MOD 3 - ventilation outlet limit

Shaft is too close to Waitarra public school. Please install filter to reduce air polution risk for kids and teachers in school.

We 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 4mg/m3. Please see attached letter with justification.

My submission is attached to object to a modification to VOC in the NorthConnex project.

Dear Sir/Madam,

Here’s why I'm objecting to this modification (to increase the emission rate limit by 300% from 1mg/m³to 4mg/m³.

1. The original emission rate limit as 1mg/m³ should be kept therefore any abnormal emission would trigger a notification for the proper handling. We should keep the normal emission rate limit as low as possible instead of allowing a spike limit to be used a daily basis one.

2. Install more air (pollution) monitor stations and collect as much data as possible. This is the proper way to have enough data to confirm if the tunnel has no impact to the local environment.
It’s the truth that the real data always beats anyprediction which got calculated on paper. We need the real data for understanding if there is an impact or not.
Currently, the situation is:
-- NO air pollution monitors located in circle of 0.25km radius
-- NO air pollution monitors located in circle of 0.5km radius
-- NO air pollution monitors located on the east side of the NorthConnex in Wahroonga area
-- NO air pollution monitors located close to those two public schools:
WPS (Waitara Public School ~500m circle, and Wahroonga Public School ~1.25km circle)

3. Increase the stack to the appropriate height. Thecurrent stack height is planned as ~26m only. Theheight as 26m is far less than the Australia standard(https://www.epa.gov/sites/production/files/2017-12/documents/62.7-2017.pdf ):
"Good Engineering Practice" (GEP) Stack Test Height - The greater of:
1. 65 meters, measured from the ground-level elevation of the base of the stack;
2. Hg = H + 1. 5 L,
where Hg = good engineering practice height, measured from the ground-level elevation at the base of the stack,
H = height of nearby structure(s) measured from the ground-level elevation at the base of the stack,
L = lesser dimension, height or projected width of nearby structure(s)
The Department or EPA may require the use of a field study or fluid model to verify GEP stack height for the source

4. Install filters into the stack to reduce the emission
Different tunnels are with different scenarios. The excuse like "other tunnels like the Sydney Harbor Tunnel doesn't have filters" should NEVER be used as an official reason for Northconnex not to use filters inthe stack.
We no longer live in 1990’s. We should stay tuned with the modern design trends.

What would be your advice if you live within the 500m radius of the NorthConnex north stack?

Thanks.

I against the project which will pollute the air.

protect our people

Director, Transport Assessments
Major Projects Team
NSW Dept of Planning, Industry and Environment

Re: Submission in Response to State Significant Infrastructure Modification SSI-6136-Mod-3 – Modification to Northconnex Ventilation Outlet Limit.

Dear Sir,

I am making this submission as the parent of two young girls (aged 4 and 8) currently attending Abbotsleigh Junior School. I would like to express my strong objection to the modification request by the RMS to amend Condition of Approval E11 to raise the Volatile Organic Compound (VOC) limit from 1mg / m3 to 4mg / m3. This is based on the following concerns:

1) Potential adverse impacts of this change on the 17 schools and childcare centres within a km of the stack (including Abbotsleigh Junior School) have not been adequately considered.
2) Concerns regarding adverse health impacts, particularly on children and the elderly, have been raised by the Australian Medical Association NSW and the Asthma Foundation NSW. As a medical specialist, this is of great concern to me.
3) NorthConnex will emit 500 micrograms per cubic metre of diesel particulates. The normal level across Sydney is between 8 and 25 micrograms. 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. These particulates are known to cause or exacerbate asthma and other respiratory illnesses, impair lung development in children and cause heart disease and cancers. As my four-year-old daughter has been diagnosed with asthma, this is of particular concern to me.
4) The WHO, as well as other scientific reviews, have concluded that there is no safe level of fine particulate matter (such as that which will be released from the NorthConnex stack) for children.
5) Original modelling of the dispersal of air pollution used weather patterns from other parts of Sydney, including Terrey Hills, 20 kilometres away, and Sydney Airport. Actual weather patterns in the Wahroonga area are likely to result in less dispersal of air pollution.
6) My understanding is that many of the health impacts of pollution from exhaust stacks are caused by ultrafine particles, which are difficult to measure and as such may be under-measured in tests of local air quality around these stacks.

