NorthConnex

Sir/Madam,
I support the construction of the tunnel. However I have concerns regarding the working hours at the Trelawney Support facility site.

Your fact sheet dated July 2014 in the segment titled Construction Hours,states standard construction hours will be 7am to 6pm Monday to Friday. On Saturday the hours are 8am to 1pm with no Sunday or public holiday work .

Yet- in the data regarding Construction Traffic it states vehicle movements would occur up to 24 hours per day and 7 days per week-this seems to be a contradiction with the previous statement.

I strongly object to the removal of spoil from the site on a 24/7 basis. This will result in noise pollution to nearby residents and will infringe on their quality of life and peace of mind 24 hours per day

Secondly I object to the transport vehicles using Loch Maree Ave as an entry site to the facility. Entry and exit should be via a slip road to Pennant Hills Road from the site.

Finally if the authorities insist on using Loch Maree Ave as an entry point then could traffic lights be installed at Nelson St / Pennant Hills Road to enable residents from within this catchment area to exit the area safely.

Thank you

Please find below my submission in response to the exhibition of the EIS for NorthConnex.

Firstly I would like to state that 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.

2. The placement of the northern ventilation stack in a valley in Wahroonga where there are often low wind speeds, which will result in poor dispersion and exposure to community to high levels of tunnel emission.

3. 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.

4. I am concerned about the project including future provisions for portal emissions in densely populated areas, which will result in emissions remaining at ground level, and hence exposing the local population to pollutants. I am also concerned that NorthConnex's claim that there will no portal emissions from current proposal cannot be verified.

5. I am concerned about the large amount of diesel emissions which will be emitted from the NorthConnex tunnel, as it is being designed for heavy freight to bypass Pennant Hills Rd. Diesel emissions have been classified as carcinogenic by the World Health Organisation, and also contain a larger number of fine particles which penetrate deep into lung tissue and remain there causing inflammation.

6. I am concerned about the air quality within the tunnel which is shown in the EIS to have exceedences above standards for pollutants such as NO2, and haze from particulate matter at the ends of the tunnel.

7. I am concerned about the multiple flaws in the air quality modelling of the northern stack in the EIS. These include:
a) extrapolation of meteorological data from other weather stations which do not reflect the local meteorology, local topography, and the valley location.
b) The use of a coarse topographical model
c) The failure to consider polluted intake air from the Pennant Hills/M2 interchange as part of the project contribution to air quality at Wahroonga
d) the background air quality being based on air quality at Lindfield and Prospect and the lack of any actual data on PM2.5

8. I/we am concerned that a full and transparent options assessment process was not undertaken to assess alternative designs for the project. Unlike other tunnel projects in Sydney there are alternatives for locating the stack and portals in non-residential areas.

9. I am concerned that the justification for not providing filtration for the stacks is cursory and unconvincing.

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

1. The air quality and human health impact assessment need to be revised to address the issues raised above.
2. An independent options assessment process should be undertaken to assess alternative locations for the ventilation stack and portals.
3. To undertake a Life Cycle Analysis and assessment for the provision of filtration
4. A long term health study on children and residents in areas impacted by stack discharges be included as part of the conditions of approval.
5. A comprehensive air quality monitoring program is developed and implemented.
6. An independent review of the ventilation system is undertaken to ensure that NorthConnex's claim of no portal emissions is justified.
7. Portal emissions from NorthConnex in the future are banned.
8. The Submissions Report/Preferred Project be exhibited to allow the community to respond to the revised information contained in the report.
9. The Department does not approve the project in its current form as it clearly does not meet the principles of Ecologically Sustainable Development as required by the Environmental Planning and Assessment Act.

Joanna Joyce
10 Halcyon Ave
Wahroonga NSW 2076

Please find below my submission in response to the exhibition of the EIS for NorthConnex.

Firstly I would like to state that 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.

2. The placement of the northern ventilation stack in a valley in Wahroonga where there are often low wind speeds, which will result in poor dispersion and exposure to community to high levels of tunnel emission.

3. 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.

4. I am concerned about the project including future provisions for portal emissions in densely populated areas, which will result in emissions remaining at ground level, and hence exposing the local population to pollutants. I am also concerned that NorthConnex's claim that there will no portal emissions from current proposal cannot be verified.

5. I am concerned about the large amount of diesel emissions which will be emitted from the NorthConnex tunnel, as it is being designed for heavy freight to bypass Pennant Hills Rd. Diesel emissions have been classified as carcinogenic by the World Health Organisation, and also contain a larger number of fine particles which penetrate deep into lung tissue and remain there causing inflammation.

6. I am concerned about the air quality within the tunnel which is shown in the EIS to have exceedences above standards for pollutants such as NO2, and haze from particulate matter at the ends of the tunnel.

7. I am concerned about the multiple flaws in the air quality modelling of the northern stack in the EIS. These include:
a) extrapolation of meteorological data from other weather stations which do not reflect the local meteorology, local topography, and the valley location.
b) The use of a coarse topographical model
c) The failure to consider polluted intake air from the Pennant Hills/M2 interchange as part of the project contribution to air quality at Wahroonga
d) the background air quality being based on air quality at Lindfield and Prospect and the lack of any actual data on PM2.5

8. I/we am concerned that a full and transparent options assessment process was not undertaken to assess alternative designs for the project. Unlike other tunnel projects in Sydney there are alternatives for locating the stack and portals in non-residential areas.

9. I am concerned that the justification for not providing filtration for the stacks is cursory and unconvincing.

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

1. The air quality and human health impact assessment need to be revised to address the issues raised above.
2. An independent options assessment process should be undertaken to assess alternative locations for the ventilation stack and portals.
3. To undertake a Life Cycle Analysis and assessment for the provision of filtration
4. A long term health study on children and residents in areas impacted by stack discharges be included as part of the conditions of approval.
5. A comprehensive air quality monitoring program is developed and implemented.
6. An independent review of the ventilation system is undertaken to ensure that NorthConnex's claim of no portal emissions is justified.
7. Portal emissions from NorthConnex in the future are banned.
8. The Submissions Report/Preferred Project be exhibited to allow the community to respond to the revised information contained in the report.
9. The Department does not approve the project in its current form as it clearly does not meet the principles of Ecologically Sustainable Development as required by the Environmental Planning and Assessment Act.

Please find below my submission in response to the exhibition of the EIS for NorthConnex.

Firstly I would like to state that 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.

2. The placement of the northern ventilation stack in a valley in Wahroonga where there are often low wind speeds, which will result in poor dispersion and exposure to community to high levels of tunnel emission.

3. 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.

4. I am concerned about the project including future provisions for portal emissions in densely populated areas, which will result in emissions remaining at ground level, and hence exposing the local population to pollutants. I am also concerned that NorthConnex's claim that there will no portal emissions from current proposal cannot be verified.

5. I am concerned about the large amount of diesel emissions which will be emitted from the NorthConnex tunnel, as it is being designed for heavy freight to bypass Pennant Hills Rd. Diesel emissions have been classified as carcinogenic by the World Health Organisation, and also contain a larger number of fine particles which penetrate deep into lung tissue and remain there causing inflammation.

6. I am concerned about the air quality within the tunnel which is shown in the EIS to have exceedences above standards for pollutants such as NO2, and haze from particulate matter at the ends of the tunnel.

7. I am concerned about the multiple flaws in the air quality modelling of the northern stack in the EIS. These include:
a) extrapolation of meteorological data from other weather stations which do not reflect the local meteorology, local topography, and the valley location.
b) The use of a coarse topographical model
c) The failure to consider polluted intake air from the Pennant Hills/M2 interchange as part of the project contribution to air quality at Wahroonga
d) the background air quality being based on air quality at Lindfield and Prospect and the lack of any actual data on PM2.5

8. I/we am concerned that a full and transparent options assessment process was not undertaken to assess alternative designs for the project. Unlike other tunnel projects in Sydney there are alternatives for locating the stack and portals in non-residential areas.

9. I am concerned that the justification for not providing filtration for the stacks is cursory and unconvincing.

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

1. The air quality and human health impact assessment need to be revised to address the issues raised above.
2. An independent options assessment process should be undertaken to assess alternative locations for the ventilation stack and portals.
3. To undertake a Life Cycle Analysis and assessment for the provision of filtration
4. A long term health study on children and residents in areas impacted by stack discharges be included as part of the conditions of approval.
5. A comprehensive air quality monitoring program is developed and implemented.
6. An independent review of the ventilation system is undertaken to ensure that NorthConnex's claim of no portal emissions is justified.
7. Portal emissions from NorthConnex in the future are banned.
8. The Submissions Report/Preferred Project be exhibited to allow the community to respond to the revised information contained in the report.
9. The Department does not approve the project in its current form as it clearly does not meet the principles of Ecologically Sustainable Development as required by the Environmental Planning and Assessment Act.

I strongly object to the above proposal and wish to make the following points to which I would like a response:
- Unfiltered ventilation stacks should not be built in residential zones within such close proximity to homes, schools and hospitals.
- Every tunnel in Sydney currently have stacks located in industrial areas.
- Regardless of the location of stacks, in a modern society they should be filtered to reduce emissions as much as possible to protect our environment.
- In Japan filtration has proven to remove 90% of particulate matter.
- Residents should not be forced to have a stack directly in front of their home.
- It is immoral to allow any development that may be to the detriment of society's health.
-There are viable alternatives to locate the ventilation stacks.
- The stack has been designed too low, leading to poor dispersion of particulate matter.
- Local wind and weather studies show that the assumptions applied in this proposal are flawed.
- Prior to any further developments with this project, 12 months of weather observations and data collection are necessary in order to assist with a best practice design.

