Northern Beaches - Roadworks Stage 2

The grade separation on the intersection of Warringah Road and Wakehurst Parkway is the most critical element and must proceed. Also, it would be very worthwhile to go ahead with extending Aquatic Drive to meet Wakehurst Parkway.

The hospital and upgrade to Frenchs Forest Rd West will create significantly more traffic on Forestway - but the movement of traffic from Forestway west onto Warringah Rd is a significant downgrade to the existing setup. While there will be less through traffic, the turn right from Forestway will be difficult to navigate. Today drivers often struggle to merge to one lane - but when they do they have a dedicated lane onWardingah Rd to continue onto. But in the proposal, traffic will have to merge to one lane then merge into traffic travelling at 70km/h on the underpass. Today the traffic turning left off Forestway (East) travelling on Warringah Rd often struggles to merge with traffic on Warringah Rd - they need to wait for a change of lights to wait for a gap. In the setup where the traffic turning left from Forestway, there will be no gap in traffic on the underpass as the traffic coming through there will not be held up by lights. So the traffic trying to merge into Warringah Rd will back up along the one then two lanes, and all the way back up Forestway- few cars will get through a green light as they wait for a timid driver to try and merge onto Warringah Rd. today there is often traffic backed up to Adams St in the AM peak trying to turn right onto Forestway. With the additional traffic and the degraded merging experience this will only get worse. Forestway adds a significant amount of traffic onto Warringah Rd in the AM peak hour - why would the thru traffic on the underpass not have to merge to one lane (which could be managed over a hundreds of metres) and the Forestway traffic get a dedicated lane? The current plan improves the situation for those not affected by the hospital (the tru traffic on the underpass) and makes the situation for those affected by the extra traffic that the hospital will generate worse. This is clear even in the pretty animations - as you can see all of the extra traffic lights that cars will need to deal with (which the cars in the animation never seem to have to deal with!) as well as the tricky merging that people will need to manage - which as you know well is often a reason for significant traffic hotspots in Sydney.

This project does not include the provision of dedicated cycling lanes. Progressive cities such as Vancouver, Canada have dedicated cycling lanes. See <http://vancouver.ca/streets-transportation/biking.aspx>, <https://en.wikipedia.org/wiki/Vancouverism>.

On a recent visit to Vancouver, I noticed a huge increase in the number of cyclists and a positive change in the liveability of the city since I lived there five years ago. Cycling lanes have been rolled out during that 5-year period.

There is no way that someone could effectively commute by bicycle to somewhere like Chatswood on this road as designed.

SUBJECT: Stage 2 RMS roadworks around the Northern Beaches Hospital

As part of the Wakehurst Parkway upgrade to the north of Frenchs Forest Road (Frenchs Forest), I both suggest and strongly request that a combined pedestrian path/cycleway be constructed on the western side of Wakehurst Parkway running from May Gibbs Way to Frenchs Forest Road with a connection to Epping Drive via the easement between 44 and 46 Epping Drive.

I support the plan strongly. As far as I am concerned you have seriously attacked the critical bottleneck areas. Just speed up implementation.

I support all of the proposed design, with the exception of the following issues, which are poorly considered in the design and require modification to the Project scope to resolve. There are also a number of issues where the impacts have not be adequately considered in the traffic impact assessment, and these require an update to the work undertaken to ensure the impacts of the project have been assessed correctly, and hence the scope of the Project is appropriate to mitigate all significant impacts.

*Warringah Council has a proposal to construct a bike path/ shared path along Warringah Road. The Project must consult with Council to determine if the path is to travel along the northern side of Warringah Road, and if so, the footpath proposed between Allambie Road and Wakehurst Parkway, should be constructed as shared path as part of the Project.

*The section of footpath proposed on the north side of Warringah Road between Maxwell Parade and the Forest Way Shopping Centre should be constructed as shared path, as this route connects with the pedestrian/ bicycle bridge proposed at the Forest Way intersection, and also provides connectivity for cycle routes between regional cycling destinations accessed via Roseville Bridge, and the Forest Way pedestrian/ bicycle bridge via the quiet back streets of Forestville, on the north side of Warringah Road. A shared path instead of a footpath is required along this section as part of the project.

*Shared paths proposed as part of the project encounter a number of signalised intersections. Bike lanterns should be incorporated as part of the pedestrian crossing lanterns at all signalised intersections to enable cyclists to cross intersections without having to dismount their bikes.

*The shared path on the northern side of the intersection of Warringah Road citybound and Fitzpatrick Avenue East incorporates a ramped access in the shared path to accommodate grades encountered at this location. The design of the shared path should also include stairs so that pedestrians do not have to travel the length of the ramps.

*The prevention of straight ahead movements from Hilmer Avenue northbound into the hospital is unlikely to be effective. A superior design is to relocate the eastbound entry from Warringah Road into the Hospital to a location further west of the intersection of Hilmer Street, so that a slip lane is created into the hospital to the immediate west of the Hilmer Street intersection.

*There is no ability to turn right from Aquatic Drive to travel northbound on Wakehurst Parkway as part of the Stage 2 roadworks package. This increases the traffic demand on Allambie Road/Warringah Road intersection and on Frenches Forest Road East. Total travel time and total delay time in the traffic modelling may be lower if the right turn is permitted from Aquatic Drive directly onto Wakehurst Parkway, and hence be a superior outcome. The GTA traffic report does not identify if this scenario has been assessed, or what the results were.