There has been inadequate consultation by the RMS with the local community, including the parents of children attending local schools, about the potential impact of the proposed modifications. Further, this modification request is quite sudden, and the limited time allowed for submissions is manifestly insufficient.

I would respectfully make the following requests of the NSW Dept of Planning, Industry and Environment:

1) Withhold approval of State Significant Infrastructure Modification SSI-6136.
2) Mandate the installation of filtration at ventilation outlets by RMS to reduce VOC emissions 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. Further, it should be mandated that such filtration be operational at all times.

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

Sincerely,
Dr. Fong

Director, Transport Assessments
Major Projects Team
NSW Dept of Planning, Industry and Environment

Re: Submission in Response to State Significant Infrastructure Modification SSI-6136-Mod-3 – Modification to Northconnex Ventilation Outlet Limit.

Dear Sir,

I am making this submission as the mother of two young girls (aged 4 and 8) currently attending Abbotsleigh Junior School. I would like to express my strong objection to the modification request by the RMS to amend Condition of Approval E11 to raise the Volatile Organic Compound (VOC) limit from 1mg / m3 to 4mg / m3. This is based on the following concerns:

1) Potential adverse impacts of this change on the 17 schools and childcare centres within a km of the stack (including Abbotsleigh Junior School) have not been adequately considered
2) Concerns regarding adverse health impacts, particularly on children and the elderly, have been raised by the Australian Medical Association NSW and the Asthma Foundation NSW.
3) NorthConnex will emit 500 micrograms per cubic metre of diesel particulates. The normal level across Sydney is between 8 and 25 micrograms. 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. These particulates are known to cause or exacerbate asthma and other respiratory illnesses, impair lung development in children and cause heart disease and cancers. As my four-year-old daughter has been diagnosed with asthma, this is of particular concern to me.
4) The WHO, as well as other scientific reviews, have concluded that there is no safe level of fine particulate matter (such as that which will be released from the NorthConnex stack) for children.
5) Original modelling of the dispersal of air pollution used weather patterns from other parts of Sydney, including Terrey Hills, 20 kilometres away, and Sydney Airport. Actual weather patterns in the Wahroonga area are likely to result in less dispersal of air pollution.
6) My understanding is that many of the health impacts of pollution from exhaust stacks are caused by ultrafine particles, which are difficult to measure and as such may be under-measured in tests of local air quality around these stacks.


There has been inadequate consultation by the RMS with the local community, including the parents of children attending local schools, about the potential impact of the proposed modifications. Further, this modification request is quite sudden, and the limited time allowed for submissions is manifestly insufficient.

I would respectfully make the following requests of the NSW Dept of Planning, Industry and Environment:

1) Withhold approval of State Significant Infrastructure Modification SSI-6136.
2) Mandate the installation of filtration at ventilation outlets by RMS to reduce VOC emissions 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. Further, it should be mandated that such filtration be operational at all times.


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



Sincerely,
J. Fong.

Director – Transport Assessments
Major Projects Team
NSW Department of Planning, Industry and Environment
Application Number: SSI-6136-MOD3
GPO Box 39,
SYDNEY NSW 2001

Re: Submission in response to State Significant Infrastructure Modification SSI-6136-Mod-3 – Modification to NorthConnex Ventilation Outlet Limit

Dear Sir

My name is Maureen Fong and I live in Pyrmont and have two granddaughters who are currently attending Abbotsleigh School for Girls (Abbotsleigh). I am absolutely appalled that the government is considering such an abhorrent scheme. I cannot believe such a cavalier approach which would likely have a detrimental impact on the health and wellbeing of children attending schools in the area. Would you recommend a pollution stack be placed so close to where you lived, or your loved ones?

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.

I 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 the limited time allowed for submissions is also unacceptable.

