Eds: This sample submission focuses on air quality impacts of Stage 3 WestCONnex.
It’s written in the first person but you can easily change it for a group submission or use part of it for an information sheet. You can also:
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Submission to WestConnex New M4/M5 EIS, project number SSI 16_7485
I object to the M4-M5 Link as outlined in the Environmental Impact Statement. My objection is partly based on my concern about the impacts of the project on air quality in the areas surrounding the tunnel portals and the use of unfiltered stacks.
This proposal involves unacceptable risks to public health. I call on the Minister for Planning to reject the M4-M5 Link as proposed.
The findings of the EIS on air quality cannot be relied upon.They are totally dependent on the traffic figures which have been questioned by independent experts. Traffic modellers have a long record of poor predictions in Australia and elsewhere.
Costs of Air pollution
The health costs of air pollution in Australia are estimated to be in the order of $11.1 billion to $24.3 billion annually, solely as a result of mortality (Begg et al. 2007; Access Economics 2008). For the Greater Metropolitan Region of Sydney alone it has been estimated that the health costs of air pollution range between $1 billion to $8.4 billion (NSW DEC 2005).
The project will not solve traffic congestion, it will in fact encourage the use of cars and trucks in Sydney and dot inner Sydney with unfiltered pollution stacks. This will all add to health costs.
NSW should be seeking to lower pollution levels as much as possible but pursuing sustainable transport alternatives.
No Safe levels of PM 2.5
Motor vehicles account for 14% of Particulate Pollution of 2.5 microns and less in Australia. There is no safe level to exposure to particulate matter of 2.5 microns and less. Particulate matter is linked with asthma, lung Disease, cancer and stroke.
The EIS claims that the annual mean PM 2.5. levels are expected to increase on the following streets if the M4-M5 link is built and open to traffic in 2023. A WHO fact sheet claims that “There is a close, quantitative relationship between exposure to high concentrations of small particulates (PM10 and PM2.5) and increased mortality or morbidity, both daily and over time. Conversely, when concentrations of small and fine particulates are reduced, related mortality will also go down – presuming other factors remain the same. ” (WHO 2016). It goes onto say that “The most health-damaging particles are those with a diameter of 10 microns or less, (≤ PM10), which can penetrate and lodge deep inside the lungs. Chronic exposure to particles contributes to the risk of developing cardiovascular and respiratory diseases, as well as of lung cancer. ” A number of studies have linked increased PM levels to respiratory diseases, increasing rates of hospitalisation and preterm births (Brunekreef and Holgate 2002, Orru et al. 2010; Huynh et al. 2006, Zabnobetti et al. 2009, Dominici et al. 2006).
It is unacceptable to expose residents and workers in the areas listed below to increased levels that bring them closer to the NSW PM2.5 threshold. An article published in the Lancet states that “There is now no doubt that air pollution, and especially fine particulate matter (PM2·5), has many serious consequences for health and leads to avoidable premature deaths” and that “that there is no safe threshold level, rather a linear concentration-response relationship.” (Lanclet 2013). And in another scientific publication Giannadaki et al. 2016 have asserted that ” there is no strong evidence for a “safe” PM2.5 concentration threshold below which no health risk can be assumed ” In light of this it is important that this part of the WestConnex Project, and the project overall is stalled.
