BEACHES LINK TUNNEL Project ID SSI- 8862 - EIS SUBMISSION by John Berry -CHAPTER 15 ABORIGINAL CULTURAL HERITAGE

INTRODUCTION
The lower north shore area of Sydney area has a rich indigenous heritage dating back 4500. There is evidence of Aboriginal occupation throughout the study area. Aboriginal occupation focused on accessing resources from diverse ecological areas, seasons and conditions. Occupation sites, hunting, travel and inter-clan contact would have been associated with coastal areas, smaller rivers, creeks and swamps. Aboriginal people have left us with a rich cultural heritage, both tangible and intangible, which needs to be preserved. (1)

OBJECTION
I object to the potential damage or destruction to known and unknow Aboriginal cultural heritage within the construction footprint of the Beaches Link Tunnel project
The EIS identifies several know Aboriginal sites in the study area, within 50 metres of the construction zone ranging in significance from "low' to "moderate high". (2)

THE PROBLEM
The EIS states that the potential risk of damage to know terrestrial Aboriginal as "negligible". (3)
However large construction projects can be unpredictable. For example, during the construction of the Lane Cove Tunnel there was an unplanned partial collapse of a unit building which had to be demolished. A similar fate could await known (and unknown) Aboriginal heritage sites.

The construction zone can vary post EIS approval depending on problems and constraints encountered by engineers of the construction company. For example, tunnel depths, tunnel routes and dive site locations can all be altered post EIS approval.

Even minor variations to these could put know terrestrial Aboriginal sites at greater risk of damage or destruction.

RECOMMENDATIONS:
The potential for destruction or damage to significant aboriginal cultural heritage would be unacceptable to the community (particularly in light of recent destruction of aboriginal heritage by mining companies and others).

1)The project should be modified so that there is no risk to known Aboriginal heritage sites.
2) Management recommendations Section 9, Appendix L Pg 74 should be made a condition of consent.

3. Archaeological monitoring during construction by qualified archaeologists specialising in Aboriginal cultural heritage should be a codition of consentpresent. The proposed training of construction staff in cultural and heritage awareness alone would be grossly inadequate. (4)

If unexpected finds are located during works, an archaeological consultant should be engaged to assess the significance of the finds and the NSW Aboriginal Heritage office notified.

4) Real time vibration monitoring of known aboriginal sites should take place and construction should cease in the event that damage is detected so that it can be accessed by a qualified archaeological consultant.


5) Any variation to the EIS sought by the construction company once the EIS has been approved should not be granted until the risk to known and potential Aboriginal heritage has been reassessed by engineers and archaeologists.

OBJECTION
I object to the potential damage or destruction of unknown but highly probable terrestrial and submerged Aboriginal sites in the study area.

THE PROBLEM
The EIS acknowledges the likely existence of unknown Aboriginal sites - which could be damaged or destroyed by the project and it would be very difficult to mitigate against damage or destruction of these unknown sites. (5)
The EIS identifies several areas in the study area with the potential for Aboriginal sites “The lower North Shore portion of the study area includes several parks and reserves including St Leonards Park, ANZAC Park, Cammeray Golf Course, Artarmon Park and Artarmon Reserve, as well as the Flat Rock Reserve and the surrounding alluvial terraces and exposed sandstone outcrops. These parks and reserves have been subject to less intensive disturbance and may have increased potential for Aboriginal sites.” (6)
Destruction of unknown aboriginal heritage at these and other sites cannot be ruled out.
The study area is likely to have undiscovered submerged Aboriginal archaeology. "The pronounced rock outcrops at about 20 metres depth close to Seaforth Bluff are considered to have moderate to high potential for the presence and survival of inundated rock shelters. The possibility of unindated rock shelters requires further investigation and rock shelters at Seaforth be protected from damage or destruction. There is a moderate to high potential for submerged aboriginal heritage at Pearl Bay (west of Spit West Reserve) and the area between Clive Park and Beauty Point." (7)