*The scheme does not consider the faster arrival rate of vehicles downstream of Forest Way, in the AM peak period travelling citybound. Currently, congestion occurs at the intersections of Currie Road, Starkey Street, Darley Street and Forestville Avenue. The release of upstream congestion proposed by the Project will relocate queues to these downstream intersections. Currently, bus journey times between Forest Way and Forestville Avenue are protected to a degree from queues at these downsteam intersections due to vehicles being held at upstream locations. These enables buses to move at a decent average speed through the network between Fitzpatrick Avenue East and Forestville Avenue. Additionally, overall bus journey times in the study area are currently protected to a degree at the upstream locations due to the provision of bus priority/ bus lanes and bus queue jumps, enabling buses to move through the network at a good average speed. The construction of the project will impair bus journey times, relative to their current journey times. Buses are a key part of the long term strategic transport task for the Northern Beaches, and the impairment of bus journey times to any degree is unacceptable at the opening year or any future modelling horizon year. The project has not provided any improvement to bus operations or bus priority. The GTA traffic report does not consider bus journey times downstream citybound of Forest Way and is a gross oversight.

*The approach routes to the Northern Beaches Hospital is counter intuitive from some approaches, in that right turns from Warringah Road westbound into the Hospital are not permitted. As a result, vehicles travelling from Wakehurst Parkway northbound, as well as vehicles travelling westbound on Warringah Road east of Allambie Road, and vehicles travelling north of Allambie Road south of Rodburough Road, are at a high risk of taking the wrong approach route to the hospital, and risking illegal or dangerous movements in order to then access the hospital. A guide sign scheme to identify the correct route to approach the hospital for the 3 counter intuitive approach routes should be provided as part of the Project.

*Saturation flows on the eastbound approach of Warringah Road to Allambie Road are unbalanced, which is likely to lead to weave conflicts and unbalanced queue lengths on the eastbound approach lanes. From the midblock location of Warringah Road between Wakehurst Parkway and Allambie Road, only the kerbside lane provides access to the through traffic movement eastbound across Allambie Road. There will be a high weave movement into this single approach through lane. There is a risk of side swipe crashes, rear end crashes or aggressive and dangerous merge movements closer to the intersection. There is only approximately 150m of weave length available, and if queues extend back into this weave length, there is a risk of flow breakdown and rear end collisions in the eastbound underpass. The GTA traffic report identifies that Level of Service at the Allambie Road/ Warringah Road is likely to be poor, and as a result congestion and queuing on the eastbound approach is likely.

*The Project proposes a dual left turn lane from Forest Way southbound into Warringah Road eastbound. There is a zebra crossing existing and proposed across this lane. Provision of two approach lanes to a zebra crossing is unsafe for pedestrians and must be resolved.

*The location of bus stops is not identified in the published consultation brochure Figure. It is likely that a bus stop on the eastbound frontage of the Hospital site on Warringah Road will be required in order to provide access to the Hospital. A bus stop at this location will conflict with the heavy left turn from Warringah Road eastbound into Wakehurst Parkway northbound, resulting in rear end and side swipe crashes in following vehicles, or risk of collision between buses pulling away from the kerb to continue eastbound and vehicles attempting to access the kerbside lane in order to undertake a left turn movement into Wakehurst Parkway.

*The Project does not address the need for the Northern Beaches Hospital public transport interchange, by not providing a location for this facility. Without inclusion of the facility in the design, the traffic impact of bus stops cannot be accurately determined in the traffic modelling undertaken for the scheme. If bus stops are to occur in kerbside traffic lanes, then the modelling undertaken will underestimate the network delays.

*The traffic modelling in the GTA report underestimates the number of outpatient trips, by using an unrealistic model of apportionment of outpatient trips. It divides the total number of outpatients by 10 hours of hospital operation per day, such that 10% of the total outpatient number each day arrives each hour. Most hospital outpatient services require patients to present to the hospital earlier in the day, such that an even daily distribution is unrealistic.

*The GTA traffic report fails to identify a common rat run which is for westbound vehicles on Warringah Road, using the right turn at Government Road to travel via Ellis Road and Iris Road (or for vehicles on Wakehurst Parkway southbound to utilise Dreadnaught Road and Oxford Falls Road for a southbound rat run), to then utilise Romford Road/ Hurdis Road to access Frenches Forest Road East, left turn into Wakehurst Parkway and then right turn back into Warringah Road, avoiding the 6kph average travel speed along Warringah Road between Allambie Road and Wakehurst Parkway in the AM peak period. There is the potential that the modelled results understate the level of queues and congestion likely at the Government Road/ Warringah Road intersection and hence fail to identify needed upgrades to this intersection.

The Bantry Bay community enjoy significant connectivity and social inclusion through the footpath connection from Karingal Crescent to Warringah Road at both the eastern and western ends. The footpaths connect the community to Forest Way shops, to the Hospital site and to buses on Warringah Road and the Wakehurst Parkway. The noise barrier design must not remove this access. Possible methods for addressing this would be to have staggered walls at the footpath connection, similar to the access points along the East Hills railway or to extend the noise barriers down the connecting footpaths.

Many residents along Karingal Crescent enjoy connectivity to the community space along Warringah Road through access via their back fence. How will the likely loss of this community connectivity be addressed and compensated?

P72 5.1.1
Why are the breakdown bays needed, half way, for how many incidents per year?
What happens if the breakdown is after the bay? How is the additional capital cost and maintenance and use of land width justified?

The slot is only one kilometre long, why is there a need for breakdown bays? Should the tax payer foot the bill for the rare event of a vehicle breakdown in the first 500m of the slot? The breakdown bays seem a lot of capital works and additional use of land for a rare event

The Fitzpatrick Ave bus stop should be retained, essentially the above ground road configuration does not change, the land is acquired to allow the slot, why can enough land not be acquired to keep this bus stop.