|Location||Increase in PM 2.5 (µg/m3 )|
|Burrows Road, Alexandria (near St Peters)||0.18-1|
|Gardeners Road, Alexandria||0.18-1|
|Kent Road, Mascot||0.18-1|
|Bourke Road, Mascot||0.18-1|
|O’Riordon Street, Mascot||0.18-1|
|Botany Road, Mascot||0.18-1|
|Albert Street, St Peters||0.18-1|
|Euston Road, Alexandria||0.18-1|
|Ada Place, Pyrmont||0.18-1|
|Church Avenue, Mascot||0.18-1|
|Miles Street, Mascot||0.18-1|
|Hughes Avenue, Mascot||0.18-1|
|Coward Street, Mascot||0.18-1|
|Carinya Avenue, Macot||0.18-1|
|John Street, Mascot||0.18-1|
|Western Distributor (Sydney Fish Market)||0.18-1|
|Saunders Street (Near Western Distributor, Sydney Fish Market)||0.18-1|
|Bank Street (Near Western Distributor, Sydney Fish Market)||0.18-1|
|Bulwara Road (Sydney Fish Market)||0.18-1|
|Sydney Fish Market||0.18-1|
|Mount Street , Pyrmont||0.18-1|
|John Street, Pyrmont||0.18-1|
|Quarry Master Drive, Pyrmont||0.18-1|
|Little Mountain Street, Pyrmont||0.18-1|
|Miller Street, Pyrmont||0.18-1|
|Harris Street (Between Miller Street and Pyrmont Bridge Road)||0.18-1|
|Harris Street (between Allen Street and Pyrmont Bridge Road near Sydney Fish Market)||0.18-1|
|Experiment Street, Pyrmont||0.18-1|
|Pyrmont Street, Pyrmont (Next to Oaks Goldsborough Apartments)||0.18-1|
|Jones Lane, Pyrmont||0.18-1|
|Fig Street, Pyrmont||0.18-1|
|Darling Harbour area||0.18-1|
|Campbell Street, St Peters||0.18-1|
|Barwon Park Road,St Peters||0.18-1|
|Frederick Street, Ashfield||0.18-1|
|Henry Street, Ashfield||0.18-1|
Unfiltered pollution stacks pose unacceptable risk to Sydney’s residents
I completely reject the notion that unfiltered pollution stacks should be built anywhere in Sydney, let alone three or four in a single area.
I am particularly concerned that schools would be near such unfiltered stacks.
The EIS states, there are at least 5 schools that will be in the orbit of these poisonous fumes. Children and the elderly are most at risk of lung ailments. The Education Minister Rob Stokes declared in 2017, that “No ventilation shafts will be built near any school.” in his electorate. The same should be applied in all areas of Sydney and the government needs to urgently review its policy of support for unfiltered stacks.
The government needs to urgently review its policy of support for unfiltered stacks.
I note that the Education Minister, who as Planning Minister approved the M4 East and New M5, stated that the would not allow unfiltered ventilation stacks in his electorate.
Annandale, Haberfield, Rozelle, Lilyfield and St Peters will be exposed to unacceptable health risks.
With four unfiltered emissions stacks in Rozelle, two in Haberfield (one each for the M4East and New M5) and two in St Peters, along with a large number of exit portals, residents of these area will suffer greatly from direct exposure to poisonous diesel particulates.
This is negligent when you consider that the World Health Organisation in 2012 declared diesel particulates carcinogenic.
The Rozelle interchange is only a concept at this stage and should not be approved.
But even as a concept, its dangers are revealed. Rozelle would be lumbered by an unprecedented concentration of stacks, in a valley, adjacent to densely populated suburbs.
The interchange has long climbs which will increase emissions concentrations, which will then be pumped into the surrounding area.
The EIS shows significant traffic volumes will head onto the Anzac Bridge, which already operates at the lowest Level of Service (F) in peak times.
There will be significant queues heading into the tunnels, greatly increasing the level of emissions, but the model does not account for these conditions.
The three pollution Stacks in the Rozelle Rail yards are shown to be 38 meters high. This is a totally inappropriate location for these pollution stacks as the Rozelle Rail Yards are in a valley and the stacks will be on land that is approximately 3.5 meters above sea level.
Balmain Road between Wharf Rd and Victoria Road is at an elevation of on average 37 meters. Orange Grove Primary School is at an elevation of 33.4 meters. Areas of Hornsey Rd Rozelle are at 28 meters. The area near the junction of Annandale and Weynton streets in Annandale has an elevation of 29 meters.
All these areas are in close proximity to these stacks and as a result, all the pollution from these stacks will almost be on the same level and so will be blowing almost directly into these properties, especially in summer when many windows are open. This is completely unacceptable.
In addition, when there is no wind, the pollution will accumulate in this valley area and make the surrounding area highly polluted. This is also not acceptable. Young children, the elderly and those suffering from lung and heart disease will be placed at serious risk.