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

Sincerely,

Maureen Fong.

Dear Sir/Madam,

Here I'm commenting to object this modification (to increase emission rate limit by 300% to 4mg/m3. The reason are:
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
I don't think a emission rate limit is used to allow a spike (meaning occasional incident).

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
This is very important, because we should NOT depends on our engineering prediction (calculated on paper) without monitoring the real pollution.
Currently, 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 those two WPS (Waitara Public School ~500m circle, and Wahroonga Public School ~1.25km circle)

3. Increase the stack to appropriate height; current stack height is ~26m only
I doubt the 26m height is higher than the buildings close to the stack. E.g. Waitara Public School, which has ~960 students, is on the top of the mountain just ~ 500m away. I think the top of the stack isn't higher than WPS's location.
According to an Australia standard(https://www.epa.gov/sites/production/files/2017-12/documents/62.7-2017.pdf ):
"Good Engineering Practice" (GEP) Stack Test Height - The greater of:
1. 65 meters, measured from the ground-level elevation of the base of the stack;
2. Hg = H + 1. 5 L,
where Hg = good engineering practice height, measured from the ground-level elevation at the base of the stack,
H = height of nearby structure(s) measured from the ground-level elevation at the base of the stack,
L = lesser dimension, height or projected width of nearby structure(s)
The Department or EPA may require the use of a field study or fluid model to verify GEP stack height for the source

4. Install filter into stack, to actually reduce the emission
First, existing use case like "other tunnel like the Sydney Harbor Tunnel doesn't use filter" should NOT be used as a reason for Northconnex not to use filter in stack. Every tunnel has its special situation; they are independent. Even we say the "Sydney Harbor tunnel" is a okay not to use filter, I do think the following reasons which makes it okay:
1) It's much shorter, and its depth is much less than NorthConnex
2) There are far fewer trucks passing the "Sydney Harbor Tunnel"; most of them are general sedans/cars. While NorthConnex is built for heavy trucks
3) when "Harbor Bridge Tunnel" was built, it was not designed for today's high traffic per day
In short, it's not an excuse to refer to the "Sydney Harbor Tunnel" as the reason for no filter in stack

In short, I don't think 1) it's a good idea to increase the emission rate limit 2) we need more actions to improve the air quality.
What would be your advice, if you live here within 500m scope of the NorthConnex north stack? Appreciate your time and advice!

I was alarmed by the exhibit in the Northern District Times (28/8/2019 p.10), whereby the RMS, via the Department of Planning, Industry and Environment, sought approval to increase NorthConnex emmissions, seemingly on the basis of very weak supporting documents from NSW Health, EPA and RMS & modelling as per the following link: https://www.planningportal.nsw.gov.au/major-projects/project/13681.

This indicates “The modification seeks to amend condition E11 - Ventilation Outlets - Limits, of the approval, to modify the Volatile Organic Compounds outlet limit from 1 mg/m3 to 4 mg/m3”.

A “data entry error” has been blamed as the reason behind the request to quadruple the VOC emissions. That makes me suspicious, given it is a State Significant Project which you would think would be checked and double-checked. In addition to that, I find the responses in the communications furnished by NSW Health in particular to be very casual to say the least – a three line email on a modification request that required half page advertisements in all the local media.

My concerns appear to be well justified as the story was on Channel 9 News on 3/9/2019 6.00pm, and in the Daily Telegraph online 4/9/2019 6pm.

https://www.9now.com.au/nine-news-sydney/2019/episode-252

https://www.dailytelegraph.com.au/newslocal/north-shore/pollution-levels-from-northconnex-motorway-smoke-stacks-set-to-quadruple/news-story/d1cf0990db7b2b39462d0a419833c3a7

Given I live near the site and may need to use it, I wonder what impact this will have on the air quality in our local environment? While I am told NorthConnex is about “taking trucks off the road”, a day doesn’t go by without a truck(s) break down on Pennant Hills Road, so I suspect they will break down in the tunnel too, when these emissions are likely to increase.

