Please see attached submissions for details of the Australian Institute of Architects' objection and suggested alternative approaches.

Whilst I generally support the Western Harbour Tunnel project to build an alternative harbour crossing that bypasses the CBD and provides an alternative Northern Beaches crossing that bypasses Military Rd/Spit Bridge, I do object to the following aspects detailed in the Environmental Impact Statement:
Pollution impact:
That the smoke stacks (including the Ernest St smoke stack) are UNFILTERED. The smoke stack should be filtered - any reduction in particulate emissions and pollution for the local residents should be encouraged. Not only am I concerned about the impact on residents and visitors, but very much to the students and staff of ANZAC Park Public School.
Loss of green space:
The permanent loss of 3 hectares of green space in It is inexcusable to be losing so much green space in an inner-city area.
Traffic impact:
The use of Berry St, North Sydney as a major access point. Berry St is currently a major thoroughfare through North Sydney, and even more traffic will be funneled into and through Berry St to access the WH Tunnel. Consideration should be given to converting Berry St into a West-East tunnel to separate through-traffic from local traffic, and/or identify alternative access points to the WH Tunnel that will not rely on an already-congested access road such as Berry St.
Access:
There is no access to the WH Tunnel from the Military Rd/Falcon St on-ramps, Ernest St on-ramp or the Cammeray Miller St on-ramp. The Lower North Shore is the entry-point for the tunnel, but there is no direct access to the tunnel for residents in the Lower North Shore. We would need to travel to Brook St in Crows Nest or Berry St in North Sydney to access the WH Tunnel.
There is no access to the Cahill Expressway except via the Kirribilli on-ramp. I would like to see an access to the Cahill Expressway from one of the major on-ramps in the Lower North Shore: Military Rd/Falcon St on-ramps, Ernest St on-ramp or the Cammeray Miller St on-ramp.

Thank you for the opportunity to comment on the Environmental Impact Statement for the proposed Western Harbour Tunnel project. The comments we make below are those of residents who will be impacted by both the construction and operation of this project.

1. Is there a case for this project?

We urge the NSW Government to reconsider the need for building an outdated freeway project and instead convert the concept to that of public transport. This would better serve the needs of residents and business on the northern side of the harbour and accommodate expected future population growth. There are many roads in cities around the world that have induced demand and reached capacity relatively quickly, whereas public transport is better able to scale up to accommodate increasing demand.

This project as currently proposed is, we believe, at odds with the NSW Government’s commitment to reach net zero emissions by 2050 and to lead the way in decarbonising our economy – both measures we support. Public transport on the other hand serves the needs of current and future generations.

NSW seeks to portray itself as smart, innovative and a leader. Yet we are not aware of another city as advanced as Sydney that is still building major road infrastructure, which may be seen as an outdated solution to a 21st century challenge.

Given the enormous call on government spending as a result of COVID-19, (now and envisaged well into the future) it is incongruous that such a large sum could be allocated to this project. We also note that given the current massive disruption to the economy, changes to patterns of work and the material uncertainty as to what the longer term behavioural changes will be (e.g. will working at home become an established practice?), the current traffic forecasts can no longer reasonably be relied on to assist make the case for this project.

2. Construction Impacts

Potential property damage
As residents in close proximity to the indicative alignment in Waverton, we are very concerned about the impact of the tunnelling on our property. We have observed the very poor handling of another other tunnelling project and do not want to see the same lack of governance and seeming disregard of the impact on residents repeated on this project.

Specifically, we are concerned that the EIS will be approved with indicative alignment and depth for tunnelling, yet we understand we will:
• not be afforded the opportunity to see the final alignment and depth which will be determined by the contractor;
• not have an opportunity to comment or register an objection to it; or
• understand the implications before the contractor puts it in place (unless of course a mandatory acquisition of the sub-stratum occurs).
Instead, the preferred alignment and depths should be re-advertised with sufficient time for genuine public engagement.

