This document summarises my objections to the recently published EIS for the M4East proposal. It concentrates on aspects of the health and social impact, including social & emotional wellbeing of residents that would result if the M4 East proposal was allowed to go ahead. This along with linked projects, the M5 East duplication & the M4-5 link projects are the bulk of the 33 km long road & tunnel project, collectively known as WestConnex.
Individually and collectively these projects have already impacted on the social and economic life of residents and workers in the inner west, since the current proposal was first mooted in late 2013. In particular, the M4 East project impacts heavily on the residents and businesses around Homebush/North Strathfield & Concord and its Western end and Haberfield/Ashfield & Croydon at its eastern end.
In addition the proposals for this project occur while there are other significant proposals that are affecting residents in the inner west.
- The first are the NSW Urban growth proposals for the Parramatta Road Corridor, with five of the eight proposed growth precincts within the inner west, coupled with the Bays precinct and the Central to Eveleigh project. Together these projects will have substantial influences on the character, built environment and population make-up of the inner west.
The second are proposals for forced amalgamations of local councils. The majority of residents do not wish to be represented at a local level by large distant bureaucracies. There is a real sense that local decision-making and democracy is being removed from residents by this enforced process. There is also great frustration that decisions affecting the lives of people are being made by a government that has shown no interest in the impacts these decisions have on the lives of local people. There has been no attempt by the Premier of relevant Government ministers to actually visit the sites of where residents are being forced from their homes, to explain why it is necessary and how the impact on people and their lives will be mitigated.
I object to the proposal partly because it has not been presented in a way that enables the public to determine if the proposal is an appropriate and effective solution for Sydney’s significant transport problems.
I object because the whole process has been corrupted by the agencies who are its proponents. This is evidenced by, the awarding of contracts for the project, notice of compulsory acquisition of family homes and the planned destruction of local communities, all before the matter has been considered and approved.
These factors combined have left local residents feeling sad and angry about the process to date and left many feeling sceptical that there is any real concern about their rights and welfare. In addition no comprehensive business case has been presented and the arguments in the 5000 page EIS are simplistic and lack depth. Critic such as the NSW Auditor-General and MLC Ms Mehreen Faruqi have seen the business case and have made strong arguments against what they consider to be a flawed process and proposal. There has been no serious rebuttal from the proponents, which suggests that the critique is accurate and that the whole process is flawed. If this was private money that was taking the risk, this would be disturbing but only for shareholders. In this case it is public money that is being proposed for investment. The scheme proponents are keeping the public in the dark about their financing methods. The opportunity costs of this project and the alternatives that could be developed by equivalent investment have not been tested in public.
The most disturbing outcome of this proposal, coupled with the other assaults on community rights and the ability of the public to engage in decision making about their city, is further distrust about governance and probity in NSW.
The whole process of the development of this proposal smacks of back room deals hidden behind the cloak of “commercial-in- confidence concerns” so that the public who pays for this are not truly involved in the decision. This is a fundamental core of my objection to what appears to be a flawed proposal.
I object to the poorly handled process of how this process has been announced and the poorly run community “consultation”.
The process appeared more concerned with the marketing and media spin, rather than the provision of information.
The initial announcements of this project were made in the last quarter of 2013. The WestConnex Delivery Authority (WDA) conducted a series of information sessions near where the project would impact. Many local residents and businesses received letters that their homes/ buildings would probably be resumed for the project.
The consultation sessions were characterised by what many residents in Homebush, Concord, Ashfield and Haberfield characterised as contradictory and misleading information. There was considerable distress amongst older residents at the prospect of being forced from their homes to an unknown and uncertain future.
There was also immediate deflation on local real estate prices in the affected areas. Many rental property owners were not advised of the resumption intention. who rented out properties found They discovered that their tenants were the persons had been advised by WDA of the property resumption plans and this sometimes occurred when the tenants gave sudden notice. and sometimes when their tenants were moving out. Other long-term owners in Haberfield and Concord were subjected to pressure, to sell their properties for low prices, by WDA agents.
Many businesses faced uncertainty about their prospects and found that trade reduced quite quickly through 2014.The loss of a family run motel on Parramatta Road would be significant loss for the district.
In mid 2015, a large number of residents who had lived with the apprehension of their homes being resumed for over 18 months, were advised that their properties were no longer required. Others who had not had any such advice received letters stating their properties would be resumed. This occurred in Ashfield and Haberfield. The impact of proposed resumptions in Haberfield and Ashfield is significant.