To the NorthConnex Project Management:
The proposed project will be a great piece of infrastructure for both Sydney and NSW road users. However proposed use of the tiny street LOCH MAREE in Thornleigh as a route for inbound traffic and trucks to the Trelawney St Tunnel support facility will be crippling for the traffic into and out of the immediate area. As you can see on any map there are no alternate routes for local traffic to use. Access from Pennant Hills Road ONLY in and out of the site will not make a huge difference to the noise or congestion on the Pennant Hills Road itself but the use of a small side streets such as Loch Maree Ave will mean prolonged disruption to numerous residents for years! This area will be completely unbearable for the community to live in with large trucks 24 hours per day 7 days a week! No one day of peace. It is not fair to place such a long term burden on Loch Maree residents.
PLEASE KEEP THE TRUCKS ON PENNANT HILLS ROAD PLEASE!

Director - Infrastructure Projects
Department of Planning and Environment
Number: SSI 13_6136
Major Projects Assessment
GPO Box 39
SYDNEY NSW 2001
NorthConnex Application Number: SSI 13_6136
Please find below my submission in response to the exhibition of the EIS for NorthConnex. As it does meet the project objectives listed below.
Please I note I endorse the submission of the CAPS group. I have read what the caps group will submit.
Follows my own submission
Terry Cook
I am a senior citizen who chose this location to reside so I would be near a train station for when I can no longer drive. Near a hospital for medical needs. If this stack goes ahead I will need to sell my house at below market value. I am trying to retain good health as long as possible and breathing the cocktail of chemicals that comes from the stack will be very detrimental to my health.
This will impact on my financial situation and I don't see myself being able to be a self funded retiree as was my aim. I will have to fork out thousands of dollars in stamp duty for a new home. I won't be able to afford another home close to a station and other facilities that my present location provides.

Summary:

1. Air Quality
2. Destruction of local Amenity and Visual Impact.
3. Alternative Solution for positioning of Northern Portal and Ventilation facility.
4. Tunnel design.

 
Destruction of local Amenity and visual impact.

Attached photos. Fig.7-60.1, 7-61.
1. The placement of Northern portals and ventilation facility will turn a once residential area into an industrial area.

2. This can be proven because they have had to demolish homes to accommodate this industrial complex.

3. Many people in the area where told this was a heritage area and presumed they would be protected from adverse development.

4. If they no longer wish to reside in an area that has been turned into an industrial precinct. The same reasons they want to leave will be the same reason that will prevent people buying in the area. Reducing the market value of the surrounding properties.

5. Those wanting to sell but wish to buy in an area offering the same facilities i.e. close to schools, hospital, transport and shopping will find they cannot afford to do so.

6. So compensation should be paid by transurban and stamp duty on the new property should be waivered by the Government who put their seal of approval on this project.
 
Air Quality
By the placement of the portals and the ventilation facilities in residential area.
The residents and school children of this area are put at a higher risk than in previous tunnel projects, where industrial and commercial area have been used to accommodate these ventilation facilities. It would also be found that the other current stacks are at a greater height helping to disperse the pollutants into the atmosphere.

Attached page 448 north connex EIS
There is also concern that portal emissions are being considered in the future.
I wish to refer to this document website below.
At this date 28/8/2014 these very vital pages to this report are missing.

1. Trends in motor vehicle emissions

4. Road tunnel ventilation systems

6. Road Tunnel Portal Emissions

8. Options for treating Road Tunnel Emissions

10. Role of Regulators for tunnel projects

11. Criteria for in-tunnel and ambient air quality
Papers are at http://www.chiefscientist.nsw.gov.au/reports
The air quality modelling for this project has relied on monitoring data from Lindfield and Prospect a considerable distance from where these impacts are going to occur.
Northconnex have had ample time to place monitoring stations in the relevant area even today there is no proposal to monitor air quality at the sites of the portals and ventilation facilities to give air quality readings prior to the construction period, during the construction period, and during the operation of the tunnel.
Other countries e.g. Canada utilise mobile monitoring stations. Why not this Billion dollar company?
Public/stakeholder consultation process has been criticised in the past, but it seems was improved recently in the lead up to the EIS and after its release. However, it has failed to translate many of the concerns that were raised during earlier consultation stages. This includes three out of five of the main issues highlighted by stakeholders in the 2004 report - ventilation outlets (predominantly issues around number and location of outlets), general concerns about air quality, and health impacts (NorthConnex EIS, p.219). Although it has been stated that such feedback was considered as part of the recent design development, the EIS fails to sufficiently address and respond effectively to the public health concerns of local residents.
One main issue is that the EIS's technical working paper on air quality, Appendix G, fails to provide any options for local monitoring of air quality in the community surrounding the northern ventilation outlet. There are strong concerns that air quality of the local area will be impacted. Yet, there is no planned in stack air quality monitoring. Environmental management measures for air quality include monitoring in the `vicinity of the project' (OpAQ2, EIS p.528). Responding to local community concerns, and reducing the potential health impacts on local residents, in stack air quality monitoring must be implemented.
* Appendix G provides results of studies proving the ineffectiveness of filtration However, it provides a biased approach and lacks in providing research supporting a filtrations system or any other alternatives, which would directly address community concerns that should have appropriate response as part of the EIS and greater consultation process.
* Precautionary Principle:
* The EIS has identified the precautionary principle within the context of the project and in supporting ecologically sustainable development (ESD) as defined by the Environmental Planning and Assessment Act 1979. The precautionary principle is also supported through the Intergovernmental Agreement on the Environment (1992), which is the framework used by all levels of government in Australia and supports the use of the ESD principles in areas including environmental impact statements.

With regards to predicted air quality, the EIS reports that "...the low levels of predicted pollutant concentrations do not indicate that further mitigation would be required for the operation of the tunnel." (EIS, Appendix G, p.169) However, in applying the precautionary principle, sufficient research and continued monitoring should be included to avoid exceedances in air quality and potential health impacts on the local community.
Reference has been made by Northconnex that fresh air will be pulled into the tunnel through the piston action of vehicles entering the tunnel as the entrance of the North bound tunnel is situated in the vicinity of the M2 it is very likely that the air already will contaminated by the pollutants from the M2 and the southern ventilation facility drastically altering the calculations applied to the fresh air supply.Ref: Page 467 Eis
Ref: Page 449 Eis
Ref:Community against pollution stacks eis submission.
 
Alternative Solution for the Position of Northern Portal and Ventilation Facility.
See Attached: Photos fig: 5-9 and 5-18
As they are using the tunnelling method cut & cover to link the main tunnel to the exit portal,the cut & cover method could be extended by 2klms north along the motorway. Where the portal and ventilation facility could be bounded by the industrial area of Asquith and National Park and green belt. This would create a buffer zone between these facilities and residential area.

 
At the time of writing this submission Tony Abbott has made comment about the Pink Batts debacle during the GFC.
As a timely reminder of what can happen when Government rush things through.
It is quite obvious that this Northconnex project is being rushed through without proper enquiry into the health effects. 
Tunnel Design.

When the M5 East was first designed it had 3 ventilation stacks along 4 klms lengh. This was changed on 1 stack placed in the suburb of Turella. The M5 has now turned out to be one of the most polluted tunnels in the world.
Northconnex is twice as long and has 2 ventilation stacks. It appears the mistakes made in the design M5 are being repeated in the Northconnex design.
It is of great concern that Nsw Health report an spike in lung cancer in the Turrella area.

To address my/our concerns I request that the following actions are undertaken:

1. The air quality and human health impact assessment need to be revised to address the issues raised above.

2. An independent options assessment process should be undertaken to assess alternative locations for the ventilation stack and portals.

3. To undertake a Life Cycle Analysis and assessment for the provision of filtration.

4. A long term health study on children and residents in areas impacted by stack discharges be included as part of the conditions of approval.

5. A comprehensive air quality monitoring program is developed and implemented.
An independent review of the ventilation system is undertaken to ensure that NorthConnex's claim of no portal emissions is justified.

6. Portal emissions from NorthConnex in the future are banned.

7. The Submissions Report/Preferred Project be exhibited to allow the community to respond to the revised information contained in the report.

8. The Department does not approve the project in its current form as it clearly does not meet the principles of Ecologically Sustainable Development as required by the Environmental Planning and Assessment Act.

Name: Terry Cook
Address 84 Woonona Ave
Wahroonga 2076
Signature

PROPOSED NORTHCONNEX M1 / M2 TUNNEL PROJECT - Application Number - SSI 13_6136
We object to many aspects of this project
We would like to record that we are in favour of a tunnel linking the M2 with the F3 / M1. We see this as a necessary improvement to The Hills Area and the Sydney road network as a whole. It will clearly benefit most residents along the Pennant Hills Road corridor. It will also greatly benefit the long-haul freight vehicles travelling between Victoria, New South Wales and Queensland. However, we have serious concerns with regard to the tunnel project as it is currently proposed in the NorthConnex Environmental Impact Statement (EIS).
Our concerns fall into six sections. These are:
1. The Environmental Impact Statement (EIS) does not show any connection between the ventilation stack and the southbound tunnel which is 250 metres away. Will the polluted air be allowed to flow like an invisible sewer through West Pennant Hills, North Rocks, Carlingford and Beecroft?
ACTION: Provision of diagrams and detailed description of what ventilation is proposed for the southbound tunnel at the Southern Interchange. We would liketThe opportunity to lodge further submissions once that has been provided.
2. The ventilation stack should be located immediately above the tunnels on the corner of the Pennant Hills Golf Course and the M2. NorthConnex admit that this is the most efficient location for the stack. Why is the stack not being correctly located and positioned as far as possible away from homes?
ACTION: Purchase of golf course land to position the stack in its most effective location.
3. The ventilation stack must be filtered. It is accepted scientifically and medically that there are no safe levels of diesel emissions which are a Group 1 carcinogen.
ACTION: Filtration of the ventilation stacks to provide a safe and sustainable environment.
4. The NorthConnex proposal to use Aiken, Oakes, Eaton and Karloon Roads for construction traffic is totally unacceptable. We propose that construction vehicles turn right on to the M2 from Pennant Hills Road, drive to the Windsor Road Passover, double back along the M2 and access the construction compound directly by the creation of a ramp from the M2 straight into the construction compound. Trucks heading north should also exit via this ramp onto the M2 if they do not have direct access to Pennant Hills Road.
ACTION: Adoption of our proposal as detailed above. The route proposed by NorthConnex must not be used.
5. The restoration and preservation of the landscape around residential properties, especially along the M2 and those homes immediately close to the construction compounds and boundary walls, is of vital importance.
ACTION: Landscaping on the residential boundary of NorthConnex buildings, walls, compounds etc. to maintain the leafy outlook of homes and the parkland look of our suburbs.
6. The general public, and the local community in particular, must be kept informed of the changes made to the EIS as a result of the submissions sent by concerned residents and consulted going forward.
ACTION: As the EIS does not provide sufficient detail, on-going community consultation is seen as important and necessary. More information and detail must be provided.
We would appreciate a detailed review of our concerns and we await the supply of the requested additional information.

