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Submission for: Western Harbour Tunnel & Warringah Freeway Upgrade


Cammeraygal P&C

CROWS NEST, New South Wales


We object to the Western Harbour Tunnel and Warringah Freeway upgrade on behalf of our children. Our objections are due to:

1. Climate Change

1. Health and Safety

1. Green Space

1. Climate Change, Sustainability, Accessibility, Liveability

On behalf of our children, we object to these projects. Climate Change is the biggest concern facing our children’s futures. Greenhouse gas emissions from transport emissions and environmental impacts from car and truck manufacturing must be reduced, not increased. These road projects are in complete conflict with our children’s need to combat climate change.

Furthermore, a more liveable, accessible, sustainable city will never be achieved with these road projects. Sydney needs mass transit, rapid public transport for congestion relief and future proofing for population increase. These road projects will produce more traffic in Sydney, and in particular to the new Warringah Freeway interchange near our school. Not to mention the surrounding road network. If the problem is congestion, then more roads are not the answer.

By committing to the Western Harbour Tunnel and Warringah Freeway upgrade, and signing a contract with Transurban (the likely contract winner), the contract will preclude a Public Transport option that acts in competition with Transurban toll road profits. This project permanently subjects Sydney residents to reliance on their cars, and permanently subjects our children and their environment to extraordinary amounts of additional pollution due to induced traffic demand.

2. Health and Safety

We object to these projects on the basis of their significant and numerous Health and Safety impacts.

2a. We object to unfiltered ventilation stacks. If these road projects are to be built, then they must be safe. Ventilation stacks (2 of which are located within 300m of our school) must be filtered.

There will be over 40km of additional polluting road (if the Northern Beaches Tunnel is also built) being pumped out unfiltered from the stacks near our school. Regardless of how much air is blown out of the stack along with the pollution (ventilation), the dose that will be delivered to our community is undisputedly the largest public health experiment we have ever seen. And the effect of the dose is cumulative. The RMS policy to not filter at any cost is wrong. The M5 East filtration trial cannot be extrapolated to filtration of stacks, which is what we are demanding. Filtration works and provides a demonstrable improvement to air quality. Filtration removes up to 95% of pollutants. It is used by first world countries on long road tunnels (over 5km) in urban areas. There is no other tunnel of this length with longitudinal ventilation in an urban area in the world. Other countries filter or do not allow trucks to travel in them.

2b. We object to the significant uplift in surface road pollution on the Warringah Freeway so close to our school. 18 lanes of traffic within 600 metres of our school senior campus is unacceptable without mitigation.

2c. We object to the 6 years of adverse construction noise and vibration that these projects will bring, impacting our children’s ability to learn

2d. We object to increased truck movements in and around our local area, impacting our children’s ability to walk safely to and from school

2e. We object to the Rosalind Street truck lay-by so close to our school, where idling trucks pollute the air that our children breathe all day long, waiting to collect tunnel spoil

2f. We object to further encroachment of surrounding green space around ANZAC park school, loss of greenspace behind the Greens and loss of green space at St Leonards Park and the 11 other construction sites taking green space for the duration of the project.

3. Green Space

Green Space should be increased, not decreased. The North Sydney Local Government area has the highest density living on the North Shore and the least amount of green space. This project cannot make this worse.

A green overpass, over the entire length of the Warringah Freeway between Miller and Ernest Streets should be built to mitigate significant loss of green space and protect children’s lungs from the surface road pollution of the Warringah Freeway. The air within this short overpass should be redirected to the ventilation stack for subsequent filtration and distribution through the stack.

The EIS should be revisited to address the following:

· Assess, then address Climate Change Impacts from the construction of the project, and resultant induced traffic demand and energy demand from ventilation facilities that this project brings;
· Other options to address the problem of congestion must be considered in the EIS, as specified in the SEARS. Public Transport solutions must be assessed against the road proposal as specified in the SEARS;
· A project Business case must be performed for the project. The business case for all alternative options (eg Public Transport) must be considered;
· A cost of stack filtration should be provided in the EIS. This cost should be the additional cost on top of ventilation;
· The proponents should seek to clarify the cost benefit analysis against calculated loss of life and the ‘cost of a life’ due to increased particulates. If the proponents will not use filtration, they should openly show how little they value our childrens’ lives;
· The EIS should be revisited to plan for a green overpass, over the entire length of the Warringah Freeway between Miller and Ernest Streets. This replanning should include a plan to redirect the air within this short overpass to the ventilation stack for subsequent filtration and distribution through the stack;
· The EIS should be revisited to reflect accurate traffic data. The traffic data is currently based on 2016 data and does not consider benefits of the B-line;
· The EIS should correctly reflect uptake of roads versus Public Transport as population increases. Many more people are turning to public transport and this is reflected in research, but not in the EIS;
· The EIS should be recalculated to reflect actual emissions data, as this will impact health assessment. The EIS currently calculates emissions assuming that we will be at Euro 6 standards by 2021. This is wrong. There is no plan to achieve Euro 6 standards. The proponents cannot claim that there is. There could be legal implications for a government body misrepresenting something so important. The Science on Health impacts of air pollution has overtaken this project. We know so much more about the negative impacts of air pollution. The Department would be wise to ensure that they adequately address the accuracy of air quality, number of sensitive receivers and health claims made by the proponents;
· The EIS should be revisited to accurately represent the numbers of sensitive receivers impacted by these projects. There are significantly more children to be considered in the numbers of sensitive receivers at schools. There are 1000+ children per school, so 1000+ sensitive receivers per school, not the current estimate of one school counting as 1 sensitive receiver; and
The proponents must be made to address all these things and our community see the resultant EIS before the Department makes its decision