Great Western Highway Blackheath to Little Hartley

I with my family are a long term residents of Little Hartley and I have been holidaying here prior to residency and have enjoyed the valley as it stands for the past 40 years.
I (including my family) strongly object to proposal due to the following:
*The environmental and social implications for an extended period greater than 10 years with 24 hours per day operation.
*Negative impact to water, air quality, soil, noise and dust levels.
*Significant traffic congestion.
*Well-being impact to residents from work fatigue, noise and disruption for kilometres for us twice a day as a commuter in and out of the valley. Not to mention significant delays and impact for emergency services navigating kilometres of road works and costs if having to utilise helicopters for hospital transfers over 10 years plus.
*Cost to tax payers, especially as there is no business case, there are insufficient State funds and no Federal funding.
*Turning a historical beautiful valley into a motorway that is the transporter route for tonnes of tunnel materials.
*A drop in real estate values. This has already been felt with the plans and recent vegetation removal. People move to the valley for the peace and tranquillity which will be eliminated during the construction phase and with the end tunnel and excessive motorway road.
*Concerns for fires or road accidents or medical emergencies when the tunnel is blocked, and there are no exit routes out of the 11km tunnel.
*It being a extremely high cost construction that is politically driven for individuals notoriety, career path and financial business deals in the private sector (eg transport companies to run B-Double trucks throughout the valley and into the Blue Mountains which they are not allowed to do) that benefits no one that lives in the area.
*Money that the State does not have after the effects of COVID and wide spread flooding.
*The money that the State Government does have should be prioritised and utilised in areas that need it for transport for all ie Extensive road damage that remains after flooding across NSW.
*Enormous concerns in terms of environmental, cultural, indigenous, historical, flora/fauna and social losses due to the impact of this.

All of these concerns have raised significant stress levels for all residents in the valley.

My objection to this project identically reflects all of the contents in the submission letter from the Hartley District Progress Association Incorporated dated 28/2/2023, as does the majority of residents in the valley.

please see attached submission

please see attached submission

Please refer to attached submission.

Please refer to attached submission

Please consider the points raised in the attachment, when making your assessment.
Thank you for your time.

Regards Patrick

For the reasons identified in the submission lodged by the Hartley District Progress Association on 28 February 2023, this project should not be approved. It is environmentally destructive and that cannot be mitigated. A far superior solution would be to build a stand alone expressway from Lithgow to North Richmond north of Bells Line of Road instead of pouring billions into the Great Western Highway, which is no more than a suburban road. This project is fiscally irresponsible and politically motivated. The entire EIS should be rejected and work stopped in the Hartley Valley.

See attachment below.

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.

Southleigh
573 Browns Gap Rd
Hartley NSW 2791
1st March 2023

Director of Transport Assessments
Planning and Assessment
Department of Planning and Environment
Locked Bag 5022
PARRAMATTA NSW 2124