SUMMARY OF ADDITIONAL CONCERNS IN RELATION TO
THE PROPOSED NORTHCONNEX TUNNEL
Application number - SSI 13_6136
This is an objection to many aspects of the proposed NorthConnex tunnel.
As stated in our first submission dated 6th August 2014, we have serious concerns with regard to the tunnel project as it is currently proposed in the NorthConnex Environmental Impact Statement (EIS). Since filing our first submission we have learnt of new information in relation to our original concerns and a number of additional issues have surfaced.
We are really concerned that the proposal put forward, that is, the Unsolicited Bid, does not appear to take account of best practice from either a health or a technology perspective. Current international research and practical application provide clear evidence that this Bid is not world¡¦s best practice ¡V nor does it appear to take full account of Governments¡¦ (State and Federal) ¡¥Duty of Care¡¦ obligations under their respective Work, Health and Safety Legislation.
This tunnel will be the longest urban road tunnel in the World.
Australia has an opportunity to be a World Leader yet NorthConnex is proposing a project that falls short of contemporary best practice. Why are the governments of Australia, State and Federal, allowing construction of infrastructure in Australia that does not take account of known international advances in technology?
This submission lists concerns falling into six sections:
,,« Section A - Page 2
The location of the NorthConnex Southern Ventilation facility at the Southern Interchange.
,,« Section B - Page 4
Lessons learned from the failed M5 East tunnel
,,« Section C - Page 6
The case for filtration of Sydney tunnels
,,« Section D - Page 10 Properly designed filtration systems
,,« Section E - Page 11
Ongoing monitoring of surface air quality at the tunnel portals
,,« Section F - Page 12
Flooding problems downstream of the southern interchange ¡V impact of the water treatment plant
.
,,« Section G ¡V Page 12
Southern Interchange - detention basin: Lisle Court Reserve.
Date: 7th September 2014 SCAPS Group Page 2 of 12
SECTION A:
THE LOCATION OF THE NORTHCONNEX SOUTHERN VENTILATION FACILITY
Environmental Impact Statement (EIS) Page 448 asserts that:
¡§The most efficient location for ventilation outlets is close to the main alignment tunnel exit portals. This is because vehicles travelling through the tunnels create a piston effect, which draws air into the tunnel and pushes it forward in the direction of traffic flow. Locating the ventilation outlets near the main alignment tunnel exit portals maximises the benefit of the piston effect and minimises the need for additional energy consumption to operate tunnel jet fans and to transport the exhaust air from the tunnel to the outlet. This approach provides environmental benefits through the reduction in energy consumption and greenhouse gas emissions from the project.¡¨
According to this statement the most efficient, effective and economical location of the Southern Stack would be on the highest ground close to the vicinity of the portals, that is, the south-western region of the Pennant Hills Golf Club, directly above the twin tunnels. (A significant change to the original M5 East proposal was to move from three stacks situated on high ground, to a single stack positioned in the valley. The outcome is well known. We should learn from history, otherwise we are doomed to repeat it)
When we questioned the proposed location with the NorthConnex staff at the many briefing sessions we attended, we were consistently informed that the Roads and Maritime Service (RMS) already owned the land on the opposite side of Pennant Hills Road and that this land was therefore the best place for the Southern Stack.
A simple search of the NSW Land and Property Titles and confirmed by the Hills Shire Council, revealed that the RMS owns FOUR blocks of land in the exact position where the Stack needs to be. See diagram and extract below.
Date: 7th September 2014 SCAPS Group Page 3 of 12
This land is the ideal location for the southern ventilation stack.
Speakers at the NorthConnex Air Quality Forum spoke of the importance of the topography in the placement of the ventilation facilities. In the NorthConnex proposal the southern ventilation facility is at the lowest point of the M2 intersection where it is surrounded on three sides by hillside cuttings. In this location the ¡§discharge point¡¨ will barely be above the adjacent high ground.
How can this be the most suitable position for the outlet when land that is more suitable is already owned and available?
Much is made of the intention to discharge the polluted air through the stack at 13 ¡V 19m/s. Given that the stack is only 15m above Pennant Hills Road, a simple calculation indicates that the particles will be ejected to a height of between 23m and 33m above Pennant Hills Road. That will only be sufficient for them to be dispersed by prevailing winds IF there is wind and it is strong enough. For instance, the weather history graph showing the wind speed and direction at West Pennant Hills measured on the 24th August 2014 indicated that there was no wind until 9am and what wind there was, came from the west. Wind speeds of less than 2m/sec (ie about 8km/hour) are not considered sufficient to disperse pollution from the stack. Only a very few gusts on this day were in excess of 8km/hour.
We also noted the EIS Page vii Certification Declaration which states:
I certify that I have prepared this environmental impact statement in accordance with the Director-General¡¦s Requirements dated 11 April 2014. The environmental impact statement contains all available information that is relevant to the environmental assessment of the infrastructure to which the statement related. To the best of my knowledge, the information contained in the environmental impact statement is neither false nor misleading.
Name: Scott Jeffries Todd Brookes
Date: 02 July 2014
The EIS does not contain all available information that is relevant for a fair assessment and understanding of the project, and it is more than misleading ¡V it is patently incorrect. As documented above, the RMS owns FOUR blocks of land in the exact position where the Southern Stack needs to be. It is accepted that a small amount of additional land may have to be purchased to accommodate access.
The absence of relevant information appears to be a deliberate strategy but the question must again be asked ¡V why? One has to ask why the community appears to have been consistently misinformed by omission, when the RMS is in a position to place the Stack, (by its own admission in the EIS), in its most effective and efficient location!
Requirement 1: That the Government ensures that the southbound ventilation facility ie the Stack, be located at the south-west corner, on the RMS owned land, at the edge of the Pennant Hills Golf course. In this location, the southbound tunnel can be efficiently, effectively and economically ventilated. The impact of the stack plumes on the surrounding residential areas must be modelled using its current proposed position and height and also modelled with the stack positioned on the golf course side of Pennant Hills Road, where it is topographically higher. This would allow an objective, impartial, scientifically based assessment to be made of the most effective location for the stack. (NB: RMS were asked to carry out the golf course related modelling but verbally declined). In addition, to ensure best health outcomes for the residents, the ventilation facility must be properly filtered.
Date: 7th September 2014 SCAPS Group Page 4 of 12
SECTION B:
LESSONS LEARNED FROM THE PROBLEMATIC M5 EAST TUNNEL
Given the dubious history associated with the M5 East AND other tunnels such as the Lane Cove Tunnel, there is significant West Pennant Hills community concern in respect of the standards of ¡§modelling¡¨ that have been undertaken in relation to the proposed NorthConnex ¡Ó 9km twin tunnel project. Having attended all the drop-in information sessions, we became aware that many of the NorthConnex staff had worked on other tunnels around Sydney. Not surprisingly no one owned up to being involved in the M5 East tunnel.
The design of the stacks and the ventilation mechanisms are dependent on reliable raw data such as the anticipated volume of traffic. With respect, Government has miscalculated appallingly in relation the M5 East tunnel where they estimated an increase in traffic numbers of 1% per year, whereas the real figure was 1% per month! The Government is being litigated against for over-representing the vehicle numbers in the Lane Cove Tunnel . Given this recent history, it is reasonable to question the accuracy of the current estimates in relation to both the traffic volumes and the plume modelling of particulate matter and nitrogen dioxide. The Government does not have a good track record with regard to modelling.
The modelling of dispersal of the pollutants by the prevailing winds using data gathered from weather stations at Sydney airport and Terrey Hills is clearly not satisfactory. Both the airport station and the Terry Hills weather stations are close to the coast where the winds are influenced by the ocean. The Southern and Northern ventilation stacks are much further inland and in valleys where there is frequently little or no wind. Instead, as currently proposed, there will inevitably be considerable plume strike (location(s) unknown). A well-designed tunnel filtration system would make this questionable ¡§modelling¡¨ obsolete
The issues associated with the M5 East tunnel have resulted in numerous reports and studies commissioned by the NSW Government in an attempt to allay fears. These have included studies into the effects of portal emissions, of apparent exceedances of air quality limits by the stack and three Parliamentary inquiries, all of which led to the uncovering of new and greater problems. In many cases, these problems were only identified by the release of confidential records of Government departments supplied under the motions of the NSW Legislative Council1.
Of particular note in relation to the M5 East Tunnel, it became apparent that in 2003/4, the tunnel operator, with the approval of RMS but contrary to the tunnel's conditions of approval, dumped large volumes of vitiated air (in excess of 400 m3/sec) from both tunnel portals in response to apparent high carbon monoxide levels in the tunnel. These emissions occurred day after day and lasted for in excess of 8 hours in some cases. In fact these 'levels' were the result of a faulty monitor which gave results in obvious error for almost 12 months before the fault was identified.
The net result of this mistake (which only came to light just before the tabling of documents relating to the operation of the tunnel in the Legislative Council), is that there had been a marked increase in eye irritation, headaches and asthmatic-related incidents in the vicinity of that portal. In fact, Health Department documents from that time stated that there was ¡§prima facie evidence of adverse health effects related to the vent stack¡¨. There never were excessive levels of carbon monoxide in the tunnel, simply shortcomings in maintenance and management oversight systems. It is not surprising that it is felt by many, that Government has little credibility and cannot be trusted to always do the right thing!
It is accepted that the filtration systems put into place in the M5 East Tunnel were less than efficient. Questions should firstly be asked as to why, with the first version of the filtration trial, it took almost two years to reach a decision to determine which of the three groups short-listed would be granted the tender; (originally 13 companies registered an interest in providing the filtration system). The net result of this Government bureaucracy and apparent Ministerial procrastination was that the Government was left with no option but to go with the only company that still displayed an interest. With no competition, Siemens Ltd/FILTRONtec Gmbh was the only option.2
1 Submission to the Senate of the Commonwealth of Australia Standing Committee on Community Affairs Reference Committees¡¦ Inquiry into the Impacts on Health of Air Quality in Australia (March 2013): Mark Curran representing ¡¥Residents Against Polluting Stacks Inc.
2 Mark Curran (RAPS Inc): Personal communication documents.
Date: 7th September 2014 SCAPS Group Page 5 of 12
The outcome is well documented. There were technical, operational and oversight issues related to the:
,,« Air flow turbulence associated with the design prior to entering the electrostatic filter; no stabilizing pre-filter; the lack of clarity associated with the functioning of the attenuators;
,,« High voltage generator faults, unexplained alarms, failures to start, fan issues, pre-ioniser HV faults;
,,« Air velocity in the filter, ionizer voltage, collector voltage issues;
,,« Leakage of NO2 past the carbon beds;
,,« Reliability of the equipment ¡V in particular the EP system; but in particular,
,,« An apparent lack of substantial root cause analysis.
What appears to have been studiously ignored in all of the analysis of the filter system installed in the M5 East tunnel, is that it was and is a trial, installed into a working tunnel under exceptionally difficult and challenging conditions. It is tendentious in the extreme to suggest that the costs of such an exercise give any guidance about the likely costs of a properly designed system installed by an experienced supplier in a new tunnel, where appropriate provision has been made for its installation. The use of such figures is dismissive towards modern filtration technologies. The going price for electrostatic precipitator equipment on the world market, supplied, installed and commissioned in a prepared space is £á1-2 million per 100m3/sec treated, based on actual prices from recently completed projects.
In spite of all of the problems with the 'trial', when operating, the filter system produced a noticeable reduction in haze and respiratory discomfort in the west end of the tunnel and a measurable reduction in the stack emissions.
Government appeared to down-play this success by claiming that the 'reduction' was only between 4-5%, however this was determined on the basis of a 24 hour average when the filter never operated for more than 6 hours a day.
Taking into account the size of the filter system and the volumes of air treated, the MAXIMUM filter effect possible was a reduction of between 14 and 18%. The measured reductions in stack emissions carried out while the filter was operating were close to these figures.
In fact, the trial was successful. Both forms of filtration worked but significant practical and operational problems were identified, along with severe technical and reliability deficiencies in the actual equipment chosen. The only inexplicable thing was the apparent failure of RMS or the operator to force the equipment supplier to get the equipment to operate at the particle removal efficiency levels (in excess of 90%) which were claimed and still are being claimed by this particular supplier.
The M5 East tunnel has been described as one of the dirtiest tunnels in the world.
It must be asked why the M5 East filtration system was considered ¡§not value for money¡¨? The filtration system was operating for only six hours each day, yet over that short time it was removing a FULL TWO THIRDS of the air pollutants from the air that was filtered!!
