The Yurulbin Park in Birchrgrove is a historically, aesthetically and socially significant Harbourside park and needs to be protected. Also our dogs swim in the harbour and we believe that this project will make the water toxic for all the dogs in Balmain. The Suburb is being hammered on all sides from government projects destroying the local environment. Including the westconnex at Lilyfield taken away the cycle path bridge joining us to Glebe (no replacement) the fracking under our houses at Rozelle, the rubbish dumping from westconnex in Victoria rd near the iron cove bridge. Don’t destroy another vital part of the community and the reason why so many people have moved to this community - because of its parks and pet friendly life style.

I object to this project as it stands as a train line should be considered for commuter traffic rather than allowing additional cars on the roads. In addition the increased noise post construction will be extremely detrimental. I urge for this proposal to be re-considered and for noise and pollution to be not just considered but actively addressed with no shortcuts.

I object to the project on 3 main grounds:
1. The EIS process should be suspended as NSW is in a state of emergency as a result of the Covid 19 pandemic. This project will cost many billions of dollars and further public money should not be spent on any part of the process until it is possible to have more certainty about NSW's social, economic and health situation. Moreover, it is very probable that many individuals and businesses who intended to put in a submission in March have been unable to or have forgotten to do so because of the effects of the pandemic and therefore the process will not have the benefit of their submissions. The impact of the construction of this tunnel will exacerbate the living conditions for residents of the North Sydney and Willoughby LGAs. They will lose access to green spaces. They will be affected by co) nstruction noise and pollution.
Recent studies have linked small particles in air pollution to serious health impacts for people with chronic disease (eg https://journal.chestnet.org/article/S0012-3692(18)32723-5/fulltext). Until the Covid-19 disease and its effects on humans are fully studied and known there should be no new projects which could increase air pollution or locate air pollution near residential areas, because of the risk posed to people affected by the virus. Dr Chant's letter of 8/11/19 does not consider this.
The EIS relies on a reduction in surface traffic as a result of the tunnel. But studies have shown that traffic increases when new motorways open, so a reduction in overall traffic is highly improbable, particularly given Sydney's growing population.
2 Noise and Traffic - there are multiple noise catchments for this project. The extent to which this project will impact upon the amenity of people living around the Harbour is unprecedented. I live in Ridge Street North Sydney, where a construction site is located. I note that Chapter 6 of the EIS states that "The Ridge Street north construction support site is expected to be used for the duration of construction." This is an area with 4 schools in the immediate vicinity. Ridge St is a narrow street and cannot easily handle large traffic. On completion, Berry street will become a 4 lane feeder for the Freeway, which means that more traffic will clog adjacent streets seeking to enter. The plan appears to ignore the many people who live in North Sydney whose enjoyment of their premises will be adversely affected by traffic and noise. This will discourage pedestrians, cyclists and also affect the kinds of shops and cafes that are open there.
3. Environment - the project is contrary to the stated goal for NSW of no net emissions by 2050. Also there are a large number of contaminated sites which will be disturbed by construction , not just under the harbour but also in the sites which must be demolished and rebuilt such as material from the construction of the Warringah Freeway and particulate matter from cars using the freeway. It is clear from the EIS that the quantity, nature and possible effects of disturbing this material is unknown. It is also stated that the sediments in Sydney Harbour would potentially pose a high contamination risk due to the contamination associated with historical industrial use of the harbour and the addition of polluted stormwater runoff originating from adjacent catchments.
The following threatened species either occur within the construction area or are highly likely to:
• Eastern Bentwing-Bat (Miniopterus schreibersii oceanensis)
• Grey-headed Flying-fox (Pteropus poliocephalus)
• White-bellied Sea Eagle (Haliaeetus leucogaster) f
• Eastern Freetail-bat (Mormopterus norfolkensis)
• Little Bentwing-Bat (Miniopterus australis)
• Southern Myotis (Myotis macropus)
• Powerful Owl (Ninox strenua).
The well known population of Little Penguins in the Manly Point Area also are known to occur in the construction area. The EIS says they could be susceptible to collisions with watercraft or barges carrying out construction and basically suggests that they will just have to dodge water vessels!
That is not to mention the large numbers of threatened, vulnerable or highly endangered marine fauna which will be in the direct line of the tunnel construction, such as the Grey Nurse Shark, Leatherback and Loggerhead turtles. The EIS does not appear to consider the impact of contaminants which it says will be stirred up by the dredging on the waterbirds and marine fauna, not to mention species like the sea eagle which eat fish. The risks to our endangered fauna are extremely high and the mitigation is unsatisfactory.

