SUBMISSION GUIDE

Western Harbour Tunnel and Warringah Freeway Upgrade – Environmental Impact Statement

Prepared for the community by the Office of Jamie Parker

The government has released the Environmental Impact Statement (EIS) for the Western Harbour Tunnel and Warringah Freeway Upgrade. The EIS carries significant health and amenity impacts for the inner west.

This submission guide aims to provide information on how to make known your concerns to this EIS. It is not intended as an exhaustive analysis of the EIS.

There is no set format for a written objection but your submission can be written from your perspective and look at how the project will impact you and doesn’t have to be expertly constructed.

Separate detailed submissions are being made by a number of experts.

Please feel free to elaborate on any of the information given below in your submission. The closing date for submissions has been extended to 30 March.

How to view the Environmental Impact Statement

Go to www.planningportal.nsw.gov.au/major-projects Enter the project name: Western Harbour Tunnel

How to make a submission

Online To make an objection to this proposal, login to the Department of Planning website here. This online portal is hard to use so please allow some time to create a login.

Mail Attention: Director, Transport Assessments Planning & Assessment, Department of Planning Industry and Environment Locked Bag 5022, Parramatta NSW 2124

Include the application number SSI-8863

Email The Department of Planning have not offered an email submission option however, if you’re unable to operate the online portal or send your objection via the mail, you can email our office on [email protected] and we will send your submission in through the mail.

We acknowledge the contribution of the community in helping to prepare this submission guide.

Submission Guide – Page 2 Western Harbour Tunnel and Warringah Freeway Upgrade

ISSUES TO CONSIDER

The project has three major areas of local impact you may want to comment on, depending on where you live. Please note the number of properties affected by noise and vibration are estimates provided by the government.

The experience of the WestConnex project to date demonstrates these projections can be seriously flawed with lived impacts being more intense and widespread. In fact, in Rozelle the government has acquired several properties that were not planned to be purchased as the impact was so severe.

Impacts at Victoria Rd, Rozelle construction site

The former Balmain Leagues Club site will be used as a tunnel excavation site. Construction at this site will place the community under unacceptable pressure due to:

● Excessive construction noise 208 homes will be impacted by noise including 27 homes which will be ‘highly noise affected’ by rock-hammering during site establishment. In addition, 210 properties will be impacted by noise at night. Excessive noise can cause stress, impact sleep and reduce quality of life while ongoing noise can seriously impact people’s health. Extensive noise monitoring and noise mitigation should be required at all impacted homes.

● Ineffective dust mitigation A large amount of dust is expected to be generated by demolition, earthworks and track-out at this site. While mitigation measures like watering will be put in place the EIS admits that they will not be ‘effective all the time’. Extensive measures are required to adequately mitigate the impact of construction and excavation dust.

● Increased truck movements The Project will generate 420 heavy vehicle movements and 230 light vehicle movements per day at the Victoria Rd, Rozelle site which is already subject to capacity traffic movements at both Darling St and Victoria Road. Increased traffic on local roads and truck stack parking decreases existing residential amenity and lessens land value.

● Construction workers taking on-street parking and truck stack parking Local experience with WestConnex demonstrates that despite efforts by the contractor to bus in workers or encourage public transport usage, workers suck up on-street parking around major construction sites. The contractor should be required to provide parking for 100% of workers on site to protect resident amenity.

Submission Guide – Page 3 Western Harbour Tunnel and Warringah Freeway Upgrade Impacts at White Bay construction and sediment treatment site

White Bay will be used to construct and transport immersed tunnel tubes as well as for the treatment and transfer of sediment and spoil dredged from the harbour floor. The site will also be used for worker parking for other construction sites like Rozelle Rail Yards and Yurulbin Point. Work at this site will place the community under unacceptable pressure due to:

● Possible health risks Dredged sediments excavated from White Bay and from the immersion tube tunnel (from Birchgrove to Waverton) contain the toxic contaminants including dioxins, tributyl tin, polynuclear aromatic hydrocarbons, and heavy metals. While the EIS provides the volumes of sediment that will be dredged, it does not provide the concentrations of these compounds meaning that the risk to human health and to the marine ecosystem of Sydney Harbour cannot be adequately assessed. The dioxins are of special concern because they are the contaminants that led to prohibition and limits of fishing in Sydney Harbour west of the Harbour Bridge. Tributyl tin is especially toxic to marine life and was widely used to prevent growth on the hulls of vessels until banned from use.