- Lack of analysis of the Socio-economic impact :The EIS identifies the social impacts on individual finances, health and loss of equity caused by compulsory land acquisition. It also concludes that this disadvantages the sick, frail, elderly and poor. It also concludes that property owners who seek to find property in the district would also be disadvantaged by the limited time available to find suitable property. The remedies offered in the EIS are limited and do little to identify how local residents would be supported. It appears to conclude disadvantage to property owners would just be collateral damage. There is no detailing of the socio-economic cost of these impacts. These need to be appropriately estimated and considered within a comprehensive social impact statement. Those disadvantaged by the proposed measures must have appropriate financial restitution to compensate for current and future losses.
Demolition of Apartments and social housing stock: One impact particularly for Haberfield/Ashfield and also Concord is the proposed demolition of many apartments and social housing blocks. Haberfield will lose over 50% of its apartment dwellings, many of which house single person and elderly long term residents. There is little if any equivalent stock available for purchase or rent nearby. Many of the people who are being forced from their homes will be forced to try and find a new home some distance away from where they have been part of established communities for years. Compulsory acquisition processes are already being implemented on local residents before the project is approved. Families, Friends and Neighbours are being separated. So while the impact is most significant for the 400 or more people forced to move, it also affects the hundreds who remain. Any stock demolished must be replaced and locally available for people on low incomes.
Supports for those affected and impacted by proposals : The EIS suggests WestCONnex would offer a counselling service to those affected: this is a somewhat akin to a party assaulting someone, then offering counselling in order for a person to deal with the assault. The only solution is to offer support for independent financial, legal and other counselling advice to affected people and to pay full and appropriate sums to compensate.
Destruction of Urban Heritage in Historic Conservation Area:The heritage report identifies that many of the historic houses that are slated for destruction are in Haberfield and Ashfield. This would result in a permanent scar on the historic fabric of the world’s first garden suburb and also cut off the western corner of the suburb from the rest of this treasured precinct. The EIS states that this proposal would have a major adverse impact on Haberfield and the overall project would have a major cumulative impact on the Haberfield Conservation Area. It does not propose any mitigation or restitution for this loss. (Definition of Major Adverse Impact p 19-11, Table 19-4 EIS Section 1B: “Actions that would have a severe, long-term and possibly irreversible impact on a heritage item. Actions in this category would include partial or complete demolition of a heritage item or addition of new structures in its vicinity that destroy the visual setting of the item. These actions cannot be fully mitigated. ”)
Loss of Community:The EIS itself says in 14.4.2, “Changes to the amenity of a street or suburb can negatively impact the sense of belonging and identity of its residents and consequently their cohesion and connectedness. Areas with heritage values can also be a significant contributor to local character and community sense of place. Impacts on heritage assets affect not only the value of the assets, but the value communities place on the quality of their environment, and their connections to it, both past and present.” “These impacts are primarily along the M4 corridor in Homebush at the western and eastern ventilation facilities, Concord Road interchange, and Parramatta Road and Wattle Street interchanges.” It describes the impacts for Haberfield as “major adverse impacts” with the whole project having cumulative adverse impacts. It proposes no solution or restitution for this impact. This is not acceptable.
Ongoing implied forced Acquisition of property prior to any official approval for the project:This week identified Residents and Businesses in Haberfield & Ashfield have received compulsory acquisition notices (PANS), which set a 90 day time frame for a negotiated settlement to be finalised, before court proceedings would commence. Residents who have lived their whole lives in the district will be forced from their homes, often with what is considered inadequate funds to secure housing within the neighbourhood. Residents report that RMS staff have been behaving in a forceful and what some consider a bullying manner towards them. They find it difficult to understand that as an EIS has just been released for community consultation, the planned acquisitions are being forced through, prior to any formal approval and prior to any consideration of community responses and concerns. Many believe the process to be a sham formality, without taking any real consideration of resident concerns. All property acquisition processes must cease until there is a full release of the Business case to the parliament and public to allow appropriate analysis of the proposal and for alternatives to be properly considered. This must include a full socio-economic impact analysis that accounts for all costs of the project and does not hide the costs borne by individuals if this project were to proceed.
Construction related impacts
The size of the project is huge with a 65 hectare (650,000 square metres) project footprint. This includes clearance of 13 hectares of vegetation and established tree cover.
I object to the proposed destruction of healthy iconic trees in the Reg Coady reserve.
- Noise and Dust : The EIS discusses the extent of the construction period of some 3 years. This includes a plan for 24 hour operations of heavy truck removal, with many places experiencing 20-40 heavy truck movements an hour 24 hours a day, as over 1.7 million cubic metres or some 16 million tonnes of spoil are removed. Part of this includes trucks running up and down Wattle Street adjacent to residential areas, where traffic is usually light between 9 pm & 6 am. I object to the proposed 24 hour spoil removal by truck. There would have to be respite from this process, from 9pm to 7am.