As usual, the exhibition period is very short (30/8/2019 to 12/9/2019), and the process to make a submission increasingly cumbersome, particularly for those without internet access or who do not receive the local paper.

While I expect this will get the rubber stamp of approval, because a precedent has been set with WestConnex, I wish to object for the aforementioned reasons.

Dear Sir/Madam,
We live close to Northconnex and we are really concerned and object to this modification (to increase the emission rate limit by 300% from 1mg/m³ to 4mg/m³.

1. The original emission rate limit as 1mg/m³ should be kept therefore any abnormal emission would trigger a notification for the proper handling. We should keep the normal emission rate limit as low as possible instead of allowing a spike limit to be used a daily basis one.

2. Install more air (pollution) monitor stations and collect as much data as possible. This is the proper way to have enough data to confirm if the tunnel has no impact to the local environment.
It’s the truth that the real data always beats any prediction which got calculated on paper. We need the real data for understanding if there is an impact or not.

3. Increase the stack to the appropriate height.

4. Install filters into the stack to reduce the emission
Different tunnels are with different scenarios. The excuse like "other tunnels like the Sydney Harbor Tunnel doesn't have filters" should NEVER be used as an official reason for Northconnex not to use filters in the stack.

5. Put the same low emmision rate of 1mg/m³ to the emergency extraction stack as well and more transparent for the rules for the case need to use the emergency extraction and don't change the emergency extraction stack to daily extraction stack.

Thanks.

I object to increase emission rate limit by 300% to 4mg/m3.

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.
Currently, 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 those two WPS (Waitara Public School ~500m circle, and Wahroonga Public School ~1.25km circle)

3. Increase the stack to appropriate 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 ):
"Good Engineering Practice" (GEP) Stack Test Height - The greater of:
1. 65 meters, measured from the ground-level elevation of the base of the stack;
2. Hg = H + 1. 5 L,
where Hg = good engineering practice height, measured from the ground-level elevation at the base of the stack,
H = height of nearby structure(s) measured from the ground-level elevation at the base of the stack,
L = lesser dimension, height or projected width of nearby structure(s)
The Department or EPA may require the use of a field study or fluid model to verify GEP stack height for the source

4. Install filter into stack, to actually reduce the emission.
First, existing use case like "other tunnel like the Sydney Harbor Tunnel doesn't use filter" should NOT be used as a reason for Northconnex not to use filter in stack. Every tunnel has its special situation; they are independent. Even we say the "Sydney Harbor tunnel" is a okay not to use filter, I do think the following reasons which makes it okay:
1) It's much shorter, and its depth is much less than NorthConnex
2) There are far fewer trucks passing the "Sydney Harbor Tunnel"; most of them are general sedans/cars. While NorthConnex is built for heavy trucks
3) when "Harbor Bridge Tunnel" was built, it was not designed for today's high traffic per day
In short, it's not an excuse to refer to the "Sydney Harbor Tunnel" as the reason for no filter in stack

We have grave concerns about the pollutants and the level of pollutants approved for this project. There are many young families and it is a hub for many schools in the area who will be adversely impacted. People in the area will be subject to an irreversible and serious health risk due to pollutants. It should not be approved.

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

I strongly OBJECT to the modification request by RMS to amend condition of approval E-11- Ventilation Outlets-Limits to modify the approved Volatile Organic Compound (VOC) limit from 1mg/m3 to 4 mg/m3.
I have great concern regarding the following issues:

1. The increased level of VOC's from 1mg/m3 to 4mg/m3 from the northern ventilation stack in the densely populated residential area of Wahroonga will expose local residents, over 9,300 school children, multiple aged care facilities, hospitals and businesses to far greater concentrations of harmful emissions.

2. Many largescale research studies across the world have shown that air pollution is a major environmental risk to health, which increases the risk of stroke, heart disease, lung cancer, and both chronic and acute respiratory diseases. 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. Many of the VOC's, including benzene and formaldehyde from vehicle exhaust, are classified as Group 1 carcinogens to humans (IARC 2009).

