This sample submission is specifically relevant to the Darley Rd. construction site in Leichhardt. This massive dive site would be used to tunnel under Leichhardt. Since the potential selection of this site was announced, it has been hugely controversial. The Inner West Council and an independent engineer are opposed to this site and consider it to be dangerous.
It is 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:
• copy and paste whole or part of this submission for your own submission or share it with others
• use some of the points and mix them with objections on other topics relevant to the EIS ( for example Air Quality)
When you have finished drafting a submission, here’s the link to our online submission. Remember you can make as many submissions as you like.
Submission to WestConnex New M4/M5 EIS, project number SSI 16_7485
Darley Rd Construction site
I am very strongly opposed to any approval of the Darley Rd, Construction Site. The material in the EIS related to this proposal lacks detail about what is actually proposed or how the severe impacts of the proposal would be mitigated if it were to go ahead. On this basis, it should be rejected on the grounds that it exposes a residential community to unacceptable danger.
An important reason for objecting to the location of the Darley Road civil and construction site is because the site cannot accommodate the projected traffic movements without jeopardising the road network. Darley Road is a critical access road for the residents of Leichhardt and the inner west to access and cross the City West Link. As the EIS acknowledges and anyone who have driven there knows, this route is already congested at peak hours. The intersection at James Street and the City West link already has queues at the traffic lights. The only other option for commuters to access the city West Link is to use Norton Street, a two-lane largely commercial strip which is already at capacity. The addition of hundreds of trucks and contractor vehicles will result in traffic grinding to a halt and traffic chaos at this critical juncture with commuter travel times drastically increased. There should be an independent review of this construction impacts which I believe underestimate the true likely impact of extra traffic.
One detail that is included is the number of vehicles that would go in and out of the site on a daily basis. 170 heavy and light vehicles accessing Darley Road. This creates an unacceptable risk to the safety of pedestrians accessing the North Leichhardt light rail stop as well as bicycle users accessing the bicycle route on Darley Road and entering Canal road to join the dedicated bike paths on the bay run. Many school children cross at this point to walk to Orange Grove and Leichhardt Secondary College.
The EIS proposes that all trucks will arrive at the Darley Road civil and tunnel site from Haberfield and travel along Darley Road to the site, with a right-hand turn permitted into James Street. The proposed route will result in a truck every 3-4 minutes for 5 years running directly past small houses on Darley Road. These homes will not be habitable during the five-year construction period due to the unacceptable noise impacts. The truck noise will be worsened by their need to travel up a steep hill to return to the City West Link, so the noise impacts will affect not just those homes on or immediately adjacent to Darley Road. The proposal to run trucks so close to homes is dangerous. There have been two fatalities on Darley Road at the proposed site location. The EIS does not propose any noise or safety barriers to address this. Despite the unacceptable impact to nearby homes, there is no proposal for noise walls, nor any mitigation to individual homes. The proposal places residents in danger and should not be permitted.
Health risks to residents
The EIS states that the ‘main risks’ during construction would be associated with dust soiling and the effect of airborne particles and human health and amenity (xii). This will affect local air quality. There is no detail as to how this will be managed other than covering the spoil under an acoustic shed (of low grade). It is likely the Dan Murphy building has asbestos which creates additional risk during the demolition process.
Removal of vegetation
The EIS proposes removal of all vegetation on the Darley Road site. There is a mature tree located on the site which serves as a visual and noise barrier to the heavy City West Link traffic. Removal of this tree and other vegetation will increase noise impacts to nearby residents and affect the visual amenity, with homes having a direct line of sight to the City West Link. The existing mature tree needs to be retained on this and environmental grounds. Under the New M5, there was a condition that a tree report had to be done on every tree that the project proposed to remove. The effect of this condition was that a report was simply commissioned that always found removal was warranted if the project team desired it to happen. Rather than balance construction against the protection of the environment, these assessments effectively rubber stamped destruction.
I object to the selection of the Darley Road site on the basis that the works required (demolition and surface works) will create unacceptable and unbearable noise and vibration impacts for extended periods. The EIS indicates that at least 36 homes will basically be unliveable during this period. In addition, the planned 170 heavy and light vehicles will considerably worsen the impact of construction noise.