The removal of the southbound bus stop at Fitzpatrick Ave is completely the opposite of the need to integrate public transport.

EIS Chapt 8-15 See page 27. "bus stops to match as minimum on Warringah Rd". EIS does not achieve this by removing the Fitzpatrick Ave bus stop.

Reference - pg 80 of Appendix C. 6.7. Impact of Removing the Fitzpatrick Ave bus stop.
It should be noted that I the order of 10 cars use Fitzpatrick Ave for commuter parking every weekday. Removing the bus stop will require replacement of the commuter parking, otherwise this will be another detrimental impact on public transport.
Rerouting the bus routes, which primarily operate from Froestway, via Fitzpatrick Ave is not the answer. To support the residents in Bantry Bay in getting to the City and Chatswood a footbridge direct to the bus stop on the eastern side of Forestway is a better answer.

The current bus service between Warringah Aquatic Centre and Manly Circular Quay ( Bus No.136) , should be improved with great frequency of buses.

I am aware of numerous residents that have lived in the Bantry Bay area for 20 years without even knowing this bus service exists.

I would like to draw your attention to access into and out of Hilmer Street as noted on the documentation.

In peak periods, both am and pm, traffic banks up in Hilmer Street waiting to get out onto Warringah Road for both left and right turns. Vehicles parked on Hilmer Street facing north cause the vehicles waiting to bank up in a single line, very often beyond Primrose Street. No parking signs on the approach to Warringah Road in Hilmer Street could solve much of this problem.

The traffic also banks up in the right hand turn lane from Warringah Road to Hilmer Street and often extends beyond into the median strip lane of Warringah Road causing congestion. Making that right hand turn lane longer may alleviate this problem.

Thank you for taking time to consider these points.

While I believe the proposals will improve traffic flow in the area, I offer the following comments and suggestions.

- Pedestrians crossing near bus stops
In, and near, the project area there is a need for people to cross Warringah Road when going to and from bus stops. It is common for these crossings to occur away from allocated pedestrian crossings. I believe the following two areas should be examined to optimise pedestrian safety and convenience.

South-west of the western entry to the underpass between Fitzpatrick Avenue and Maxwell Parade (near existing stops 100, 669, 670 and 741); and east of the eastern entry to the underpass between Wakehurst Parkway and Allambie Road (near stops 652, 666, 672 & 673).

In both areas, the nearest crossings are some distance away. While it would be easy to say that people should walk to the nearest crossing, if you get off (or are running for) a bus and your destination is directly across the road but the nearest crossing is several minutes away, there is a good chance that you'll take the direct route.

The area near the eastern entry is of more concern because groups of people cross together. I regularly catch east-bound buses in the morning peak and see people, who alight at these stops, wait for the bus to go before crossing the road. Particularly at stop 674, which is opposite Innovations, 5-10 people will get off the bus and very few will walk away from the stop (possibly towards the businesses on the northern side of Warringah Road), with the majority waiting to cross.

These areas will become less safe for such crossings due to the extra traffic. More particularly the through traffic (using the underpass) will be travelling faster, and there will be fewer gaps in that traffic due to the absence of traffic lights.

I suggest that there may be a need for infrastructure to reduce unsafe crossing in these areas.

Putting barriers along the median strips may be the quickest and least expensive option, but pedestrian overpasses would be the most convenient for the pedestrians (if RMS was a business, I would say the customer-friendly option).

No doubt there are benchmarks for the volume of expected use before the expense of an overpass would be considered and these areas would probably not give high volume use. Perhaps, in the case of the eastern area, the nearby businesses could be persuaded to make some contribution to the cost for the convenience and safety of their employees and customers, possibly in exchange for some promotional signs on the overpasses (I know this is a radical thought).

I ask that you examine the pedestrian behaviour in these areas to consider whether any measures are necessary.

- Bus stops
Figure 5.9 in Section 5.1.5 of the EIS shows the location of existing bus stops in & near the project area. The following stops are not shown in that figure.

* 208630 & 208655 - on Wakehurst Parkway near Yarraman Avenue. I assume this is because they are outside the project area (but stops on Warringah Road outside the area are shown).

* 2086126 - On the west side of Warringah Road just before the limited access slip road next to Frenchs Forest Public School and near the pedestrian overpass. There is no mention of this stop being removed, so I assume this is an oversight.

In case it is planned to remove this stop, please note that it is used by people coming from Chatswood & the City who have to walk over the overpass to reach their destinations. It is more convenient for this purpose than the Forestway Shops stop because it is closer to the overpass & is before two sets of traffic lights. Also, removing this stop would force more people to use the already-busy Forestway stop.

- Safety of right turns into Warringah Road
After the works are completed, (considering the higher volume of freer flowing traffic) is it planned to review the safety of vehicles turning right into Warringah Road from streets between Cook St and Fitzpatrick, particularly from Maxwell Parade and Cook Street?

Thankyou for providing the infrastructure to support the new hospital that will also help with the existing road traffic bottleneck at this location - 2 comments:

1. The Right turn from Mona Vale Rd (Eastbound) into Forest Way (Southbound) currently has a double Right turning lane of some length. The queue for Right turning traffic at this intersection during the evening peak can sometimes extend around the corner (90kmh zone) creating rear-ender accident risks, and emergency braking is evident on the road. There is ample space in the median strip to double the capacity of the (double) Right turn lane, which could alleviate this safety concern, and provide for increased traffic access to the Northern Beaches Hospital.