refer to my Submission attached below

SUBMISSION:
I make the following OBJECTION to the project of the WHT & Warringah Freeway, having attended a Public Consultation at Hutley Hall, (but unable to attend the last one- due to Covid19) and reviewed some of the documentation, but certainly not all 9000 pages of the EIS. My grounds for OBJECTION are:

1. Cost/benefit analysis and Business Case for WHT failed to be done;
2. NO alternative sustainable transport options have been considered;
3. Northern Beaches Tunnel (NBT) was offered, at NorthShore By-election and this EIS does not consider NBT at all;
4. Pollution be increased due to unfiltered tunnels and vent stacks - this is unacceptable for the health of all residents in the area;
5. Loss and lack of Green Open Space is not acceptable in a growing city;
6. Impact on Traffic on all our local streets – especially High Street is not acceptable.

All these factors will impact on the health and well being of all the residents of North Sydney, only for the benefit of a shorter travel time in cars for others. This is totally unacceptable, especially as this EIS has failed to give a Business Case with Cost Benefit analysis nor to look at alternative non-motorway solutions for a growing city.

I agree fully with NSC Submissions and report of 23.3.2020, outlining their objections. Please read and consider this submission:

 The project should be halted at this point in time, given the COVID19 pandemic

 The submission time should be extended due to pandemic

 EIS used outdate data as basis of analysis, on population projections, as well as not including the Metro West project

 EIS not complete a Business Case as per 2018 requirement for Infrastructure NSW & Australia

 EIS has not done a Cost Benefit Analysis to show the social, economic or environmental benefits with substantial costs to the NSW taxpayers, in the order or $20B only to benefit drivers of cars.

 This is not an acceptable spend for the benefit of a small portion of the community.

 EIS fails to analyse any alternate sustainable transport options which would be a better use of this amount of capital for a growing Sydney population.

 Beaches Link and the cumulative impact of those tunnels, pollution etc. should be considered at the same time, and this EIS failed to address this BLT.

 It is unacceptable that these tunnels are being built without pollution mitigation, which will impact the health and well being of all residents and tunnel users. Currently, as you enter any Sydney tunnel – they advise you to close your windows, and use air conditioning on recycle air, vs taking air in from the outside. So if this is the current case with tunnels of shorter distances, why plan to build longer tunnels without mitigating the pollution. It is cheaper to build now, that try to retro fit at a later time. So CHANGE it to minimum European standards for tunnel and pollution emission.

 At the very least you should CONDITION in the planning that the ventilation stack and tunnels should be built to be able to be later fitted with pollution controlling mechanisms. So as to protect the health of the community of North Sydney and Sydney as a whole.

 If these projects are built without pollution controls, then it is likely to cause many to think about a class action against the government of NSW, building infrastructure that would impact on the long term health of the community, by knowingly poisoning us with heavy metal pollutants.

 The Cammeray Golf Course structures should be CONDITIONED to be underground so that open space is not lost.

 Also there should be a CONDITION that open space links over the top of the Warringah Freeway be provided to link both sides of the community of NS.

 Unacceptable to loose Green Open Space in St. Leonards’ Park along the Warringah freeway site, as well as the Morten Bay Fig trees.

 Increased traffic along High Street North Sydney will be to an unacceptable level, with 50% of the B-Line buses NOT continuing on into the City but are to disgorge their passengers at North Sydney train station or the new Victoria Cross Metro station. It should be CONDITIONED that a separate Busses tunnel be built to provide an ‘at grade’ access to disgorge their occupants, at NS Station and Metro stops.

 This EIS has failed to consider the NS Council’s plans that have been discussed for the past 4-5 years, to pedestrianise Miller St between the Pacific Highway and Berry St., nor the Ward St Precinct Redevelopment along Berry St.

 The proposed Berry Street four (4) lanes traffic will impact the NS CBD and liveability of the properties north of Berry St. This proposal for Berry St. will cut the LGA in North-South direction, as the Warringah Freeway did in a East-West direction 60 years ago! This is not acceptable in this day and age … Condition that these access road must be placed underground.

