MOD 3 - ventilation outlet limit

I have attached my response to this proposal.

I was disturbed to hear that the Northconnex tunnel operators wish to raise the level of emissions allowed from this project. It is disturbing enough that the stacks aren't going to be fileterd as other major urban tunnels in other parts of the world are, but now the level of emissions might be even greater than originally outlined. As a resident of Wahroonga who lives close to the stack I am disappointed and troubled by this situation. The powers that be may not have children among the thousands within less than a kilometre radius of the stack, but I cannot understand why the risk to these school childrens' and local residents' long term health is considered acceptable? Yes, it might be in 10, 20 or 30 years time, but do you want to be responsible for adversely affecting the health of so many people? And if there is a problem in the long run, who will pay out those class action law suits? Lendlease? Or the State government. I have often felt secure thanks to Australia's many rigorous laws and yet in 2019, with all the knowledge and research available, the prospect of a non filtered stack with even higher emissions than originally tabled is even being considered. It's hard to even articulate how unacceptable, irresponsible and culpable this organisation's actions are. Please let commonn sense prevail - is there a downside to erringon the side of caution, besides their back pocket?

I would like to object to the suggested increased ommissions in the Wahroonga area .

My daughters attend Abbotsleigh School who have also objected to this request for modification of VOC (Volatile organic compounds) levels;

The school also demands filtration of the tunnel emissions from the Wahroonga ventilation stack.

We have 3 daughters at Abbotsleigh which is located within very close proximity to the stack. The effects of no filtration of the pollution coming from the tunnel is a genuine concern for my children’s health. I am all for progress and projects that will improve our day-to-day lives but never at the expense of the people living nearby or the many school children breathing the polluted air for 6 hours each day over many years. We don’t want this to be a class-action case down the track when we suddenly see an increase in respiratory disease and cancer. Build the stack but it MUST have the appropriate filtration systems in place.

I am writing to object to the request by NorthConnex to increase the Volatile Organic Compounds limit from 1mg/m3 to 4mg/m3. That is an increase of 400%! And it is unfiltered!

A request to increase the limit - and especially without filtering - is putting many people's health at risk.

It is clear that diesel fumes are harmful (and they are just one part of the pollution picture):
* The Safe Work Australia (a government website) clearly states that exposure to diesel exhaust "can cause both short-term (acute) and long term (chronic) health
effects."
I quote "Exposure can irritate the eyes, nose, throat and lungs and cause light-headedness, coughing, phlegm and nausea. Very high levels of
diesel exhaust exposure can lead to asphyxiation from carbon monoxide poisoning. Long term exposure can worsen asthma and allergies and increase the risk of heart and lung disease... and there is epidemiological evidence which indicates ongoing exposure to diesel exhaust emissions may result in an increase in the risk of lung cancer."

The NSW Cancer Council website also states that Diesel Engine Exhaust is linked to both lung and bladder cancer.
Here's the quote "DEE contains a mixture of gases and soot, which is also called particulate matter. Other substances, including carcinogens, may stick to the soot. Because soot particles are very small they can easily get deep into the lungs. This is how they cause a range of short-term and long-term health problems, including cancer. Regular exposure to high levels of soot, over a long period of time, increases the risk of getting lung and bladder cancer."

So, NorthConnex is asking for an INCREASE in the pollutants that will fill the air view the ventilation stacks around my area?! NO.
I have serious concerns about the health of the community with the 1mg/m3... I am shocked at the request to increase it by 400%.

I think it is vital to note that there are many schools around the ventilation stacks in Wahroonga. My daughter attends one of those schools. The idea that a government body could say "YES" to such a request by NorthConnex is shocking.

In December 2018 the NSW Parliament Legislative Council Public Accountability Committee’s Report on the Impact of the WestConnex Project recommended:

"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".

This has been ignored.

There is no filtration planned for the pollution stack or in-tunnel air. As you well know, NorthConnex are now requesting an increase in the allowable levels of pollutants.

These pollutants will impact up to 3 km away with the 1.5km radius being the most concentrated. This is indeed of the utmost serious concern.

What do other countries do?? Modern long urban road tunnels in locations such as Madrid, Italy and Hong Kong and others HAVE filtered ventilation or else diesel trucks are not permitted.

Further Facts Regarding the Health Risks posed by Particulates emitted by the NorthConnex tunnel:
NorthConnex will emit 500 micrograms per cubic metre of diesel particulates. The normal level across Sydney is between 8 and 25 micrograms.