2. The Starkey Street pedestrian bridge at Forestville project (and hopefully syncing of traffic light cycles for the 4 sets of traffic lights on Warringah Rd though Forestville) will assist with Warringah Rd through traffic.

However, the traffic to/from Roseville Chase (delivered quicker to Roseville Chase by stage 2 works in the morning peak) may only be alleviated by the construction of a Northern Beaches Tunnel between the Burnt Bridge Creek Deviation and the Warringah Freeway at Cammeray. This tunnel would divert a large volume of traffic to/from the city, North Sydney, St. Leonards, Kingsford Smith and Badgerys Creek Airports from Roseville Chase. It will also relieve traffic congestion on the Spit Bridge/Military Rd corridor.

Submission to Stage 2 Northern Beaches Hospital Road Connectivity and Network Enhancement Project.

This submission is on behalf of Garigal Landcare.

We object to stage two of the roadworks.
The hospital access is secured with the widening of Frenchs Forest road and the proposed Stage 2 works are grossly destructive and show no substantial benefit.
The assessment by SMEC predicts that the endangered ecological community (DFEC) will most likely become in the area extinct. Its preservation must be a priority and its preservation has not been sufficiently attempted.
The destruction of the north- south wildlife corridor for terrestrial fauna is equally a priority. It is a regional wildlife corridor and its significance was explained by ecologist Peter Smith in his review of stage 1 roadworks (see below). The argument that no endangered terrestrial fauna species have been documented is firstly unsatisfactory because of the limited timespan SMEC used for surveys and secondly it ignores that common species like swamp wallabies will become locally threatened and extinct in the Manly Dam bushland area once this corridor is cut.
The spotted tail quoll should be included in the 7 part test as it was recently documented in the local area.
The name of the suburb "Frenchs Forest" is fundamentally linked tddayo the forest that is proposed to be destroyed. As a Landcare group, we particular enjoy area names with reference to their vegetation. To remove the forest is destroying us our heritage.
The offset proposal is not completed and if this destructive development goes ahead we demand that all offsets are locally within the Narrabeen Lagoon Catchment or Manly Dam Catchment acquired.
Finally we like to conclude, that the roadworks will lead to an increase in car use rather than promoting environmentally friendly public transport options and encouraging pele to get out off their cars.

Conny Harris
President

In the following review arguments regarding the inadequate wildlife corridor and offsets are specified:

P & J SMITH ECOLOGICAL CONSULTANTS

P.J. SMITH B.Sc.Hons, Ph.D.&#8203; 44 Hawkins Parade, Blaxland NSW 2774
J.E. SMITH B.Sc.Agr.Hons, Dip.Ed., Ph.D.&#8203; Phone/Fax: (02) 4739 5312
&#8203; Email: [email protected]
&#8203; ABN: 81 751 396 499




REVIEW OF BIODIVERSITY ASPECTS
OF
NORTHERN BEACHES HOSPITAL
ROAD CONNECTIVITY AND NETWORK ENHANCEMENTS PROJECT
ENVIRONMENTAL IMPACT STATEMENT


Peter Smith and Judy Smith
24 November 2014




1. Introduction

We have been engaged by the community group HEAL (Health, Environment, Access, Locality) to review the biodiversity aspects of the Environmental Impact Statement for the proposed Northern Beaches Hospital Road Connectivity and Network Enhancements Project at Frenchs Forest (SMEC 2014a). We are consultant ecologists and have carried out many flora and fauna studies in the Sydney region since 1985. These include major studies of the Duffys Forest Ecological Community (Smith and Smith 2000, 2005a) and of wildlife/vegetation corridors in the Warringah Local Government Area (Smith and Smith 2005b, 2009a, 2009b). Our studies of both issues are quoted and relied on by SMEC (2014b) in their Biodiversity Assessment Report for the Environmental Impact Statement. Our work was also relied on by the NSW Scientific Committee (2002) in their final determination to list the Duffys Forest Ecological Community as an Endangered Ecological Community.

We are concerned about two issues in particular: the impact of the proposal on an important wildlife/vegetation corridor; and the inadequacy of the proposed mitigation and offset measures.


2. Impact on Important Wildlife/Vegetation Corridor


The site of the proposed works forms part of a north-south Priority 1 wildlife/vegetation corridor of high conservation significance, linking Manly Dam Reserve and the Bantry Bay section of Garigal National Park with bushland at Oxford Falls and thence with the Narrabeen Lagoon catchment section of Garigal National Park (Smith and Smith 2005b, 2009b). The proposed works will involve clearing of a large amount of vegetation within the corridor, consisting of 5.7 ha of native vegetation (including 5.1 ha of an endangered ecological community, the Duffys Forest Ecological Community) and 1.4 ha of urban exotic/native/weed vegetation. The project will also involve widening and increased traffic on Warringah Road, Wakehurst Parkway and Frenchs Forest Road, three roads that bisect the corridor and already act to inhibit fauna movement. Their inhibitory effects will be significantly increased by the proposed works. The combined vegetation clearing and road widening effects of the proposal threaten to have a severe impact on the effectiveness of this wildlife corridor in maintaining a vegetation/wildlife link across the urban landscape. The widening of Warringah Road will involve subsurface eastbound and westbound lanes in a channel (underpass) along the middle of the Warringah Road corridor, plus surface eastbound and westbound lanes running parallel to the slot. Such an arrangement is likely to prevent all movement of non-flying terrestrial fauna across this section of the road.

