I OBJECT to this project for the following reasons:
1. Affordability - Given the effects of Covid 19 on the state economy, this project should not proceed until the State budget has been repaired.
2. Requirement - the State Government has not made a compelling case for this project in terms of the problem it is designed to fix. The project will not fulfil the stated intention to provide a link to the Northern Beaches.
3. Alternatives - the State Government has not fully considered the alternatives to this project, including the option to improve rail connections to the Northern Beaches.
4. Environment - this project encourages the continued reliance by residents on motor vehicles which is short-sighted and does not reflect the preferred desire to move to other forms of transport.
5. North Sydney CBD - this project will irreparably damage the CBD and local areas with increased traffic contributing to pollution and detracting from the amenity of the area, particularly in and around Berry Street.
6. Pollution - it is unacceptable to increase pollution in areas of high residency and with large numbers of schools close by.

Attention: Director, Transport Assessments
Planning & Assessment, Department of Planning
Industry and Environment
Locked Bag 5022
Parramatta NSW 2124

26/03/2020

Objection: Western Harbour Tunnel and Warringah Freeway Upgrade - SSI-8863

I write to express my strong objection to the Western Harbour Tunnel and Warringah Freeway Upgrade.

Global experience of toll road construction has demonstrated conclusively that projects like this increase air pollution, encourage more car use, fleece road users with exorbitant tolls and eventually fill the increased road capacity they create.

I object to this Project as it:
• Is based on false assumptions about public transport demand;
• Will not achieve its stated goal of addressing long-term traffic congestion in Sydney;
• Is also not properly tested against competing public transport projects;
• Fails to adequately address impacts on the community, especially noise, air quality and health impacts for local residents;
• Puts homes and businesses at risk of damage from vibrations, settlement and ground movement;
• Requires the compulsory acquisition and demolition of a number of homes;
• Will not require the filtration of exhaust stacks, at a risk to public health;
• Will pollute our harbour with toxic sediment putting Sydney Harbour’s marine life at risk;
• Will have an adverse impact on greenhouse gas emissions and contribute to climate change; and
• Is not justified by any publicly released business case.

