WestConnex - M4 East Upgrade

I make this submission to comment on the Environmental Impact Statement of Westconnex M4 East Application Number SSI6307. I object to the Westconnex M4 East motorway proposal.

The realignment of Parramatta Road to facilitate the tunnel portals at the Parramatta Road Interchange will result in a significant increase in noise at numerous residences between Orpington Road and Bland Street, and particularly at 98 Chandos Street (SP66454), which contains fifty-six residential lots. The realignment of Parramatta Road will result in the distance between the nearest point of the roadway and the apartment building at 98 Chandos Street being reduced from approximately 40 metres to approximately 6 metres. As noted in the EIS, the effect of the reduction in distance to Parramatta Road will be compounded by the demolition of existing noise screening provided by adjacent buildings that are to be acquired and demolished to facilitate the interchange.

98 Chandos Street is identified in EIS Vol. 2C App. I as a receiver considered for additional noise mitigation, due to the triggering of at least two of the NMG criteria:

1. The predicted noise build noise levels exceed the NCG controlling criterion and the noise level increase due to the project is greater than 2dBA; and

2. The cumulative limit for additional noise mitigation is exceeded.

EIS App. I Clause 14.20 states that "Noise barriers have been considered in this assessment, however, based on further feasible and reasonable considerations the barrier may potentially sterilise future use of the adjacent land by restricting visibility and/or access. Therefore, consideration of at-property treatments for the triggered receivers instead of a barrier have been recommended and are to be further considered during detailed design." The omission of noise barriers will result in a significant increase in noise on terraces and balconies in 98 Chandos Street that will not be mitigated by any of the at-property architectural treatments contemplated in the EIS. This will cause a major reduction in amenity for all of the affected properties. In essence, the EIS is justifying the omission of noise barriers by reference to the impact on the value of land that the State has or will acquire as part of the Westconnex project. The EIS proposes that existing residents suffer loss of amenity in their property to avoid future impacts that "may potentially" occur on unoccupied adjacent land, the future use of which the EIS is silent. This represents a subordination of the health and amenity of existing residents to the commercial management of land acquired by the government.

The EIS indicates that external noise levels are expected to be greater than 10 dBA above the NCG target at 98 Chandos Street. EIS Vol. 2C App I Section 7.5 indicates that where the NCG internal criteria in habitable rooms can only be achieved with windows and vents closed, then mechanical ventilation should be provided (subject to individual consultation with dwelling owners) to ensure sufficient airflow inside the dwelling, so as to meet the requirements of the Building Code of Australia. Given the existing building construction at 98 Chandos Street, in which most of the bedrooms and living rooms have little ceiling void space in which to install mechanical ductwork, it is unclear how this can be practicably achieved. It will be very difficult and disruptive, if not impossible, to meet the NCG target at 98 Chandos Street without the provision of a noise wall.

The EIS identifies twenty-one (21) buildings, between Orpington Street and Bland Street, as receivers that should be considered for additional noise mitigation. Sixteen (16) of these buildings trigger both of the cumulative limit and the noise increase criteria identified in the EIS. Many of the said buildings, including 77-79 and 98 Chandos Street and 1, 1A, 3-5, 7-9, 11, 13, 15 and 17 Loftus Street are high density residential constructions. A large number of residents would benefit from a noise wall, which would provide significant attenuation of noise for at least the first two floors. A noise wall should be constructed along the westbound side of Parramatta Road, running from Orpington Street to Bland Street. At the Chandos Street intersection, a noise wall should be provided on the east side of the street in order to provide noise mitigation for 77-79 Chandos Street and should be provided along the southern side of part of the proposed driveway at 98 Chandos Street in order to provide noise mitigation for 90 Chandos Street.

The noise wall should consist of clear acrylic or similar panels where a non-translucent wall would result in unacceptable overshadowing of properties. The noise wall should be similar to the 455m long wall that was constructed along the north side of Syd Einfeld Drive, Woollahra, in 2013-2014, which consists of combination of reinforced concrete and acrylic panels. The noise mitigation that I am proposing is not more onerous than that which was constructed along Syd Einfeld Drive and, due to the large number of residents that would otherwise be affected by noise, the benefit would be great.