The impact is also a cumulative one since the corridor has already been badly impacted in this location by the recent clearing of 5.1 ha of corridor vegetation (all of which was the Duffys Forest Ecological Community) for construction of the Northern Beaches Hospital. Further clearing of corridor vegetation is likely to occur in the near future on the eastern side of Wakehurst Parkway north of Warringah Road for a Frenchs Forest Town Centre (Department of Environment and Planning 2014). The combined effects of all these major developments in the area is likely to be a major gap this important wildlife/vegetation corridor, leading to increased isolation of Manly Dam Reserve and the Bantry Bay section of Garigal National Park, threatening the long-term genetic viability of their fauna and flora populations, and making recolonisation less likely should those populations die out. This would also weaken the ability of Warringah's fauna and flora to adapt to climate change. Maintaining landscape connectivity will be critical for climate change adaptation since it allows flora and fauna species to change their distribution in response to changing environmental conditions.

The Biodiversity Assessment Report (SMEC 2014b) recognises that this is an important regional wildlife/vegetation corridor connecting large patches of remnant native vegetation to the north and south of the site. It recognises that the proposal will have an impact on the functioning of the corridor and that this impact is a cumulative one that will exacerbate the effects of the existing roads that cross the corridor, and the recent vegetation clearing for the hospital. However, the report understates the seriousness of the impact.

The Biodiversity Assessment Report notes that there are no known species-specific studies of the ecological importance of this vegetated corridor to fauna populations in the region, seeming to imply that this is a reason to disregard or downplay impacts on the corridor. Such an approach is contrary to the precautionary principle, which is one of the five principles of ecologically sustainable development adopted by all Australian governments. Lack of scientific certainty should not be used as an excuse not to take appropriate steps to counter the potentially harmful consequences of a proposed development. Maintaining landscape connectivity (the extent to which a landscape facilitates the movements of organisms and their genes) is a central principle of current best practice biodiversity conservation, and is critical for increasing the resilience of reserve networks to potential threats associated with climate change (Worboys and Pulsford 2011, Rudnick et al. 2012, Lindenmayer and Fischer 2013). The value of wildlife/vegetation corridors is well established and does not need to be proven for each individual corridor (a very time-consuming task) before taking action to protect that corridor.

The Biodiversity Assessment Report also notes that connectivity in this corridor is already limited by the existing road network, which interrupts the vegetated extent of the corridor and is likely to be a deterrent to movement of some groups of fauna. Again, this is no excuse not to take action to protect and enhance the corridor. In fact, it indicates that the corridor is likely to be particularly vulnerable to the impacts of the proposal, and requires special protective measures. SMEC's (2014b) own fauna surveys showed that Long-nosed Bandicoots are moving between patches of habitat on either side of Warringah Road (presumably based on retrapping of marked individuals on the other side of the road). The existing road network may be inhibiting fauna movements but it is not preventing them, even for a small ground mammal such as the Long-nosed Bandicoot that is especially prone to being killed on roads. This important corridor function needs to be maintained.

The Assessments of Significance for individual threatened species in the Biodiversity Assessment Report fail to recognise that significant fauna habitat fragmentation and isolation is likely to occur as a result of this project. For each species assessed, SMEC's (2014b) answer to significance assessment question `d', which covers habitat fragmentation and isolation, was `no or positive impact'. Their reasoning was generally along the lines of the following quote from their Assessment of Significance for the Southern Brown Bandicoot:

`The existing road network acts as a physical barrier to fauna movement and it is unlikely the clearing resulting from the concept proposal would affect connectivity to the extent that it will result in habitat becoming fragmented or isolated. It is unlikely that Bandicoot and Potoroo habitat will become fragmented as a result of the proposed actions as it is already highly fragmented.'

We disagree with these assessments. The existing road network may be inhibiting fauna movements but it is not preventing them, as has been shown by SMEC's own survey records of Long-nosed Bandicoots moving across busy, multi-lane Warringah Road. Our concern is that the proposed works involve significant clearing of native vegetation in the corridor, together with widening of the roads crossing the corridor, and future increase in traffic on those roads. Widening of Warringah Road will also involve construction of lanes in a channel (underpass) along the middle of the road, which is likely to prevent all movement of non-flying terrestrial fauna across this section of the road. These effects are cumulative, combining also with recent extensive clearing of corridor vegetation for the Northern Beaches Hospital, and likely future clearing of further corridor vegetation for a Frenchs Forest Town Centre. There is an obvious threat that this important regional wildlife/vegetation corridor will be completely severed, resulting in a significant adverse impact on a wide range of fauna (and flora) species, including a number of threatened species. The Biodiversity Assessment Report (SMEC 2014b) should have recognised the seriousness of this impact, and the Concept Proposal (SMEC 2014a) should have incorporated effective measures to ensure that a functioning north-south wildlife/vegetation corridor is maintained through the area.


3. Inadequacy of the Proposed Mitigation and Offset Measures

The Concept Proposal does not include any concrete measures to maintain a wildlife/vegetation corridor through the area. Instead, the Biodiversity Assessment Report (SMEC 2014b) merely states that options for maintaining and enhancing wildlife connectivity (and reducing roadkill) across the Concept Proposal area will be explored as part of the Environmental Impact Statement for Stage 2 of the project. This is not an adequate response to this significant issue. The issue needs to be addressed at the Concept Proposal stage. There needs to be a firm commitment to maintaining an effective wildlife/vegetation corridor and there needs to be sufficient design detail provided to show that that commitment can be kept. Necessary measures include maintaining a vegetation linkage through the area, and providing fauna crossings under or over the roads.

