider impacts on water tables, and
porosity of substrata to eliminate adverse environmental impacts, manage runoff
and eliminate the risk of sink holes occurring.
9. Consider the use of several exhaust stacks to reduce the quantity exhausted
from each. This proposal made by Ku-Ring-Gai Council in their submission on
the EIS would be politically difficult and should not be done if it exposes any
communities to health risks or significantly impacts local amenity.
10. The effectiveness of stack filtration to reduce exhaust emissions be modelled.
That the capital and maintenance costs over the service life of the project be
estimated and compared to alternative options for dealing with emissions.
11. Review vehicle modelling used for exhaust and air quality prediction. Include
sensitivity analysis to determine how much changes made in vehicle size and
loading, vehicle speed and gradient data make to predictions.
12. The Department of Planning and Environment implement independent review of
the alternative stack and portal assessment process.
13. Local road proposals for trucks around the southern stack be reconsidered. That
construction of a short tunnel under Pennant Hills Road for trucks approaching
from the south be considered and the incorporation of such tunnel into the tunnel
operating plan be considered to stop major impacts by heavy construction traffic
for many years on large areas of currently residential areas.
14. Undertake a review of the health effects of fine particle pollution (PM2.5 ) and
ultra- fines (PM0.1) and advise how the NorthConnex project will deal with this
risk. The EIS has included finer particles in its count of PM10. In light of current
research and medical concern, including that recently expressed by the AMA and
local concerned doctors, this is unsatisfactory.
15. Traffic flow modelling and pollution modelling for NorthConnex be based on three
lanes of traffic, and maximum tunnel capacity so as to reflect the tunnel's
capabilities.
16. NorthConnex be required to set up and maintain for the service life of the tunnel,
air quality monitoring stations at critical points external to and along the tunnel
corridor, and similar in-tunnel air quality monitoring stations, as part of the
licensing conditions for the project. That air quality monitoring be conducted
independent of NorthConnex and be publically available electronically in real
time. That significant penalties be imposed on the tunnel operator for breeches of
the terms of its license, especially those affecting public health.
17. Air flow be modelled around all portals including those with no exhaust stack
close by, to ensure zero portal emissions as has been claimed by NorthConnex.
NorthConnex EIS Submission
12
18. The effect on portal emissions, of reducing the height of portals from the design
height of tunnel roofs down to a height just able to allow safe exiting of maximum
legal height vehicles be modelled.
19. NorthConnex be required as a condition of its operating license to maintain all
infrastructure associated with the tunnel, including sound walls, monitoring
equipment, berms, embankments and runoff controls to meet ongoing
performance requirements, for the operating life of the project.
20. Architectural and landscape architectural design be employed to ensure effective
and aesthetic integration of exhaust stacks, plant rooms, pump rooms
substations, water tanks, sound walls and ancillary infrastructure into their
surrounding heritage and residential environments. That architectural forms and
colour, landscape elements and ground contours be used to ensure this
integration.
21. NorthConnex develop detailed design of its construction and operating plans to
minimize destruction of all existing vegetation especially that which could screen
surrounding homes from the visual impact of proposed development. That
penalties be imposed for damage to significant vegetation as would be required
of other developments. That plans be prepared showing what action
NorthConnex will take to replace any vegetation removed and how it will address
the impacts of its vegetation removal in the period of regrowth. That NorthConnex
amend its plans to deforest major areas of blue gum high forest. That any
environmental offset plans provide benefits to the immediate areas where
microclimates and urban amenity has been affected. That NorthConnex be solely
responsible for the cost of replacing and maintaining all vegetation affected by
the project for a period of 20 years.
22. All revisions to the NorthConnex EIS and project be submitted for review by
independent specialists appointed by the Department of Planning and
Environment to reduce the ongoing expense and lack of surety by both the
community and the developer. The resulting report be exhibited to allow the
community limited opportunity to respond to the revised information contained in
the report.
23. Detailed design not yet determined or that becomes necessary during the course
of construction to be agreed to by independent experts in that field to protect
Government and the community from decisions that may be made without due
regard to these interests.
24. That risk management plans be prepared and made public for each aspect of the
project. That this includes the risk of death to constructors and the community
from transport of excavation material. That the location of sites for disposal of
excavated material be announced. That the distance material has to be
transported be taken into account when developing risk management plans. That
the Mayor of Hornsby's suggestion that the Hornsby Quarry site at Asquith could
accept a significant portion of excavated material be pursued with the Council
and assessed for its suitability including how this site could work if the northern
portal was located further north.
NorthConnex EIS Submission
13
25. A long term health study on children and residents in areas impacted by stack
discharges be included as part of the conditions of approval. This could be used
by all parties to future class actions for health damages.
26. All revisions to the NorthConnex EIS and project be submitted for review by
independent specialists appointed by the Department of Planning and
Environment to reduce the ongoing expense and lack of surety by both the
community and the developer. The resulting report be exhibited to allow the
community limited opportunity to respond to the revised information contained in
the report.
27. Sensitivity analysis be conducted on all modelling to determine the sensitivity of
particular presumptions and the effect they may have on results.
28. The precautionary principle be applied to all modelling and measurements
especially where there is incomplete scientific understanding of issues and likely
changes in public opinion and expectation. This includes but is not limited to the
effects of particle and other pollution on public health.
29. Considering the serious effect this project has had on some members to date,
and the level of use that has been made of the NorthConnex psychological
counselling service, this service be continued and be funded by NorthConnex for
the entire construction and bedding in period of the project.
Bryan Johnson
23 Gipps Street
Drummoyne 2047