3. There has been a lack of consultation and communication and been enough time has been given for the submission process.

To address my concerns, I request that the following actions are undertaken:
1. The department of planning does not approve of the proposed modifications, due to the significant health risks to the community.
2. The ventilation stack emissions be filtered before release into the air, as in Recommendation 13, December 2018 NSW Parliament Legislative Council Public Accountability Committee Report on the Impact of the WestConnex Project.

Firstly I/we would like to state that I/we 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/We 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/We am/are 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

Sincerely,
Nancy Wong

Dear Sir/Madam,

Here’s why I'm objecting to this modification (to increase the emission rate limit by 300% from 1mg/m³ to 4mg/m³.

1. The original emission rate limit as 1mg/m³ should be kept therefore any abnormal emission would trigger a notification for the proper handling. We should keep the normal emission rate limit as low as possible instead of allowing a spike limit to be used a daily basis one.

2. Install more air (pollution) monitor stations and collect as much data as possible. This is the proper way to have enough data to confirm if the tunnel has no impact to the local environment.
It’s the truth that the real data always beats any prediction which got calculated on paper. We need the real data for understanding if there is an impact or not.
Currently, the situation is:
-- NO air pollution monitors located in circle of 0.25km radius
-- NO air pollution monitors located in circle of 0.5km radius
-- NO air pollution monitors located on the east side of the NorthConnex in Wahroonga area
-- NO air pollution monitors located close to those two public schools:
WPS (Waitara Public School ~500m circle, and Wahroonga Public School ~1.25km circle)

3. Increase the stack to the appropriate height. The current stack height is planned as ~26m only. The height as 26m is far less than the Australia standard (https://www.epa.gov/sites/production/files/2017-12/documents/62.7-2017.pdf ):
"Good Engineering Practice" (GEP) Stack Test Height - The greater of:
1. 65 meters, measured from the ground-level elevation of the base of the stack;
2. Hg = H + 1. 5 L,
where Hg = good engineering practice height, measured from the ground-level elevation at the base of the stack,
H = height of nearby structure(s) measured from the ground-level elevation at the base of the stack,
L = lesser dimension, height or projected width of nearby structure(s)
The Department or EPA may require the use of a field study or fluid model to verify GEP stack height for the source

4. Install filters into the stack to reduce the emission
Different tunnels are with different scenarios. The excuse like "other tunnels like the Sydney Harbour Tunnel doesn't have filters" should NEVER be used as an official reason for Northconnex not to use filters in the stack.
We no longer live in 1990’s. We should stay tuned with the modern design trends.

Thanks.

I object not only to the fact that no filtration has been approved but that we are not being told that the levels are to rise from 1mg/m3 to 4 mg/m3.
I am deeply concerned that these increases will severely affect the health of all the residents which has a high density of schools, retirement villages and nursing homes as well as yet to be born babies. Many of these pollutants will have high levels of benzene and formaldehyde which are Grade 1 carcinogens to humans.
I request that these changes are not approved. I also find it unacceptable that changes can be put through on a typing error. Which organisation or person would be able to justify major changes let alone ones that our detrimental to society on that excuse?

I request that you do not approve the changes as I believe we have been misled
That filters should not be ignored and are applied to the ventilation outlet as per Recommendation 13 in the December 2018 NSW Parliament Legislative Council Public Accountability Committee Report on the impact of the WestConnex Project.

We do not need this to be an issue where to little too late was done. We deserve clean air and for this not to be turned into another health issue like asbestos or led poising in years to come.
Surely we are entitled to clean air?

I object to this application. This is classic developer bait and switch. Initially, the developer promises a high level of performance in order to gain approval for a project and then, once it has been completed to such an extent that it can't be removed, requests approval for a reduction in the level of performance.

The explanation that there has been a "transcription error" seems extremely unlikely for such a significant project. I note that no evidence has been provided for this transcription error. Rather it is just presented as a fact that we are required to believe. If there was an error, why has it taken so long for it to be identified? Again, there is no explanation for this, and we are just required to accept that no one has looked at this during the design and build of the tunnel. I note that the application for the modification says that all other applications for subsequent major tunnel projects have been able to be prepared without any errors. I therefore don't believe that a transcription error is a reasonable explanation that can be used to justify the change.