,,« What criteria were used to decide what is ¡§value for money¡¨?
,,« Were the health and well-being of Australian citizens calculated in this ¡§cost benefit analysis¡¨?
,,« Were hospital and medical costs included?
,,« Who owns the money that has such a high value that the health and well-being of Australian citizens is ignored?
,,« Are the profit margins considered of more importance than the health of Australian citizens?
NorthConnex has decided not to filter the Pennant Hills twin tunnels as it ¡¥did not represent value for money¡¦ basing their argument on the $65 million cost of the M5 system. Clearly the $65 million cost of the installation in the M5 does not provide any guidance as to the likely cost of a system such as would be appropriate for the NorthConnex tunnels. The problematic M5 East filtration system DOES NOT mean , that State and Federal Governments allow the proposers of this unsolicited bid to have no filtration system at all. What it SHOULD mean, is that in the interests of Australian citizens¡¦ health, well-being and safety, the Government requires Transurban to investigate systems that are working more effectively, efficiently and cheaply in other countries.
We do not have to re-invent the wheel.
Date: 7th September 2014 SCAPS Group Page 6 of 12
Why has the Government not required Transurban to investigate filtration systems that are working more effectively, efficiently and cheaply in other countries?
Why, knowing that the M5 East tunnel filtration was not as efficient as expected, was effective filtration not an integral requirement for this ¡§Unsolicited Bid¡¦?
Requirement 2: That as a condition for any further progress in the planning process, Transurban must be required to issue an international registration of interest by suitably qualified and experienced filtration suppliers for the design, supply, installation and commissioning of an efficient filtration system for the NorthConnex tunnel. Sufficient of the results of the registration should be made public to enable an assessment of the actual cost and likely impact of the use of such equipment on both the economics of the tunnel operation and its long term health and environmental impacts.
SECTION C:
THE CASE FOR FILTRATION OF SYDNEY TUNNELS
,,« There are no safe levels of exposure to diesel emissions which are a Group 1 carcinogen.
,,« Governments, both state and federal, have a duty of care to the public.
,,« The precautionary principle of duty of care to the public health must be regardless of cost.
,,« Medical evidence is overwhelmingly clear that long term exposure to air pollution increases death rates; (Recent data indicates that in 2010, 223,00 deaths from lung cancer resulted from air pollution)3;
,,« Exposure to particulate pollution is associated with reduced lung function growth in children which persists into later life, even when exposure stops. The damage for growing lungs is permanent.4/5/6
,,« Exposure to traffic-related air pollution during pregnancy and during the first year of life is associated with autism.
,,« There is an overwhelming amount of documented medical evidence on the adverse effects of air pollution on human health. A letter recently signed by 260 Australian medical professionals has been sent to Minister Duncan Gay outlining their concerns with regard to the adverse health effects on the public if the NorthConnex tunnels are not filtered.
Our concern is that there is absolutely no intention to filter any of the four ventilation outlets: northern and southern ventilation stacks and the two emergency vents. This is despite the assurances throughout the Environmental Impact Statement (EIS) published on the 15th July 2014 that the project is fully aligned to ¡¥best practice¡¦ as is mentioned frequently throughout the documents (eg EIS Volume 1A page 64). This appears to be a direct result of the poor decisions made in respect of the M5 East Tunnel. The fact that Australia got it so wrong in the M5 East tunnel does not mean that we don¡¦t ever even try to filter another tunnel. Educated people learn from their mistakes and try to do better.
NorthConnex has chosen not to filter as it ¡¥did not represent value for money¡¦. NorthConnex has modelled the likely increases in environmental pollutants including PM2.5. (EIS Technical Working Paper ¡V Air Quality Page151 Table 37) Taking into account the topography and likely wind conditions, traffic and tunnel engineering, modelling indicates an increasing level of 25% per annum over the maximum reporting standards of 8£gg/m3 (ie 10.1£gg/m3 ) by 2019. We understand that this projection is over the 9km of the surface area above the tunnel. However, what does this mean for those residing near the tunnel exit portals or driving regularly through the tunnels and how can we mitigate this risk?
3 Straif K. IARC Scientific Publication No. 161: Air Pollution and Cancer. eISBN 978-92-832-2161-6.
4 Dockery DW, Cunningham J, Damokosh AI, et al. Health effects of acid aerosols on North American children: respiratory systems. Environ Health Perspect 1996; 104: 500-505.
5 Raizenne M, Neas LM, Damokosh AI, et al. Health effects of acid aerosols on North American children: pulmonary function. Environ Health Perspect 1996; 104: 506-514.
6 Spengler JD, Koutrakis P, Dockery DW, Raizenne M, Speizer FE. Health effects of acid aerosols on North American children: air pollution exposures. Environ Health Perspect 1996; 104: 492-499.
Date: 7th September 2014 SCAPS Group Page 7 of 12
To give these comments context ¡V the following reports need to be considered. The National Environment Protection Measure (NEPM) for Ambient Air Quality published in 1998 under the then auspices of the National Environmental Protection Council (NEPC) saw fit to set air quality advisory standards that are meant to be binding on all levels of Government. These standards were set on the basis of scientific studies together with an appraisal of other standards such as those of the WHO. In 2011, the NEPC made 23 recommendations that included introducing compliance standards for PM2.5. This set of recommendations is to be fed into a National Plan for Clean Air, which will be put to the Council of Australian Governments (COAG) at the end of 2014.
Will this project be forced to comply with these recommendations when they are introduced?
The NEPC Review supported a reduction framework that would reduce exposure for communities living in close proximity to large emission sources given that as a rule of thumb,¡¦ there is no safe level of exposure that does not cause some level of harm¡¦.
The fact that the predicted increases should be regarded as acceptable is clearly a misuse of the NEPM goals. Statements such as : "The maximum predicted contribution from the project would be 2.1 mg/m3 (¡¥with project ¡V expected traffic flows¡¦ in 2029), which is substantially less than the applicable impact assessment criterion of 50 mg/m3" and "The highest cumulative concentrations (background plus the project) occur at times where the maximum predicted project contributions for the assessed scenarios are all low (less than or equal to 0.3 mg/m3) and well below the applicable impact assessment criterion of 50 mg/m3" appear to misuse and misrepresent the NEPM goals.
The NEPM goals do not represent a level up to which it is permissible to pollute. The NEPM documentation clearly states "¡K. the air quality of some localised areas within major airsheds are dominated by local activities such as that experienced in a road tunnel or a heavily trafficked canyon street. Air quality management in these areas is complex and needs a different approach to that directed at meeting ambient standards intended to reflect the general air quality in the airshed". p 13 NEPM 1998.
Stacks and portals cannot be treated as part of the airshed. They are specific localised, permanent pollution sources, similar to industrial chimneys and must be treated as such. In addition, the particulate matter emissions from stacks are fundamentally different from those found in the general airshed, and, on the best available knowledge, are significantly more harmful, gram for gram, than emissions from other sources.
It is accepted that filtration of the emissions like PM are not totally successful as documented by CSIRO in their ¡¥Assessment of the Electrostatic Particle Technology¡¦ associated with the M5 East Air Filtration System (69% of PM2.5 removed and 70% of PM10 removed)7 and AMOG Consulting in their M5 East Tunnel filtration trial evaluation (65% PM10 removed and well below the target 80%)8. It is also understood that filtration does incur both a significant capital and recurrent maintenance cost. However, a full two thirds of pollutants were removed from the air that was filtered in that trial and yet it is still considered not ¡§cost-effective¡¨? We consider such an outcome very good value for money when set against the cost of providing long term health care for those affected by the air pollution. The Health Impact Assessment of Air Pollution9 carried out by the Public Health Institute in Madrid reported that a drop in annual levels of Particulate Matter would result in fewer post-neonatal deaths and fewer hospital admissions.
Historically, it appears that in NSW, tunnel design has been focussed on carbon monoxide levels as the World Road Association Permanent International Association of Road Congresses or PIARC is unequivocal about the maximum levels associated with CO emissions. However, tunnel design should not be based on carbon monoxide levels alone and should include the development of a health-based exposure limit for nitrogen dioxide and Particulate Matter10 (particularly PM2.5 and PM1). People need to also be aware that Work, Health and Safety exposure limits are designed for healthy active people ¡V not the vulnerable. The effects on the vulnerable will only be known after research and extensive long term monitoring11/12.
7 Final Report of CSIRO entitled ¡¥Air Filtration Plant of the M5 EAST Tunnel. Determination of Particle Removal Efficiencies¡¦. Nov 2011.
8 Report by AMOG Consulting entitled ¡¥M5 EASTEast Tunnel Filtration Trial Evaluation Program ¡V Review of Operational Performance¡¦. February 2012.
9 The Health Impact Assessment of Air Pollution; ENHIS-1 Project: WP5 Health Impact Assessment. Local City Report; Madrid. L L Carrasco & B Z Torras (2002).
10 PM refers to particulate matter. PM10 is well researched and studied and refers specifically to the maximum size of the particles in a specific sample, not the average size, the size distribution, the source of the chemical composition of the particles in question. It is the weight to f the particles with an ¡¥aerodynamic¡¦ diameter of less than 10 microns (millionths of a metre) contained in one
cubic metre of air. The Australian standard is 50£gg/m3. There is no standard for PM2.5. Almost all particles emitted from diesel engines < 1micron (PM1).
11 Beelen R. Effects of long-term exposure to air pollution on natural-cause mortality: an analysis of 22 European cohorts within the multicentre ESCAPE project. Lancet 2014; 383: 785-795.
12 Guilia. Long term exposure to Urban Air Pollution and Mortality in a Cohort of More than a Million Adults in Rome. Environ Health Perspect: DOI: 10. 1289/ehp.1205862.
Date: 7th September 2014 SCAPS Group Page 8 of 12
The National Health and Medical Research Council (NHMRC) published its report in 2008 entitled ¡¥Air Quality in and around Tunnels¡¦13 and made a number of recommendations which included:
,,h ¡§Tunnels can cause adverse health impacts¡¨;
,,h ¡§The development of a health based exposure limit for NO2 and PM as a precautionary interim measure appropriate to both average and above average tunnel transit times in order to capture normal and congested conditions¡¨ and because health effects on people living close to stacks/portals remain difficult to assess,
,,h ¡§¡Kgood practice has long been to limit, as far as possible, exposure around tunnel portals and stacks; this practice should be continued and, where possible, reinforced¡¨.
¡¥Impacts on Health of Air Quality in Australia¡¦ Senate Inquiry, published by the Federal Government Senate Committee in August 2013, heard evidence that particulate matter of a certain size, (particularly PM2.5) is:
,,h ¡¥primarily derived from direct emissions from combustion processes, such as petrol and diesel vehicles¡K.¡¦;
,,h ¡¥has negative impacts on health ¡Kis the ninth leading cause of global disease burden (Lancet 201214);
,,h that the size of the PM was the principal determinant of how deeply it is inhaled;
,,h that epidemiological studies concluded that there was a statistically significant relationship between fine particles and human health effects (CSIRO submission15); and that
,,h PM2.5 is believed to be the most health-hazardous pollutant, responsible for 10 to 20 times as many premature deaths as the next worse pollutant (CSIRO submission15); further that
,,h so far, no limit of exposure where there is no impact has been identified (Leech et al16);
,,h the populations at greatest risk are those who are exposed the most, and those inherently more susceptible ie children, the elderly, those with lung dysfunction and asthma, socio-economically disadvantaged and pregnant women. Buffer zones between pollutants and the population of >2km were suggested by some. The measurement of tunnel environmental factors like Nitrogen Dioxide (NO2) and PM2.5 is difficult and often inaccurate. These limitations are acknowledged in EIS (4.2.14). Perhaps in support of this difficulty, the 2012 study on the unfiltered Lane Cove tunnel published by Senior Research Fellow Dr Christine Cowie entitled ¡¥Respiratory Health before and after the Opening of a Road Traffic Tunnel: A Planned Evaluation¡¦17 The findings stated that no apparent deterioration in air quality was found near the ventilation stacks (which are unfiltered). However, increased reporting of some symptoms and decrements in some lung function measures in people within 650m of the stack zone in one study was reported (but not in a subset of that study). It is interesting in this context to consider the significance of the observations made in the executive summary of the 2008 NHMRC report: ¡¨No clear evidence exists to show that monitoring such as that carried out to assess compliance with air-quality goals, especially for PM10, can reliably predict the size, nature and course of adverse health impacts." Also, ¡¨People who live near to tunnels or their stacks may be at risk if the presence of the tunnel alters the ongoing quality of the neighbourhood ambient air. Risks to cardio-respiratory health might arise if people are exposed to
13 ¡§Air Quality in and around Tunnels¡¨ 2008 (Ian Longley and Francesca Kelly)
http://www.nhmrc.gov.au/publications/synopses/_files/eh42.pdf
14Stephen S Lim; Theo Vos, Abraham D Flaxman, Goodarz Danaei, Kenji Shibuya, Heather Adair-Rohani et al. ¡¥A comparative risk assessment of burden of disease and injury attributable to 67 risk factors and risk factor clusters in 21 regions, 1990¡X2010: a systematic analysis for the Global Burden of Disease Study 2010.¡¦ The Lancet, 2012; 380(9859): 2224-60.
15Commonwealth Scientific and Industrial Research Organisation, Submission 48, p.8.
