WestConnex - M4 East Upgrade

See attached for complete submission.

Key points and concerns (extract from submission):
* Air quality in the Haberfield area close to the ventilation tower and portals
* Traffic congestion from larger numbers of vehicles expected to make use Parramatta Road and the City-West Link eastbound in the morning peak upon the project completion
o The air quality impact of greater congestion, slow moving traffic, especially trucks exiting the tunnel on a rising gradient at slow speed and with frequent stopping
* The greater accessibility provided by the M4 East likely to create the congestion effect currently experienced
o on Parramatta Road near the M4 start/end at Concord
o on the length of the M5 East
* The unknown duration of operation before the M4-M5 Link is completed
o There are a number of concerns with this subsequent project, however they relate more to treatment of Parramatta Road following its completion
* The effect of the above on the amenity and value of our home
* Our likelihood of sending our children to Haberfield Public School (currently our closest)
* The connectedness of the communities of Haberfield and Ashfield as we regularly take our children to Ashfield Park and enjoy the culture of Ashfield and Summer Hill
* The overall benefit of the project to the community
* The effect the project has on other residents in the area, in particular those losing their homes or those bordering dwellings to be demolished
* The level of consideration to alternatives, namely
o Developing the M4 East from Concord to Rozelle as one project
o Intermodal freight transport
o "Fast" direct-to-city trains from key stations with large car parks

See pdf submission below

Please refer to the attached document

See pdf submission attached

Attention Director Infrastructure Projects,
Planning Services Department of Planning and Environment
Application number SSI 6307 (Westconnex M4 East).
GPO Box 39 Sydney NSW 2001

1/11/15

To whom it may concern,

Please find below my submission on the M4 East Environmental Impact Statement regarding:
Health Risk Assessment:
I look forward to your response to each of the below points.
1. General concerns with the calculation of health risks and the health impacts associated with the project:
1.1 Statistics described in the Environmental impact statement are based upon hospitalisation rates. This suppressed the risk level. For example decreased air quality can lead to increased allergy reactions and more severe asthma attacks, increased noise can lead to sleep deprivation and resulting mental health issues which are unlikely to require a hospital stay. Therefore these less extreme impacts (though important for those affected) are not accounted for in the EIS design.
1.1.1 Of note many of the risk levels using the current design are not listed as negligible (<1x10-6) but `tolerable' (>1x10-6 - <1x10-4) - a more comprehensive analysis of impact to include increased use of medication and increased GP visits may well move these risks to unacceptable (>1x10-4). As such a more comprehensive study should be undertaken.
1.2 These studies examine quite broad populations with little focus on either those closest to construction sites and the final build or vulnerable populations such as the elderly or those with pre-existing conditions which could be exacerbated.
1.1.2 Similar to pt1.1.1 an analysis focussing on those most directly affected by the project may indicate that increased health risks for these groups are unacceptable.
1.3 Risk calculations are based on exposure to the completed project and not to adverse conditions during construction.
1.4 Risks are calculated separately for exposure to decreased air quality, increased noise and vibration however exposures will be to all risk factors, not in isolation. As such cumulative risk for the multiple factors involved should be assessed prior to approval of the project.
1.5 No full health impact assessment was performed for the entire Westconnex project on the Sydney population. For example - for the M4 east the claim is made that air quality is improved due to moving traffic into a tunnel and away from surface roads. These emissions still need to go somewhere and that the exhaust stacks limit exposure to local populations only suggests that the exhaust is more widely distributed as the stacks are not filtered.