RE: GREAT WESTERN HIGHWAY BLACKHEATH TO LITTLE HARTLEY
ENVIRONMENTAL IMPACT STATEMENT
Dear Sir/Madam
The Hartley Valley, located some 125 kilometres west of Sydney is a significantly beautiful rural landscape surrounded by the 300 metre escarpment of the Blue Mountains. It’s the place where Europeans first broke through the Blue Mountains and discovered a way to the west.
Blaxland Lawson and Wentworth and their party found their way, to the later named, Mt Blaxland half way across the Valley in April 1813. William Cox and his convict road makers built the road to Bathurst in 1814. Governor Macquarie and his party camped in the middle of the valley on his way to declare Bathurst the first inland city in Australia in mid 1815. Major Thomas Mitchell’s new road to Bathurst completed in 1832 is still largely the line of today’s road and is the line along which the hugely significant lateral village of Little Hartley developed. The marks of our colonial history are everywhere in this valley. In addition the valley has been heavily subdivided for residential housing much of which is in Little Hartley.
The Hartley Valley’s importance as a cultural landscape was acknowledged by the National Trust in January 1987 when it listed the Hartley Valley Landscape Conservation Area. In that listing it acknowledged that the Hartley Valley Landscape Conservation Area is a significant heritage landscape worthy of preservation.
Often described as “the most historic inland valley” in Australia, the Hartley Valley has twice been nominated for listing as a Heritage Place under the Federal Environment Protection and Biodiversity Conservation Act 1999 (Cth). Its record on the National Heritage Database notes – ‘It has maintained exceptional continuity in patterns of life and industry, and as a result has a cultural landscape of integrity and authenticity, enriched with a large number of places of exceptional heritage value from first settlement until now’.
Transport for NSW (TfNSW)has consistently failed to recognise the heritage significance of the Hartley Valley and has gone out of its way to downplay the impact of their proposal to include first two, now three, major vehicle rest areas right in the middle of the Valley in their REF self-assessment of the Little Hartley to Lithgow upgrade, with the third rest area entirely excluded from consideration in the REF. Further, they have gone out of their way to exclude any proper assessment of the fact that the historic lookout view from Mt York (where BLW realised they had crossed the mountains) to Mt Blaxland, the end point of that historic expedition, half way across the valley, will be marred by two truck stops, accommodating up to 26 36-metre long trucks and a similar number of other vehicles.
The EIS now being considered includes chapter 17 Non Aboriginal Heritage, which at section 17.2.1 incorporates a statement on historic context that aptly demonstrates TfNSW’s total failure to understand the heritage significance of the Hartley Valley and in this case the lateral village of the heritage listed Little Hartley, that is to be devastated by the industrial complex that will be built on its boundary from which to construct the tunnel through to Blackheath. One can only presume TfNSW has gone out of its way to obfuscate and minimise the significance of Little Hartley as an outstanding example of an early Victorian lateral village.
Under a heading ‘Little Hartley’ TfNSW has stated in the EIS that ‘Many of the early buildings along the Great Western Highway at Little Hartley were constructed in around 1860’. A totally incorrect statement; the earliest buildings in Little Hartley, ‘The Harp of Erin’ and ‘Billesdene Grange’ actually date from 1832. The significant Georgian building ‘Rosedale’ at the eastern end of the village dates from 1839 and ‘Ambermere’ in the middle of the village dates from 1846. Even ‘Meads Farm’ another significant former Inn in the village dates from prior to 1860. The reality is that Little Hartley is the oldest village in the Valley and predates the village of Hartley itself which did not really exist until the courthouse was built in 1837.
In the next paragraph in the EIS it is stated that ‘Little Hartley was formed around popular travellers’ inns such as ‘the Golden Fleece Inn at the foot of Mount York’. Whilst it is at the base of Mt York, the Golden Fleece (‘Collitt’s Inn’) is at Hartley Vale some five or six kilometres from Little Hartley. The EIS then refers to ‘the Royal Garter Inn (currently known as ‘Billesdene Grange’) located adjacent to the Little Hartley Heritage Conservation Area, and Joseph Collits Inn, which became Edward Field’s Hotel (TfNSW, 2021c)’. This concludes TfNSW’s review of the Historical Context of Little Hartley. No mention is made that ‘Joseph Collits Inn’ (which is now ‘Ambermere’), dates from 1845/6. No mention is made that ‘Billesdene Grange’ dated from 1832 or earlier. There is no mention of ‘The Harp of Erin’ on the other side of the Highway (Mitchells Line) dating from 1832. Similarly, no mention of ‘Rosedale’ at the eastern end of the Village dating from 1839.
Their failure to identify with any accuracy the historic buildings comprising Little Hartley, which remain standing and prominent in the landscape of the Hartley Valley today, is a travesty. Given their failure to understand Little Hartley we cannot have any confidence that TfNSW has any understanding of or given any proper consideration to the non-aboriginal heritage assets along the rest of the upgrade corridor . TfNSW should be condemned for their incompetence and this crude attempt to downplay the significance of Little Hartley to those that are assessing the EIS.
TfNSW, in its EIS, paints a picture that is horrifying to residents and anybody that has any regard for our heritage post colonisation. A construction area that is equivalent to some 30 football fields. Parking for 600 employee vehicles. Vehicle movements that will occur at the rate of some 900 movements per hour. Spoil removal of some seven million tonnes of spoil ie more than a quarter of a million truck and dog loads. The assembly in the valley of two tunnel boring machines five stories in diameter and some thirty stories long, roughly equivalent to two city buildings lying on their side in the valley. Overall this project is going to have a devastating impact on the Hartley Valley and its residents.
Tunnel exhaust emissions
The EIS refers to two tunnel exhaust emissions options. Simple, movement driven/fan assisted portal emissions at each exit or a system whereby emissions, movement driven to a capture point close to each exit, are then fan boosted and expelled up an exhaust stack some ten metres tall. The data collected by advisers to TfNSW seem to suggest that the outcomes from each alternative are approximately equivalent.
If equivalent outcomes are achieved and provided that the resultant concentrations of pollutants are within limits prescribed by best practice and health standards then we fully support the portal emission option in order to avoid the imposition of the exhaust stack on the valley landscape.
Application of the Precautionary Principle
The perfectly intact 1832 convict causeway on Victoria Pass is a State listed heritage asset of enormous significance. The fact that it is still utilised by the current highway is a tribute to the engineers and convicts engaged in its construction.
The proposed road tunnels for the GWH have been routed so that the westbound tunnel passes somewhere between 50 and 80 metres immediately under the causeway. Whilst we have been assured that this poses no risk to the causeway we equally know that the tunnelling machine currently stuck on the Snowy 2.0 project was probably trying to cut through country where similar assurances had been given. Having regard to the precautionary principle we believe it is essential that the tunnel alignment should be changed to avoid any potential risk of damage to this asset.
Support of Hartley District progress Association Requests
We support all the requests being made by the Hartley District Progress Association in respect of the Blackheath to Little Hartley EIS.
Overall we are appalled by this proposal as it will have a devastating impact on the Hartley Valley and if it is to be approved it should be the subject of strict conditions to minimise its impact and to preserve the heritage values of the Valley.
Yours Faithfully
(Original Signed)
Ramsay and Susie Moodie