● Unacceptable odour impacts The EIS does not adequately address odour impacts which will occur during the transport and processing of toxic dredged materials at White Bay and for the immersed tube tunnel. The EIS states that odour impacts will be minimal because materials will be wet and lists no significant measures to mitigate the impact on residents. Sediments in Sydney Harbour and estuaries are known to be odorous and excavated sediments will likely require treatment.

● Excessive noise and vibrations The EIS lists 92 properties that will be impacted by noise with five properties to be impacted by noise at night. These figures seem to refer to entire stratas rather than individual homes which is misleading. Excessive noise can cause stress, impact sleep and reduce quality of life while ongoing noise can seriously impact people’s health. Extensive noise monitoring and noise mitigation should be installed in all impacted homes.

● Long operational time for White Bay sediment treatment plant The White Bay treatment facility is proposed in the EIS to treat 142,500 cubic metres of contaminated sediments that are not suitable for offshore disposal. This is a huge quantity and the space allotted in the EIS is small (1000 square metres) and is close to Birrung Park and residences in Donnelly Street. The facility is stated in the EIS to operate for 3 years, but there is concern that it may need to operate for longer.

● Increased truck movements The Project will generate up to 700 heavy vehicle movements and 530 light vehicle movements per day from the White Bay site. Increased traffic on local roads and truck stack parking decreases existing residential amenity and lessens land value.

● Construction workers taking on-street parking and truck stack parking Local experience with WestConnex demonstrates that despite promises by the contractor to bus in workers or encourage public transport usage, in actuality workers monopolise on-street parking around major construction sites. This will especially be the case at White Bay as workers who are not able to park near sites like the Yurulbin Point cofferdam will be required to drive to White Bay and be barged

Submission Guide – Page 4 Western Harbour Tunnel and Warringah Freeway Upgrade on. The contractor must be required to provide parking for 100% of workers on site to protect resident amenity.

Impacts at Yurulbin Point cofferdam Yurulbin Point will be used as a tunnel excavation site. Temporary wharves will be constructed as well as land based construction activities on Yurulbin Park. Construction at this site will place the community under unacceptable pressure due to:

● Loss of greenspace and destruction of trees Trees in Yurulbin Park will be felled to make way for a large acoustic shed and other site works which will lock this park up for four years. The EIS does not describe precisely how many trees will be destroyed or detail the plan to replace them or rehabilitate the area. If trees are felled, the contractor should be required to replace them with mature trees, not seedlings.

● Closure of Birchgrove Ferry Wharf The Birchgrove ferry wharf will be closed for up to 2.5 years which would affect existing ferry services and recreational use of the wharf. No additional bus services will be added to timetables during the wharf’s closure and the EIS suggests residents walk the 1.7km to Balmain Wharf to access ferries. The EIS states that opportunities to relocate the Birchgrove Ferry Wharf will be ‘investigated’ but makes no commitment.

● Unacceptable noise and vibrations The EIS lists 229 homes that will be impacted by noise during site establishment with 2 properties to be 'highly noise affected' by rock-hammers, chainsaws and mulchers. In addition, 79 homes will be impacted by noise at night from barges unloading concrete. Excessive noise can cause stress, impact sleep and reduce quality of life while ongoing noise can seriously impact people’s health. Extensive noise monitoring and noise mitigation should be installed in all impacted homes.

● Construction workers taking on-street parking The EIS describes a plan to barge workers in from White Bay to the Yurulbin Point construction site in order to prevent workers accessing the site from Louisa Road where parking is already extremely restricted – especially considering the planned removal of the parking spaces at Yurulbin Park. Throughout the course of the WestConnex project, workers have routinely flouted the instructions of the contractor to access construction sites via public transport and shuttle buses and instead monopolised resident parking. The EIS does not adequately address the risk of residents having to compete with workers for limited on-street parking at this site. The contractor should be required to provide parking for 100% of workers to protect resident amenity and have effective measures in place to deal with workers who do not comply.

● Poor visual amenity and impact on harbour views The Project will dominate Yurulbin Point with a number of new buildings and structures and negatively impact visual amenity by blocking views of the water and destroying vegetation. There will also be a noticeable increase in the number of boat movements within the bay with moderate to high visual impacts expected for Wharf Road residential area. There are no plans to mitigate these impacts in the EIS.

Submission Guide – Page 5 Western Harbour Tunnel and Warringah Freeway Upgrade In additional to local impacts, there are also a number of broader impacts that will affect residents across the inner west and Sydney.