We are also concerned that the area of interest with regard to properties close to the alignment is only 50 metres. We questioned the science of 50 metres at two of the public information sessions and as a result, understand it to be an arbitrary distance. We request that:
• any property owner within reasonable proximity of the alignment, not simply those in the arbitrary 50 metre zone, should also have free access to both a pre-construction and post construction dilapidation report; and
• the process to assess damage to properties should have independent governance arrangements, such that at no point does the contractor have either an actual or perceived conflict of interest.

Vehicle movements
It appears that the matter of construction vehicles and vehicle movement has not been adequately addressed. The North Sydney area comprises both major roads that are very busy during peak hours and small local streets that were never intended to take the increased traffic volume envisaged during construction. Parking is also constrained and, around many of the construction locations, limited to short-stay only. It seems likely that across these areas, there will be a net loss of parking spaces during construction. We request that these issues be addressed by either:
• all construction workers be provided car parking within their construction compound as a condition of consent; or
• transport to and from the local train station be provided to reduce the need for the workers to drive their personal vehicles to work.

3. Environmental Impacts

The environmental impacts of this project are considerable, both during construction and operation. At a time when emissions from transport must materially reduce, this project facilitates an induced demand for private vehicle travel and, as outlined in Appendix X, increased CO2 emissions. This is counter to the Government's emission reduction policy and makes it more difficult to achieve its target of net zero emissions by 2050.

The construction methodology is also emissions intensive, generating extensive diesel-sourced emissions. Construction involves a large amount of water consumption and will produce a significant volume of waste. The concrete used in the tunnels is one of the more CO2 intensive materials in the world.

We are also very disturbed to learn from the EIS that air quality in our neighbourhood will decline as a direct result of this project. NO2 and PM10 are forecast to rise in the area close to our home, which will likely increase the risk of poorer health outcome for local residents. We therefore request that the air quality impact be mitigated.

We urge the Government to reconsider this project in its entirety and develop a project that is suited to Sydney in the 21st century, rather than this one that belongs in the 20th century.

Bus lane attached to Alfred St North – “Falcon St Interchange Orbit”
It is unclear why this bus lane needs to be elevated and attached to Alfred St North. To achieve you propose the removal of 47 regularly utilised parking spaces from Ridge St pedestrian bridge to Merlin St while carving away the rock wall to widen the freeway. It is proposed that the raised bus lane will operate 24 hours/daily thus greatly increasing noise for the approximately 300 residents between Falcon and Rose Streets. In addition, residents will have constant illumination from the buses on the raised lane. Currently noise and illumination is greatly buffered by a solid rock cutting.

Should it be proposed that Alfred Street North is reopened to local traffic, the bus lights will affect them as the vehicle ascends the steep hill northwards, directly towards the lights of the southbound buses.

WE OBJECT STRONGLY to the loss of the 47 car spaces in Alfred St North from Ridge to Merlin Streets.

Removal of parking spaces in Alfred Street North
In your proposed plan, it appears 47 or more parking spaces between Wyagdon St and Ridge Street will be removed. At the North Sydney Council February meeting, when querying your representative about this huge loss, he replied: ‘in adjoining streets’. I would recommend you to check a UBD map….we have no adjoining streets.

It is estimated there are some 300 units and approx. 20 family homes in the precinct west of Bent St, (Alfred St North, Winter Ave, Rose Ave, Wyagdon and Merlin Streets). The buildings in our area are predominantly pre1990s built with one car space per unit and no visitor parking. Therefore, units with more than one bedroom, dual occupancy and for visitors to any of the buildings in this area, the loss of so many parking spaces is critical.

WE OBJECT UNRESERVEDLY to the loss of so many vital car spaces along Alfred St North.

Merlin Street Compound – WFU07
Not only is it planned for 47 parking spaces to be removed, but you plan to construct a compound on our small patch of residential green space, to be used for up to six years. It is noted that while no ‘heavy’ vehicles will use this compound, there will be approximately 150 vehicles entering/exiting this daily. Where will the workers using this compound park their vehicles? “In the adjoining streets” as your representative advised the February meeting at North Sydney Council. There are NO ADJOINING streets with parking available for your work force.

