I lodge the strongest possible objection to the central section EIS now published as it fails entirely to be a correct assessment of the impact this construction will have on the Hartley Valley and its community, on Indigenous, Environmental and Colonial heritage.
The EIS is wholly deficient. The concept design on which it is based is self described as preliminary and therefore is subject to substantive change.
The EIS therefore cannot correctly assess the impact.
The construction phase is acknowledged to stretch over at least 10 years with an enormous scale of disruption and environmental impact for this closely settled rural residential community which has had a wholly inadequate REF (which is a self assessment by the proponents of the project).
The scale of this construction has not been adequately assessed in the REF and similarly, in the EIS for the Central Section. It is a gross understatement which must be reviewed before any further stage commences and before any approval is given.
The EIS fails to include the capital and operating cost. Any Benefit Cost Ratio is not adequately addressed in this EIS and is absent as it relates to the Hartley Valley.
The EIS states the adversity on the Hartley Valley as low. This is untrue and grossly negligent. The EIS as it exists must not be approved.
The scrutiny is inadequate and the Hartley Valley must have better than this.
I support the Hartley District Association (HDPA) submission in its opposition to this Central Section EIS and indeed to the REF for west section of this project.
This EIS has failed the Hartley Valley and I ask that it not be approved.

Please see attached Submission and accompanying cover page.

Although supportive of the tunnel, there are deficiencies in the EIS that should first be addressed:
• Risk of damage to sandstone cliffs: Potential impacts to natural cliff faces west of Mt Victoria, have not been considered in the EIS. Impacts include potential for rockfall and cliff failure, risking Public Safety, environmental damage and damage to the many established rock-climbs. The tunnel alignment west of Mt Victoria appears to be through Illawarra coal measures, directly beneath more than a kilometre of overlying cliff lines. Although TBMs are planned as the primary tunnelling tools, there will also be drill and blast / road-header excavation that needs consideration with respect to risk to cliff-lines.
• Insufficient consideration of the consequences of tunneling through the Illawarra coal measures: Most of the tunnel, west of Mt Victoria will be excavated within the Illawarra coal measures. Although mention is made of coal seam gas (drainage, depressurising and dewatering), there is no specific mention of disposal of the coal (carbonaceous material) excavated while tunnelling. Tunnelling with a TBM is inherently non-selective and is likely to produce thousands of tonnes of co-mixed coal-shale-sandstone material with limited options for re-use, requiring specialised emplacement.

SSI-22004371
In principle I support the project as it gets trucks off the highway and will ultimately lead to a better local environment. However I’m concerned about the visual and environmental impact on the water catchment area and world heritage listed National Park.
If there are to be huge 10m concrete stacks for ventilation they could be made aesthetically pleasing - for example concrete plant receptacles could be built with the concrete stack, as it is built, to hold hanging natives such as grevilleas and banksias. They’d then be green without paint.
Also, emergency exits will be required at regular spacing

Tunnel must be lined to protect Upper Blue Mountains hanging swamps, creeks etc.
I would like to see at least two emergency exits along the route. It would be sensible to place these emergency passages/staircases at relatively shallow points. I make this point as a retired mining engineer.

On August 5 2021, onthe Zoom Feedback community sessions, both Pete Styles and Alistair Lunn of TfNSW categorically denied that the highway was for the purpose of 30m trucks. The subsequent announcement says they are now 36m trucks.
Both them, and the representatives in this process aligned to the GWH are deceitful and dishonest. Their process in this "project" has been a failure of transparency, and representative of bureaucratic bullying - threats of acquisition, and double deals with both the Medlow Bath petrol station and the Hydro.
They need to be held accountable. This process has been corrupt and must be referred to the ICAC.
At no point, at no time, has their been due consideration with the residents.
At no point, at no time, has their been due consideration to by pass Medlow.
Instead, this work will block access to houses and residents in the NW corner of Medlow. In a bushfire, we will be trapped. In snow we will be isolated. In high traffic we will be unable to leave or enter with proper access to our properties .

Even the noise management recordings were fraudulent. Only ONE microphone was suitable for noise management recording. It recorded levels equivelent to a jet plane taking off. The other microphones were hidden behind garages and fences behind the shadows of hills. It's all in the REF documents - if you choose to read all thousands of pages.