The EIS states that construction noise levels would exceed the relevant goals without additional mitigation. The additional mitigation is mentioned but not proposed. All possible mitigation should be included as a condition of approval. The EIS acknowledges that substantial above ground invasive works will be required to demolish the Dan Murphys building and establish the road. The EIS noise projections indicate that for 10 weeks residents will suffer unacceptable noise impacts. The EIS doe not contain a plan to manage or mitigate this terrible impact. There is no detail as to which homes will be offered (if at all) temporary relocation; there are no details of any noise walls or what treatments will be provided to individual homes that are badly affected.
The EIS states that ‘reasonable and feasible work practices and mitigation measures would be implemented to minimise potential noise impacts due to activities occurring at the Darley Road civil and tunnel site.’ 96-52). What is ‘reasonable and feasible’? This is not good enough. The EIS does not contain any detail whatsoever of these proposal on which they can comment. In addition, there is no requirement that measures will in fact be introduced to address noise impacts. If this proposal was to be approved, conditions must contain detail of specific noise mitigation measures that are mandated in particular areas and can be enforced. Experience in Haberfield and St Peters has shown that the contracting company has disputed the need for mitigation and residents have been exposed to horrific noise. This level of non accountability is not acceptable to me or my community. Standard conditions without detail or accountability are not acceptable to me.
The EIS does not mention the impact of aircraft noise and its cumulative impact. As such, the noise levels identified are misleading.
The EIS states that to minimise disruptions to traffic on the existing road network (including in peak hours) there will be night works where appropriate. Given the congested nature of Darley Road, it is likely there will be frequent night work (EIS, 6.4). This will create an unacceptable impact in residents. The community is well aware of the dreadful night noise that has impacted on the residents of Haberfield and finds it unacceptable that SMC and RMS would be again knowingly allowed to inflict it on another community. NSW Planning should not impose such open ended conditions. And, instead of a proper plan to manage traffic, the EIS contemplate work simply occurring. Night work is objected to in the strongest terms.
No workers associated with the WestConnex project should be permitted to park on local streets. There is already a shortage of parking in this area and many residents to not have off-street parking. The removal of 20 car spaces for five years as is proposed on Darley Road will worsen this situation as will the removal of ‘kiss and ride facilities’ at the light rail. There is also a pre-DA application for 120 units on William Street which is not taken into account in the EIS. This will place further stress on parking. The EIS needs to outright prohibit any worker parking on local streets.
Installation of a permanent motorway operations complex
I object to the location of a permanent substation and water treatment plant following the completion of the project on the Darley Road site. n This was no included in the concept design and is a breach of promise by SMC that the land would be returned after construction to the community. The land is Government-owned. The presence of this facility will forever prevent the ability for safe and direct pedestrian access to the light rail stop, with users required to walk down a dark and winding path. It will also limit the future use of the site. If a permanent facility is to be located there it would have to be moved to the north of the site so that it is out of sight of homes and has less visual impact on residents.
Tunnelling dangers to Leichhardt community
The estimated tunnel depths for the Leichhardt area as low as 35 metres. This creates an unacceptable risk of damage to homes due to settlement (ground movement). The EIS acknowledges that tunnelling at 35 metres and less presents a real risk. There is no mitigation provided for this risk. Instead, it states that properties will be repaired at the Government’s expense. However no details or assurance as to how this will occur are provided. The project should not be approved with such tunnelling depths permitted with no detail provided about potential risk of damage and how and when it will be repaired. If damage were to occur, residents and businesses would be forced to engage structural engineers and lawyers to prove that the damage was linked to Westconnex works, with no assurance that this property damage will be promptly and satisfactorily fixed. There is an added legal risk to residents should the project be privatised.
Impact on safe walking and riding to schools
Many students walk or ride to Orange Grove and Leichhardt Secondary College schools via Darley Road.There are also a number of childcare centres very close to the Darley Road site.
The presence of 170 heavy and light vehicle movements a day at this site will create an unacceptable risk to students. The EIS should not permit any truck movements near the Darley Road site. If the proposal should be approved ( which I certainly hope it is not), an alternative proposal which provides that all spoil trucks enter and leave from the City West link is the only proposal that should be considered.
Lack of transparency and Improper handling of public moneys
Acquisition of Dan Murphys
I object to the acquisition of this site on the basis that Dan Murphys renovated and started a new business in December 2016, in full knowledge that they were to be acquired, with the acquisition process commencing early November 2016. This is maladministration of public money and the taxpayer should not be left to foot the compensation bill in these circumstances.