There appears to be no traffic management logistics in your EIS. Where Alfred St North becomes Merlin St, there is a tight right then a blind left bend, just where the WFU07 compound is to be located. There is already a steady flow of resident vehicles going to their ONLY exit to Falcon Street. Adding a further 150 vehicles will of course increase the congestion at this already short ‘green light’ onto Falcon Street. That will only serve to back up traffic down Alfred St North more than it is already.

Your morning traffic flow plan shows this as “B” for the current traffic conditions however it has a FAIL with Build WHT ‘only do something’. The afternoon traffic plan in your document shows all options as FAIL.

WE OBJECT STRONGLY TO YOUR PROPOSAL as it will affect the 300 residents using this access. It appears there has been no modelling has been undertaken for the impact on Falcon St/Military Rd.

In addition, it is likely there will be regular night works for the proposed elevated bus lane. Such close proximity, this will affect approximately 300 residents who live in Merlin and Wyagdon Streets and Rose Avenue. I OBJECT STRONGLY.

I was flabbergasted to note that there are NO PLANS or funding for RETURNING this compound and any other associated work depots, to the community. You take our green space and build a monstrosity and leave us with What?
THIS IS UNACCEPTIBLE and WE OBJECT STRONGLY and request that our green space be returned with the demolition of WFU07 compound.
Alfred St North closure for bus lane construction
Your statement indicates ‘temporary long-term closure’ of Alfred St North for construction, however there is no breakdown area/timeline. This will affect residents from Kurraba Road all the way north to Merlin St. And while different sections are likely to be affected at different times, there is no indication for those residents from Rose Avenue to Wyagdon St, as to how they will access their homes during this long drawn out construction.
WE STRONGLY OBJECT TO THE LACK OF INFORMATION TO RESIDENTS AFFECTED

Access to Wyagdon St from Warringah Freeway southbound
Your EIS (pg9-28) indicates that “access would be removed from the Alfred Street North southbound off ramp to Alfred Street North in the northbound direction. Traffic would be required to exit the Warringah Freeway at Falcon Street or continue on to High Street and travel via the local road network to access Alfred Street North”.

It appears your plan for Wyagdon St access when coming off the Warringah Freeway southbound and onto Falcon St eastward, will require using the short Tramway Lane and then cross Falcon Street, without traffic signals. Falcon Street has multiple westbound lanes and to access the far south lane in order to turn left into Merlin Street is already dangerous with a limited sight in a small vehicle of the westbound Falcon St traffic before crossing four lanes of traffic. We already have many accidents on this blind corner. Appears you’ll be adding more.

I would appreciate your providing the plan you envisage for ‘travel via the local road network to access Alfred Street North’. It is missing from the EIS. With the increase in traffic using these local roads, you are setting up a rat run situation in already narrow streets filled with parked vehicles. As the only access for Wyagdon and Rose Streets is via Falcon St, this adds further traffic congestion to an already constant Falcon St. Using Bent St and the super narrow Winter Avenue to access Alfred St North at the newly installed STOP sign and raised ramps, will cause major congestion in the narrow Winter St.

Your third alternative for Wyagdon St residents is via High Street. There is NO local road access so recommend you review your design.

It appears you are cutting off the Wyagdon/Merlin/Alfred Street North precinct at both ends – Alfred Street north hairpin AND Merlin/Falcon Streets AND adding in your own compound traffic to the already bustling local traffic causing even more congestion at the traffic lights for exiting the precinct.

WE STRONGLY OBJECT TO THE CLOSURE of the hairpin exit off the Warringah Freeway

Tunnel Exhaust stacks
The EIS indicates an exhaust stack will be located next to Cammeray Golf Course. There is great concern that this will be UNFILTERED. No matter which direction the wind blows, exhaust will invade the clean air of the area.

Residents living around the M5 fought for filtration so I’m greatly surprised that this EIS is not making amends for past errors early. PLEASE PLEASE PLEASE if you must take our green space, at least have the courtesy of allowing us clean air to breath. No everyone using those tunnels is in a position to buy an electric car immediately so it will take a lifetime for your claim that microscopic particles will diminish with that introduction.

