MOD 3 - ventilation outlet limit

Please find below my submission in response to - EXHIBITION OF STATE SIGNIFICANT INFRASTRUCTURE MODIFICATION REQUEST NORTHCONNEX(M1-M2) PROJECT- MODIFICATION- SS6136 MOD 3

Firstly, I would like to state that I OBJECT to the modification request by RMS to amend condition of approval E-11- Ventilation Outlets-Limits. That is to modify the approved Volatile Organic Compound (VOC) limit from 1mg/m3 to 4 mg/m3. This is because of inadequate communication and dialogue to the community from Road and Maritime services (RMS) and the Department of Health. There has been no consultation and explanation of what these levels mean in relation to air quality and pollution levels in Wahroonga and surrounding suburbs. There has been no explanation by the Department of Health as to why they have given their approval.
There has not been enough time given for the public to consider all aspects of this matter and giving the public only 2 weeks to respond is a an abuse of the submission process.

I have a high level of concern regarding the following issues:

1. The increased level of VOC's from 1mg/m3 to 4mg/m3 will increase the concentrations of diesel emissions from the northern ventilation stack in a densely populated residential area in Wahroonga, where 9,300 school children will be exposed, as well as multiple aged care facilities, hospitals, businesses and homes.

2. I am extremely concerned because research studies have proven the impacts of air pollutants on health are serious. These include increased death from heart disease, increased risks of lung cancer, stroke, poor lung growth in children, increased asthma, and recent research suggesting low birth weight for pregnant women, increased autism, and congenital heart defects. These studies confirm air pollutants have prothrombotic and inflammatory effects on humans which cause the above health problems. Specifically, many of the VOC's, including benzene and formaldehyde from vehicle exhaust, are classified as Group 1 carcinogens to humans (IARC 2009). When VOC's and NOx react in the presence of sunlight, ozone is formed. In the short term, exposure to ozone can result in reduced lung function and exacerbation of asthma and chronic respiratory diseases, as well as irritation and inflammation of eyes, nose, throat and lower airways. These pollutants cause cancer and there is NO SAFE LEVEL, when thousands of trucks will be using the Northconnex tunnels daily and emitting concentrated diesel emissions. In the long term, this area will become a cancer cluster. In the long-term 9,000 plus growing children in the area will suffer health issues as a adults.

3. I would like to point out that the project was approved based on the approval limit of 1mg/cubic metre.
Any change requires a new EIS. The request is to allow for short term incidents , why is the modification request a constant limit increase instead? The the "Ltr Dispersion Modelling Results_28Sep15" report becomes invalid if the parameters are changed. The Department of Health and the EPA should be conducting their own research at the dispersion factors and it’s effects on air pollution and health and not just accept the theoretical modelling results provided by Aecom.

To address my concerns I request that the following actions are undertaken:
1. I request the department of planning does not approve of the proposed modifications
2. That more pollution monitors are installed in the vicinity of all the schools and preschools in the area.
There is : — NO pollution monitor in circle of 0.25km radius
-- NO pollution monitor in circle of 0.5km radius
-- NO pollution monitor on the east side of the NorthConnex in Wahroonga area
-- NO pollution monitor close to Waitara Public School within 500m radius from the stack, Wahroonga Preparatory School within 410 m radius from the stack.
There is an insufficient number of air pollution monitors, given the number of schools in the area.

2. That the ventilation outlet emissions are filtered before release into the air, as per Recommendation 13 in the December 2018 NSW Parliament Legislative Council Public Accountability Committee Report on the Impact of the WestConnex Project, that all long road urban tunnels are filtered.

I have not made any political donations in the previous two years

FROM:

Dr Samantha Lander
Killara NSW 2071


TO:


Director – Transport Assessments
MAJOR PROJECTS TEAM,
NSW Department of Planning, Industry and Environment
Application Number: SSI 6136 MOD3
GPO Box 39,
SYDNEY NSW 2001

Please find below my submission in response to - EXHIBITION OF STATE SIGNIFICANT INFRASTRUCTURE MODIFICATION REQUEST NORTHCONNEX(M1-M2) PROJECT- MODIFICATION- SS6136 MOD 3

Firstly, I would like to state that I OBJECT to the modification request by RMS to amend condition of approval E-11- Ventilation Outlets-Limits. That is to modify the approved Volatile Organic Compound (VOC) limit from 1mg/m3 to 4 mg/m3.

As a general practitioner, I have researched the health impacts of exposure to VOC’s and have a high level of concern regarding the proposed increase.

