Castlecrag Progress Association (CPA) supports and endorses the submission made by Willoughby Environmental Protection Association (WEPA) in objection to the project. We have read the WEPA submission and find its arguments sound and compelling.

For this reason we oppose the Beaches Link Tunnel until such time as:
1. the business case is released for public consideration;
2. the need for the project, and its superiority over public transport alternatives has been demonstrated by way of a transparent process involving informed public engagement and consultation, noting that the EIS process has to date failed to evaluate the relative merits of public transport alternatives.

yours faithfully
Dr Paul Stokes
President, CPA

I object to the proposal on a number of grounds. First, the EIS indicates that this project will result in the clearing of more than 350 trees from parkland around Flat Rock Gully. This area is home to a range of native wildlife and it also provides valuable green spaces for local residents. As someone who lives and works nearby, it would be a real shame if this beautiful part of the Lower North Shore was lost or permanently damaged. The impact this will have on the regions biodiversity would also be considerable. Flat Rock Gully also has considerable Aboriginal Heritage which should be protected - the waste generated by this project has the potential to cause harm to this Heritage. Furthermore, the EIS suggests there will likely be significant pollution coming from unfiltered tunnel stacks. This will impact not only the local environment, but potentially the health and wellbeing of those who live and work nearby. This risk is not acceptable - the impact is too great.

I also object to the proposed tunnel because there is not enough evidence that this will improve traffic congestion. Building new toll roads is simply not a sustainable approach, it won't relieve congestion and it will make hitting our emissions targets harder. What we need is to invest in more public transport infrastructure. This will help remove congestion from our roads while also protecting our green spaces, and helping us collectively reduce our carbon emissions. The Government should commission a full options analysis that looks at alternatives including public transport infrastructure that could have a smaller footprint on the local area.

I am also deeply concerned that despite community requests, the business case for this project has not been made publicly available. In the interest of full transparency, the business case should be published and the public consultation period re-opened with new opportunities for residents to consider the proposal and provide their input.

I am a father of 2 school aged children and have serious concerns about many aspects of the beaches link tunnel project. Given the state governments recent declaration of a net zero emissions target by 2050, I find that building a new motorway in a built city environment goes against this. Public transport options give us the best opportunity for the generations to come having a liveable climate like we currently enjoy. Every little bit counts for our future. See my points below to expand further.

Air quality and pollution –the impact on the environment and to my community from the increase in truck movements on local roads is completely at odds with the 2050 target. RMS Air Quality team have already confirmed it one of the biggest risks, causing potential cancer and fatality impacts in children, is the diesel emissions from the high levels of trucks. Hydrogen-fuelled trucks instead must be made mandatory if this project proceeds. The location of the unfiltered ventilation stacks nearby to schools is morally wrong also. Are the health risks to our next generation acceptable? I don’t think so when increasing and improving public transport is the way of the future.

Noise and traffic – The huge increase in truck traffic will cause unacceptable levels of noise, vibration, dust and diesel fumes that even the RMS team themselves have identified as highly toxic and dangerous. Having no time restrictions on certain types of truck movements is hard to believe. Previous objects to this have been ignored so far. Permanent noise abatement walls should be installed around the site as well as adjacent to those who are subject to significantly increased traffic noises due to truck movements, both during and outside of work hours ie along Flat Rock Drive and Brook Street and the south facing streets of Northbridge
Pedestrian road safety. Large numbers of pedestrians, particularly school children cross Brook Street every day. Installing traffic lights at the intersections of Grafton and Slade Street on Brook Street will somewhat improve this situation. If truck drivers need traffic lights to leave site for their safety surely our school children need to same protection also.

Waterways – we are blessed with an incredible harbour in Sydney and the risk of damage caused by dredging around the point in Northbridge unnecessarily puts this ecosystem at risk. Thousands of people enjoy this part of the harbour every week, many travelling from out of area to do so. Is this risk worth the so-called reward?
Bushland – The bush corridor that flat rock gully is part of is an important link for wildlife and recreational users. These corridors are part of what makes Sydney such a unique city. Thousands of people and animals use this corridor every day. Given that this area is a remediated tip site, it is quite astonishing that tunnelling through such a former site was even considered in the first place. How will you control the release of toxic gases and the removal of asbestos from this former tip? No indication is given as to how this will be controlled and or monitored.

Aboriginal sites of significance – There are known sites in the area dating back at least 4500 years. How will they be persevered and protected? These sites are important part of our pre-European history and need to be protected for our future generations.

In summary I feel the negative impacts of this tunnel project far outweigh the so-called benefits.

My submission is attached.

I object to the Beaches Link and Gore Hill Freeway Connection for many reasons.

I want to see new public transport infrastructure to support the sustainable future growth of the Northern Beaches, not a motorway that locks us into car dependency. Toll roads do not solve congestion. Sydney is already riddled with urban motorways that destroy the fabric of the city and create huge traffic jams.
In order to make this a livable city for the future, you have a once-in-a-generation opportunity to make the correct long-term decision and provide public transport, preferably by rail, as other progressive cities around the world have done.
I object that Transport for NSW has failed to consider other options to achieve a reduction in congestion and improved travel times for the relevant communities.
In addition, there is plenty of evidence that WFH will continue. A number of large employers (including TfNSW itself and many government departments) have officially adopted a hybrid form of WFH. However, TfNSW have evaluated the movement to WFH as “temporary” in relation to the Northern Beaches. This must be re-assessed.