1.5.1 As such we request that a full health impact assessment be conducted for the entire westconnex project be conducted compared to `do nothing' and `improved public transport and freight by rail' options to truly assess the impact of this project on the health of Sydney residents. We would request that this report be completed by an independent and preferentially international specialist firms including the use of health economists to predict the increased health costs arising from increased car and heavy truck traffic.
1.6 The health risk assessment does not in any way assess the increased cost to taxpayers via increased utilisation of the health care system - this should be taken into account when determining the cost and feasibility of the project. For example as cited below studies have linked many of the adverse health effects of large road projects such as this to increased leukaemia/lymphoma development. Current cutting edge therapy for adult chronic lymphocytic leukaemia and Non-Hodgkin's lymphomas are tyrosine kinase inhibitors such as Ibrutinib and Idelalisib. These treatments are expected to cost ~$10000 per month to administer per patient and need to be taken long-term to provide maximal benefit. This may be for many years. As such each new case is a significant cost burden to the healthcare system, independent of cost to the individuals involved. We request that no approval be given to this project until a full cost analysis of all adverse health effects is conducted.
Specific health impact issues:
2. Location of substations:
2.1 There has been a reasonable amount of research performed on the effect of substations on cancer risk for those living in close proximity. Major concerns have been increased risk of lymphoma/leukaemia and malignant brain cancer. Given varying study design, length of follow-up period and specific parameters measured there has been variability in the results of these studies. The International Agency for Research on Cancer (IARC) assessed the published studies in 2002 and determined that "Extremely low-frequency magnetic fields are possibly carcinogenic to humans
(Group 2B). and Static electric and magnetic fields and extremely low-frequency electric fields are
not classifiable as to their carcinogenicity to humans (Group 3)." We would note that this last statement is not that there is no carcinogenic effect but that there is not sufficient evidence to determine this. However quite regularly a link has been found in studies between long-term exposure to magnetic fields >0.4µT and increased cancer risk, particularly leukaemia/lymphoma. This level of magnetic field can be generated by domestic substations. Studies have also examined the effect of distance on cancer risk. It has been concluded that for adults (>18yr) cancer risk drops to background level for housing ~25-50m from a source and for children (<18yr) at ~50-100m (Coleman et al, British Journal of Cancer, 1989 - first author member of the International Agency for Research on Cancer (IARC)).
International Commission on Non-ionising Radiation Protection (ICNIRP) 2010 publication in Health Physics 99(6):818-36. Aimed to "establish guidlelines for limiting exposure to electric and magnetic fields (EMF) that will provide protection against all established adverse health effects". This report stated that "A considerable number of epidemiological reports, carried out particularly during the 1980's and 90's indicated that long-term exposure to 50-60Hz magnetic fields....might be associated with cancer" and that "pooled analyses indicate that an excess risk may exist for average exposure exceeding 0.3-0.4µT". These levels are in the range of those in close proximity to a substation. This report then states that it is difficult to set exposure thresholds for this type of risk. We suggest that the evidence that is available would recommend a prudent approach to placing new structures next to residential housing and as such proposed substations should be located as far as possible from residences.
Consequently the location of the proposed substation at the corner of Sydney Street and Concord Rd poses a health risk to a number of residences that fall within the 0-100m radius. We propose that this substation should be located where a utility substation is temporarily located during construction (near large acoustic shed) or on the opposite side of Sydney St to the proposed location where it could be located in the `green zone' area where it is not in very close proximity to housing. This small change to the plan can greatly decrease the health risks for Westconnex neighbours.