Thank you for the opportunity to comment on the Environment Impact Statement part of this major project.

As a resident of the Hartley Valley for 13 years this project has a significant personal impact. My objections are not based on NIMBYism; I recognise the need for long term infrastructure planning. The problem is that the GWH corridor is and always has been a 'wicked problem' and the current project is as far as can be from a real solution.

The Hartley District Progress Association has prepared a detailed submission addressing the EIS. Please accept this as an endorsement of the points raised there. That submission has been carefully researched and I know that those involved have met with TfNSW and politicians and others. Their views are informed by those meetings.

I have been to TfNSW meetings and viewed the maps and brochures on offer. I am aware of Paul Toole's promises of significantly shorter travel times from Sydney to the West, and that when Cth funding was made available for the GWH upgrade it was part of a Coalition 'cash splash' and prior to the economic devastation caused by COVID. When an independent body formed the view, recently, that the economic case for the upgrade was not made out, and the present Cth government put a 2 year pause on funding, I assumed there would be a re-think. Evidently not. It seems that just before going into caretaker mode the NSW government signed contracts for part of the project at Cox's River Road knowing that the underlying rationale for the whole thing - the 11km twin tunnels - were unfunded and at such an early stage of planning as to have probably little to do with the end product.

It has become clear in recent months that far from what Paul Toole and the Nationals have been telling their local constituents in the West about the benefits of the upgrade, all of this turns on the tunnels being built. There is no Cth funding for this and even the present NSW government understands that major projects need to be reconsidered due to costs. It was a cynical thing to do to sign contacts that would saddle an incoming State government for work that would only make economic sense if tunnels were built - which they may well never be.