There is NO safe limit of diesel particulates.

The World Health Organisation (WHO) has classified diesel emissions as a Group 1A carcinogen, which is the same class as asbestos, arsenic and mustard gas.

The tiny and invisible particulates deposit deep into lung tissue permanently and can pass into the blood and end up in any organ including the brain.

Short and long-term exposure can include asthma attacks, bronchitis, and respiratory issues, hear attacks, strokes, cardiovascular diseases, lung cancer and the list goes on.

These particulates are known to cause or exacerbate asthma and other respiratory illnesses, impair lung development in children and cause heart disease and cancers.

Children show reduced lung function growth which persist later into life, even when exposure stops, i.e. the damage for growing lungs is permanent.

Please do the right thing:
* Do NOT increase the limit of VOC for NorthConnex
* Insist upon filtering!!

For the sake of our families, friends, community and environment, please make a decision that ensures better health for us all.

Thank you.

I am concerned that the emission from the stacks will cause harm to those in close proximity (including Abbotsleigh). I object to the request for modifications of VOC levels to be increased and strongly request that the emissions from the stack in Wahroonga be filtered for the sake of the health of those around it.

As a parent, I am very concerned about the potential impact of our children. I support our school and Parent Association's objection to this request for modification of VOC levels and the demand for filtration of the tunnel emissions from the Wahroonga ventilation stack!

I have a strong objection to this request for modification of VOC (Volatile organic compounds) levels;
I demand filtration of the tunnel emissions from the Wahroonga ventilation stack.

I am both a resident of the area as well as have my daughter at the local school

I understand this ventalation outlet is close to both where I live and where my daughter schools so the level of toxic fumes coming out will affect my family

We would like the emission to be well under moderate level and not at 400%.

Both of my daughters go to Abbotsleigh, and I believe it is extremely important to have appropriate filtration for the tunnel emissions from Wahroonga ventilation stack, otherwise the local community will be exposed to unimaginable risks to pollution.

To whom it may concern,

I am a parent of students attending Abbotsleigh School for Girls (Abbotsleigh).

I strongly object to the modification request by the Roads and Maritime Service (RMS) to amend Condition of Approval E11 to raise the Volatile Organic Compound (VOC) limit from 1mg/m3 to 4 mg/m3. This objection is raised on the basis of the following:

1. the adverse impacts of this modification on our school, a sensitive receptor, has not been adequately considered; and
2. the increasing of air pollution within close proximity to our children and for potentially extended periods will result in short-term and long-term health impacts.

Abbotsleigh’s Early Leaning Centre and Junior School is located at 22 Woonona Avenue, Wahroonga, and is approximately 500 metres from the NorthConnex northern ventilation outlet. The Early Leaning Centre and Junior School has approximately 600 students from Pre-School to Year 6 and with a range of ages from 0 to 12 years.

Abbotsleigh’s Senior School is located at the corner of Pacific Highway and Ada Avenue, Wahroonga, and is within 1 km of the NorthConnex northern ventilation outlet. Approximately 600 students attend the Senior School from Years 7 to 12 and with a range of ages from 12 to 18 years.

In additional to Abbotsleigh, other schools are located within close proximity of the NorthConnex northern ventilation outlet. These include Wahroonga Preparatory School, St Lucy’s School, Knox Grammar Preparatory School, Prouille Catholic School, St Edmund’s School for Blind & Visually Impaired, Wahroonga Public School, Knox Grammar School, Waitara Public School and St Leo’s Catholic College. The NorthConnex northern ventilation outlet is also within close proximity to the residential areas of Wahroonga and Waitara, and a number of aged care facilities.
The decision to increase the level of VOC from 1mg/m3 to 4mg/m3 will put the health of our children and the local community at risk. Young children and the elderly are most susceptible to developing asthma. A more serious concern is the development of lung/respiratory diseases and cancer from the carcinogenic substances found in VOC.
The proposed VOC emission level of 4mg/m3 is above the acceptable levels in the air we breathe
4mg/m3 is considered exceeding high level and is in contradiction to the RMS claims that it is within the acceptable level. High levels of VOC are harmful to peoples’ health. Exposure to VOC can cause eye, nose and throat irritation, as well as upper respiratory infections, nausea, allergic reactions and headaches etc. It can also aggravate existing respiratory diseases such as bronchitis and pneumonia. Regarding long-term exposure to outdoor air pollution, it can cause chronic respiratory diseases, lung cancer, heart disease, as well as acute respiratory infections in the case of children.