Also all trucks from Haberfield/Ashfield would aggregate in Concord through Homebush and beyond for 24 hours a day, subjecting many people along that corridor to extended period of noise & dust. Appropriate noise mitigation through double glazing and sound barriers would have to be installed. This would also require installation of high capacity dust filtration on air-conditioners. The capital and recurrent operating costs should be borne by WDA
Vibration & potential damage to homes:There is significant local resident concern on the impact of tunnelling beneath and around properties and the possibility of structural damage to old homes. There must be independent structural assessment of all houses in the region of the proposed tunnelling and blasting (within 200metres of the tunnels). All damage must be compensated with full remediation.
Destruction to Neighbourhood and Community : The grief and mourning caused by the forced breakup of family kinship and community ties would be long-lasting.
I object to this project because a number of health induced impacts are not satisfactorily addressed in the EIS.
- Sleep Disturbance: If heavy vehicle traffic is permitted on a 24 hour basis, it would disrupt sleep patterns for many local residents. Poor sleep is associated with a raft of health impacts, including increased blood pressure, increased cholesterol levels, impaired work performance, increased anxiety and depression. This would require a noise curfew between 9pm and 7am, along with noise mitigation described above
Respiratory Irritation due to dust: Spoil removal from tunnelling would increase dust locally and this would impact on general respiratory health, particularly for young infants and children and those with pre-existing heart & lung conditions. This would require appropriate glazing and air filtration mitigation as proposed above. In addition round the clock monitoring of local air quality would be required and residents would need to be alerted if dust levels were raised at certain times.
Mourning & Grief over loss over home & community: This would be an enduring influence on many people, including those forcibly moved and those that remain. It would also increase the risk of both anxiety and depressive conditions. The loss of home and community attacks a basic need for all humans, to have stable shelter and accommodation. Many people believed that a home within the confines of the Heritage Conservation area would safe-guard them from the destruction and vandalisation of their community. The lack of any proposed mitigation for this major impact is a serious deficiency in the EIS. It would require appropriate address and resolution. There should not be any progress on the project until this matter is satisfactorily addressed and appropriate restitution made to affected residents
Anxiety about impact on homes: The ongoing work, associated, with blasting, tunnelling and spoil removal would leave many remaining residents anxious about the security of their own homes and possible financial loss.
Impact on Family life: The loss of close family and friends from an immediate neighbourhood diminishes the quality of life for many people. Increased isolation, particularly those who were in their own or rented flats is associated with increased health morbidity. It is most likely that the initiation of the project would hasten the death of many elderly residents if they were displaced from their long-standing homes and community. No mitigation has been proposed for this problem.
Post Construction related impacts
I object to the proposal on the basis that even if the M4 East tunnel was completed, traffic congestion impacts in the Haberfield/Ashfield localities will remain unresolved.
Once the project is completed in 2019, the Haberfield/Ashfield sector would remain significantly impacted as the increased induced traffic would funnel into 2 already crowded corridors, namely Parramatta Rd and Dobroyd Parade. Proposed new right hand turns at Ramsay Street & and Waratah St off Wattle Street would increase through traffic in what is a residential suburb. The EIS also notes in its cumulative impact section (26), that there would be greater traffic densities along both the Eastern sector of Parramatta Rd and Wattle St when the whole project is complete. This appears to contradict other assertions about the localised benefits. It also states in Section 26.4.2 that there would be significant increases in concentrations of pollutants in a select number of sites, but does not specify where. Detailed information is required about where the pollution impacts are predicted to be worse as consequence of this project and identification of what remedies or solutions are proposed. These matters must be satisfactorily addressed before the proposal proceeds any further..
Questions about Ongoing Health Impacts
I object to the current proposal because the EIS fails to satisfactorily address a number of significant concerns about ongoing health impacts
- Localised noise hot spots: The redistribution of traffic and focussed portal entry & exits would cause concentrations of noise. In addition ventilation fans and exhaust stacks would create new noise sources that would require monitoring.This information should be clearly spelled out and readily identified and appropriate mitigation planned.
Ongoing sleep disturbance: The localised hot spots would contribute to ongoing sleep disturbance with health impacts that are known and documented
Localised Pollution hotspots: The Portal entry and exits would create localised pollution hot-spots. In addition until the project is complete, as described above there will be ongoing increased traffic in Parramatta road east of Bland street, which would cause local problems. Again detailed information of these impacts is required along with mitigation proposals
Exhaust stack plume dispersal: Even if we accept the assertion in the EIS that the exhaust ventilation tunnel would for the most part allow for reasonable distribution of pollutants away from the immediate vicinity, two issues of concern remain.