The Concept Proposal will have a large residual impact on biodiversity values (i.e. the proposed avoidance and mitigation measures are insufficient to reduce the impact to an acceptable level). This will require substantial offset measures if biodiversity values are to be maintained or improved. The residual impact of the Concept Proposal on biodiversity values has been assessed under the BioBanking Assessment Methodology as requiring the purchase and retirement of 176 ecosystem credits (for the impact on the Duffys Forest Ecological Community) and 36 species credits (for the impact on the Red-crowned Toadlet) (SMEC 2014b). However, this assessment does not include any offsets for the likely significant impacts on other threatened species as a consequence of the disruption of an important regional wildlife/vegetation corridor. As discussed above, these impacts have not been adequately assessed in the Biodiversity Assessment Report.

No specific offset proposal is provided, only a general Biodiversity Offset Strategy (SMEC 2014b). Part of that strategy states that if no Duffys Forest Ecological Community credits are available, then credits in other `equivalent' communities will be purchased and retired. This approach is likely to result in a very unsatisfactory offset, as has occurred with the offset for the recent clearing of a similar area of Duffys Forest for the Northern Beaches Hospital. Because Duffys Forest is such a restricted and depleted community, very few credits are available for retirement in this community. Our review of the offsetting strategy for the hospital (Smith and Smith 2013, 2014) found that the final offset involved the retirement of only 16 Duffys Forest ecosystem credits. The remainder of the ecosystem credits to be retired were in other plant communities that were not threatened and were, in fact, common, well conserved communities. Most of these credits were not even in the Warringah Local Government Area. The communities were considered `equivalent' to Duffys Forest, despite their much lower conservation significance, because they form part of the same vegetation formation (a broad grouping of plant communities). SMEC's (2014b) proposed Biodiversity Offset Strategy is likely to result in a similar very unsatisfactory offset that not only fails to compensate for the creation of a major gap in an important regional wildlife corridor, but also fails to compensate for the loss of a significant area of an already highly depleted community. The main distribution of the Duffys Forest Ecological Community is in the Warringah Local Government Area. It is the forest type after which the suburbs of Duffys Forest and Frenchs Forest were named. It is an integral and important part of the natural heritage of Warringah, and much more attention needs to be given to its protection and rehabilitation.


References

Department of Planning and Environment (2014). State Significant Infrastructure Assessment Report: Northern Beaches Hospital Concept proposal and Stage 1 (site works), corner Wakehurst Parkway and Warringah Road, Frenchs Forest (SSI 5982), June 2014. NSW Department of Environment and Planning, Sydney.
Lindenmayer, D.B. and Fischer, J. (2013). Habitat Fragmentation and Landscape Change: An Ecological and Conservation Synthesis. Island Press, Washington.
NSW Scientific Committee (2002). Final determination to list Duffys Forest Ecological Community in the Sydney Basin Bioregion as an Endangered Ecological Community, June 2002. NSW Scientific Committee, Hurstville.
Rudnick, D.A., Ryan, S.J., Beier, P., Cushman, S.A., Dieffanbach, F., Epps, C.W., Gerber, L.R., Hartter, J., Jenness, J.S., Kintsch, J., Merenlender, A.M., Perkl, R.M., Preziosi, D.V. and Trombulak, S.C. (2012). The role of landscape connectivity in planning and implementing conservation and restoration priorities. Issues in Ecology, Report Number 16. Ecological Society of America
SMEC (2014a). Northern Beaches Hospital Road Connectivity and Network Enhancements Project Environmental Impact Statement. Prepared for NSW Roads and Maritime Services, October 2014. SMEC Australia Pty Ltd, North Sydney.
SMEC (2014b). Biodiversity Assessment Report. Appendix F in Northern Beaches Hospital Road Connectivity and Network Enhancements Project Environmental Impact Statement. Prepared for NSW Roads and Maritime Services, October 2014. SMEC Australia Pty Ltd, North Sydney.
Smith, P. and Smith, J. (2000). Survey of the Duffys Forest Vegetation Community. Prepared for NSW National Parks and Wildlife Service and Warringah Council, November 2000. P & J Smith Ecological Consultants, Blaxland.
Smith, P. and Smith, J. (2005a). Warringah Natural Area Survey: vegetation communities and plant species, 2005 update. Prepared for Warringah Council, August 2005. P & J Smith Ecological Consultants, Blaxland.
Smith, P. and Smith, J. (2005b). Warringah Natural Area Survey: vegetation history and wildlife corridors, 2005 update. Prepared for Warringah Council, August 2005. P & J Smith Ecological Consultants, Blaxland.
Smith, P. and Smith, J. (2009a). Core habitats and wildlife corridors in the Warringah Local Government Area. Prepared for Warringah Council, June 2009. P & J Smith Ecological Consultants, Blaxland.
Smith, P. and Smith, J. (2009b). Warringah Natural Area Survey: vegetation history and wildlife corridors, 2009 update. Prepared for Warringah Council, July 2009. P & J Smith Ecological Consultants, Blaxland.
Smith, P. and Smith, J. (2013). Review of biodiversity aspects of Northern Beaches Hospital Environmental Impact Statement. Prepared for HEAL, November 2013. P & J Smith Ecological Consultants, Blaxland.
Smith, P. and Smith, J. (2014). Review of biodiversity aspects of Northern Beaches Hospital Environmental Impact Statement: additional comments. Prepared for HEAL, July 2014. P & J Smith Ecological Consultants, Blaxland.
Worboys, G.L. and Pulsford, I. (2011). Connectivity Conservation in Australian Landscapes. State of the Environment 2011 Committee, Department of Sustainability, Environment, Water, Population and Communities, Canberra.

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This highly destructive road upgrade should not be allowed to proceed in its present form for the following reasons.