EIS Vol. 2C App. I Clause 8.5 states that "Roads and Maritime does not consider it reasonable to consider noise mitigation above the ground and first floor." Due to the realignment of Parramatta Road and the associated demolition of existing buildings that provide acoustic screening, many residents of 98 Chandos Street on the floors above first floor will receive a significant increase in noise due to the project. The EIS is deficient in that it has completely excluded the occupied upper four floors of 98 Chandos Street in its modelling. There is no scientific basis to model only the noise impacts on first two floors of affected properties or to determine that a residence above the first floor should not receive noise mitigation regardless of whether modelling indicates that it meets the noise criteria for provision of mitigation. Basic trigonometry would inform the proponent that in this case there will be little difference in the distance between noise sources and receivers located at ground floor and, for instance, second floor.

It is completely unreasonable to disregard the impact on residents above the ground and first floors at 98 Chandos St. It should also be noted that the level of Parramatta Road at the intersection with Chandos Street are well above the ground floor level of 98 Chandos Street. For the purpose of identifying noise impacts of the realigned Parramatta Road on 98 Chandos Street, the First Floor ought to be considered to be the closest to Parramatta Road.

In summary, if the proposed project proceeds, the following should be provided:

1. A noise wall should be constructed along the westbound side of Parramatta Road, running from Orpington Street to Bland Street. At the Chandos Street intersection, a noise wall should be provided on the east side of the street in order to provide noise mitigation for 77-79 Chandos Street and should be provided along the southern side of part of the proposed driveway at 98 Chandos Street in order to provide noise mitigation for 90 Chandos Street.

2. The criteria for the provision of architectural noise mitigation should be the same for all residences and all floors. The EIS is deficient in that it has completely excluded the floors above the second floor in its modelling and recommendations, except to state that RMS has a policy of completely excluding even the consideration of noise mitigation above the second floor.

I wish to register my objection to the government awarding tenders for construction of the project before a full business case has been publicly released and before the EIS had been published and the public has exercised its right of participation. The EIS is supposed to allow for genuine public input and to result, potentially, in approval, non-approval, or approval with modifications, of the project. The present procedure makes a mockery of that right.

The government and the EIS have failed to publish a robust business case for the proposal and in these circumstances it is disgraceful that billions of dollars of government funds are proposed to be expended on the project.

I have not made a reportable political donation.

Our submission, '151101 Climate Change Balmain-Rozelle submission on M4 EIS", will be uploaded.

Attached objection to Westconnex

See attached PDF

My submission is uploaded

My submission relating to 142 Alt St Haberfield - heritage concerns is attached

My submission relating to 142 Alt St Haberfield - heritage concerns is attached

My submission relating to 142 Alt St Haberfield - heritage concerns is attached

Submission on the Environmental Impact Statement
Scott Rudd: Mobile Phone 0418 261 248
Jane Robinson: Mobile Phone 0402 114 288

Attention Director Infrastructure Projects,
Planning Services Department of Planning and Environment
Application number SSI 6307
GPO Box 39 Sydney NSW 2001

To whom it may concern,
We live at 1 Cove Street, Haberfield.
The Environmental Impact Statement (EIS) in relation to the M4 East disclosed the proposed location of the tunnel sites.
We have the following concerns in relation to the proximity of our home, and other homes in the heritage conservation area on Wolseley and Cove Streets, to the proposed M4 East `Northcote Street tunnel site'.

1. Misleading original information
We would like to register our extreme distress with the misleading/incorrect original information released by the Westconnex Development Authority (WDA).
We made a decision to remain in our home on the basis that we would not be directly diagonally opposite the proposed construction site. We now understand that an additional home in the heritage conservation area has been acquired, 3 Wolseley Street, and our home will be completely exposed. The EIS aerial photographs are not as per the original aerial photographs. We have a copy of the original aerial photographs.