The first issue is: what is the impact of intense localised plume strikes onto small areas, which would cause often short, but quite intense concentrations of pollutants in a restricted area, due to changes in wind patterns or atmospheric inversion layers? These acute events can be a major trigger for acute asthma episodes or people with other chronic lung conditions. A further issue is that plume strikes would more frequently hit high rise buildings, so projected high rise apartments along the Parramatta Rd corridor would be more likely to be affected than low rise housing.
The second issue is: _**do these pollutant plumes continue to contribute to the adverse air quality conditions in the SW of Sydney? **_So is the claim of an improved local air quality in in the inner west, done at the expense of a worsening of the air quality in the South West, due to the prevailing air movements?
- In Tunnel exposure to pollutants: The EIS identifies the pollutant exposure for the Concord-Haberfield journey. However, there does not appear any recognition of cumulative exposure for people such as transport and taxi drivers, once all proposed tunnel projects are complete. If a person takes a return trip from Hornsby to the airport via NorthCONnex & WestCONnex, over half the journey by 2023 would be in a tunnel. So there would be some 40 or more minutes spent driving in a tunnel on a return trip. What would be the cumulative in-tunnel exposure from such a lengthy trip? Or if a taxi driver did this trip three times in a day, the exposure would be even longer; say a minimum of 120 minutes of in tunnel ambient exposure. How would the cumulative impact accrue in terms of NO2 or CO exposure? Would there need to be advisory information to limit in-tunnel exposure to less than 60 minutes per day?
The lack of analysis about particulate matter pollution: The EIS raises a number of contradictory issues about PM monitoring. The EIS argues that the NSW approved methods has no requirement to measure PM2.5. In fact much of the analysis is done on standards promulgated in 1998, and probably on science that is over 30 years old! There have been huge advances in knowledge and measurement technologies since then. This raised questions about claims that this project is being based on world’s best practice.
We know that there is no safe limit to most exhaust emission exposure. Exhaust emissions contribute to both increased rates of cardio-vascular disease and lung conditions, including lung cancer, which is now increasing amongst non-smokers.
Diesel exhaust emissions are carcinogenic. Modern Diesel exhaust consists mostly of particles sized PM0.5 and smaller (i.e less than 0.5 micrometer, at least one fifth smaller than PM2.5). There is no measurement of the quantity of these particles which drivers will be exposed to in tunnels. These particles penetrate into the blood stream and long term effects are not well known. It is not acceptable to state that the technology to measure these PM emissions is difficult and not required by NSW approved methods (section 9.2.4). The public needs to know what they would be exposed to in tunnel and via the tunnel exhaust vents. There are mitigating technologies that reduce in-tunnel and from tunnel exhaust ventilation stacks, by the use of electronic precipitators, which if designed from the start can work satisfactorily, as they do in Madrid and Hong Kong. Also carbon filtration can reduce Nitrous oxide build-up both in tunnel and from exhaust.
It may be that diesel vehicles need to be banned from tunnels and also urban environments.
The EIS clearly outlines the enduring and destructive impact that the WestCONnex project will have on the lives of people in select communities of the inner west. The loss of heritage items will be irreplaceable. The social connections and networks of families and friends will be disrupted. No meaningful mitigation is proposed. The central argument of the project proponents is that the perceived benefits will make Sydney a better place, so that the enforced sacrifices of a few justify this outcome. The proponents do not give any real evidence to support their thesis and to date no true business case that includes all socio-economic costs and benefits, has been made available. In fact it would appear that the proponents are pushing ahead with the project in spite of clear external critiques and with no logical rebuttal to the critics.
The project has already had an impact on the health and wellbeing of local citizens. During construction further impacts are proposed, that if unmodified would have serious impact on local wellbeing, particularly the 24 heavy vehicle traffic and tunnelling work. Even if the M4East was to be completed, local pollution and noise hot-spots would remain; East of Bland St and along City West link would be as congested as ever, with increased capacity coming to a stuttering halt at those 2 choke points. Increased public transport plans for Parramatta road are not even planned to be operational until 2031.
As outlined there remain too many unanswered questions about the health impacts. From a health perspective for local affected communities this is a slow moving disaster. The disaster is easily avoidable and should be avoided by not proceeding headlong with this project. It is the wrong project at the wrong time for Sydney. Let us stand back, take a deep breath and work collaboratively, using proper planning principles, to design a twenty-first century transport solutions for our communities and metropolis.