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

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:

The increased level of VOC's from 1mg/m3 to 4mg/m3 from the northern ventilation stack in Wahroonga will lead to more than 9,300 school children, hospitals, multiple aged care facilities, local residents and businesses in this densely populated residential area of Wahroonga being exposed to far greater concentrations of harmful emissions.
Worlwide research studies have shown that air pollution is a major health risk. These studies confirm air pollutants have prothrombotic and inflammatory effects on humans which increases the risk of stroke, heart disease, lung cancer, and both chronic and acute respiratory diseases. Recent research also suggest low birth weight for pregnant women, increased autism and congenital heart defects. Many of the VOC's, including benzene and formaldehyde from vehicle exhaust, are classified as Group 1 carcinogens to humans (IARC 2009).
There has not been enough time given for the submission process, especially since there has been a lack of consultation and communication.

I request that the following actions are undertaken to address my concerns:

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 prior to releasing into the air, as the NSW Parliament Legislative Council Public Accountability Committee Report on the Impact of the WestConnex Project, December 2018; Recommendation 13.

Thank you for this opportunity to make a submission about the proposal to increase the North Connex emission limit. I object to any increase in the emisions permitted.

Long term exposure to fine particles is an important health risk. (see Pope's 2002 American Cancer Society cohort) (also Bowatte's 2016 study of traffic related pollution exposure over 5 years).

Rather than accept an increasingly polluted environment we should be actively looking at clean options. North Connex could be a participant in this by:
1. Filtering stacks
2. Giving toll discounts for low emission electric vehicles.

I am keen to know whether these are being considered.
Yours Sincerely
Dr Barbara Davis (member of Doctors for the Environment Australia

please see attached letter.

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

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

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.
The basis of my objection is as follows:
• The approval for the North Connex Tunnel was made some years ago
• The approval was based upon a VOC level of 1 mg/m3.
• The EIS was based on a 1mg/m3 level
• The approval is subject to the monitoring of emissions from the stacks based on the original estimate of emissions
• This arbitrary increase in the level of VOC invalidates the original approval and the monitoring process
• The assessment of what is an acceptable levels of emissions from the two ventilation stacks on the North Connex tunnel are not comparable to other tunnels and should be assessed on a stand-alone basis
• In any case, the emissions from the tunnel should be filtered in order to ensure the future health of the local residents who will be subject to exposure to high levels of pollutants from the emission stacks. That is, the exhaust emitted from traffic travelling through a 9 kilometre (mainly trucks) being ejected out of a single stack. One at the northern end, and one at the southern end
• It has been estimated that over 9000 children attending local schools around the Wahroonga area will be affected by the denigration of the air quality and the associated health risks. This is not acceptable and it is the responsibility of government to care for the health and wellbeing of our children and our community.

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

Too much air pollution will be caused by this ventilation outlet without sufficient filter.

Dear sir/madam,

Volatile Organic Compounds (VOCs) can produce a spectrum of illnesses from mild (eg eye, nose and throat irritation) to very severe (eg cancer). It can lead to upper respiratory infections, nausea, and headaches. It can aggravate existing respiratory diseases; and can cause chronic respiratory diseases, lung cancer, and heart disease with long term exposure. These effects have been seen at very low levels of exposure in many epidemiological studies. The community has ongoing concerns regarding the safety of the NorthConnex project with regards to air quality.

It is inappropriate to increase the approved limit of VOCs from 1mg/m3 to 4mg/m3. Whilst it is argued that this will provide a reasonable margin to manage short term incidents in the tunnel; it will permit this level of VOCs to be emitted at all times. If short term incidents could potentially lead to exceedances, then techniques outlined in the “Potential Ventilation System Modifications CoA B5 Report” should be employed to ensure this does not occur, and the limit should remain at 1mg/m3.

Increasing the limits undermines the community’s trust in the approval system. It is astonishing to believe that a supposed “transcription error”, resulting in the request of a 4 fold increase in the permissible VOC level, is only noted approximately 5 years after the EIS process, and only a few months prior to the original opening date of the project.

Having been very active in the “community consultation” process since the original announcement of the NorthConnex project in March 2014; I am anticipating the department of planning to ignore these concerns, just as they have ignored almost every other community concern regarding this project.

Yours sincerely,

Dr Elizabeth Johnson

The reported benefits of this tunnel project in improving air quality along the Pennant Hills Road corridor arrogantly ignores the health concerns of those who live, work and/or attend school in proximity to the ventilation outlets. These point sources of pollution place a health burden on those people. Volatile Organic Compounds (VOC) have been proven in many epidemiological studies to present health risks to the community. The risk posed from these (and other) chemicals is relative to the concentration in the air. As such a greater concentration of VOC presents a proportionally higher risk of harm to these people. When making determinations about limits on emissions from polluting stacks, it is incumbent on the Department of Planning to set limits which are as low as possible, rather than simply kowtowing to the wishes of developers who clearly have a profit focus, and whose principal aim here is to reduce running costs.

In suggesting an increase to acceptable VOC concentrations, the proponent uses "short term traffic incidents" to justify these changes but makes no reference to:
1. What incidents would necessitate such a change and how commonly this would be expected to occur
2. Why short term incidents necessitate a permanent change to permissible levels rather than using an "incident level" and returning to a lower "non-incident" (or background) level
3. Why it is in any way justifiable on any grounds that the above mentioned people in the community should be exposed to significantly higher levels of carcinogenic materials because of the proponent's reluctance to use measures within the design of the tunnel (such as running exhaust fans at higher speeds) to keep VOC levels lower.

The proponent should be held to the original determination limiting VOC levels to 1mg/m3 and any future adjustments should yield positive outcomes for the community subjected to the pollution rather than the proponent's bottom line. Stricter pollution limits would be in keeping with worldwide emission standards, which are progressively tightening due to improvements in technology and increasing concerns about the harm that these pollutants cause to humans.

I am a parent from the Abbotsleigh Junior School.
To mitigate the health risks posed by NorthConnex and ensure clean and unpolluted air for our local community, I demand for filtration of the tunnel emissions from the Wahroonga ventilation stack.
Please refer to the attached letter for detail.
Thank you!

The proposed change to the VOC emission limit of 4mg/m3, together with the associated modelling, fails to consider the views expressed by numerous world health and safety authorities that there is no safe emission thresholds or exposure limits for BaP (Benzo[a]pyrene). Yet the modelling uses a a criteria of 0.4. This criteria is at odds with the UK authorities which recommend a maximum exposure limit of 0.0002 mg/m3.
The modelling used makes no mention of the VOC concentrations and maximum likely VOC concentrations that will occur at the points of air intake for the tunnel exhaust ventilation systems. This will influence the concentration at the pint of discharge.
Safety in design considerations must dictate that the tunnel ventilation systems meet or exceed best practice in the world and include the necessary air scrubbing, catalytic and gas phase air cleaning systems necessary to ensure that all carcinogenic compounds including the BaP and formaldehyde and soot components are removed. These engineering controls must be in place to deal with all traffic contingencies within the tunnel and the air quality at the points of air intake to the the tunnels.
Accepting anything less will be harmful to the health of local residents, schools and hospitals which would be completely unacceptable and irresponsible.