VOC's include carcinogens such as benzene and formaldehyde from vehicle exhaust. There is NO SAFE LEVEL of exposure to these pollutants. As well as cancer, these chemicals cause eye, nose, throat and airway irritation, reduced lung function and cause exacerbation of asthma and COPD. When VOC's and NOx react in the presence of sunlight, ozone is formed. In the short term, similar to VOC’s, exposure to ozone can result in reduced lung function and exacerbation of asthma and chronic respiratory diseases, as well as irritation and inflammation of eyes, nose, throat and lower airways. In the long term, as well as causing cancer, there is a growing body of evidence to support that exposure to ozone increases death from respiratory and cardiovascular causes. There is currently inconsistent evidence to indicate there is a threshold below which exposure to ozone is not associated with adverse health effects. That is to say, there is NO SAFE LEVEL.


The NorthConnex stacks are located in densely populated areas in the near vicinity of over 9000 school students, along with health and aged care facilities, businesses and of course many residents. These people all stand to suffer the potential health impacts of exposure to the pollutants emitted from the stacks as discussed above.

This is in the context of the wider issue that the ventilation stacks for the North Connex will NOT BE FILTERED. Recommendation 13 in the December 2018 NSW Parliament Legislative Council Public Accountability Committee Report on the Impact of the Westconnex Project recommended "the NSW Government install, on all current and future motorway tunnel, filtration systems in order to reduce the level of pollutants emitted from ventilation stacks". This has been dismissed. Reference is made to the lack of cost effectiveness of filtration on the basis of a short trial of filtration on the M5 East tunnel from March 2010 to September 2011. This was NOT stack filtration and incurred many additional costs to those that would be required for retrofitting filtration into an existing stack. The NorthConnex Stacks have been designed for such retrofitting.

I have also attached the doctors letter of medical evidence which was signed by over 200 doctors in 2014 regarding the health impacts of exposure to the tunnel pollutants.

In summary, could you please provide the evidence that there will be no health impact on those living, working and studying in the vicinity of the Northern ventilation stack of this exposure to increased levels of VOC's. This should take into account the prolonged exposure of many of these people over many years, as well as the sensitivity of particular people exposed, including children and the elderly. If there is no evidence of safety, the proposal to increase in the acceptable level of VOC's should NOT be approved.

This is also an opportunity to reassess the need for filtration in the NorthConnex stacks, or in-tunnel filtration. There is no modern longitudinally ventilated long urban road tunnel greater than 5km in length elsewhere in the developed world that is recently built or under construction which allows diesel trucks with this inadequate ventilation design.

The UK and USA have no such tunnels. In France and Turkey they ban the diesel trucks, as well as buses and motorcycles. In Spain, Norway, Italy, Japan, Hong Kong and Switzerland they have installed filtration, to clean the air before it is sent out of ventilation stacks over urban areas. Australia should be no different.

Please prioritise the health and safety of the air that we breathe and the constituents you represent.


I have not made any political donations in the previous two years

Yours sincerely,

Dr Samantha Lander
BSc MBBS (Hon 1) FRACGP

TO:
Director – Transport Assessments
MAJOR PROJECTS TEAM,
NSW Department of Planning, Industry and Environment
Application Number: SSI 6136 MOD3
GPO Box 39,
SYDNEY NSW 2001

Please find below my submission in response to - EXHIBITION OF STATE SIGNIFICANT INFRASTRUCTURE MODIFICATION REQUEST NORTHCONNEX(M1-M2) PROJECT- MODIFICATION- SS6136 MOD 3

Firstly I would like to state that I OBJECT to the modification request by RMS to amend condition of approval E-11- Ventilation Outlets-Limits. That is to modify the approved Volatile Organic Compound (VOC) limit from 1mg/m3 to 4 mg/m3.

As a mother of two girls attending school at the affected zone, I have a high level of concern regarding the following issues:

1. The increased level of VOC's from 1mg/m3 to 4mg/m3 will increase the concentrations of emissions from the northern ventilation stack in a densely populated residential area in Wahroonga, where 9,300 school children will be exposed, as well as multiple aged care facilities, hospitals, businesses and homes.

2. I am highly concerned about the multiple large scale research studies that suggest the impacts of air pollutants on health are serious. These include increased death from heart disease, increased risks of lung cancer, stroke, poor lung growth in children, increased asthma, and recent research suggesting low birth weight for pregnant women, increased autism, and congenital heart defects. These studies confirm air pollutants have prothrombotic and inflammatory effects on humans which cause the above health problems. Specifically, many of the VOC's, including benzene and formaldehyde from vehicle exhaust, are classified as Group 1 carcinogens to humans (IARC 2009). When VOC's and NOx react in the presence of sunlight, ozone is formed. In the short term, exposure to ozone can result in reduced lung function and exacerbation of asthma and chronic respiratory diseases, as well as irritation and inflammation of eyes, nose, throat and lower airways. In the long term, as well as causing cancer, there is a growing body of evidence to support that exposure to ozone increases death from respiratory and cardiovascular causes. There is currently inconsistent evidence to indicate there is a threshold below which exposure to ozone is not associated with adverse health effects. That is to say, there is NO SAFE LEVEL.