 High Street - with the only entry heading north onto the Warringah Freeway being from High Street, it will place additional impact on this road network and intersections, with traffic banking up in Kirribilli and along Clark Road.

 These additional delays along the streets of our LGA will cause additional and unacceptable pollution adjacent to James Milson Village, (Clark Rd & High St) a care facility for aged persons, currently housing about 250 people.

 EIS has failed to adequately address any alternative sustainable transport options to be built in place of these motorways. This is unacceptable.

 ALSO With ANY Redevelopment or Upgrade of the Warringah Freeway, WHT and / or Beaches Link, it should be CONDITIONED that the proposed ‘HarbourLink’ project should be built at the same time, to allow a 3% gradient from Cammeray down to the Sydney Harbour Bridge, as a 5 - 6 metre wide shared elevated pathway for pedestrians and cyclists.

This would go someway to a sustainable transport option for those living closer or for those cycling from further afield.

Thanking you for your consideration of my submission.
Await your response.

Regards,

Jillian Christie

I believe there are a number of deficiencies in the EIS that need to be addressed regarding traffic modelling.
And I provide a range of other comments.

91 Eddy Road,
Chatswood 2067
28.3.2020

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

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

I write to express my objection to the Western Harbour Tunnel and Warringah Freeway Upgrade. I have done my best to read the extensive EIS documents at this very difficult time. 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.
My objections include the following points:
1. This project being placed on exhibition during the COVID-19 Crisis. This project impacts the largest precinct of schools in Australia and passes through highly residential areas. Families, community groups and schools have been under a huge amount of strain throughout the exhibition stage. Meetings have had to be cancelled and we have been social distancing as instructed. Trying to read these documents has created more community anxiety. The project should be re-exhibited well after the COVID-19 crisis has passed and when normal life returns.
2. The project should not proceed because of the financial implications. Lack of government investment in essential public services was clearly demonstrated to the public during the national bushfires 2019-2020 when fire, RFS and emergency services could not cope with the fires largely due to inadequate investment by governments. The lack of investment in funding, maintenance and management of national parks was a contributing factor to the fires. Currently the inadequate funding of NSW public hospitals has resulted in lack of protective equipment, inadequately equipped intensive care units and under-staffing. The NSW government must abandon this wasteful harbour tunnel proposal and properly invest in the public sector, for effective public services, emergency services, hospitals and community services in the public interest, to benefit the wider community
3. When the world needs to decarbonise, we should not continue to support other carbon based energy sources with clear and immediate impacts on this case water and biodiversity.
4. Poor climate and sustainability outcomes and the negative impact on our precious waterways and green spaces. The Concept of Citizens Right to Health inherent in the Paris Climate Agreement to which Australia is signatory should be explored in the context of the proposed road tunnel, which will create air, water, land pollution through excavation, and more pollution from facilitation of more traffic on roads. This is contrary to the health and well-being of citizens and the environment.
5. Protecting Sydney Harbour’s water quality needs to be a top priority. Toxic sediments derived from past industrial activities and storm water overflows, have built up on bottom of the harbour. A range of chemicals can be found in these sediments including dioxins, heavy metals and pre- and poly-fluoroalkyl (PFAS) chemicals. These sediments, if mobilised into the water column, can severely degrade the harbour’s water quality and pose significant risks to public health and marine biodiversity up and downstream of the construction activities.
6. Previous testing by the NSW government revealed elevated levels of dioxins in fish and crustaceans across Sydney Harbour and consequently imposed a ban on all commercial fishing. Restrictions on recreational fishing are in place with clear advice that no fish or crustaceans caught west of the harbour bridge should be ingested because of the contamination and risks to health. Toxic sediments can effect those swimming in the harbour or ocean pools fed by Sydney harbour waters. Dioxins are known carcinogens which can cause birth defects while PFAS can cause reproductive and immunological effects in laboratory animals. Minimising toxic sediments on the bed of Sydney Harbour being released into the water column is therefore critical. The removal of approximately 140,000 cubic metres of toxic sediments during planned construction is risky. It would require stringent management, monitoring reporting and fines for breaches. No reduction of water quality and full community use of the harbour must be paramount principles.
7. In the public interest I believe the following recommendations should be adopted if the controversial tunnel proceeds: a) Public release of exact concentrations of chemicals in the sediments. It is understood these are ‘commercial in confidence’ at present, but, in public interest , transparency is needed to ensure that the severity of the risk to the public can be scrutinised by a range of stakeholders, not just the state government. b) Councils on the harbour must be immediately alerted when water quality is effected to enable councils to immediately alert their communities about the public health risks of swimming, and to implement immediate controls for maintenance of ocean and harbour pools and beaches. These costs should be born by the government. c) Provide water quality data for use in the Greater Sydney Harbour Coastal Management Program (CMP).
8. Minimise effect on Marine Biodiversity: Mobilising toxic sediments will likely have detrimental effect on water quality and consequently marine biodiversity living in and around the harbour. Mobilised toxic sediments could affect availability and suitability of food sources for threatened biota including the Little Penguin and White bellied sea eagle. Other marine species including Black Rockcod, New Zealand Fur Seal and Whites Seahorse may be adversely effected by the proposed project.
9. Poor Traffic and Congestion outcomes. The proposed tunnel will empty thousands of extra motor vehicles into Naremburn and the lower north shore generally.
10. Air quality and Health:
Clean air is considered to be a basic requirement of human health and well-being. However, air pollution continues to pose a significant threat to health worldwide. The World Health Organisation (WHO) assessed the burden of disease due to air pollution, that more than 2 million premature deaths each year can be attributed to the effects of urban air pollution(WHO 2005).