It will not significantly improve traffic movements vs current levels. Indeed by 2028 traffic movement in the afternoon peak is anticipated to be slower than current traffic movements.

It is not part of an integrated transport plan which takes into account the impact the increased traffic generated by the hospital and associated developments on the wider road network. For example there are 4 sets of traffic lights on Warringah Road between the junctions of Currie Road and Forestville Avenue, and little, if anything appears to have been proposed to improve transport flows through these junctions and beyond. A similar scenario will occur on Forestway as well as to the eastern side of Warringah Road. Hence the proposed upgrade will contribute to even worse bottlenecks in these adjacent areas.

There is inadequate planning for additional traffic that will be generated by high density housing and commercial developments that have been mentioned as being inevitable in the Forest area in association with the construction of the new hospital.

There is inadequate planning for public transport to help contain / reduce the amount of traffic flowing through the Forest area.

The disruption during the construction period is likely to bring key arterial roads such as Warringah Road, The Wakehurst Parkway and Forestway to a standstill.

The proposed upgrade will require the removal of a large number of mature trees that are an integral part of the Forest area. These provide natural shade, reduce soil erosion, help purify the air and generally beautify this unique part of Sydney.

Stage 2 Traffic and Transport Assessment (Appendix C)

The section of the Stage 2 proposal on the south side of Warringah Road between the intersection with Forest Way and the westbound exit of the underpass looks like a point of future congestion. This view is supported by Section 6.2.1 on page 68 of the traffic report. The proposal requires 4 lanes of traffic to merge into two lanes over a short distance and at the location where traffic will join from Fitzpatrick Avenue East. Four lanes then merge to 3 lanes at the exit of the westbound underpass.

The report states that the performance of the Forest Way and Warringah Road junction remains at LoS F in the morning peak after the completion of the Concept Proposal in 2018. This suggests congestion for vehicles turning right onto Warringah Road heading South/West in the morning peak and entering the above zone.

What alternative design solutions has RMS considered for this section of the proposal to improve the performance of the junction and reduce congestion prior to the exit of the underpass?

Urban Design Report and Landscape Character and Visual Impact Assessment (Appendix G)

Why is a raised path ramp required between Fitzpatrick Avenue East and the proposed new footbridge to Forest Way? Figure 4-6 on Page 100 of Appendix G shows a steep ramp rising from grade level turning 180 degrees and connecting to a flat elevated path to the bridge.
Given the distance between Fitzpatrick Avenue East and the new footbridge, could an at-grade footpath meet the relevant accessibility requirements?

TO: Director of Infrastructure, Department of Planning and Environment
GPO Box 39, Sydney NSW 2001
Fax 02 9228 6366
Online via www.majorprojects.planning.nsw.gov.au

Re: Northern Beaches Hospital Road Connectivity and Network Enhancement Project Stage 2 Environmental Impact Statement: Overview (EIS Overview) / Application number (SSI 14_6434)

Submission: My feedback and comments regarding the above project follow for consideration as part of the assessment process.

1) Noise walls / Noise barriers
* EIS Overview says `Noise barriers are proposed along sections on the southern side of Warringah Road`. A noise wall is shown at rear of houses between Warringah Rd, Frenchs Forest and Panorama Crescent, Frenchs Forest
It appears that the noise wall will be constructed south of Fitzpatrick Ave, along the rear of houses toward No 597 Warringah Rd. This follows a natural creek line, at times piped, which passes through the reserve in Parni Pl, eventually draining into Bantry Bay.
Taking ground levels and topography into account, the proposed noise barrier currently appears to offer no protection to properties at 595, 597, 599, 601 or 601A Warringah Rd.

2) Public transport access:
* Access to bus stops appears to need review
* Access to bus stop on Warringah (Road Stop ID: 2086118, opposite Forest High School) appears blocked due to the noise wall barrier. An appropriately constructed break in the noise barrier would need to be provided to allow access via existing path between No 60 and No 62 Karingal Crescent
* Warringah Road Stop ID: 2086100, near Fitzpatrick East. As this bus stop is to be removed, residents in the Karingal Crescent area will need to use Forestway bus stop. An appropriately constructed break in the noise barrier would need to be provided to allow access via existing path between No 20 and No 22 Karingal Cresc.

3) New (replacement) shared pedestrian and cycle bridge ( Warringah Road to Forest Way intersection).
* Ramp at Forestway end of overbridge is a great idea for disabled / prams / bikes going to Frenchs Forest Public School or / Forestway Shopping Centre. However no steps are shown on ramp for pedestrian egress, including the able bodied and the active school children heading to the school located nearby. I suggest adding steps for ease of pedestrian egress.
* Access to the new bridge is not shown from Karingal Crescent, as is currently available to allow pedestrians and cyclists to enter shared path from Karingal Crescent to access shops, bus, school on other side of the new (replacement) bridge.
An appropriately constructed break in the noise barrier would need to be provided to allow access via existing path between No 20 and No 22 Karingal Cresc.

4) Shared pedestrian cycle path
* Shared pedestrian cycle path at rear of Karingal Crescent ends with a ramp at intersections of Warringah Road with Fitzpatrick Avenue East, (EIS Overview page 10 at No.3)
* Direct access from the ramp onto Warringah Rd is shown on the EIS Overview. This appears dangerous and should be avoided as a matter of safety.
* There are no pedestrian steps shown for pedestrian egress, including able bodied pedestrians and children travelling from the nearby school. I suggest adding steps for ease of pedestrian egress.
* The EIS Overview shows an overly complicate ramp system which might possibly be simplified by taking the ramp to ground level at a higher point on Fitzpatrick Ave East, closer to boundary of 2 Karingal Crescent.
* Path ends abruptly at Fitzpatrick as the bus on Warringah Rd (stop ID: 2086100) near Fitzpatrick Av is to be removed the shared cycle path could continue to Maxwell Parade, providing a safe cycle route to Currie Road's School and Forestville Park sports fields and the purpose-built mountain bike trail in Garigal National Park off Currie Road.