There are also at least 4 schools of primary age children well within one kilometre of these stacks. Young children are the most vulnerable to pollution related disease.
The additional unfiltered exhaust stack on the north-west corner of the St Peters interchange will further increase the vehicle pollution in an area where the prevailing south and north-westerly winds will send that pollution over residences, schools and sports fields.
St Peters Primary School in particular will be at the apex of a triangle between the two exhaust stacks on the south–western and north-western corners of the interchange and near congested roads. This is utterly unacceptable.
St Peters will have large volumes of vehicles accelerating and decelerating as they enter and exit tunnels and access roads, next to proposed playing fields. This will be complicated by emissions stacks located in the Interchange – meaning that pollution from the interchange will be supercharged by the emissions from the stacks.
The EIS states that ‘the ventilation outlets would be designed to “effectively disperse the emissions from the tunnel and are predicted to have negligible effect on local air quality.”
Details of the impacts on air quality need to be provided in an accessible way so that the residents and experts can meaningfully comment on the impacts. Even small increases in PM 2.5 are not acceptable.
I am completely opposed to approving a project in which the EIS consultants recommend rather than filtrating stacks now, extra stacks could be added later if there is a problem? How long would that take? Twenty years until a cancer cluster developed? One of two RMS experts at an EIS session did not even know that this statement was in the EIS. Where would these stacks be built? This indicates a level of uncertainty about the safety of unfiltered stacks.
RMS has stated at EIS sessions that there will be a review of the government’s policy on unfiltered stacks but was unable to provide any information about the review or the identity of the person doing the review.
Air quality danger in tunnels
The EIS shows a diagrammatic explanation of the way the polluted air will be expelled from the Westconnex tunnels.
This method will work on straight tunnels of short distance providing there is no traffic congestion.
Existing tunnels in Sydney have signs advising motorists to roll up their windows and put on their ‘in vehicle circulating’ air conditioning.
This type of straight line pollution expulsion doesn’t work if the tunnels go around corners, which is the case with the tunnels from the Rozelle Rail Yards site.
I demand that NSW Planning respond to this specific concern, rather ignoring it as has occurred with responses to the EIS for the M4East and New M5 projects.
The tunnels under Rozelle/Lilyfield are going to be in three levels. The EIS of the Rozelle Interchange are nothing more than a concept design and must not be approved.
The EIS does not explain what safety procedures would be built into the project to deal with situations like serious congestion, accidents or fire.
In the event of a serious hold-up on the deepest of these tunnels, it is clear that the air quality will very quickly become toxic unless substantial air conditioning is a major part of the design. However, there is no substantive detail about how these issues are going to be addressed and it is simply not acceptable for the EIS to continually state that issues will be postponed to the design phase.
There needs to be independent scrutiny and public feedback and consultation into a project carrying such potential risks to the public.
Government should seek sustainable strategies to reduce air pollution not worsen it in chosen spots.
Rather than adding to pollution, the NSW government should be seeking ways to reduce emissions. It is not acceptable to argue that worsening pollution is not a problem in particular spots , simply because it is already poor.
The M4-M5 tunnel will increase annual mean PM10 levels on the following Streets in the St Peters area and near Sydney Fish Market (data from WestConnex EIS) when it is opened in 2023, (DS 2023-DM 2023). PM10 is a carcinogen and a paper published in 2013 (Raaschou-Nielsen et. al. 2013), which involved 312 944 cohort members, linked increases in PM10 levels with increases in lung cancer rates. The increases in PM 10 concentration is completely unacceptable, some of these areas are residential or are people’s workplaces. The project should be rejected on the grounds that it will gave a detrimental impact on air quality and people’s health.
|Location||Increase in PM10 (µg/m3 )|
|Active Kids Mascot||0.4|
|Burrows Road||0.5-1, around 2 in some areas|
|Princess Highway SW of Sydney Park||NA|
|Western Distributor (Sydney Fish Market)||2-3|
|Saunders Street (Near Western Distributor, Sydney Fish Market)||0.5-1|
|Bank Street (Near Western Distributor, Sydney Fish Market)||0.5-2|
|Harris Street (between Milers Street and Allen Street, near Sydney Fish Market)||0.5|
|Bulwara Road (Sydney Fish Market)||0.5-3|
|Pyrmont Bridge Road (between Harris Street and Western Distributor)||0.5-3|
|Sydney Fish Market||0.5-1|
Source: M4-M5 EIS_Vol 2C _Part B__App I Air quality _Annexures__part 4.pdf pg K70
Air pollution on surface roads near portals will be worse.