This could be better managed by removing diesel trucks from the tunnels (and assist with congestion when the drivers don’t bother to adhere to height regulations). However I feel sure they’re just return to Military Road and cause more accidents and congestion than there is already.

Alternatively instead of building this tunnel, NSW Government could build a light rail – as was originally proposed – that would move people far quicker and cleaner than this proposed tunnel system.

WE STRONGLY OBJECT TO THE LACK OF FILTRATION IN THE PROPOSED STACKS

Intersection at Merlin and Falcon Streets
The video of your proposed plan indicates that residents of Wyagdon St, whose only exit is Alfred Street North/Merlin St (ie 22 multi storey buildings with approximately 300 units and around 20 houses from Bent to Falcon Street), can only make a left turn onto the Warringah Freeway southbound. There appears to be a concrete barrier preventing westbound travel down Falcon Street to Crows Nest/St Leonards. Access to the lane to travel north on the Warringah Freeway also appears blocked. Further your video prevents travel eastbound from the Merlin/Falcon Street exit due to a concrete barrier. How do Wyagdon St residents to Crows Nest, Cammeray, Cremorne or any other destination than south on the expressway?

Residents travelling south on the Expressway is now forced to exit onto an already congested Falcon St, crossing four busy lanes of traffic at a blind corner in order to ‘slip over’ to the southern lane to turn left into Merlin St. No traffic lights to aid that merge and greater potential for accidents.

It is alarming to note that the RMS traffic tables in the EIS indicates current operations as ‘reasonable/satisfactory’ in morning/afternoon operations. However once the proposed works have been implemented, the Merlin/Falcon St intersection rates a FOUR FAILS for residents returning home. They have no other access to their homes.

From the EIS, it appears the residents living in the Alfred St North/Rose Avenue, Wyagdon and Merlin Streets precinct have been put in the ‘too hard basket’ while those local narrow streets east of High Street will become an accident waiting to happen with the much increased additional traffic.
If there were ever a major incident, fire/gas explosion/medical emergency, the changes planned both for access and exit would render the situation even more dangerous. During peak hour now there is often traffic jammed all the way up Alfred Street North when there is an incident on the freeway going north or often just with heavy traffic on the freeway.

WE OBJECT STRONGLY to your proposed routing for Wyagdon St residents

In my previous submission I commented on the article in the Sydney Morning Herald regarding the underestimation of demand for public transport in the models which would have been used in the EIS. The link to that article is https://www.smh.com.au/national/nsw/public-transport-growth-surges-past-nsw-government-predictions-20200218-p54208.html

I also commented that the proposed B2 bus service between the Northern beaches and Chatswood, along Warringah Road, would be likely to reduce traffic growth on the Sydney Harbour Bridge. In support of this assertion I point to the projected traffic increases referred to in the Beaches Link Project Udate document dated August 2018, in particular the reference to 'currently 69,000 vehicles a day cross the Spit Bridge, forecast to carry 80,000 vehicles by 2037' which is contradicted by RMS data 'Average daily traffic - all days' which shows no increase in traffic. I have attached the relevant graphs.

This apparent contradiction can, however, be explained by planned population growth within the Northern Beaches LGA, principally around Frenchs Forest.
But the traffic growth generated by this could be alleviated by public transport along the Warringah Road connecting to the new Metro station at Chatswood. Such transport could be another B-line service (B2), a trackless tram, a metro extension from Chatswood to Frenchs Forest (or further).
Any of these measures would alleviate traffic travelling from the Northern Beaches LGA to the Sydney CBD and would consequently reduce the traffic which would be crossing the Sydney Harbour Bridge. None of these measures have been considered as part of the consideration of alternatives to the project, despite there being a commitment at least to the B2.