Increasing population density and car dependency has resulted in poor air quality. Lead free petrol & improved emissions standards have resulted in reduction airborne lead and emissions, but the number of cars, kilometres travelled, and traffic congestion have increased.
Air pollution is exacerbated by heatwave conditions. During the Melbourne heatwaves 4+ years ago, emergency services were called out every 12 minutes hence Emergency Departments and ambulance services were stretched to capacity.
Clean air is a common good: In Paris (May 2019) a court ruled in favour of mother & daughter who claimed deterioration in health due to air pollution that “The state (France) committed fault by taking insufficient measures concerning air quality’. The case, backed by an NGO was the first brought by individuals against the state over health problems due to air pollution, that ‘during 2012 & 2016 the ‘state failed to take sufficient action to curb air pollution in Paris.

Evidence on airborne particulate matter (PM) and public health impact is consistent showing adverse health effects at exposures currently experienced by urban populations in both developed and developing countries. The range of health effects is broad, predominantly respiratory and cardiovascular systems. All populations are affected, but susceptibility to pollution may vary with health or age, particularly young children and the elderly.
Risk for various outcomes increases with exposure, with little evidence to suggest a threshold below which no adverse health effects would be anticipated. The low end of the range of concentrations at which adverse health effects has been demonstrated is not greatly above the background concentration, which for particles smaller than 2.5 μm (PM2.5) has been estimated to be 3–5 μg/m3 in both USA and western Europe (WHO 2005).

Nitrogen Dioxide (NO2): air pollutant: Animal and human experimental studies indicate NO2 at short-term concentrations exceeding 200 μg/m3 is a toxic gas with significant health effects. Epidemiological studies have shown bronchitic symptoms of asthmatic children increase in association with annual NO2 concentration, & that reduced lung function growth in children is linked to elevated NO2 concentrations within communities already at current North American and European Urban ambient air levels. Recently published studies demonstrated that NO2 can have higher spatial variation than other traffic-related air pollutants, for example, particle mass. These studies also found adverse effects on the health of children living in metropolitan areas characterized by higher levels of NO2 even where the overall city-wide NO2 level was fairly low.

Recent evidence of poor air quality in St Peters includes higher levels of fine particulate matter PM 2.5 than other parts of Sydney, apart from other WestConnex sites in Haberfield. PM 2.5 is known to be dangerous to health, especially that of small children, pregnant women, older people and those with heart and lung conditions. When WestConnex opens there will be unfiltered exhaust stacks within a few hundred metres of schools, and preschools. Over three months, all eight new M5 monitors are currently showing an average above 8 micrograms per cubic metre or 8 µg/m3, which is the national annual average limit. The three St Peters monitors are showing an average of above 10 µg/m3. Medical research has found there is no safe level of PM 2.5. Health risks
increase as levels rise. PM 2.5 has been linked to cancer and heart and lung disease.

The NSW government should