The EIS acknowledges that air pollution will be worse on surface roads near the tollway portals in 2023 when the project is finished and a decade later in 2033.
It also acknowledges that construction traffic can pose a pollution risk.
The EIS describes the additional pollution in these terms: a ‘small increase in pollutant concentrations’ on surface roads near portals compared to existing conditions.” In other words, the EIS acknowledges that some residents will be left worse off after the project.
The EIS also states that potential health impacts associated with changes in air quality (specifically nitrogen dioxide and particulates) within the local community have been assessed and are considered to be ‘acceptable.’
I disagree that the potential impacts on human health are ‘acceptable’ and object to the project in its entirety because of these impacts.
Those who have time to access the full EIS will discover that concentrations of some pollutants PM2.5 and PM10 are already near the current standard and in excess of proposed standards (9-81, 9-93).
These particulates are a classified carcinogen and are known to have critical, and at times fatal, consequences if elevated.
People living within 500 metres of heavily affected areas have demonstrably shorter lives, much higher incidences of chronic lung conditions and higher levels of cardiovascular diseases.
I am opposed to a project that will have an anticipated result of leaving some residents exposed to exceedances of safe standards of air pollution.
It is not an answer to say that some people will be exposed to less air pollution. If people are currently exposed to unsafe levels of pollution, it is the job of government to take active steps to lower pollution where these residents live rather than exposing others to harm.
The mechanical ventilation proposed depends on single direction tunnel construction, so how it can possibly work for large curved tunnels on multiple levels is unknown.
Since this information is not provided, this EIS should be rejected.
EIS ignores impact of ozone emitted in Eastern Sydney on the West of Sydney
The EIS states that the impact on regional air quality is minimal. It concludes that the project’s impact on ozone is negligible.
Ozone is a major pollutant and Western Sydney, Campbelltown in particular, suffers the worst ozone pollution.
Major components of ozone are generated in eastern Sydney and drift west. Previous environment departments have spoken about the need for an eight-hour standard concentration and goal for ozone (DECCEW, 2010, State of Knowledge: Ozone).
The Office of Environment and Heritage (OEH) needs to provide information about the value of this standard and on the impact of new motorways on that level. This should be required to be included in the EIS.
Unreliability of data and lack of clarity
The Air quality data provided in the EIS is confusing and is not presented in a form that the community can interpret. The lack of clarity leads to a suspicion that areas of concern are being covered up.
I do not believe that the air quality studies are reliable as they are dependent on the traffic studies which are fundamentally flawed and have not included sufficient modelling of impacts on local roads.
I believe the EIS underestimates the traffic and therefore the pollution on local roads. It also fails to take sufficient account of impacts on residents at Haberfield and St Peters who after living with years of construction emissions and dust will then be exposed to traffic near the portals.
Both the traffic studies and the air quality studies should be independently assessed and verified before any approval of this project. The review should be public and itself open to public submissionsand evidence .
The Environmental Impact Statement (EIS) for the Westconnex M4-M5 link predicts that overall air quality will be improved by 2033 with the motorway in place in comparison to a scenario with no motorway, though it does acknowledge that some localities will suffer worse air quality. It also states that even in the areas that will see increases (including within the tunnels and around exhaust stacks), the air quality will still be below national criteria. The predictions are based on four seriously flawed assumptions:
It overlooks alternative public transport solutions to Sydney’s transport problems that involve far less air pollution.
It relies on traffic modelling that is highly dubious (finding that overall traffic movement will be reduced compared to the do nothing scenario).