Impact of tunnelling under homes

● Potential for damage to homes The construction of this tunnel has the potential to affect hundreds of homes above the tunnel corridor and in proximity to the tunnel through vibration, ground movement and settlement. The EIS does not adequately address these impacts and fails to address critical details such as the zone of influence (which identifies the area of potential impact), compensation measures, and methods of vibration monitoring. Instead of risking damage to people’s homes, the government should be investing in transformational public transport which poses less risk to property.

● Potential for changing tunnel depths The EIS emphasises that tunnels are expected to be built up to 70 metres deep under the inner west, implying that this reduces the risk to homes. The WestConnex EIS stated that the majority of tunnels would be under 35 metres. While this EIS was approved by government, when the contractor took on the project and released the detailed construction design tunnel depths were reduced to as shallow as 6 metres below homes in Annandale and under 10 meters in Rozelle. If tunnel depths change significantly, the EIS should be placed on public exhibition again to allow for detailed review by the community.

Impacts on emissions and climate change

● No consideration of induced demand Global experience of toll roads indicate that they induce demand, create more traffic in the long term and push people into their cars. The EIS makes no consideration of induced demand and the consequential impact on emissions and climate change.

● No benchmarking against public transport The Western Harbour Tunnel was not adequately benchmarked against public transport alternatives. Public transport projects can provide a genuine, long term solution to road congestion without significantly increasing greenhouse gas emissions.

● Ignores lack of fuel standards in Australia The Environmental Impact Statement makes ridiculous claims that climate change impacts of this project will reduce over time as fuel efficiency standards are increased. However, Australia’s transport-related emissions have continued to rise and there is no commitment by government to implement any efficiency or fuel quality standards for vehicles. In fact Australia remains the only country in the OECD without a fuel efficiency standard for passenger vehicles and has one of the worst fuel quality standards in the 36 nation OECD.

Submission Guide – Page 6 Western Harbour Tunnel and Warringah Freeway Upgrade Impacts on air quality

● There is no safe level of particulate matter Research demonstrates that there is no safe exposure level to particulate matter generated by traffic. The EIS fails to fully evaluate the long-term health impacts of the Project. It especially neglects the increased susceptibility of children, the elderly and people with chronic disease who are particularly at risk of the health effects of traffic related particulate matter.

● No filtration of exhaust stacks With two-thirds of people in NSW living in metropolitan Sydney relatively close to major roads, vehicles are one of the most important sources of particulate matter (PM) exposure in NSW and are a significant contributor to negative health impacts including increased mortality, respiratory and cardio-vascular disease, and adverse birth outcomes. The EIS proposes to install a double exhaust stack at Cammeray and vent pollution to the exhaust stacks already planned for Rozelle Goods Yard. These stacks should be filtered according to the world's best practice to reduce the impact on air quality and human health.

Impact on Sydney Harbour and marine life

● Dredging of toxic sediment will pollute the harbour 142,500 cubic metres of contaminated sediment will be dredged from the harbour floor and processed at White Bay. This sediment was stated in the EIS to be contaminated with dioxins, tributyl tin and heavy metals as a result of the harbour’s industrial past. Dredging threatens to contaminate harbour waters by creating a toxic plume that will be difficult to contain. While some minimisation measures are proposed like shallow floating silt curtains, these measures may not be sufficient to prevent plumes of contaminated sediments escaping to the harbour.

● Pollution puts marine species at risk Australian Museum records since 1850 indicate that Sydney Harbour is biologically diverse, with over 2473 species of polychaetes, crustaceans, molluscs and echinoderms recorded. The EIS proposes to dredge toxic sediment from the harbour floor creating toxic plumes of pollution which will threaten Sydney Harbour’s marine life. 70 threatened species are at risk including fragile sea grasses that support 20 species of endangered seahorses and dragons.

● Road-header options have not been given adequate consideration The EIS states that road-header options (which would remove the need for dredging) were discounted for the harbour crossing because the tunnel depth required by this method would significantly compromise gradients and force drivers to descend and climb into the tunnel. Here the EIS is placing driver amenity and comfort ahead of environmental protection without even weighing the costs and benefits.

● Critical details about the sediment have been left out While the EIS lists the massive volumes of sediment that will be dredged it doesn’t list details about the concentration of dioxins, tributyl tin, polynuclear aromatic hydrocarbons and heavy metals which is a critical factor in determining the impact on marine life and biodiversity. These details must be released to provide any meaningful feedback on the proposal.

Submission Guide – Page 7 Western Harbour Tunnel and Warringah Freeway Upgrade