Therefore I don't believe that there are any grounds to support the modification. Further, if the modification is approved, then it will provide a precedent for future "transcription errors" leading to future reductions in performance that will adversely affect the public and benefit the developer.

I wish to register my objection to the Northconnex project's ("the Project") request to increase the ventilation outlet limit ("the Modification Request").

The Project is proposing a 400% increase in allowed VOC emission levels from 1mg/m3 to 4mg/m3. The result will be to adversely affect the air quality of the surrounding Wahroonga and neighbouring communities. Over 9,300 school children will be exposed as well as multiple aged care facilities, hospitals, businesses and homes.

VOCs are a class of environmental pollutant and include benzene and formaldehyde, which are classified as Group 1 carcinogens (ref: IARC 2009). There is no 'safe' limit of VOCs and no such literature has been referenced by the Project in its Modification Request for scrutiny by the community.

When VOCs react with NOx molecules, ozone is formed. In the short term, exposure to ozone can result in reduced lung function and the exacerbation of respiratory diseases. In the long term, ozone is a known cause of cancer, and 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.

The Project in its justification points to the EPA's assessment that "the AECOM modelling demonstrates increased VOC emissions limit does not result in adverse air quality impacts". This is logically and factually incorrect. It is, logically speaking, a nonsense that increasing emissions of a class of pollutant such as VOCs will not result in adverse air quality impacts.

The "EPA Letter Response", states that the "EPA also notes the AECOM modelling demonstrates the increased VOC emission limit from 1 mg/m3 to 4 mg/m3 does not result in adverse air quality impacts." However, the provided AECOM "Dispersion Modelling Results" makes no such claim. AECOM merely notes that the levels "would result in no exceedances of the speciated VOCs" and in fact, as would be logical, their modelling shows an expected increase in the level of VOC pollutants emitted into the atmosphere. With regard to the 'exceedances', the levels to be exceeded have not been exhibited in the Project's Modification Request and have thus been kept from scrutiny. The EPA's assurance that there will be no adverse air quality impacts should therefore be rejected on the grounds that the modelling provided actually demonstrates an increase in pollution levels, and that neither the EPA nor the Project has not exhibited any justification as to why the VOC levels modelled will not adversely affect the local community's air quality and health outcomes.

The Project has chosen to exhibit no alternatives to its Modification Request. The Project has not provided any expert advice or assessment of options that could reduce, if not eliminate, the level of VOC emissions (or the level of the many other pollutant categories, such as Diesel particulates) that will adversely affect the air quality of the local community. For instance, there has been no consideration of the option of filtration of emissions. The increase of pollutant emission levels should be a last choice and not a first choice for a major, highly impactful project such as NorthConnex. I don't believe the Project's current Modification Request has put the mitigation of risk to the local community's health outcomes and environment ahead of its other priorities. The reduction of risk to the local community must always come first.

The Project has not acted in good faith in its engagement of the impacted Community. I note for instance that the exhibition period of two weeks for the Project's Modification Request is the shortest of any of the other major project planning requests currently active on the Dept of Planning's website. There has generally been no engagement with the local community beyond the minimum that is statutorily required of them. One must wonder if that is to reduce the opportunities the local community and other stakeholders to scrutinise its activities and raise its objections.

It is my view and request that the following actions are undertaken:
1. The Department of Planning does not approve the Project's proposed modification request.
2. That the Project be required to assess the feasibility of alternatives to the increase of VOC and other pollutant emissions. This to include the option that the ventilation outlet emissions are filtered before release into the air, as per Recommendation 13 of the December 2018 NSW Parliament Legislative Council Public Accountability Committee Report in the Impact of the WestConnex Project. Notwithstanding a superior option, filtration of NorthConnex emissions should be strongly preferred, whilst the very notion of an increase in damaging pollutants to be relegated as the very last, and not first, choice.