16Judith A Leech , William C Nelson, Richard T Burnett, Shawn Aaron and Mark E Raizenne
¡¥It's about time: A comparison of Canadian and American time¡Vactivity patterns¡¦, Journal of Exposure Analysis and Environmental Epidemiology (2002) 12, 427¡V432.
17 Christine T Cowie, Nectarios Rose, Wafaa Ezz, Wei Xuan, Adriana Cortes-Waterman, Elena Belousova, Brett G Toelle, Vicky Sheppeard, Guy B Marks. ¡¥Respiratory Health before and after the Opening of a Road Traffic Tunnel: A Planned Evaluation¡¦; PLOS One Research Article¡¦. Nov 2012.
Date: 7th September 2014 SCAPS Group Page 9 of 12
contaminated air from tunnel emissions. Important indicators for this risk are levels of NO2 and particulates. Of particular concern is an association between impaired lung development in children and emissions from traffic. Particulates from tunnels and volatile compounds including benzene may produce an increased lifetime risk for cancer.¡¨ Nonetheless, the Senate Committee did recommend pollution monitoring of proximate population exposure to pollution point sources (Recommendation 4 of ¡¥Impacts on Health of Air Quality in Australia¡¦ Senate Inquiry¡¦). Much is made of improvements in vehicle technology to reduce the harmful impact of submissions. The EURO design rules have caused a progressive change to the composition of particle and resulted in a decrease of 80% or more, in gravimetric terms (ie weight) but the changes have resulted in an increase in the number of smaller (more harmful) particles18 . However, this improvement appears to have increased the concentration of smaller particles which literature indicates is capable of being ingested deep into human lungs and absorbed into corresponding tissue19. The only real solution to this is to move the stacks well away from residential areas and/or filtration.
We also fully understand that allowable pollutants in the atmosphere are a necessary compromise between human health and economic growth necessity. For instance, it is anticipated that the tunnel will be take 5000 trucks and 9000 cars off the Pennant Hills Road traffic every day; this should improve the air quality along this road. It is also appreciated that the efficiency of diesel vehicles has been regulated since 2002 and that CSIRO anticipate a significant reduction of emissions by 2030. However, it must also be noted that the proportion of diesel vehicles in the national fleet increased by almost 40% between 2006 and 2013.
Although it is never included into cost accounting, it can be argued that the greatest cost of tunnel emissions arises from their potential to cause short, medium and long term adverse health effects to pockets of the community. A true accounting, that is, a proper long term cost benefit analysis of the real costs and savings of any tunnel ventilation system should include an assessment of the cost of potential health impacts to the community. In this regard, it is both right and just to expect that a portion of the profit resulting from the management of the tunnel, be set aside to cover these health contingencies.
In the meantime, in the construction of these twin tunnels, the precautionary principle used in proper scientific analysis must be paramount to meet the State and Federal Governments¡¦ duty of care. Filtration is best practice. Filtration provides identifiable health benefits. Filtration systems are operating successfully in First World countries and they can equally successfully operate in Australia. Care for the welfare of its citizens is the mark of a progressive society. Governments set the standards of a progressive society; these high standards appear to be lacking in this Unsolicited Bid, and this needs to be addressed. Requirement 3: That Air Filtration Systems must be included in this twin tunnel proposal; In addition, this project must be forced to comply with the National Plan for Clean Air recommendations when they are introduced in late 2014.
18Particulate Emissions from Vehicles by Peter Eastwood (2008) John Wiley & Sons. Sec 11.2 ¡¥Smaller particles in larger numbers; or larger particles in smaller numbers.¡¦ Pp393-396
19 Brown DM. Size dependent pro-inflammatory effects of ultrafine polystyrene particles: a role for surface area and oxidative stress in the enhanced activity of ultrafines. Toxicol Appl Pharm. 2001; 175: 191-199.
Date: 7th September 2014 SCAPS Group Page 10 of 12
SECTION D PROPERLY DESIGNED FILTRATION SYSTEMS
The first basic ventilation (transverse) system for highway tunnels was installed in the Holland Tunnel in the America in1927. The transverse design has been regarded as the safest and most reliable ventilation system for decades.
There is clearly scope for a reconsideration of a cost effective filtration system operating 12 hours a day during peak times ¡V not just 6 hours per day as occurred in the M5 East. The cost of operating the EP filtration system (3kw per 100 m3/sec) is likely to be significantly less than the cost of operating the lighting systems for the tunnel. Despite the M5 East outcomes, filtration technology by means of electrostatic precipitators is mature and sufficiently well proven for road tunnel applications.20 The conclusion of the September 2010 CETU Tunnels Study Centre document21 states¡¦ It is now an established fact that, technologically speaking, electrostatic precipitators furnish excellent results in terms of filtration performance¡¦.
Therefore, literature suggests that there appear to be two basic filtration design options:
1). Filtration could be affected through a three tier system ¡V a pre-screening filter to remove large PM (so as not to overload the electrostatic precipitator equipment) and a contemporaneous electrostatic precipitator capability to remove the very fine PM; in addition, activated charcoal filters to remove the gases such as NO2;
or
2). Install electrostatic precipitator units in the ceiling at approximately 2 km intervals along the length of the tunnel (or at a frequency that matches the pollution as do the Japanese and Norwegians) which will remove the majority of the PM from the air. The balance of the PM and the NO2 and CO are removed at the ends of the tunnel in the stacks. Progressive filtration means that it is not only safer for the community at the tunnel portals but it is also much safer for those travelling routinely through the tunnels ¡V and that is where a significant risk also lies.
There is also evidence that because the requirement to routinely vent and filter the large volume of air at only two exit points of the tunnel, progressive filtration provides a significantly cheaper solution to the end-to-end filtration process. When comparing costs of running tunnels (including maintenance and replacement costs) such as the old fashioned Japanese transverse system with stacks (Sasago), with stacks and EP installed filtration systems (Kan-Etsu) and with longitudinal, ventilated tunnels (Fukuchiyama), Japanese researchers concluded that longitudinal systems with electrostatic precipitators have a cost advantage over a transverse stack system of 2:3 depending on tunnel design.
Continuous longitudinal ventilation systems using EPs consume relatively small amounts of electrical power and are deemed economical systems in terms of total cost including maintenance and repair. We argue that there is sufficient evidence to show that filtration inside the tunnel can give rise to significant savings in operational costs. The Japanese are certainly doing this showing a whole of life power cost reduction of +/-30% for ventilation systems in longish tunnels (over about 3km). EP filtration does not add to the cost ¡V it reduces it. The health benefits come for free and it is imperative that the health care costs for the community living in the vicinity of the ventilation stacks and exit portals should also be taken into account. A comparison made by a Sydney University academic concluded that the M5 East is at least 2.5 times more expensive than the Japanese tunnels listed above.
If you examine the results from well-considered, well-engineered filtered tunnels in Norway, Japan and Spain, their assessments indicate particulate matter removal of greater than 80% up to 95%+. In addition, the Norwegian firm Clean Tunnel Air International (or CTA) has reported tunnel filter efficiencies based on number counts of between 0.3£g and 10£g+ since 2001. Why do we not bring in overseas expertise as appropriate? Furthermore, there are modern designs that indicate that a properly filtered, longitudinal air filtration system could make the process more efficient and cheaper. Why do we not learn from relevant overseas experience? That does NOT mean New Zealand expertise where the population and road traffic is neither comparable nor relevant. Unfortunately, there is no equivalent suburban tunnel model worldwide that we can learn from, given that a 9
20 A Goria; M Bettelini & G Gianola. (2008). World Tunnel Congress. ¡¥Exhaust ¡Vtreatment technologies for the tunnel Lugano ¡V An investigation on the state-of-art¡¦.
21 [http://www.cetu.developpement-durable.gouv.fr/IMG/pdf/CETU_DocInfo_Air_treatment_EN_2011.pdf]
Date: 7th September 2014 SCAPS Group Page 11 of 12
kilometre suburban tunnel will be the longest suburban tunnel in the world. If we get this right, this is a chance for Australia to be a leader in this field.
Of particular note is the fact that First World countries are continually striving to improve the percentage of air pollutants removed from their tunnels using a combination of ventilation and filtration. Why is the State of NSW and Australia satisfied with merely dispersing the pollutants rather than removing them? Why is the Australian Government satisfied with standards that do not appear to be comparable with those used by technologically advanced countries?
Requirement 4: That Australia investigates expertise and technology in countries where they have been successful in removing 95% of harmful emissions. That Ventilation Facilities at both the northern and southern intersections must be filtered using this modern technology. That the Southern Ventilation Facility must be located and filtered on RMS land ¡¥near the main alignment tunnel exit portals to maximise the benefit of the piston effect and minimise the need for additional energy consumption to operate tunnel jet fans and to transport the exhaust air from the tunnel to the outlet. This approach provides environmental benefits through the reduction in energy consumption and greenhouse gas emissions from the project¡¦.
SECTION E:
ONGOING MONITORING OF SURFACE AIR QUALITY AT THE TUNNEL PORTALS
Given the experience of the M5 East Tunnel, the decision to monitor air quality on the surface along Pennant Hills Road for only 12 months (particularly in the vicinity of the portal exits), clearly needs to be revisited as does transparency around the results. The indicative costs of monitoring the surface, (that is $3,000 per monitor unit per week), appears very excessive and should be verified.
It has been suggested that it would be much cheaper if the air monitoring system was set up on RMS land at both interchanges and at the two emergency facilities at Wilson Road and Trelawney Street . The system could be easily automated and therefore ongoing if on RMS land.
NorthConnex are happy to state loudly and frequently that OVERALL the air quality along Pennant Hills Road will be improved but we reiterate our contention that a decrease in diesel emissions from location ¡¥A¡¦ should not mean an increased concentration at location ¡¥B¡¦, particularly given that the World Health Organisation (WHO) listed diesel emissions as a Group 1 carcinogen.
The NorthConnex modelling acknowledges a decrease of air quality at both the northern and southern interchanges. This should not be allowed to occur. The installation of a good quality, world-class filtration system in all the tunnels in Sydney would see an overall improvement in air quality for the whole of Sydney.
Our position is that filtration of the tunnel and ventilation facilities would prevent the decrease in air quality around the tunnel exit portals and lead to an overall improvement in Sydney¡¦s air quality.
Requirement 5: That independent, on-going monitoring of air quality around the tunnel exit portals must be undertaken for the life of the tunnels, to ensure that the air quality remains of the highest standard. This will guarantee that the long term health effects of the tunnel can be appropriately assessed.
Date: 7th September 2014 SCAPS Group Page 12 of 12
SECTION F:
FLOODING PROBLEMS DOWNSTREAM OF THE SOUTHERN INTERCHANGE ¡V IMPACT OF THE WATER TREATMENT PLANT
A further concern is the potential impact on those properties downstream of Blue Gum Creek. A number of properties already have flooding problems when there is excess rain. Clarification needs to be provided regarding the volume of water that will flow into Blue Gum Creek from the water treatment plant adjacent to the Southern Stack.
Will the water leaving the tunnel storage plants be absolutely pollutant free? What guarantees are there? Who will be responsible for monitoring the purity of the water discharged from the storage treatment facility downstream?
What procedures and checks have been put in place to ensure that properties near the Blue Gum Creek are not flooded as a result of water released by the storage treatment plant?
We are cognisant of the fact that filtration brings with it the necessity to clean and wash the filter systems. However, it is noted that the wash water can be cleaned and recycled for use as is the case with the PV1 filtration station in Madrid.
Requirement 6: That an independent organization should monitor the toxicity of the water and the rate at which it is released into Blue Gum Creek. Every care should be taken to avoid flooding the homes located close to the creek.
SECTION G:
SOUTHERN INTERCHANGE - DETENTION BASIN: LISLE COURT RESERVE
The RMS are in the process of compulsory acquisition of the Public Reserve on the Northern side of the M2 behind the residences of Lisle Court and Savoy Court, West Pennant Hills, (Lot 15, DP 841778), for the purpose of extending the detention basin on the Western end of the Reserve.
This Public Community facility is well used by local residents and their children for numerous activities, from riding bikes and ball games to walking dogs. It is valued for being separated from local roads with access only via two pedestrian laneways and is therefore safer, particularly for small children. There are at least three large Sydney Blue Gums at the Western end that may be impacted if this extension to the detention basin is not minimised. There is also a natural creek line that flows through the Reserve. It should also be noted that this creek provides for a considerable population of birds, frogs, ducks, etc. Even eels and water monitors have been seen here. Vegetation screens the very high wall of the M2 at this point, but the centre area has been left open for use by local residents. No doubt the Design Engineers for the detention basin are also aware that the main sewer line for this area runs through the centre of the Reserve. Requirement 7: That any extension to the existing detention basin must be minimised as far as possible so that it does not unduly encroach on this Council Reserve. Furthermore, it is imperative that the residual land, after completion of the works, is not denied to the local community.