To address my/our concerns I request that the following actions are undertaken:
1. Due to the significant health concerns that will occur in the community, I request the Department of Planning does not approve of the proposed modifications; and
2. That the ventilation outlet emissions are filtered before release into the air, as per Recommendation 13 in the December 2018 NSW Parliament Legislative Council Public Accountability Committee Report on the Impact of the WestConnex Project.

I have not made any political donations in the previous two years.

Sui Chan

I have provided a submission in the attached file.
Thank you for your time in reading it.

To keep a safe/clean neighborhood, we need maintain the most strict standard.

I am very concerned the potential pollution to the air quality if this project is going ahead, especially the impact to the children study nearby.

THE HEALTH AND WELFARE OF THE CHILDREN MUST COME FIRST WITH NO NEGOTIATIONS.
I OBJECT YOUR PLAN TO INCREASE THE MOD 3 - VENTILATION OUTLET LIMIT ON NORTHCONNEX, I ALSO INSIST THAT A FILTER IS ESSENTIAL TO BE INSTALLED.

Firstly I would like to state that I strongly OBJECT to the modification request by RMS to amend condition of approval E-11- Ventilation Outlets-Limits. That is to modify the approved Volatile Organic Compound (VOC) limit from 1mg/m3 to 4 mg/m3.

I have a high level of concern regarding the following issues:

1. The increased level of VOC's from 1mg/m3 to 4mg/m3 will increase the concentrations of emissions from the northern ventilation stack in a densely populated residential area in Wahroonga, where 9,300 school children will be exposed, as well as multiple aged care facilities, hospitals, businesses and homes.


2. I ame highly concerned about the multiple large scale research studies that suggest the impacts of air pollutants on health are serious. These include increased death from heart disease, increased risks of lung cancer, stroke, poor lung growth in children, increased asthma, and recent research suggesting low birth weight for pregnant women, increased autism, and congenital heart defects. These studies confirm air pollutants have prothrombotic and inflammatory effects on humans which cause the above health problems. Specifically, many of the VOC's, including benzene and formaldehyde from vehicle exhaust, are classified as Group 1 carcinogens to humans (IARC 2009). When VOC's and NOx react in the presence of sunlight, ozone is formed. In the short term, exposure to ozone can result in reduced lung function and exacerbation of asthma and chronic respiratory diseases, as well as irritation and inflammation of eyes, nose, throat and lower airways. In the long term, as well as causing cancer, there is a growing body of evidence to support that exposure to ozone increases death from respiratory and cardiovascular causes. There is currently inconsistent evidence to indicate there is a threshold below which exposure to ozone is not associated with adverse health effects. That is to say, there is NO SAFE LEVEL.

To address my concerns I request that the following actions are undertaken:
1. Due to the significant health concerns that will occur in the community, Iwe request the Department of Planning does not approve of the proposed modifications; and
2. That the ventilation outlet emissions be FILTERED before release into the air, as per Recommendation 13 in the December 2018 NSW Parliament Legislative Council Public Accountability Committee Report on the Impact of the WestConnex Project.

I have not made any political donations in the previous two years

I OBJECT to the modification request by RMS to amend condition of approval E-11- Ventilation Outlets-Limits. This is to modify the approved Volatile Organic Compound (VOC) limit from 1mg/m3 to 4 mg/m3. This is apparently due to a "typo".

This is extremely concerning for many reasons.

1. A project based upon it's original EIS process can't be changed due to a typo. It makes a mockery of the process in the first place and leaves no faith from the public who bear the brunt of a poorly thought through project. What else has not been thought through? Where are the studies indicating a 400% increase in VOC levels is safe to human health. You have a duty of care to ensure projects are done properly or not at all, particularly when there is so much risk on these types of health impacts. We have accumulated much more evidence since 2014 (my initial submission) of the extremely negative health impacts and evidence this type of pollution has on people. It was dangerous at 1mg/m (cubed) and so by raising it to to 4mg/m (cubed) is just totally irresponsible. Please look at the data by those who are independent of this project and I request the precautionary principle be upheld and human health be a top priority.

2. The increase in emission levels is four times the original submission and sweeping statements are made by the RMS that just haven’t been qualified. This includes a statement made by S.Shand that ”An amended VOC limit will result in little, if any change to local air quality for the surrounding community and no mitigation measures are required.” Even a lay person can understand what goes in must come out.

3. What is the level of confidence in all other technical aspects of the project, given such a fundamental error has only just been identified?