RECOMMENDATIONS
The potential for destruction or damage to significant aboriginal cultural heritage, both known and undiscovered sites, would be unacceptable to the community (particularly in light of recent destruction of aboriginal heritage by mining companies and others). The project should be modified so that there is no risk to known and potential Aboriginal heritage.
1. The project should be modified so that there is no risk to potential Aboriginal heritage.
2. Further investigation of submerged sites prior to EIS approval is warranted.
3. Management recommendations Section 9, Appendix L Pg 74 should be made a condition of consent.
4. Qualified archaeologists specialising in Aboriginal cultural heritage should be present at all times at all constructions sites where known Aboriginal sites exist whilst work is in progress. Proposed training of construction staff in cultural and heritage awareness alone would be grossly inadequate. (3)
5 Any variation to the EIS sought by the construction company once the EIS has been approved should not be granted until the risk to known and potential Aboriginal heritage has been reassessed.

REFERENCES

(1) 15.3.1 Ethnographic and archaeological context. The Sydney area has a rich indigenous heritage. Aboriginal occupation focused on accessing resources from diverse ecological areas, seasons and conditions. Occupation sites, hunting, travel and inter-clan contact would have been associated with coastal areas, smaller rivers, creeks and swamps.(7)
(2) EIS CH 15Aboriginal cultural heritage Table 15-6 Pg21
(3) Table 15-7 Assessment of potential impacts to known Aboriginal cultural heritage sites Pg24

(4) EIS Ch 15 15.5 Environmental management measures - AH6ConstructionAboriginal heritage –impacts
Cultural and historic heritage awareness training will be carried out for personnel engaged in work that may impact heritage items before commencing works for the project. (31)
(5) EIS Ch15, Pg's 7,8
15.3Existing environment
15.3.1Ethnographic and archaeological context
“There is evidence of Aboriginal occupation throughout the study area, with areas of plentiful food resources associated with shorelines, riparian zones and adjacent areas including Clive Park, Burnt Bridge Creek and Flat Rock Creek. During urban development, many of these areas have been covered by fill, concealing original formations. Some evidence of Aboriginal occupation may also be present along movement pathways, meeting and camping sites, which were often associated with ridgelines.”
(6) EIS Ch 15 15.3Existing environment
15.3.2Environmental and landscape The lower North Shore portion of the study area includes several parks and reserves including St Leonards Park, ANZAC Park, Cammeray Golf Course, Artarmon Park and Artarmon Reserve, as well as the Flat Rock Reserve and the surrounding alluvial terraces and exposed sandstone outcrops. These parks and reserves have been subject to less intensive disturbance and may have increased potential for Aboriginal sites.
“in areas of remnant landscape, Aboriginal sites, where present, may be relatively undisturbed.”
5.3.2Environmental and landscape context
“At the Wakehurst Parkway landscape region, there are sections of undisturbed remnant landscapes in two locations within or in close proximity to the project (Garigal National Park and Manly Dam Reserve)….. The Wakehurst Parkway landscape region is particularly significant because of the Hawkesbury Sandstone and its association with known Aboriginal rock engravings.”

(7) 15.3.4 Potential submerged Aboriginal sites Pg 17

See Document attached

Northern Beaches Tunnel Objection
I object to the Northern Beaches Tunnel. It will lead to unwanted overdevelopment on the Northern Beaches. It seems more development is the only way to make the business case viable. I object to the destruction of trees and green space with the demolition of the Balgowlah Golf Course. Wild life there and along the Wakehurst Parkway will lose their habitats. Defer it and redesign it with more empathy to the beautiful landscape of the Northern Beaches.
Sue Sharp