RE: NORTHCONNEX ENVIRONMENTAL IMPACT STATEMENT - Application number - SSI 13_6136
This is an objection to the NorthConnex proposal.
1 Connection of twin tunnels to a ventilation system at the Southern Interchange.
There is not one single scrap of tangible evidence in the EIS of any intention to connect either of the twin tunnels to the ventilation stack at the Southern Interchange. When this lack of evidence was raised with NorthConnex we were advised that this was merely an oversight. They subsequently drew an arbitrary line on their display photographs to show a connection. This is not satisfactory.
EIS Page vii Certification
Declaration:
I certify that I have prepared this environmental impact statement in accordance with the Director-General's Requirements dated 11 April 2014. The environmental impact statement contains all available information that is relevant to the environmental assessment of the infrastructure to which the statement related. To the best of my knowledge, the information contained in the environmental impact statement is neither false nor misleading.
Name: Scott Jeffries Todd Brookes
Date: 02 July 2014
In order to satisfy this declaration the missing information, including diagrams and descriptions, needs to be provided to the community with additional time to allow for public scrutiny.
The NorthConnex website now has a new section purportedly "Addressing misconceptions about the project" and yet this issue is not addressed. Is that because it is not a misconception and there is no intention to connect either tunnel to the ventilation system and that NorthConnex has no intention of putting anything in writing?
Requirement 1 The twin tunnels MUST be connected to a filtered ventilation stack at the Southern Interchange. Documented evidence must be provided with details describing and demonstrating how the connection will work. Time for public scrutiny must be provided.
2 Filtration of air pollutants from within the tunnels and at the exit portals
NorthConnex repeatedly write and state, both in the EIS and in public forums, that the tunnels and ventilation systems have been designed according to "world best practice" and "international standards". This is not true.
First World countries such as Norway, Spain and Japan design tunnels according to "world best practice". In fact they are the leaders of "world best practice". Their tunnels are designed and constructed with air filtration systems currently removing 80-95% of air pollutants and they are researching ways of improving on this. Japan has over 50 tunnels, all with "world best practice" air filtration systems.
Why has Australia not sort advice and expertise from countries who are clearly world leaders with regard to air filtration systems? New Zealand is not one of these countries.
The bald assertion "There is no tunnel ventilation outlet in Australia that has filtration" is a disgraceful indictment on Australia governments and Australian standards. Why do Australian tunnels not conform to "world best practice"? Why has Third World infrastructure been visited on the Australian people? It is time that this disgraceful practice stopped.
Requirement 2 That NorthConnex be required to investigate "world best practice" in air filtration systems and that the best possible air filtration systems be installed in all Australian Tunnels starting with the proposed NorthConnex twin tunnels.
Page 2 of 3 SCAPS Group 6th September 2014
3 Targeting of emission sources will provide ongoing improvement in air quality
The statement that "the NSW Government is continuing to target emissions at the source, the vehicles themselves, through a range of measures .... including better fuels, improved technology and stringent emission standards" is pure nonsense. The very reason that we now have such tiny particulate matter is because the fuels have been so refined and vehicles have become so fuel efficient. The better our technology, the tinier and more harmful the emissions will become. The ONLY solution for this problem is to install well-designed air filtration systems in the tunnels. It is my opinion that the construction of tunnels without air filtration is tantamount to criminal neglect on the part of our Federal and State governments. Where is their duty of care?
Requirement 3 The governments of Australia, both Federal and State, must comply with their duty of care and install air filtration systems in the NorthConnex twin tunnels and retrospectively fit air filtration systems into all existing tunnels.
4 Health impact for those living close to tunnel exit portals
"The human health risk assessment found the health risk due to emissions from motorway outlets would be very low." On what research of "world best practice" or "international standard" was this NorthConnex statement based? On the internet, visit any international environment protection authority or government health research site to find ample evidence that this is statement is clearly nonsense. Health systems around the world are clearly extremely concerned about the health impacts of traffic emissions.
To quote from just one internet site:
http://informahealthcare.com/iht ISSN:0895-8373 (print), 1091-7691 (electronic)
"Particulate matter beyond mass: recent health evidence on the role of fractions, chemical constituents and sources of emission."
Authors Flemming R.Cassee Dept of Environment al Health, National Institute for Public Health and the Environment, Bilthoven, The Netherlands
Institute for Risk Assessment Studies, Utrecht University, Utrecht, The Netherlands
Marie-Eve Héroux WHO European Centre for Environment and Health, Bonn, Germany
Miriam Gerlofs-Nijland Dept of Environment al Health, National Institute for Public Health and the Environment, Bilthoven, The Netherlands
Frank J. Kelly MRC-PHE Centre for Environment and Health, King's College, London, UK
"Particulate matter (PM) is regulated in various parts of the world based on specific size cut offs, often expressed as 10 or 2.5&#956;m mass median aerodynamic diameter. This pollutant is deemed one of the most dangerous to health and moreover, problems persist with high ambient concentrations. Continuing pressure to re-evaluate ambient air quality standards stem from research that not only has identified effects at low levels of PM but which also has revealed that reductions in certain components, sources and size fractions may best protect public health. Considerable amounts of published information have emerged from toxicology research in recent years. Accumulating evidence has identified additional air quality metrics (eg black carbon, secondary organic and inorganic aerosols) that may be valuable in evaluating the health risks of, for example, primary combustion particles from traffic emissions, which are not fully taken into account with PM2.5 mass. Most of the evidence accumulated so far is for an adverse effect on health of carbonaceous material from traffic. Traffic-generated dust, including brake and tyre wear, also contribute to the adverse effects on health. Exposure durations from a few minutes up to a year have been linked with adverse effects. New evidence collected supports the scientific conclusions of the World Health Organisation Air Quality Guidelines, and also provides scientific argument for taking decisive actions to improve air quality and reduce the global burden of disease associated with air pollution."
Page 3 of 3 SCAPS Group 6th September 2014
This is just one research paper from world-renowned research institutions based in The Netherlands, Germany and the United Kingdom. The paper clearly states the growing volume of evidence to show that the assurances in the EIS of "world best practice" are complete nonsense. Allowing the air pollutants from twin tunnels each nine kilometres in length to spew out over Sydney suburbs at just two unfiltered ventilation stacks IS NOT WORLD BEST PRACTICE.
Requirement 4 That the governments of Australia, both Federal and State, comply with their duty of care and properly investigate the adverse health effects of tunnel emissions. Requirement 5 That the governments of Australia, both Federal and State, comply with their duty of care and ensure that all infrastructure planned for Australia is actually "world best practice" and in the best interest of Australians. Requirement 6 That the governments of Australia, both Federal and State, comply with their duty of care and use taxpayer funds to protect the health and environment of Australians before allowing for the profit considerations of business.
5 Cost analysis of tunnel filtration systems.
The M5 East air filtration system was not considered "value for money".
The filtration system was operating for only six hours each day in the `Trial', yet over that short time it was removing a FULL TWO THIRDS of the pollutants from the filtered air!! Given the volume of evidence on the adverse health effects of traffic emissions on human health, the public must be informed on the criteria used to assess the value for money.
What criteria were used to decide what is "value for money"?
Were the health and well-being of Australian citizens included in the cost analysis?
Were hospital and medical costs included in the cost analysis?
Did the Government consider its duty of care when making the decision to construct other unfiltered tunnels?
Have these same cost analysis criteria been used in the decision not to filter the NorthConnex twin tunnels?
Any cost benefit analysis must include social impact costs.
Requirement 7 That an independent authority undertakes a full cost analysis of the adverse health effects of polluted air from traffic emissions on human health. Requirement 8 To comply with governmental duty of care, the filtration system in the M5 East tunnel must remain turned on to allow a FULL TWO THIRDS of the harmful air pollutants to be removed from the filtered air spewing into Sydney suburbs. Consideration must be given to increasing the volume of air filtered and extending the daily length of time that the filtration system runs. Requirement 9 All Australian road tunnels must be retrospectively fitted with air filtration systems.