4. The design of the 9km tunnel which has been made to take diesel trucks does not have adequate ventilation. Tunnel ventilation engineers know that the efficiency of longitudinal ventilation reduces with length and add extra fans to pull the air through. Without regular exhausting and addition of fresh air the quality of the air in tunnels, especially heavily trafficked or with a high proportion of diesel vehicles, becomes increasingly problematic. They use this overseas to include filtration for long urban high trafficked tunnels or remove diesel vehicles from the mix. Or simply don't place stacks in urban areas. On top of this raising the VOC limit in tborders on the unbelievable.
I think it is important to do the following"
1. Keep the original emission rate limit 1mg/m3 unchanged, so that any abnormal emission can be exposed and trigger a notification for proper handling
2. Install more pollution monitor stations, and collect as much as we can so that, in the future, we have data to verify if the tunnel has no impact on our environment
3. Increase the stack height; current stack height is ~26m only
According to an Australia standard, https://www.epa.gov/sites/production/files/2017-12/documents/62.7-2017.pdf
4. Most importantly install filters into stacks, to actually reduce the emissions.

Councils are already paying for monitoring stations because they know the dangers of pollution. Overseas developed nations filter because it is necessary to protect human health when stacks are in urban areas. It seems only necessary that this be the absolute baseline for a safe and quality project.

Aimee Brice

I object to the modification request by RMS to amend condition of approval E-11- Ventilation Outlets-Limits. That is their request to modify the approved Volatile Organic Compound (VOC) limit from 1mg/m3 to 4 mg/m3.

There is a large amount of people who have significant concerns about the health impacts of the air pollution, both in-tunnel and around the ventilation stacks, and this increase in what is allowed to go to without being reported on is even more concerning.

As you may be aware, VOC's include carcinogens such as benzene and formaldehyde from vehicle exhaust. There is NO SAFE LEVEL of exposure to these pollutants. As well as cancer, these chemicals cause eye, nose, throat and airway irritation, reduced lung function and cause exacerbation of asthma and COPD. The stacks are in densely populated areas in the near vicinity of over 9000 school students, along with health and aged care facilities, and of course many residents.

Recommendation 13 in the December 2018 NSW Parliament Legislative Council Public Accountability Committee Report on the Impact of the Westconnex Project recommended "the NSW Government install, on all current and future motorway tunnel, filtration systems in order to reduce the level of pollutants emitted from ventilation stacks". This has been ignored. Over 200 doctors signed a letter in 2014 stating their concerns of health impacts from this tunnel pollution.

There should be supported evidence to say that there will be no health impact on those living, working and studying in the vicinity of the Northern ventilation stack of this exposure to increased levels of VOC's. If there is no evidence of safety, the increase in the acceptable level of VOC's should not be supported.

In the interest of public safety and your duty of care this should be the utmost importance.

Regards,
Libbie

I am writing regarding the requested increase in Volatile Organic Compound (VOC) limit from 1mg/m3 to 4 mg/m3. I object to such a limit being approved.

A "typo" can not just get through without supporting evidence and approvals that the new levels are safe.

This is not only bad news for tunnel users who will breathe the carcinogenic pollution but also people who live, go to school and work near the stack and wider areas of where this pollution reaches. Currently, there is no “industry standard” or Australian Standard for tunnel design and construction. We are definitely in need of one and it could refer to the 17Dec18 NSW Legislative Council Public Accountability Committee The Impact of the WestConnex Project – Recommendation 13: “That the NSW Government install, on all current and future motorway tunnels, filtration systems in order to reduce the level of pollutants emitted from ventilation stacks”.

There is so much evidence now that exposure to diesel emissions is extremely dangerous for children as it inhibits lung development, causes and exacerbates asthma and some 9000 children go to schools with the 1.5km fall out zone. The medical profession, including the World Health Organisation and the Public Health Association of Australia have given very clear warnings about exposure to diesel particulates – Diesel particulates are a Group 1A carcinogen, just like asbestos and there is no safe level of exposure. I would not want my children or family members anywhere near the stack nor drive in the tunnel.

This is actually really serious health risks of people both in the tunnel and outside the stack. A potential future scenario: The traffic is bad in the tunnel, all 9km of it, and someone has asthma or unknown lung/heart issue that is currently not a known issue. The lack of tunnel filtration plus the lack of car movement increases the VOC level (containing particulates and many other dangerous things) because there is no filtration. Or there could be an accident or car break down and smoke is coming out of the car into the unfiltered tunnel. Is a higher limit of accepted pollution before triggering a report protecting the travellers in the tunnel?

Isn't it your responsibility to ensure and show something is safe before approving it? If not sure then isn't the risk too big? Isn't it essential that a "typo" doesn't get pushed through given these things? If so it makes an absolute mockery of the EIS process and project protocols.

I strongly object to this increase in VOC's being approved. It is a public health matter and you have a chance to do something about it before there are serious health events. What if it were your child or family member?

John

Please see attachment

Please see attachment for details