Specific Issues I have concern with are:
Impacts on emissions and climate change:
● No consideration of induced demand Global experience of toll roads indicate that they induce demand, create more traffic in the long term and push people into their cars. The EIS makes no consideration of induced demand and the consequential impact on emissions and climate change.
● No benchmarking against public transport The Western Harbour Tunnel was not adequately benchmarked against public transport alternatives. Public transport projects can provide a genuine, long term solution to road congestion without significantly increasing greenhouse gas emissions.
● Ignores lack of fuel standards in Australia The Environmental Impact Statement makes ridiculous claims that climate change impacts of this project will reduce over time as fuel efficiency standards are increased. However, Australia’s transport-related emissions have continued to rise and there is no commitment by government to implement any efficiency or fuel quality standards for vehicles. In fact Australia remains the only country in the OECD without a fuel efficiency standard for passenger vehicles and has one of the worst fuel quality standards in the 36 nation OECD. Submission Guide – Page 7 Western Harbour Tunnel and Warringah Freeway Upgrade Impacts on air quality
● There is no safe level of particulate matter Research demonstrates that there is no safe exposure level to particulate matter generated by traffic. The EIS fails to fully evaluate the long-term health impacts of the Project. It especially neglects the increased susceptibility of children, the elderly and people with chronic disease who are particularly at risk of the health effects of traffic related particulate matter.
● No filtration of exhaust stacks With two-thirds of people in NSW living in metropolitan Sydney relatively close to major roads, vehicles are one of the most important sources of particulate matter (PM) exposure in NSW and are a significant contributor to negative health impacts including increased mortality, respiratory and cardio-vascular disease, and adverse birth outcomes. The EIS proposes to install a double exhaust stack at Cammeray and vent pollution to the exhaust stacks already planned for Rozelle Goods Yard. These stacks should be filtered according to the world's best practice to reduce the impact on air quality and human health.
Impact on Sydney Harbour and marine life
● Dredging of toxic sediment will pollute the harbour 142,500 cubic metres of contaminated sediment will be dredged from the harbour floor and processed at White Bay. This sediment was stated in the EIS to be contaminated with dioxins, tributyl tin and heavy metals as a result of the harbour’s industrial past. Dredging threatens to contaminate harbour waters by creating a toxic plume that will be difficult to contain. While some minimisation measures are proposed like shallow floating silt curtains, these measures may not be sufficient to prevent plumes of contaminated sediments escaping to the harbour.
● Pollution puts marine species at risk Australian Museum records since 1850 indicate that Sydney Harbour is biologically diverse, with over 2473 species of polychaetes, crustaceans, molluscs and echinoderms recorded. The EIS proposes to dredge toxic sediment from the harbour floor creating toxic plumes of pollution which will threaten Sydney Harbour’s marine life. 70 threatened species are at risk including fragile sea grasses that support 20 species of endangered seahorses and dragons.
● Road-header options have not been given adequate consideration The EIS states that road-header options (which would remove the need for dredging) were discounted for the harbour crossing because the tunnel depth required by this method would significantly compromise gradients and force drivers to descend and climb into the tunnel. Here the EIS is placing driver amenity and comfort ahead of environmental protection without even weighing the costs and benefits.
● Critical details about the sediment have been left out While the EIS lists the massive volumes of sediment that will be dredged it doesn’t list details about the concentration of dioxins, tributyl tin, polynuclear aromatic hydrocarbons and heavy metals which is a critical factor in determining the impact on marine life and biodiversity. These details must be released to provide any meaningful feedback on the proposal
Impacts at White Bay construction and sediment treatment site
Work at this site will place the community under unacceptable pressure due to:
● Possible health risks Dredged sediments excavated from White Bay and from the immersion tube tunnel (from Birchgrove to Waverton) contain the toxic contaminants including dioxins, tributyl tin, polynuclear aromatic hydrocarbons, and heavy metals. While the EIS provides the volumes of sediment that will be dredged, it does not provide the concentrations of these compounds meaning that the risk to human health and to the marine ecosystem of Sydney Harbour cannot be adequately assessed. The dioxins are of special concern because they are the contaminants that led to prohibition and limits of fishing in Sydney Harbour west of the Harbour Bridge. Tributyl tin is especially toxic to marine life and was widely used to prevent growth on the hulls of vessels until banned from use.
● Unacceptable odour impacts The EIS does not adequately address odour impacts which will occur during the transport and processing of toxic dredged materials at White Bay and for the immersed tube tunnel. The EIS states that odour impacts will be minimal because materials will be wet and lists no significant measures to mitigate the impact on residents. Sediments in Sydney Harbour and estuaries are known to be odorous and excavated sediments will likely require treatment.
● Excessive noise and vibrations The EIS lists 92 properties that will be impacted by noise with five properties to be impacted by noise at night. These figures seem to refer to entire stratas rather than individual homes which is misleading. Excessive noise can cause stress, impact sleep and reduce quality of life while ongoing noise can seriously impact people’s health. Extensive noise monitoring and noise mitigation should be installed in all impacted homes.
● Long operational time for White Bay sediment treatment plant The White Bay treatment facility is proposed in the EIS to treat 142,500 cubic metres of contaminated sediments that are not suitable for offshore disposal. This is a huge quantity and the space allotted in the EIS is small (1000 square metres) and is close to Birrung Park and residences in Donnelly Street. The facility is stated in the EIS to operate for 3 years, but there is concern that it may need to operate for longer.
● Increased truck movements The Project will generate up to 700 heavy vehicle movements and 530 light vehicle movements per day from the White Bay site. Increased traffic on local roads and truck stack parking decreases existing residential amenity and lessens land value.
● Construction workers taking on-street parking and truck stack parking Local experience with WestConnex demonstrates that despite promises by the contractor to bus in workers or encourage public transport usage, in actuality workers monopolise on-street parking around major construction sites. This will especially be the case at White Bay as workers who are not able to park near sites like the Yurulbin Point cofferdam will be required to drive to White Bay and be barged Submission Guide – Page 5 Western Harbour Tunnel and Warringah Freeway Upgrade on. The contractor must be required to provide parking for 100% of workers on site to protect resident amenity
This project is a missed opportunity to transform our city’s transport system to make getting around Sydney cheap, easy and fast without having to get into a car and pay a toll.