3. Air Quality:
We request further information regarding mechanisms to mitigate exposure of the general population and particularly exposure of residents to decreased air quality during construction.
3.1 The adverse health risks described in this report are related to the impact of the completed project. We request that this assessment be completed for the impact of the actual construction process on the residents of the surrounding properties prior to approval being given to the project.
3.2 According to the World Health Organisation exposure to particulate matter is responsible for up to 800000 premature deaths each year worldwide. Exposure to particulate matter can increase risk of respiratory disorder, cardiovascular disease and cerebrovascular disease. The risks are particularly high for vulnerable groups -children, the elderly and disease exacerbation for people already presenting with these diseases. Mechanisms do appear to be in place to try and limit exposure of tunnel neighbours to increase exposure from vehicle exhausts, increased air flow and dispersion once construction is completed. Particulate matter is also derived from road wear, tyre wear and brake wear amongst other sources. We request additional information on whether the road surfaces to be utilized for the M4 widening and tunnel have been chosen to minimize the creation of particulate matter.
3.3 An Australian Federal Senate report was released in 2013 regarding limitation of air pollution levels and recommended courses of action. We would be interested to know how this report and particularly the submission of the Australian Medical Association to this committee have been considered when designing the entire Westconnex project. Within this report are suggestion limits for exposure. We request that hard limits be set for the construction phase of this project and that there be penalties applied to the contractors if they exposure project neighbours to levels of pollutants higher than these limits.
3.4 During construction there will also be an increased presence of heavy vehicles operating in the area for prolonged periods of time. What mitigations or controls are planned to be in place to ensure that vehicle fumes and dusts from construction phases are not impacting neighbouring properties and residents. Further are there mechanisms to compensate or protect direct neighbours of Westconnex for increased dust and particulate matter in their homes or businesses both during construction and from the final project?
4 Noise:
4.1 We would also request additional information on how noise levels will be monitored both during construction and afterwards. What mechanisms will be used to limit the impact of increased noise on neighbours - are these solely sound barriers in appropriate areas or will compensation be made to nearby home owners to assist with noise proofing their residences to deal with the increased noise levels. This is also a health matter - increased noise levels can lead to mental health problems, sleeping disorders and increased risk of cardiovascular disease and lymphoma. We believe that measures should be taken to minimize this impact on Westconnex neighbours.
4.2 There does not appear to be any noise barrier provision on Sydney street or Carrington Lane following completion of construction. We request that consideration be made for inclusion of sound barriers at these sites.
4.3 High noise is a stressor which results in activation of the endocrine and autonomic nervous system, these systems do not fully habituate to chronic exposure. There is evidence that adverse effects from exposure to increased noise is cumulative over time with chronic night time night exposure "likely to result in detrimental effects as they accumulate overtime and thus indirectly create an increased risk for cardiovascular disease" (Pirrera et al Environment International 36, 492-8 (2010) and references within). Given the length of the construction period for this proposal the noise generated could have significant adverse health effects on nearby residents particularly the proposed night work. We request that the allowance for night time work particularly the continuous use of heavy trucks to remove spoil from the Concord Rd tunnelling be re-assessed and limited to reduce the adverse impact on neighbours. While there are some allowances for noise monitoring it is unclear as to how realtime results will be fed back to the construction company and if this will result in changes to construction practice if noise levels routinely exceed the recommended 65dB. We request that if permission for night time works is given that it is only if this noise limits are not exceeded and if they are that penalties be imposed on the contractors and approval for night works can be revoked.
4.4 Noise from traffic is a concern for many Sydney residents - we request that the NSW state government look at altering the legislation which limits the amount of noise individual vehicles can make - we request that noise limits be placed on the amount of noise an accelerating vehicle can make and also that the current limit for stationary engine noise of 96dB for older cars and 100dB for motorcycles be decreased to reflect technological advances made since the legislation was written.
5. Vibration:
5.1 Vibration can similarly act as a stressor. Given the large amount of proposed excavation and piling for construction of the tunnel entry at Concord Rd we request further information on how affected properties can be protected from these impacts.
5.2 For both noise and vibration the assumption is made that residents will not be at home during daytime work hours for many of the assessments. Many residents may work from home making this particularly disruptive to their work life. Additionally there are people who do not work (stay at home mothers, retirees etc) as well as residents' pets. For these people and animals the impacts of the construction phase and the final build are effectively constant. We request that this be addressed prior to approval being given to the project.