I endorse the attached SCAPS Group submissions

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

Dear sir or madam,
My name is XXXXX. We including my husband, XXXX and two young daughters (2 and 7 years old) just recently bought the property and moved in the new property on 01/08/2014. After settling in, then we received the letter in regards to the project of NorthConnex.

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

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

From the information published online, I acknowledged this project maybe will benefit the economy of Australia. But there are so many factors need to be considered before starting the project. We have the following concerns:
* Health concern:
1. 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 human which cause the above health problems.
2. There are so many families including many many young kids and elderly people living here. How can we imagine the polluted air from the 9km tunnel will spew out over our suburbs, through our windows, our homes and into our lungs.. We cannot see the illness happen on us straight away, but after years, when a lot of people living here get lung illness including the lung cancer, then it will be too later to be regretful of the current decision.
3. Especially, the construction work will start just adjacent my backyard. I have the concern there will be a lot of dust and noisy to affect our day to day life.

* House value concern:
1. The commencing construction project and the sub-station/work station adjacent to my backyard will for sure de-value the property I purchased.

* Traffic concern:
1. There will be more trucks in and out of the local residential area, further causing traffic and air pollution.

Due to the above concern, I have lost sleeps in most nights and my friends/colleagues all say I lost weight these days, I start to concern my two young daughters' health as they will study and grow up in this polluted environment.. I went to see XXXX for help and he prescribed me some medication for sleeping. You could call XXXX on 98721152 if you require any further details.
So our suggestion to the project is:
1. Due to the above significant health concerns of the current project design, I strongly request the Department of Planning does not approve the project in its current form;
2. If there is a need to solve the traffic problem, why not considering the Viaduct in stead of tunnel as many countries have successfully implemented it and efficiently using it now, for example Japan and China. Meanwhile, I believe the project of viaduct will cost less money and less pollution than tunnel.
3. Please allow the ventilation stack to be located as far as possible away from residential areas. Please stack it to the other side, on the Pennant Hills golf course side of Pennant Hills Road, where is no residential living.
4. If it happens on this side, please set up an at least 6m high fence between the construction site and the residential houses to minimize the inconvenience of noisy and air pollution.
5. The air should be filtered properly before spew to the community and it should be ongoing monitored by an independent third party and update the pollution figure to the whole community.
6. Due to the direct air pollution and work station adjacent with the backyard, I would like to suggest the residence house adjacent with those facilities should get some kind of allowance to cover the loss of their current house value.

Thank you for your support and hope you could accept the above suggestions and minimize the harm to the local residence.

Kind regards
XXXXX


09/09/2014

I endorse the attached SCAPS Group submissions

11 September 2014
Director - Infrastructure Projects
Department of Planning and Environment
Number: SSI 13_6136
Major Projects Assessment
GPO Box 39
SYDNEY NSW 2001
Via online form:
http://majorprojects.planning.nsw.gov.au/index.pl?action=view_job&job_id=61
36
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.
Introduction
My name is Anne Johnson. Three of my grandchildren live immediately adjacent to
the proposed northern stack and portal of the NorthConnex development. Two of
them, twins now 2 years old were premature babies. They are therefore at greater
risk of suffering lung and breathing problems from pollution. The NorthConnex
development therefore poses a greater risk to them than to other children. All
children are at greater risk from pollution while their bodies are developing than are
adults.
The family will also be exposed to years of construction noise and vibration.
Construction will be even more intrusive for hundreds of families living close to areas
where trucks will transport rubble through their communities for years.
None of these families sought this development. Many are so affected by the
proposals that they cannot afford to move, so affected are their property prices.
I endorse the submissions made by the CAPS group and by Ku-Ring-Gai Council as
they try to limit some of the worst and most dangerous intrusions of this development
on the surrounding community, and attempt to make this a better project for the
state.
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, 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
NorthConnex EIS Submission
2
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 at times exceeded 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 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.
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.
2. An independent options assessment process should be undertaken to assess
alternative locations for the ventilation stack and portals. Stack location in
Pennant Hills Golf Course at the southern portal and in Ku-Ring-Gai Chase at
the northern end would provide significant and effective unpopulated radiuses
around the stacks to limit fallout on residential communities. Relocation of the
NorthConnex EIS Submission
3
northern portal 1.6Km north past Asquith could allow an almost flat tunnel
especially if the tunnel passes above rather than below the railway tunnel.
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.
Anne Johnson
23 Gipps Street
Drummoyne 2047

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