RE: NORTHCONNEX ENVIRONMENTAL IMPACT STATEMENT - Application number - SSI 13_6136
This is an objection to the NorthConnex proposal.
Composition of Particulate Matter and its Effects on Health
For Minister Duncan Gay to give us statistics saying that 7% of particulate matter comes from vehicles and 50% comes for wood fire heaters is mischievous in the extreme.
What is missing in the NorthConnex EIS and public debate is the fact that not all Particulate Matter has the same chemical composition.
Diesel exhaust is a mixture containing over 450 different components, including vapours and fine particles coated with organic substances. Over 40 chemicals in diesel exhaust are considered toxic air contaminants overseas. Exposure to this mixture may result in cancer, respiratory effects, and other health problems.
Weight-for-weight diesel particles are more than 40 times as carcinogenic as tobacco smoke.
In June 2012 the WHO declared diesel fumes to be a Level-1 Human Carcinogen ie proven evidence of carcinogenicity in human beings http://www.iarc.fr/en/media-centre/pr/2012/pdfs/pr213_E.pdf
What is happening at the exit portals and stacks of all Sydney tunnels is morally wrong. Passive smoking is banned in public spaces and in cars where children are present, but a substance that is 40 times more carcinogenic is being allowed to spew out over Sydney suburbs where children run and play.
The argument that the polluted air is being sent up into the atmosphere to be "dispersed" means that this substance, which is 40 times as carcinogenic as tobacco smoke, is being spread over the whole of Sydney. Given that it is acknowledged that there are no safe levels of exposure to diesel emissions, this is a disgraceful indictment on Australian governments both State and Federal.
Requirement 1 That NorthConnex is made to investigate the best quality air filtration system using the latest in world class technological design and to install this system in all four ventilation outlets of the M1 - M2 twin tunnels. i.e. Southern Ventilation Stack, Northern Ventilation Stack, Wilson Road Emergency Outlet and Trelawney Street Emergency Outlet. Requirement 2 That all Sydney tunnels are retrospectively fitted with well-designed and well-maintained air filtration systems.