We believe that there has been inadequate dialogue and consultation by RMS with the local community, including the parents of children attending local schools about the impact of the modification. Many parents are not aware of this sudden modification request and we consider that the limited time allowed for submissions is also unacceptable.

We request that the NSW Department of Planning, Industry and Environment undertakes the following actions:

1. withhold approval of State Significant Infrastructure Modification SSI-6136;
2. mandates the installation of filltration at ventilation outlets by RMS to reduce VOC emission into the air, noting that filtration at tunnels is an international standard and is Recommendation 13 in the December 2018 NSW Parliament Legislative Council Public Accountability Committee Report on the Impact of the WestConnex Project;
3. mandates the installation of air monitoring devices by RMS within Abbotsleigh’s school grounds as offered by Mr Tim Parker, RMS Project Director

I am opposed to the modification given the significant health risks associated with the increase of VOCs by up to 400%. These pollutants are a known health risk which which a previous letter signed by 200 local doctors called out. It is unacceptable that the project is now proposing to increase the level of pollutants in an area with a significant number of schools, with one in particular (Abbotsleigh Junior school) being less than 250 meters from the ventilation stack, and the local hospital being with 1.5 Kms. This is an unacceptable modification which I object to.

Regards
Gerard Lai-Smith

I object in the strongest terms to the North Connex stack in Wahroonga being without a filter.
The emissions stack in Wahroonga must be filtered.
There are no safe levels of air pollution and there are several schools including one right next to the stack.
The health and safety of our children must come before progress and profit.

Firstly I would like to state I object to the project as described in the EIS.

I have a high level of concern regarding the following issues and request that these be considered by NorthConnex and the Department of Planning. In regards to the NorthConnex tunnel, I am concerned about:

1. Placement of the northern ventilation stack in the centre of 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. I personally live less than 1.5 kms from the stack.

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.

To address my/our concerns I request that the following actions are undertaken:
1. Due to the significant health concerns of the current project design, I request the department of planning puts a filter in the ventilation stack.
2. I also request that alternative transport options to ease congestion on Pennant Hills Rd be considered such as an orbital surface route

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

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.

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
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

Dr. Chan Nguyen
_______________________

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 absolutely 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 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 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

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.

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

We have a lot of schools in the area and it will affect the health of the children attending nearby school and residents living in the area.

I note that the North Connex Project has lodged a modification to the emission levels from the planned exhaust stacks.

The statement on their website is:

E11 Modification Request
Roads and Maritime Services is requesting a modification for the NorthConnex condition of approval on display with the Department of Planning, Industry and Environment (DPIE) for feedback to rectify an unfortunate historic transcription error.

The transcription error relates to VOC limits listed in the Environmental Impact Statement (EIS) that was publicly exhibited in 2014. The VOC limits were incorrectly listed as 1mg/m3 as opposed to the intended 4mg/m3.
The change reflects the 4mg/m3 limit that is consistent with all major road tunnel projects in NSW.
The Environmental Protection Agency (EPA) has reviewed the proposal and is satisfied that the proposed limit change will not change air quality impacts associated with the operation of NorthConnex as no modifications to the design and operation of the ventilation system are proposed.
The community is encouraged to have their say via the DPIE Major Projects website from Friday 30 August to Thursday 12 September and we appreciate the community’s understanding while this transcription error is rectified.

The error in transcription notwithstanding, I cannot comprehend why the State would support the implementation of unfiltered stacks as part of this project. Surely the governments fundamental concern should be the health and well-being of their constituents, and not the issue of additional cost to the project.

I am a local resident whose daughter attends a local school that will be unnecessarily close to the exhaust emission stacks.

I can neither understand nor support the implementation of unfiltered stacks.

Why, when it is possible to reduce the levels of contaminants put into our precious atmosphere, is the project allowed to save costs by pushing out concentrated levels of contaminants through these unfiltered stacks.

I note that the EPA have approved this level of pollution, and I am sure that this is supported by scientific studies on the health impact, but surely, regardless of statistics, it is far better and far less risky to the health of the population to maximise the reduction of contaminants output from the tunnel.

I urge you as our representatives to consider the health of our community and to ensure that filtration is added to these exhaust stacks.

Best Regards,

Manu Sivaraj.