2. Noise
As stated, the EIS aerial photographs show that our home is directly diagonally opposite the proposed construction site.
The EIS states that the `tunnelling works are proposed to be carried out 24 hours a day, seven days a week' (section 6.7.2). We are very concerned about the impact of the construction project noise.
Does our home qualify for on-site noise reduction or `at-property acoustic treatment'? We have reviewed the EIS and figure 10.7, and have been unable to establish whether our home qualifies for on-site noise reduction measures or other `at-property treatment'.
What measures will be employed in on-site noise reduction?
* We request double glazing of exposed windows, and reinforcement of the stain glass in our front door and side windows.
* We request the installation of ducted air-conditioning.
* We request a payment subsidy in relation to the air-conditioning. If not for construction, we would open the front door and windows of our home and rely on the cross breeze to cool our home.
What are the forecasted mean and peak noise levels during the hours of 6.30pm - 6.30am during (1) demolition of existing site, (2) construction of working site and (3) ongoing operation of site? We have struggled to understand Table 10.4 in the EIS.
Please confirm that the increase in noise due to work of Subakette/Ausgrid on Wolseley Street during October and November 2015, will be excised from the determination of `ambient' noise. The home at 5 Wolseley Street currently has a microphone installed in the front garden that we understand will be used to assess ambient noise. We are concerned that the noise related to the cable laying by Subakette/Ausgrid, involving daily use of heavy equipment and a generator to pull the cable through, will impact what will be considered as usual `ambient' noise. In addition, the concrete box in which the cables currently sit is not level with the road and causes a thumping sound when driven over by a car.
We have read section 10.3.1 of the EIS, and while difficult to understand, we believe the ambient or `background noise levels', form the basis of the acceptable noise management level.
How will noise be measured and monitored during the project?
What variation will be considered acceptable?
How will an unacceptable variation be addressed?
Who will be the contact person for local residents at the construction site?

3. Vibration
Our home is less than 200 metres from the Northcote tunnel site. We are concerned that vibrations will damage the foundations of our home.
What is the forecasted vibrations resulting from the tunnel excavator? We have struggled to understand section 10.3.2 of the EIS, and the 'Vibration damage goals'.
When are the vibrations expected to be the worst?
What measures will be taken to protect our heritage conservation area home from this damage? The EIS observes that `BS 7385 states that "a building of historical value should not (unless it is structurally unsound) be assumed to be more sensitive"' (section 10-12).
Our home is over 100 years old. We have spent a considerable amount of time and money maintaining our home, and well appreciate the issues of age. We are astounded that such a statement could be made regarding the impact of vibrations.
Who will be the contact person for local residents at the construction site?


4. Traffic
Our home is on the corner of Wolseley and Cove Streets - quiet residential streets.
We are concerned that, on top of construction noise, our streets will be subject to the noise of additional traffic due to:
* the closing of Northcote Street;
* people `rat running' to avoid turning from Parramatta Road onto Wattle Street - a practice which may also be driven by the additional truck traffic from the construction site;
* workers heading to and from the construction site.
We have reviewed the EIS but have not been able to identify where this is taken into account.
What is the forecasted increase in traffic on Wolseley and Cove Streets during (1) demolition of existing site, (2) construction of working site and (3) ongoing operation of site?
How will this be monitored for the duration of the project? How will any issues be addressed? We note the EIS disclosure that our home, and other homes in these streets, will already be subject to (among) the highest levels of noise and other disruption during construction.
We note the proposed route for construction trucks connected to the project: entering on Parramatta Road and exiting onto Wattle Street. The EIS states that `construction traffic is not predicted to significantly increase traffic noise.' We request written confirmation that construction trucks connected to the project will NOT be using Wolseley or Cove Streets, for the duration of the project stages.

5. Parking
The EIS discloses that the shift peak construction workforce numbers at the Northcote tunnel site will vary between approximately 75 and 135 per day (table 6.21).
The EIS states that the `majority of the construction sites would have parking for the construction workforce based at those sites' (6.6.5). However, we had understood from an Ashfield community meeting that the workforce for the Northcote tunnel site would be brought in by bus.
If parking is on-site, where will the construction workforce park?
Wolseley and Cove Streets currently struggle to cope with the demands of taxi change-over parking, and will not cope with the additional demands of the construction workforce.
How will parking and associated issues be monitored?

6. Local council rates
We request subsidised local council rates for the duration of the construction project in recognition of, and to compensate us for, the location of the `Northcote Street tunnel site'. The proximity of our home to the construction site, means that we will be subject to (among) the highest levels of noise, disruption and inconvenience to our lives and livelihoods, during construction.



7. Post project use of CA Wolseley Street
The EIS states that `future use of the Northcote Street tunnel site would be subject to separate assessment and planning approval' (Section 6.5.8).
We understand that the `Northcote Street tunnel site' has been transferred to the WDA. Following construction the site is proposed to be transferred back to the RMS. We understand that the RMS then propose to sell the site to the highest bidder.
We request confirmation that the purchaser will be required to comply with local council planning laws. We are concerned that the NSW Department of Planning, State Environmental Planning Policies (SEPP) provide the NSW State government with the authority to over-rule the local council, which at this point in time is Ashfield Council.
We request written confirmation from the NSW State government that the NSW State government will not override the local government planning policy post completion of the project which restricts high rise development. We understand that the land is currently zoned light industrial, with an 11.5m height restriction.