Yours sincerely,

Grant Ironside

Please see attached letter

Attention: Director, Transport Assessments
Planning & Assessment, Department of Planning
Industry and Environment
Locked Bag 5022
Parramatta NSW 2124 March 26 2020

I write to express my objection to the Western Harbour Tunnel and Warringah Freeway Upgrade.(SSI_8863) I have significant concerns about the justification for this project particularly given that there is no published business case, it is not high on Infrastructure Australia’s priority list and that the EIS demonstrates a significant risk to health and safety while delivering poor outcomes.

Firstly, I object to this project continuing to be placed on exhibition during the COVID-19 Crisis. This project significantly impacts the largest precinct of schools in Australia and passes through highly residential areas. In this current environment of the COVID – 19 crisis, families, community groups and schools have been under a huge amount of additional strain throughout the exhibition stage. We have had to cancel meetings to comply with social distancing as instructed by the Government. In a time of crisis, trying to read such lengthy documentation has further added to anxiety. It is most appropriate that this project should be re-exhibited well after the COVID-19 crisis has passed and when normal life returns and it can have the attention that it deserves.

There are other points of objection with this project.
1.The project is primarily a road project that will overall place more cars on the road. For Sydney wants to be a ‘city of the future’, we need to build a world class interconnecting and sustainable public transport system.

2, Priority as an infrastructure project.
The WHTBL project sits amongst 32 other projects in the bottom category of the Infrastructure Australia list. This infrastructure has earmarked it as a possible priority under the condition that a valid business case be submitted for assessment but at present NO business case has not been published. (even though the Business case has been called for in the Upper Parliament on several occasions) In NSW, there are 16 other higher priority projects , some have assessed business cases and several of these are located in Western Sydney and Regional Areas – the areas that most need the governments investment following drought, bushfires and the economic downturn due to COVID-19. To proceed with this project ranking not at the top of the Infrastructure Australia list and without a business case is not ‘a best option’ for NSW especially in our current COVID19 crisis.

3. I am concerned about a range of environmental impacts

Including
(a) Impacts on native fauna
Looking at your tables:
19 -5 (flora)
19-7 (fauna)
19-11 (marine species) The tables indicate that 3 fauna, 7 threatened land species, and up to 13 marine species stand to be impacted by the project including micro-bats, sea horses, sea eagles. In total, there is a significant likelihood of 25 threatened species being impacted by the project. This is posing a significant risk to some of our amazing wildlife and plantlife and it is our responsibility to preserve them

(b) Water Use (Chapter 24 Resource Management and Waste) Analysis: An enormous amount of water is required for these works to proceed. The large quantity of water needed is a direct result of the construction methods and route chosen for the project. Public Transport tunnels require far less concrete and therefore far less water and would not require the Warringah Freeway to be re-built. Public transport is vital to Sydney’s future as a global city.

As a longstanding Sydney resident, this project is a missed opportunity to transform Sydney into a world class, healthy and sustainable city with a strong public transport system. I request that an alternative public transport feasibility study be published before any further planning occurs so that impacts and outcomes can be fairly compared.

Yours sincerely,

EK
I declare also that I have not made any reportable political donations or gifts in the past 2 years.

See attachment

Please see attached PDF of my submission.