6. In summary, the current assessments of the health impacts of this project are inadequate as they do not assess the full range of health impacts but only the extreme end, they put no cost on the increased adverse health risks and the impacts on particularly adversely affected residence or vunerable populations are not adequately addressed. In the interest of the public health we request that hard exposure limits be generated for noise and air quality measures (particulate matter and toxic chemicals) and that proof that these measures can be adhered to be part of approval for this project. Additionally we suggest that penalties should be imposed on those involved in construction of the project is these limits are exceeded.

Yours sincerely,
Dr Tara Roberts
74 Concord Rd
North Strathfield NSW 2137
Private E-mail: [email protected]

Please see PDF -

Please see attached letter submission

See attached - signed and dated Westconnex EIS submission

Please see my attached submission against WestConnex M4 East.

The school peak around 9am and 3pm is not considered in the EIS
Weekend traffic is not considered in the EIS
Reducing congestion by
Car sharing
Encouraging business to have variable finishing times
Working from home and the roll out of the NBN has not been considered
Spending 15 billion of public and private money on public transport as an option to Westconnex has not been considered
The effect of the new Sydney airport has not been considered

Additional information re AECOM and its relationship to WestConnnex
M4 East EIS Services
VALUE: $4,185,470
PERIOD: 2015-07-24 - 2016-10-28
Alexandria Landfill Closure Plan Development
VALUE: $1,948,540
PERIOD: 2015-05-07 - 2016-05-05
Stage 2, Construction Power Supply Study & Design
VALUE: $150,101
PERIOD: 2015-04-08 - 2015-09-02
Traffic Director
VALUE: $697,959
PERIOD: 2015-03-10 - 2015-09-08
Stage 3 Design Engineering Services
VALUE: $973,145
PERIOD: 2015-03-04 - 2015-08-12
Stage 3 Business Development Phase Technical and Environmental services
VALUE: $198,000
PERIOD: 2015-02-25 - 2015-05-06
Geotechnical Site investigations Stage 2
VALUE: $8,633,448
PERIOD: 2015-02-23 - 2015-11-23
Stage 2 Technical and Environmental Advisor
VALUE: $12,948,727
PERIOD: 2014-06-18 - 2015-12-31
Stage 2 Industry Partner Design
VALUE: $1,338,720
PERIOD: 2014-02-12 - 2014-08-04
Stage 1 M4 East Environmental Assessments, Design Development & Communications Services
VALUE: $1,605,890
PERIOD: 2014-01-14 - 2016-01-12

See PDF for comments below.

See attachment

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

All comments in this submission pertain to the Concord Road interchange and the associated construction sites and their effect on 74 concord road unless otherwise noted.
RE: General EIS Comments
The EIS is s significant document totalling (at last count) 4377 pages. While this is great to have as a PDF, so that it can be searched and commented, the PDF is lacking in professional construction concepts. Content pages are not hyperlinks to the relevant section and landscape pages are not rotated independently for online viewing. The over use of acronyms and abbreviations, not all of which are listing in the references tables, make the document even harder to read and ensures that the reader must develop a detailed understanding of the area being discussed in order to gain any understanding at all.
Meanwhile providing this document in only digital form disadvantages many affected members of the community that are not familiar with reviewing digital documents and may not even have access to a computer. While I appreciate that it is available for review at various locations, but I have also found the advisors at some public locations to not be familiar with the document enough to be able to adequately assist. Where bulk printing and offering to at a minimal cost to particularly interested people would overcome this, where an individual would be forced to spend in excess of $280 to print it privately.
The review period for a document this large is extremely restrictive, is not in alignment with other industries review periods and it does not provide a reasonable amount of time for the community to review the EIS, keeping in mind that these are member of the community who need to do this as well as all other commitments of day to day life, like work. I also find that the EIS is not very well formatted for a community consultation document. Many figures and tables are not fully explained or lack detail.
In summary I believe the EIS has not been produced in a manner appropriate for the intended purpose of informing the community and allowing the community to comment on the project. It assumes a high level of comprehension of technical detail and jargon, access to a computer and the ability to adequately read a digital document. The EIS review period is too short for the size and complexity of the project, a quick calculation (pages x 1 page per minute) would require 73 hours to read the whole document, but does not allow for comprehension or proper analysis of the information provided. I request that no approval is given to the project until an appropriate considered public communication is facilitated.
Yours Sincerely
David Manning
74 Concord Road North Strathfield

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

All comments in this submission pertain to the Concord Road interchange and the associated construction sites and their effect on 74 concord road unless otherwise noted.
RE: Design of Concord Interchange
The current proposed design requires extensive tunnelling and road a works that require significant amounts of land to be acquired to facilitate the large footprint, and massive impact on local residents and communities. In 2003 to original proposed option and the option that went to tender, proposed the M4 be extended, no duplicated. This change has also then required massive interchange works at concord road to provide access to the new tunnel locations.
I believe that the existing corridor has been designed to facilitate expansion between Home
Bush Bay road and Concord road. There is significant corridor space that is currently unused, and the termination at Concord road appears to have been originally designed to run directly into tunnels (refer to the 2003 tunnels plan). This option would remove a significant amount of tunnelling required from Home Bush Bay road to Concord road, and the additional lanes and associated traffic could be carried within the existing corridor. This option would have significant savings in property acquisitions and construction, negating the property acquisitions and construction difficulties in the original proposal.
In addition I request the entry and exit points at Concord road could still be upgraded in accordance with the original tender proposal plan, to improve existing infrastructure to improve flow and access.
I would like to see business case justifications for abandoning the tender plans to design a significantly different and more expensive alternative. These are dealt with very superficially in the EIS.
In summary I request that no approval for the project be issue until an appropriate Cost benefit analysis and health effects of the existing proposal as compared to the original plan and making no changes is made available for public comment.
Yours Sincerely
David Manning
74 Concord Road North Strathfield