Trucks
• The introduction of 26/30/36m trucks affects the whole of the Great Western Highway ‘Freight Corridor’ in what is currently the only local road for many villages. TfNSW states that the GWH Duplication is about giving local roads back to locals. This is clearly not happening. A 36m truck is 2.5 times longer than a 40 seater bus, and these trucks when loaded can weigh between 84-91 tonnes). Many Blue Mountains Villages will have these trucks driving right through the centre.
• There has been no consultation with any of the Blue Mountains residents about the introduction of these 36m trucks. Only 26m and 30m trucks have been mentioned in the REF’s to date. This is an example of TfNSW misleading the public as the REF Submission Reports were released less than 5 months ago.

EPBC (Environment, Protection, Biodiversity and Conservation) Act
The Project requires approval by the Federal Gov under the EPBC Act if it is likely to have Significant Impact on matters of National Environmental Significance, including World Heritage. In which case it becomes a ‘controlled action’ under the Federal Gov legislation and requires the proponent to provide further information and do further assessment.

o In the Summary of the EIS it states: At the time of finalisation of this EIS there has been no decision by DCCEEW on whether the project is a controlled action or not. If the project is not determined a controlled action, Transport is not required to provide a separate assessment of the project under a Commonwealth approval pathway. If the project is determined a controlled action, Transport will need to prepare a draft environmental assessment under the EPBC Act to assess the project under additional requirements as required.

o In Chapter 1, 1.5 it states: An assessment of the project’s potential impacts on Commonwealth matters of national environmental significance (MNES) (as discussed in Chapters 12 (Biodiversity) and 17 (Non-Aboriginal heritage)) has found that the project’s impacts on MNES would not be significant. Notwithstanding, Transport has referred the project to the Department of Climate Change, Energy, the Environment and Water (DCCEEW) under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) to confirm that approval under that Act would not be required. At the time of finalisation of this EIS there has been no decision by DCCEEW on whether the project is a controlled action or not.

• Why was this EIS issued before a decision was made?

• In an area where the construction of this tunnel potentially impacts drinking water catchment, safety and World Heritage status, why was the approval of DCCEEW not received before the release of the EIS?

All project EIS
Because so many of the following issues relate to areas beyond this EIS, a single study (Full Project EIS) of the whole GWH Duplication Project is needed to ensure that the interconnected and wider environment is fully considered and addressed. Issues that deserve further consideration include:

• The effect of the planned increase in the size of trucks passing through all villages across the Blue Mountains;
• The negative impacts on the natural environment of the World Heritage Area (downstream beyond the narrow (1500mm) corridor covered by the EIS);
• The predicted reduction of inflow into the drinking water catchments and into the World Heritage Area;
• The predicted change in pH of the water flowing into the catchment and World Heritage area;
• The increased risk of disturbance to shallow aquifers near Evans Lookout Road feeding the endangered peat swamp vegetation communities;
• The negative effects on the iconic downstream tourist attractions (eg the Grand Canyon);
• The negative effects on Threatened and Endangered Species;
• The negative effect of the ongoing construction on local heritage attractions and tourist industry;
• The uncertainty of the effects upon air quality in the villages and National Park;
• The lack of information on measures to ensure the safety of tunnel workers;
• The lack of information on how dangerous goods will be transported through the Upper Blue Mountains;
• The lack of decision as to whether the project is a ‘Controlled Project’;
• The ‘less than best’ plan requiring very significant Federal Investment.

The media has also reported on some concerns raised:

1. ABC reported on the projected being a political pork barrelling exercise at the expense of the environment. great-western-highway-nsw-government-funding-concerns

2. Blue Mountains Gazette reported on the size of ventilation stacks at Evans Rd which were stealthily omitted in community presentations during the Medlow Bath to Blackheath REF, yet Evans Road Lookout section was approved under the Medlow to Blackheath REF, not the tunnel EIS. By doing this TfNSW has avoided the scrutiny of an EIS of this section. bluemountainsgazette_ventilation-stacks-three-storeys-high

Finally, TfNSW has revised the road truck capacity from 30M to 36M further jeopardising the safety of local road users. In light of the GWH and BLOR major truck accidents last week, on the same day, this is very relevant.

An EIS raises more questions than answers further proving that the project requires a full project EIS (Katoomba to Lithgow) – not a series of piecemeal REF’s and EIS.