5) New shared pedestrian and cycle bridge (Warringah Road, west of Hilmer Street
* Access to new bridge appears blocked due to the installation of the new noise wall barrier.
An appropriately constructed break in the noise barrier would need to be provided to allow access via the existing path between No 60 and No 62 Karingal Crescent

6) Loss of habitat and vegetation including Karingal Reserve
* EIS Overview states that a large number of remnant native habitat trees will removed in Karingal Reserve. It is important these trees are replaced like for like.
The assessment of biodiversity prepared to establish impacts on threatened flora, fauna and ecological communities should support this.
* EIS Overview says 'Work is likely to remove up to 6.1 hectares of Duffys Forest vegetation, which is an endangered ecological community'. The EIS Overview further states this 'is considered a significant impact largely because less than 16 per cent of the original area of Duffys Forest currently exists in the region as fragmented remnant patches.' Yet the EIS Overview suggests that a similar `Biodiversity offsets' will substitute for loss of Duffys Forest vegetation. This appears to support the idea that destruction of an endangered ecological community is okay. I suggest this is not okay and is inappropriate as it cannot replace like with like.

7) Roundabout at corner of Rodborough Rd and Allambie Rd, Frenchs Forest
* This is a small roundabout in a heavy traffic area in an area which is becoming more and more industrial. The Australia Post - Frenchs Forest Business Hub is located at the intersection and there are bus stops on three sides of the intersection. The intersection's small size requires some longer vehicles such as trucks and busses drive over the roundabout and use more than one lane to negotiate the tight turn.
* I suggest the roundabout is upgraded to accommodate trucks / busses and allow all road users safe travel through the busy intersection.

8) Historic heritage; The former Holland's Orchard and Commemorative Grove
* The EIS Overview states the above `would be partially impacted, in that the only remaining pear tree on Warringah Road from the former Holland's Orchard is within the construction footprint'.
* There appears to be no suggestion that cuttings will be taken from the roadside tree that will be destroyed, as the EIS Overview further states that subject to various discussions, `Roads and Maritime will further investigate `propagating' the tree (taking cuttings) within the Commemorative Grove in the boundaries of The Forest High School'.
* Only if the trees in the grove in the school grounds are the same species and vintage, this would seem appropriate. if not, attempts to propagate from the remaining Pear Tree should also be made.

9) Left turn from Warringah Rd to Rodborough Rd, Frenchs Forest
* EIS Overview showed a new turn left from Warringah Rd to Rodborough. To achieve this, the intersection would need reshaping.
* There is currently a `No left turn' sign on Warringah Road. As a matter of safety, this should remain as it is.

The community has been passionate over very many years to protect Manly Dam's precious bushland catchment. Conservation measures have ensured thecomparative health of the creeks that feed into Manly Dam, Manly Lagoon and ultimately Manly's famous surfing beaches. Constructing massive road over-developments, hard surfaces and Los Angeles style freeways in this sensitive area can only lead to extensive environmental degradation.

Water runoff from the top of the catchment is critical to the health of riparian areas and creeks themselves and also influence the wider surrounding vegetation via hydrological changes. Curl Curl Creek is predicted to experience an increase of inflowing run-off water from 10% addled impervious surfaces. As this is likely to affect Red Crown Toadlet breeding habitat a detention basin is proposed as a mitigation measure and nitrogen levels are forecasted to increase. These detention basins come with their own massive suite of problems, interrupt water flows and cause ongoing invasive weed blooms.

It is predicted that the local stand of forest, an endangered ecological community (DFEC) will become extinct. This prediction should in itself immediately stop the proposal. Any endangered ecological community deserves highest priority consideration and this has not happened. The forest acts as habitat and as a huge sponge and its destruction will further increase the load of water rushing into creeks. It further will vastly decrease the biodiversity of the catchment, its flora and fauna.


The North- South wildlife corridor for terrestrial fauna will be destroyed. SMECs surveys have in the previous Stage 1 assessment missed several species . The spotted tail quoll was recently found in the Oxford Falls Valley and it is highly likely to need this north-south corridor at certain times. Further our common swamp wallabies will not be able to survive if their access is cut off as planned. The local population will become endangered very quickly and will become extinct. Dan Ramp's study does not justify the destruction of this corridor.

The forest is one of the two icons of the Northern Beaches. To wipe out the forest appearance when travelling along Warringah Road in the area surrounding and adjacent to the Northern Beaches Hospital is ensuring the loss of identity of the location and it will be visible to a huge area. The visual impact statement describes the changes as most dramatic.

If this unfortunate project goes ahead, offsets should be sought in the adjacent local bushland and affected water catchment areas- not elsewhere.

The proposed destruction is not worth saving a few seconds of travel time, which is all one can expect according to the graph that has been included in the executive summary for the Road works. The hospital access is secured with the widening of Frenchs Forest Road. Stage two works are by no means essential .

I object to these massive new projected roadworks at the top of the sensitive Manly Dam Catchment. The water runoff from this project will be extremely detrimental, and detention basins interfere with water flows, cause weed invasion problems and are expensive to maintain.

The North-South wildlife corridor for terrestrial fauna will be destroyed. The spotted tail quoll is likely to need this corridor, and our swamp wallabies will not be able to survive if their access is cut off as planned.