Census data in relation to Journey to Work (JTW) bears out the importance of considering such alternatives. 2016 Census data shows that, of workers resident in the Northern Beaches LGA, 51.2% work within that LGA, 18.6% travel to work in the City of Sydney LGA, 5.2% travel to work in the North Sydney LGA, 4.6% travel to work in the City of Willoughby LGA, 4.4% have no fixed work location, and 2.8% travel to work in the City of Ryde LGA - https://profile.id.com.au/northern-beaches/residents

Further, existing (B1), under-construction (Chatswood to Sydenham Metro), and proposed (Sydney West Metro & B2) projects have a synergistic effect which the EIS has ignored in its consideration of alternatives, and their implications for future traffic volumes.
Finally a GIPA decision in relation to the B-line which I have de-identified except for the file reference, to protect the personal details of the applicant, is also attached. It shows, at 3.4 and 3.5, that further work is underway to improve the operation of the B-line and is due for completion in 2020; and, at 3.6, that analysis of the data which would allow comparison of journey times or the congestion impact of the B-line, has not been completed. This GIPA decision is available to the proponent, to whom the request was directed.

This lack of analysis in relation to the data in relation to the only completed public transport project which may impact on congestion across the Sydney Harbour Bridge further demonstrates the incomplete nature of the analysis of alternatives and checking of the modelling of the demand for public transport.

In combination these factors and the matters raised in my earlier submission, demonstrate the need for the EIS to be re-done in relation to those parts dealing with alternative transport solutions and re-exhibited for public comment.

I have been unable to attach the traffic volume graphs referred to above as I have, so far, been unable to get them into a format which your portal accepts. I will try again later.

I object to this project on so many levels.
1. That the due date despite the COVID19 pandemic has not been amended so that schools and other community groups can have the time needed to properly study the 9000 page document.
2. I object to the environmental threats due to the project - unfiltered tunnel exhaust stacks in the area in Australia with the highest concentration of school children, dredging the harbour rather than digging under it, knocking down bush and taking green space for years and years ruining precious areas that are so important in city areas , digging up toxic sites surrounded by houses, the noise issues that will effect residents, workers and school children, the massive impacts to traffic including the huge number of trucks on the streets and the permanent changes to roads that will result in cars rat-running in local streets, the destruction of water supplies and dams which is criminal in a time of drought.
3. I object that jobs are already being advertised when the project has not been approved and community consultation has not been completed.
4. I object that Gladys Berejiklian is ignoring her constituents and taking no notice of community feedback in terms of a large petition tabled.
5. I object that there is no business case provided which it should be by law.
6. I object that there is no alternative proposal shown and that there has been no thought about mass transport which is the only way traffic problems will be solved in the end.
7. I object that this is a short sighted project and that the massive impacts on many communities will offer them no benefit, only stress and health impacts and the cost of tolls and access to the road will be prohibitive for many.
This is a terrible project and I am so upset that this government who I previously trusted do not listen to independent experts and seem to barrel ahead to line Transurban's pockets with no thought of communities and their wellbeing or the environment. This is like an episode of Utopia - you seem to just be ticking a box that you've consulted but are not really listening and are providing difficult to read documents that are incomplete at a time of incredible stress and distress for people.

Submission to the Environment Impact Statement (EIS) for
Western Harbour Tunnel & Warringah Freeway Upgrade
by Robert Scott
Email: [email protected] 0418478848
I am not directly impacted by the proposed Western Harbour Tunnel & Warringah Freeway Upgrade.
However, I am directly impacted by the proposed Beaches Link Tunnel – which is linked to the
proposed Western Harbour Tunnel & the Upgrade of the Warringah Freeway. I strongly object to the
EIS for the Western Harbour Tunnel & the Warringah Freeway Upgrade for the following reasons:
1. There is no provision for public transport on the proposed Beaches Link Tunnel to connect with
the Metro Train Network.
2. The project provides for entry and exit for the Beaches Link Tunnel – a project which has very
poor economics, has low strategic priority and therefore does not merit funding.

Please allow me to object more fully at a later time.

Many thanks

Rob Scott

Under the current terms of this project I object to it going forward. Aside from the noise and ongoing pollution from unfiltered chimneys we live in a sensitive heritage home under which the proposed tunnel will pass. It will be damaged if this project goes ahead and based on past experience the government nor contractor will take responsibly or provide compensation. Please see attachment for full submission.