I am hopeful that the independent minds of the Planning department will look objectively at the EIS. TfNSW has, it seems to me, done all it could to obfuscate and misinform the public about this project. Looking at the EIS and its description of the impact on the Hartley Valley all I can say is that this is understated. The valley will be ruined. No amount of tree planting can change this. I had no idea there was meant to be a water treatment plant, tunnel boring machine storage or a 600 vehicle car park for workers. I did not consider that there would be 24/7 truck traffic in front of my house (near the Historic Hartley Village) carting spoil for at least 8 years. I knew the time saving benefits (which is really Toole's selling point to his Bathurst constituents) was overstated - but $4 billion PLUS tunnel construction to save 4 minutes travel time is outrageous. Further, I had no idea that the two truck stops would in reality be three - that last being approved 'under the radar' and without any oversight.

The truth is, and this is beyond any doubt, that the whole project is designed for the benefit of the trucking industry and to allow huge 36 metre trucks to access Sydney by travelling east of Lithgow, which they cannot now do. All the rest (travel time, safety, etc) is window dressing.

TfNSW has done its best to minimise the truth about this project, but the EIS has gone some way to lifting the lid on the difference between what we have been told and the reality. I can only hope that the independence of the Planning department leads to the kind of reconsideration that led to the pause at the Cth level.

Finally, by the time this and other submissions are considered, we may well have a new State government. If we do, it is my hope and expectation that they will see through the way we, the residents of this beautiful valley, have been dealt with by TfNSW. The GWH was upgraded not long ago at the cost of (I think) $250+ million. It is a good road, and it is designed for and easily handles 80kph traffic. That is the fastest one can go through the Blue Mountains to past Lithgow. The GWH upgrade with its 6 overpasses and huge (HUGE) elevated road at Jenolan Caves Road is only necessary because of the desire to go 100kpm through the valley. If the speed limit was left at 80kpm, as it now is, there would be no need for this monstrosity.

Thank you for reading this.

DAVID HIRSCH

SSI-22004371

OBJECTION

GREAT WESTERN HIGHWAY BLACKHEATH TO LITTLE HARTLEY
ENVIRONMENTAL IMPACT STATEMENT

Dear Sir/Madam
The EIS is one more example of what amounts to a failed attempt at a sleight-of-hand trick; apparently setting out to deflect the gaze towards the so-called benefits for Blackheath and Mount Victoria, whilst simultaneously mutilating Medlow Bath and the Hartley Valley.

None of this should detract from the literal mutilation of human lives made increasingly probable, for example, around the junction of the GWH and Blaxland Road, Wentworth Falls where the propensity for accidents is already widely recognised in the community without the addition of 36 metre B-Doubles into the equation.

The EIS:

1/ Has failed to address itself to the actual design of the proposed construction, instead basing itself on a historical document that bears only passing relevance to future plans.

2/ Has failed to address the adverse impact on the lives of practically everyone who lives between Lithgow and Penrith with the possible exception of 1/ Blackheath and Mount Victoria residents if they do not leave their village, and 2/ truck drivers.

3/ Has failed to prove itself to be an ‘environmentally led design’. Once again, this comes with the possible exception of Blackheath and Mount Victoria. This is a further example of the attempted sleight-of-hand.

4/ Has failed to address the likelihood of construction of the tunnel occurring simultaneously to major construction works of the GWH Upgrade and has, therefore, not accounted for the compounding of impacts. The impact of construction works are already understated under the notion of sequential timelines.

5/ HAS FAILED TO RESOLVE OR INFER ANY REASONABLE HOPE IN RELATION TO THE MYRIAD APPALLING ENVIRONMENTAL IMPACTS THAT IT CLEARLY INDICATES WILL OCCUR.

Kind Regards

Stuart Stawman
57 Bonnie Blink Drive
Little Hartley, NSW 2790

See attached submission