8. NSW stamp duty
We paid an enormous amount of money, including stamp duty to the NSW State government, for a home in a heritage conservation area in Haberfield. We have observed the heritage conservation rules at our expense during our 5 years in Haberfield.
With activation of the `significant infrastructure' clause on 5 December 2014, the heritage conservation status of certain homes in our streets was effectively no longer recognised, and the homes have been acquired and will be demolished. This will most certainly change the character and nature of the area in which we bought. Our valuable home has been devalued. Simply put, we would not have invested our hard earned money in this area, had the proposed planning been disclosed. While there is little we can do about this now, we request recognition of the impact of poor planning on our lives and livlihoods with the refund of stamp duty paid on our home in 2010, and a waiver of stamp duty on the next home we purchase in NSW - with such a purchase motivated by the desire not to live in the vicinity of the smoke stack and the construction site.

Confirm

update to previous submission.

Please find my submission uploaded as pdf.

General concerns Concord Rd interchange:
1. There is significant destruction of heritage area homes in the proposed plan. Earlier plans had significantly less impact on these areas. We request that alternatives which have less impact on heritage areas of the city be assessed prior as alternatives to this proposal.
2. There has been limited information provided as to the use of land taken for construction purposes after the construction is completed. These are frequently shown as parkland in maps but it unclear whether these may be reutilised as residential housing and if they are to be left as green space who will look after them and whether there will be park-style infrastructure (playground, park benches, BBQs included in the plan). We request that this information be provided to the public for comment prior to any approval going ahead.
3. There has not been an analysis of the value of this project compared to a project utilising rail to transport freight and passengers. While mentioned very briefly in the EIS there is not a compelling case brought for the proposed project over other alternatives and very little information on these comparisons has been made available to the public. We request that an appropriate comparison of this project with a project increasing public transport capacity and freight capacity is made prior to any approval for work on this project. This should include a full public release of cost-benefit analysis and a full business case. The limited transparency surrounding the choice of projects and particularly the individual plans severely undermines public confidence in the project.
4. The design of the Concord Rd interchange is overly complex and it is unclear from the EIS why this option has been selected over the others mentioned. The EIS clearly states this is a more expensive option than those which do not require new on and off ramps, but the value to the tax payer for the increased cost is not clearly articulated.
4.1 Of particular worry is the claim that one or other option is beneficial as it allows greater high rise development along Paramatta Rd - in this case at the expense of existing housing. If this is too be seen as a benefit, and major reason for choosing one design over another, there should be a full public consultation on the aim to create large stretches of high rise along Paramatta Rd prior to this project being approved.
4.2 The new westbound entry to the M4 from Paramatta Rd is a very large and expensive piece of infrastructure. This type of flyover is not common in residential areas and severely detracts from the atmosphere of the area. We request a full cost-benefit analysis of new on and off ramps also be performed as these large pieces of infrastructure do not appear to provide significant benefits.
4.3 Traffic modelling for the impact on Concord Rd is insufficient to claim that any design is preferable at this stage. Real life traffic data near the corner of Concord Rd and Paramatta Rd appears to be very limited. We request that better modelling of traffic flows including major north-south routes be assessed prior to approval of any specific design.
5. Given the various points against the complexity of this interchange we propose that the original design of the M4 at Concord Rd (2003) or a model where traffic does not directly access Concord Rd from the M4 would be preferably to the proposed project.

Kathryn Calman

attached

refer to attached submission

General Objection to the EIS process as run for this project:

I would like to object to the incredibly restrictive timeline in which residents were asked to respond to the entire EIS document. Given that a large number of people affected also work full-time and are not experts in the areas discussed this is insufficient for proper community consultation. While this may be within the letter of the law it certainly is not in the spirit of genuine community consultation. The size of the document (~5000 pages), density of abbreviations, acronyms and jargon and the refusal to provide a printed copies of the document seem to be aimed to obfuscate. I would request that the conditions around this and future EIS public consultation requirements be re-examined by the NSW government and a longer consultation time required for larger documents.

see attached submission

John Calman

Refer to uploaded documents. Please let me know if they did not upload.