I have attached a submission objecting to the comments in the EIS for the above project.

Please find submission attached

I object to the project until further investigations have taken place, as detailed in my submission.

My concern is about the impact the proposed tunnel and its construction might have on the World Heritage Area and is determined to ensure this is minimised, and that matters of national environmental significance are addressed.

I am concerned that the current piecemeal approach, dividing the upgrade into sections for review, is totally inadequate as it won’t provide a true understanding of the cumulative impact and long-term consequences for the World Heritage Area.
Aquifers supplying groundwater to groundwater-dependent ecosystems, and their dependent species, along both sides of the tunnel corridor, are at significant risk as changes to water flow is expected. A reduction in groundwater to the Commonwealth-listed Peat Swamps, particularly those near Blackheath, poses a real threat to their populations of Giant Dragonfly and Blue Mountains Water Skink, which are both endangered.
Despite this EIS being released, I want the Federal Government for a full EIS across the entire Great Western Highway project upgrade to ensure that matters of national environmental significance are addressed

The EIS is flawed as it does not include the environmental impacts that an upgrade will cause further along the GWH when further road widening and straightening is undertaken. And when hundreds of mature eucalypts are removed which will destabilise embankments next to the railway line.
And if the Blackheath bottleneck is removed, it will simply move that bottleneck to Katoomba and its busy 4 sets of traffic lights, at which point there are several back streets that the traffic will use that will cause environmental damage to these quiet back streets and adjoining bush. Not to mention accidents due to speeding motorists especially those who don't know the area and/or are challenged by the frequent foggy days.
The EIS also does not adequately address the polluted water (oils and concrete and spills and stormwater) that will flow into the upper Blue Mountains water catchment, the environmentally sensitive swamps and the world heritage national park.

Portal emissions or ventilation stack

Meeting the air quality goals

The EIS presents strong justification for portal emissions - in particular the significant reduction in energy costs. However the ongoing concern with portal emissions is how to monitor emissions (limits) at the portal. With ventilation stacks, emissions can be monitored for compliance to predetermined emission limits which in turn gives confidence in meeting ambient air quality levels near the closest receptors. However for portal emissions it is not clear whether measuring emissions from portals is practically possible. In this regard, for nearby receptors there is sole reliance on the air quality modelling that ambient air quality goals can be met. In addition, without setting emission limits at the point of emission from the tunnel (the portals) it does not address optimising the performance of the tunnel ventilation system - that is the operator can operate the tunnel in a suboptimal way (in terms of ventilation) result in “polluting up” to the ambient goals for the nearest receptors. By polluting up - meaning a potential significant change in air quality for closest receptors but still technically meeting the ambient goals. The community needs to be assured how monitoring of stack emissions will not only meet ambient goals but also optimise air quality outcomes for the community.

Design of the ventilation stack

Noting that ground level (portal) emissions are able to meet ambient air quality goal it is unclear why the ventilation stack needs to be 10 metres in height.

The current design of the ventilation stack could be improved. Whilst it is accepted this is a subjective issue - a more slender /less imposing design would have less visual impact. In addition it is assumed that far more dense screening could be provided such that with reduced height and dense screening it may not even be visible from public viewing locations

An alternative (and assuming a lower height can be achieved) could be to integrate the ventilation stack into the Motorway Control Centre.

The RtS should present the ventilation stack with more sensitve urban design outcomes (rather than presumably worse case) and could include denser screening options.

Motorway Control Centre

It is unclear why such a large area is required in comparison to all other motorway control centres currently operating in Sydney. In particular the extent of parking appears excessive. A major reduction in the size of the MCC would have considerable benefits in reducing impacts. Integration of the ventilation stack would also reduce the overall footprint of this site.

TBM operation

The decision to run both TBMs from the Little Hartley with all spoil removed to the west is commended and would be a fundamental aspect to the acceptability of the project. Accordingly, this should be locked in by way of an explicit condition of approval. Furthermore, DPE should consider whether this requirement could be conditioned by the Minister such that any change would result in a new Environmental Impact Statement rather than through a potential modification process.

I live in Faulconbridge and travel to Lithgow and further west from time to time along with traveling to Jenolan Caves with visitors to the Blue Mountains. I am looking forward to highway improvements that increase safety, improve the quality of journey, reduce speed zones and improve the environment for the local residents in the Blue Mountains.
I am in favour of a tunnel from Blackheath to Little Hartley. I would prefer a tunnel from Katoomba to Little Hartley, however, I have been informed that the proposed upgrading of the highway from Katoomba will only have one set of traffic lights at Medlow Bath and the rest of the highway will be realigned and built to a very high standard. Never the Less, I have concerns regarding the long term impact of the highway through Medlow Bath, both from a traffic and a locals point of view.
When building this tunnel and in fact all tunnels in NSW, provision should be made for running high voltage power distribution cables (330Kv). One of the major costs in under-grounding power is the cost of digging the trenches, by planning to use road tunnels would considerably reduce costs and have the additional advantages of reducing environmental impacts such as bush fires, aircraft accidents, and visual impacts, especially in national parks. Please consider this option for this tunnel and any future tunnels along with including provisions for telecommunications (fibre) cables.

Best regards,
Michael Parker