I object to this project on the grounds that -
- a vehicle corridor is not an solution - when the rest of the world is looking for public transport solution.....this band-aid approach which lasts as long as it takes to be choked and we are back to grid-lock
- the process has been RUSHED through without sufficient consultation with the community before the next election
- the design of the exhaust gas without filtration cannot be guaranteed against fallout in all weather conditions
- the reduction of public space and mature trees and habitat
- the noise and dust pollution factor - early bore hole drilling was enough to pre-empt our impending demise of our well-being for many years
- the visual impact of a stack - not the artist's impression but the true visual of living next door when the scenery has been reduced to ground zero
- a HOME is selected based on the PRESENT facts and its current ENVIRON..... NOT one changed subsequently by Government so others outside the IMPACT ZONE can benefit for short term gains
- concentrated fumes and brake dust cannot be a sensible or healthy solution to any design in this modern day ... another short -term solution

The Artarmon Progress Association objects to the Beaches Link project until the following concerns, as detailed in the attached document, are addressed:
- Significant increases in traffic through residential and industrial areas of Artarmon
- Environmental concerns, including the reduction of groundwater levels under Artarmon Reserve and Oval
- Cycling and walking impacts on residents.

Paris St Balgowlah is our treasured home and community. The vast majority of us have been residents of Paris St for decades which is unusual these days. The long-term residency is testament to the strong sense of connection to community and place. Paris St is a cul-de-sac which ends on Balgowlah Golf Course which is viewed by all as an extension of our street, an important area for walking dogs, playing golf, doing exercise, playing and socialising. We consider the Balgowlah Golf Course and Burnt Bridge Creek corridor to be the reason we are a close community and keep living here, especially contributing to our wellbeing during the Covid-19 pandemic and lockdown periods.
We believe the expensive Beaches Link Tunnel (BLT) project revealed in the recently released EIS will come at a huge cost to our community with the resultant loss of lifestyle and environment and 5-7 years of construction horror. All this loss will be for limited gain as the BLT will not solve the traffic issues for the northern beaches and lower north shore

Thank you for the opportunity to make a submission on the Beaches Link EIS.
I make the following objections in relation to the EIS.
Increased traffic in Artarmon
The EIS highlights increased traffic demand and resultant increased delays at intersections in the Gore Hill Freeway and Artarmon Area.
I am concerned this will result in increased traffic through Artarmon local streets which impacts the amenity for local residents and for visitors using local services, schools, ovals and other facilities. There is already a lot of traffic on Reserve, Hampden and interconnecting roads without further traffic from the Beaches and Western Harbour tunnels seeking alternative routes to the Pacific Highway, Mowbray Road and other major roads.
I request a condition be included requiring appropriate measures to be taken to mitigate the likely impact on local traffic in the Artarmon area.

Vegetation and bio diversity
Artarmon Park
The Gore Hill Freeway connection works will see the permanent loss of dense vegetation from a section of Artarmon Park. Also the construction support sites will occupy many areas that have been revegetated following previous freeway and tunnel works
These green bands provide important habitat connectivity. While the EIS recognises the importance of open space, it is important that wildlife corridors and refuges for the birds, reptiles, insects and other animals that can be found in urban bushland areas are maintained and restored.
I request a condition be included requiring dense revegetation of a section of Artarmon Park to provide habitat connectivity.

Flat Rock Gully
I object to the use of part of the Flat Rock Gully bushland area as a construction site and the loss of over 20 years effort of revegetation to a significant portion of the site. We are already losing a lot of urban bushland and it takes many years for suitable wildlife habitat and biodiverse communities to re-establish. Regardless of previous disturbance to the area, removal of vegetation in this area would be a significant setback as well as loss of connectivity to adjoining bushland spaces. This will not be mitigated by offsets by planting in other localities.
I am also concerned that the Flat Rock Gully site may be left as open space or buildings left on site post construction.
I request that an alternative site be sought for the Flat Rock Gully construction site.
Should the area be used as a construction site, I request a condition requiring revegetation, or contribution to revegetation, to re-establish dense bushland to provide habit and bushland connectivity.

Groundwater
The EIS identifies significant draw down of ground water both during construction and during the operational phase. I am concerned about the long term impact on trees and eco systems, ground settlement and potential for contaminated plumes from contaminated sites.
I request that ground water improvement strategies be developed to mitigate the impact of ground water draw down in the longer term.