It is very clear that there has been a lack of transparency in the dealings with this site. I refer NSW Planning to a number of media articles and questions in parliament. At the feedback sessions on the Concept Design in 2016, the M4/M5 team were asked for information about the construction sites. Journalists and residents were given conflicting information on different days. This lack of transparency is one of many examples of secrecy and lack of straightforward communication on the part of SMC which reflects a failure to comply with ‘meaningful consultation’ as required for this EIS to be accepted by the Secretary of NSW Planning.
Serious probity issues have been raised about the dealings with this site and while these may not be the responsibility of NSW Planning, if there are concerns, they should be referred to other agencies.
Tunnel vertical alignments
In 5.3.6 of Chapter 5 the EIS states that ‘the tunnels would generally have grades of less than four per cent. However, isolated locations connecting to the surface road network may require short lengths of steeper grades of up to eight percent. These grades would generally match with existing conditions on local surface roads or are required to ensure appropriate ground conditions with no direct property impacts.’
In 2014 the RMS Advisory Committee on Tunnel Air Quality published a technical paper (TP09) ‘Evolution of road tunnels in Sydney’. The paper highlights the key lessons learnt from over 20 years of experience in assessing and operating long road tunnels as it relates to the assessment, design and operation of ventilation systems to manage air quality in and around tunnels. A key lesson learnt identified in the paper is the need to minimise the gradient of the tunnel.
‘The M5 East has a gradient of eight per cent at the exit of the westbound tunnel. The increase in gradient resulted from a late design change to facilitate the placement of tunnel spoil between Bexley Road and King Georges Road. This was to substantially reduce the number of truck movements on local roads during construction. The unintended consequence of this change was that vehicles exiting the west bound tunnel are under significant load with multiple consequences for air emissions. Firstly vehicle emissions per distance travelled significantly increase with increase in grade. This is especially the case for ladened heavy vehicles (eg trucks returning from the port). Secondly the steep grade slows down heavy vehicles which contribute to congestion throughout the west bound tunnel further adding to vehicle emissions as compared to free flowing traffic. Consequently the Cross City and Lane Cove tunnels were designed to minimise gradients.‘
As a result of this analysis the RMS concludes that a key design requirement for new road tunnel projects is to minimise grades. It is therefore astonishing that the proponent is now planning to ignore this advice and repeat the mistakes of the M5 and incorporate tunnels with inclines of up to eight per cent. These steep tunnels will have multiple direct impacts on air emissions.
- vehicle emissions per distance travelled significantly increase with increase in grade. This is especially the case for ladened heavy vehicles which the tunnel is intended to take off local roads and which are intended to be users of the tunnel
- the steep grade slows down heavy vehicles which will contribute to congestion further adding to vehicle emissions as compared to free flowing traffic.
This proposal should be rejected. If the proponent wants to proceed, it should be required to redesign the tunnels so that no gradient exceeds 4%.
Darley Road and adjacent streets such as Hubert St are exposed to flood. The flood impact could be exacerbated by the disruption or blockage of existing drainage networks, which are risks identified in the EIS. The EIS has not assessed whether the identified risk to the existing drainage network will cause increased risk of flood damage to flood lots and it fails to take account of the Inner West Council’s Leichhardt Floodplain Risk Management Plan which contains recommended flood modification options. The EIS has not assessed whether its drainage infrastructure will impede the Inner West Council’s Leichhardt Floodplain Risk Management Plan option HC_FM3 to lay additional pipes/culverts from Elswick Street to Hawthorne Canal (via Regent Street and Darley Road). RMS has not assessed whether its drainage infrastructure will impede Inner West Council’s Leichhardt Floodplain Risk Management Plan option HC_FM4 to lay additional pipes/ culverts from William Street to Hawthorne Canal via Hubert Street and Darley Road. The EIS should not be approved as it has not properly explained or assessed these impacts
City West Link and James St intersection. The EIS only analyses crash statistics near the interchanges. It does not provide any detail as to the number of crashes at the James St/City West Link intersection which, on Transport for NSW’s own figures, is the third most dangerous intersection in the inner west. Nor does it comment on the two fatalities that occurred on Darley Road near the proposed construction site. The EIS should have detailed increased risk in crashes that will be caused by the additional 170 vehicles a day that are proposed to enter and leave Darley Road during the construction period.