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

All comments in this submission pertain to the Concord Road interchange and the associated construction sites and their effect on 74 concord road unless otherwise noted.
RE: Construction Concerns
74 Concord road will share a boundary with the tunnel ramp excavations. We have concerns for the structural integrity of our house due to vibration and ground movement that may be expected when the excavation is within two meters of our home.
The construction of a tunnelling site is to share a boundary with the property possess significant risk to resident health and safety, due to an increases in, noise, vibration, vehicle movement, air borne pollutants and toxins, ground movement, moving equipment, lifting and construction process (cranes etc.).
During our discussions with construction company representatives and have been assured that all required actions to mitigate and control all aspects of the construction will be in compliance with the Relevant legislation in accordance with the EIS. I when asked what is going to happen if the limits specified are exceeded (i.e. what extra measures can be introduced), specifically with relation to 74 Concord road which is in a high impact zone being directly adjacent to the site and is likely to have all the sound barriers along the fence. We were told that ever effort would be made not to exceed the limits, and that they did not know what additional mitigation measures could be used. This was the same response when discussion on any of the construction site problems where discussed (i.e. noise, vibration, dust, air pollution, air borne toxins, etc.).
74 Concord road has a number of pets that are onsite 24 hours 7 days a week and we also often work from home 2-3 days a week. We request that consideration be given to the needs of residents that cannot get away from the site during the day (elderly, young, animals) and how the construction site may affect their health and wellbeing.
We have not had any concise response to any question regarding what happens if agreed limits are exceed? It would appear that if levels are exceeded that there is nothing else that can be done to reduce the impact on residents. What are the escalation methods to minimise any impact of the construction site above what is already determined in the EIS, specifically with regards to 74 Concord Road.
In addition as a highly effected local resident I would expect that I and residents in similar circumstances have access to a consultant or communications officer on site to discuss matters around the construction sites and associated activities while the site activities are in progress.
I request that these details be made available for public comment prior to the approval of any site works.
Yours Sincerely
David Manning
74 Concord Road North Strathfield

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

All comments in this submission pertain to the Concord Road interchange and the associated construction sites and their effect on 74 concord road unless otherwise noted.
RE: Truck movement - Concord Interchange
We are concerned about the effect that an increase in heavy vehicle traffic will have on local residents during construction, especially during tunnelling operations. The EIS notes that up to around 300 trucks will be required to attend the tunnelling site operation at the concord road interchange daily, which equates to at least one truck every 5 minutes, 24 hours assuming even distribution. What transport management is in place to ensure these trucks are not cueing to enter site outside residential homes, causing traffic congestion and additional noise and pollution?
The access and exit points to both sites will require trucks to be accelerating up hill and most likely from a standing start. This places the trucks in a `worst case' scenario for exhaust and noise pollution which will have a much greater effect on local residents. The nature of both of these sites may require that uphill standing starts are required in numerous locations, this would suggest that the proposed site plan probably should be revisited to attempt to minimise this requirement, and the subsequent effect on the local community (perhaps rerouting trucks to travel in the opposite direction, downhill).
I request that no approval for site works be granted until a fully detailed site plan and vehicle management strategy be implemented and made publicly available. This should include a comprehensive analysis of vehicle movements taking into account resident proximity operating times, and nature of movement and the associated potential health effects on residents due to the planned movement.
Yours Sincerely
David Manning
74 Concord Road North Strathfield

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

All comments in this submission pertain to the Concord Road interchange and the associated construction sites and their effect on 74 concord road unless otherwise noted.
RE: Property Contamination
I have not been able to identify any controls in the EIS for employee movements and management during or around construction works.
There will be very large number of workers required to attend site each day, it is normal practice for construction workers to be on site as early as 6:00am. I have observed at other sites that areas where workers park and gather often build up with a high level of rubbish as they drink, eat and smoke before, after and during work and rest periods.
My concern is that areas around my property may be used as utility areas (i.e. parking, smoking, waiting, etc.) and as a result, that we may be subjected to rubbish from these area and the construction site being carried by various means into my property.
In addition, I have strong objections to smoking generally and the associated `second hand smoke' as it has a large negative effect on my health. I am concerned that smoking related air pollutants and rubbish may be carried and evident on my property as a result of construction activities and workers as they enter site, work, rest and leave the site.
What is the parking plan for these workers, are they going to be taking existing street parking that is already at a premium?
I request that these detail be made available for public comment prior to the approval of any site works.
Yours Sincerely
David Manning
74 Concord Road North Strathfield

Document attached.

I wish to express my objection to the WestConnex M4 East motorway proposal as per attached.