An independent cost-benefit analysis must be conducted for all transport options and publicly released. The must include a full evaluation of the option of Western Harbour Tunnel without the Beaches Link, an extension to the Metro, the use of trackless trams and driverless electric buses and proper BRT systems.

My sons are students at NBSC Balgowlah Boys Campus. The school sits directly south of the Balgowlah Construction site. The students and staff will be impacted by noise, dust, traffic congestion, safety issues, parking problems and the probable loss of the Balgowlah Oval.
The school has grown rapidly over the last few years due to its excellent academic results. This upward trajectory is in jeopardy from over 6 years of very disruptive construction that threatens to send boys and teachers to other schools.

The EIS states that 495 heavy truck movements will occur every day at the Sydney Road entrance to the construction site, noise levels will exceed Noise Management Levels consistently and dust will be a serious health hazard.

The NBSC Balgowlah Boys Campus must be listed as a ‘Community Receiver’ to ensure noise and air quality monitoring. This is a serious omission in the EIS.

The mitigation measures requested by the school must be included in the Scope of Works for the contractor and be regularly reviewed/monitored by a Working Group which includes representatives from P&C and the school.
Penalties must be imposed on the contractor(s) when acceptable air quality, noise and vibration levels are exceeded.

If the Beaches Link proceeds, the future amenity of the area around the school must be considered at the outset of the project:
• Northern Beaches Council and the NSW Government must collaborate with NBSC Balgowlah Boys Campus to design future facilities for the new open spaces to maximize benefits for the school. The open space development, if executed well, provides an opportunity to expand school’s existing campus.
• I would like TfNSW to install new bus stops for the B-Line and other express buses at the Sydney Road junction with the Burnt Creek Deviation. Space could be created for a proper bus interchange around the entrance to Dudley Street. This would dramatically improve access to the bus network for Balgowlah Boys students and local Seaforth and Balgowlah residents.

Finally, I am shocked by the environmental impacts of the project such as:
• Wakehurst Parkway will be a 4-6 lane freeway across a narrow escarpment, causing ongoing pollution into sensitive creeks and waterways at Manly Dam and Garigal National Park. 39 football fields of bushland will be cleared as well as 2,000 trees. The road will be raised several metres in some areas - making it audible and visible, day and night, for miles around.
• The Burnt Bridge Creek will die as its flow is to be reduced by 96%, destroying a delicate ecosystem that supports threatened species including the flying fox colony.
• During construction, 425,000 litres of waste water will be washed into Manly Lagoon at Queenscliff every day.
• At Middle Harbour, toxic chemicals in the harbour sediment will be disturbed during dredging, posing a major threat to the marine environment and the amenity of Clontarf and Sandy Bay.
• Balgowlah Golf Course site will be completely cleared of vegetation and native habitats during construction to allow for parking for some of the 3000 workers daily, enormous road headers, a concrete batch plant, rock crushers and acoustic sheds.

The contractors must be locked into all mitigation commitments with large fines for breaches. It is essential that due diligence is taken to protect the waterways and native habitats during and after construction. Restoration of construction sites must occur under the watch of independent experts to ensure that biodiversity is not lost forever.

The EIS is a long and complicated document and the community has not had time to review it properly in consultation with council and elected representatives. I urge you to press 'pause' on the procurement process NOW so that all stakeholders can develop a truly sustainable plan for the the development of Sydney.

Concerns around local schools:
As a local Balgowlah resident, I fear for the abundance of traffic and congestion that the construction will bring surrounding the school on Wanganella and White Streets, St Cecilia's. My children go there, and having extra traffic surrounding this already congested area where 270 primary school students are having to be dropped off, needs to be closely respected and draw traffic AWAY from the Southern side of Sydney road towards White Street. This area was listed as a place of worship, not a school. With 270 primary students, plus several hundred secondary students one block West of it at Balgowlah Boys High, congestion needs be removed, not added to this area. Careful consideration needs be placed on the use of Maretimo, Wanganella, and Condamine South of Sydney Rd, to not create a 'rat run' on this densely populated area to Ethel and Cutler Streets / Roads. Children, especially primary that bring infant siblings often in prams, need be respected and isolated from workman, work vessels, and the like, associated with constructing this said tunnel.
Concerns about commuters and toll expenses:
I would like to see a 'toll concession' applied for local residents, not unlike the old Bob Carr inspired exemption from the Wollongong Canberra freeways, whereby residents of the beaches get a capped weekly toll, to not allow for excessive billing.
Local sporting amenities:
The Balgowlah Oval, and Golf Club, specifically, should these be used for work stations of the area, then adequate relocation of cricket nets and the like etc, so our children have access. Perhaps use some of the public grounds for all to enjoy on other area's to allow for all rate paying and school paying families to enjoy the area during the construction of the tunnel. This area is a wonderful community, sharing and kind, but the pressures of construction and impacts on schooling can be devastating for the lifestyle of the area, of any area.
Thank you for considering my opinions.
Respectfully, Sam

I request the state government reconsider the northern beaches tunnel and re consider the option of improved public’s transport. To me, it makes no sense to increase the amount of cars on the road and therefore extra pressure on parking within the city. It horrifies me to think we will lose our local creek (near Balgowlah golf club) and the impact on our local bird and animal life around the Manly Dam area. My other concern, my property will become an island, surrounded by highways and smoke stacks - please reconsider this decision.

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