It assumes that pollution emissions per vehicle will fall in the future as a result of tightening regulations and technological improvements.
It assumes that the current national criteria are actually safe for human health. In fact, there is no safe level of particulates.
1) Alternative transport solutions
Mass transport systems such as rail and bus produce far fewer pollutants both because less energy is required per passenger and because they make use of less polluting power supplies (electric in the case of trains and electric/gas/hybrid in the case of buses). It is a whitewash to present air quality scenarios without a public transport based solution.
2) Vehicle use modelling
Vehicle use modelling is known to be fraught, and modelling for most recent motorway projects in Australia has been seriously inaccurate. One of the main problems is inadequate consideration of ‘induced demand’, whereby, to quote the EIS: “Even with no growth in regional population and/or economic activity, a new or substantially upgraded road has the potential to induce changes in travel patterns, which appear as induced traffic demand”. This is the main reason that new roads eventually become clogged. When congestion is eased by a new road, people will take more trips, and this will increase until the congestion becomes the same as it was before the road was built. However, the modelling used for the M4-M5 link assumes this effect will increase traffic loads by only 0.3%. This is plain stupidity and is counter to the experience of major road building in every country around the world. This oversight means that the vehicle use may be far higher than projected. Presumably by 2033 the roads will be at full capacity, which by back of the envelope calculation could be >200,000 vehicles per day in the M4-M5 tunnel, or double the prediction in the EIS. This level of vehicle use has not been modelled for air-quality and without doing so, it would be very difficult to assess the impact within the tunnels or in the surrounding suburbs. However, given that the EIS predictions are close to the air quality criteria in some locations, frequent exceedance of the criteria must be quite likely.
3) Per vehicle emissions will fall
The EIS cites recent data to argue that air quality in Sydney has improved in recent decades, in part due to reduced emissions from vehicles. They also cite studies that predict this trend will continue, presumably as a consequence of technological and legislative changes. While this may be a reasonable assumption, there is a reasonable possibility that the improvements will not occur. The EIS should have modelled the air quality under these circumstances. The EIS should also have compared a scenario with the anticipated air quality improvements in 2033 and 2023, where NO STAGES of the WestConnex projects had been built, with the Do Minimum, Do Something and Do Something Cumulative criteria. I am asking for this to be done now.
4) National air quality criteria are safe
We note that the EIS predicts pollution levels to be lower than current air quality criteria for NSW, and also that several studies into the impacts of Sydney’s existing road tunnel network conclude that they are lower than the criteria. However, state, national and international guidelines and criteria for safe levels of pollutants have changed over the decades as knowledge about the impacts of the pollutants has improved. The changes have always been to lower the criteria. Take the example of particulate matter (particularly prevalent in diesel emissions). Health authorities recognise that there is no safe level of particulates, partly because they can cause cancer and as such just one particle may be enough to kill somebody. It is likely that criteria will be tightened further in the future and then the EIS predictions that appear under current criteria to be a modest and safe deterioration in air quality may one day be judged to be a public health disaster.
The trend in tightening air-quality regulations also invalidates the logic in modelling reducing vehicle emissions (issue 3 above). Vehicle emissions will only fall if health authorities keep reducing the air quality criteria. If they are going to reduce the air quality criteria, it is misleading to base future predictions on current criteria. In other words, the scenarios should either test current per vehicle emissions against current criteria or test forecast reductions in emissions against forecast criteria (or do both).
The EIS predicts a minimal impact on air quality but this may be very far from the truth. In particular, the lack of accuracy in predicting the actual number of vehicles, the general lack of knowledge of the health impacts of the pollutants and the lack of consideration of alternative transport solutions with far better air quality outcomes are serious flaws in the EIS process.
Ashfield resident and retired TAFE Teacher wrote this submission in 2015. Much of it applies to this EIS.
Barnett, Adrian G, It’s safe to say there is no safe level of air pollution’, Australian and New Zealand Journal of Public Health Vol 38. Issue 5
Read and watch Professor Paul Torzillo on health impacts of WestConnex