Please find my submission in response to the exhibition of the EIS for NorthConnex.
Firstly 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. The location in the centre of a densely populated residential area in Wahroonga where residents, schools, hospitals, aged care facilities is not acceptable.
2. The health risks associated with particulate matter out of these stacks is not acceptable.
3. Alternate transport options need to be investigated such as an orbital surface route.
4. Filtration on the stack as in Japan to eliminate 90% of the pollutants should be added where ever the location of the stack is placed.
5. Public health should take priority above cost as the proposal as it stands now is the cheapest option but at a sacrifice to peoples lives.

9 September 2014

Director - Infrastructure Projects
Department of Planning and Environment
Number: SSI 13_6136
Major Projects Assessment
GPO Box 39
SYDNEY NSW 2001


NorthConnex Application Number: SSI 13_6136

Please find below my submission in response to the exhibition of the EIS for NorthConnex.

Firstly I would like to state that 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 over 9,000 school children will be exposed, as well as multiple aged care facilities, hospitals, businesses and homes.

2. The placement of the northern ventilation stack in a valley in Wahroonga where there are often low wind speeds, which will result in poor dispersion and exposure to community to high levels of tunnel emission.

3. 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.

4. I am concerned about the project including future provisions for portal emissions in densely populated areas, which will result in emissions remaining at ground level, and hence exposing the local population to pollutants. I am also concerned that NorthConnex's claim that there will be no portal emissions from the current proposal cannot be verified.

5. I am concerned about the large amount of diesel emissions which will be emitted from the NorthConnex tunnel, as it is being designed for heavy freight to bypass Pennant Hills Road. Diesel emissions have been classified as carcinogenic by the World Health Organisation, and also contain a larger number of fine particles which penetrate deep into lung tissue and remain there causing inflammation. Key to diesel emissions are fine particulate matters of diameters less than 10 microns (PM10) and even 2.5 microns (PM2.5). Amongst their many adverse effects on health, both have been identified as cancer causing by the Australian Federal government. Moreover, epidemiological research acknowledged by the Australian Federal government indicates that there is no threshold at which health effects do not occur.

6. I am concerned about the air quality within the tunnel which is shown in the EIS to have levels above standards for pollutants such as NO2, and haze from particulate matter at the ends of the tunnel.

7. I am concerned about the multiple flaws in the air quality modelling of the northern stack in the EIS. These include:
a) extrapolation of meteorological data from other weather stations which do not reflect the local meteorology, local topography, and the valley location.
b) The use of a coarse topographical model
c) The failure to consider polluted intake air from the Pennant Hills/M2 interchange as part of the project contribution to air quality at Wahroonga
d) the background air quality being based on air quality at Lindfield and Prospect and the lack of any actual data on particulate matter of diameter less than 2.5 microns (PM2.5).

8. I am concerned that a full and transparent options assessment process was not undertaken to assess alternative designs for the project. Unlike other tunnel projects in Sydney there are alternatives for locating the stack and portals in non-residential areas.

9. I am concerned that the justification for not providing filtration for the stacks is cursory and unconvincing. This is especially so considering current technologies (e.g. electrostatic precipitators which are known to be highly efficient filtration devices that operate at a very low pressure drop) which can easily remove fine particulate matter.

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 does not approve the project in its current form. With regards to this project, the health of the community and the health of future generations should be the government's number one concern.
2. I request that alternative transport options to ease congestion on Pennant Hills Road be considered, such as an orbital surface route.
3. The air quality and human health impact assessment need to be revised to address the issues raised above.
4. An independent options assessment process should be undertaken to assess alternative locations for the ventilation stack and portals.
5. To undertake a Life Cycle Analysis and assessment for the provision of filtration
6. A long term health study on children and residents in areas impacted by stack discharges be included as part of the conditions of approval.
7. A comprehensive air quality monitoring program is developed and implemented.
8. An independent review of the ventilation system is undertaken to ensure that NorthConnex's claim of no portal emissions is justified.
9. Portal emissions from NorthConnex in the future are banned.
10. The Submissions Report/Preferred Project be exhibited to allow the community to respond to the revised information contained in the report.
11. The Department does not approve the project in its current form as it clearly does not meet the principles of Ecologically Sustainable Development as required by the Environmental Planning and Assessment Act.

Proposed temporary facilities - construction compound route.
Construction traffic going through an already busy thoroughfare for residences surrounding the street.

See attached

Major flaw in the EIS - NorthConnex Project overview clearly states that the NorthConnex would take 5,000 trucks off Pennant Hills Road each day, and it would have capacity to carry more than 100,000 vehicles per day (50,000 in each direction). However the EIS emission calculation misleadingly used the figure of 19,500 vehicles per day per direction as the basis for their calculation. The EIS vehicle emission has been underestimated by using the figure of 19,500 daily vehicles in lieu of 50,000 daily vehicles. Therefore, the purported EIS calculation is not only unreliable but raises the concern whether it accurately includes the "5,000 [daily] trucks off Pennant Hills Road".

This project has not considered the health and well being of local residents. The M1-M2 tunnel project is base on the most cost effective approach not the best long term solution for residents and motorists.

9 September 2014

Director - Infrastructure Projects
Department of Planning and Environment
Number: SSI 13_6136
Major Projects Assessment
GPO Box 39
SYDNEY NSW 2001

Via online form: http://majorprojects.planning.nsw.gov.au/index.pl?action=view_job&job_id=6136

NorthConnex Application Number: SSI 13_6136

Please find below my submission in response to the exhibition of the EIS for NorthConnex.

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.

2. The placement of the northern ventilation stack in a valley in Wahroonga where there are often low wind speeds, which will result in poor dispersion and exposure to community to high levels of tunnel emission.

3. 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.

4. I am concerned about the project including future provisions for portal emissions in densely populated areas, which will result in emissions remaining at ground level, and hence exposing the local population to pollutants. I am also concerned that NorthConnex's claim that there will no portal emissions from current proposal cannot be verified.

5. I am concerned about the large amount of diesel emissions which will be emitted from the NorthConnex tunnel, as it is being designed for heavy freight to bypass Pennant Hills Rd. Diesel emissions have been classified as carcinogenic by the World Health Organisation, and also contain a larger number of fine particles which penetrate deep into lung tissue and remain there causing inflammation.

6. I am concerned about the air quality within the tunnel which is shown in the EIS to have exceedences above standards for pollutants such as NO2, and haze from particulate matter at the ends of the tunnel.

7. I am concerned about the multiple flaws in the air quality modelling of the northern stack in the EIS. These include:
a) extrapolation of meteorological data from other weather stations which do not reflect the local meteorology, local topography, and the valley location.
b) The use of a coarse topographical model
c) The failure to consider polluted intake air from the Pennant Hills/M2 interchange as part of the project contribution to air quality at Wahroonga
d) the background air quality being based on air quality at Lindfield and Prospect and the lack of any actual data on PM2.5

8. I am concerned that a full and transparent options assessment process was not undertaken to assess alternative designs for the project. Unlike other tunnel projects in Sydney there are alternatives for locating the stack and portals in non-residential areas.

9. I am concerned that the justification for not providing filtration for the stacks is cursory and unconvincing.

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

1. The air quality and human health impact assessment need to be revised to address the issues raised above.
2. An independent options assessment process should be undertaken to assess alternative locations for the ventilation stack and portals.
3. To undertake a Life Cycle Analysis and assessment for the provision of filtration
4. A long term health study on children and residents in areas impacted by stack discharges be included as part of the conditions of approval.
5. A comprehensive air quality monitoring program is developed and implemented.
6. An independent review of the ventilation system is undertaken to ensure that NorthConnex's claim of no portal emissions is justified.
7. Portal emissions from NorthConnex in the future are banned.
8. The Submissions Report/Preferred Project be exhibited to allow the community to respond to the revised information contained in the report.
9. The Department does not approve the project in its current form as it clearly does not meet the principles of Ecologically Sustainable Development as required by the Environmental Planning and Assessment Act.

XXXXXXX
XXXXXXX

I endorse the attached SCAPS GROUP SUBMISSION

Dear Sir/Madam,

I would like to state we OBJECT to the project as described in the EIS.

This project has 3 off 9km long lanes, and nearly 100,000 vehicles drive through everyday; please think about nearlly 10,000 children and high density community nearby, this project could be the worst thing in the history.

If it is all about money, please stop it, or add on filter facility and shift the stack to further north. our health and life can not be judged by money.

Simon