WAG objects to the negative impact the WestConnex project, including the New M5, would have on the health of residents who live, work or study along the motorway’s path, as well as drivers who use the tunnels and feeder roads.
WAG also objects to the human health risk assessment (HHRA) in this EIS on the grounds that so much of the air dispersion, traffic, noise, and vibration modelling assumptions or results upon which it is based are insufficient, poorly done, and/or unable to be verified. Unless the proponent can provide enough data and sufficient analysis to allow its assumptions in these areas to stand up to independent scrutiny, any areas of the EIS that relies on it – including the HHRA – should also be rejected, because the output of this modelling is pivotal data used by the HHRA. This is especially so for the traffic modelling and air dispersion modelling undertaken for the air quality impact assessment. Any deficiencies in the modelling, or change in predictions of pollutant air concentrations are likely to impact the HHRA, and may change the conclusions of the HHRA.
6.1 Expert views on likely health impacts
The health impacts of this project are likely to be severe. Professor Paul Torzillo, Executive Clinical Director of the Royal Prince Alfred Hospital in Sydney and a specialist in respiratory health, gave a presentation on the health risks of projects like WestConnex at a WAG public meeting in Newtown in 2015. He said (this has been edited to suit the context, but the full presentation can be seen online at https://www.youtube.com/watch?v=xjr5TEcEW-k):
“In cities like Sydney, traffic-based air pollution – which the scientists call TRAP, which I think is pretty prophetic – is a major contributor to total air pollution in the cities... it’s about 30% of the total air pollution that cities like our experience. It’s got two main components. The first is what comes out of exhaust emissions...Then there’s a second component to TRAP, and that’s road dust, fine particles from bitumen and rubber ware, and these two components contribute to this thing that they call “particulate matter”; that just means “stuff in the atmosphere”. It’s all small, some of it’s really small and some of it’s really really small, and that gets absorbed into your lungs and into your body. All these things are bad for health.
“There’s overwhelming international evidence now from organisations like WHO [World Health Organisation] that shows that that sort of pollution – if you look at what happens across big cities – it increases the number of heart attacks people have, strokes, it increases deaths from heart disease, deaths from respiratory disease, and there is some new evidence in the most recent WHO publication which says it probably impairs lung growth in children and it makes a contribution to diabetes, so these things on a population basis have a big impact on health.
“...these health effects occur both with long term exposure, and with repeated short term exposure. Again, the most recent WHO evidence suggests that repeated short term exposure has definitely got a health consequence. And the last thing that’s important is there’s no evidence about a “safe” lower level of any of these things. So less is better, but less isn’t safe. So almost all the important agency reports talk about “mitigating health effects”. The commonest word that you see in any of these reports is the word “mitigate”.
“So what happens when you get a project like WestConnex? There have been lots of these around the world, what do they do? Well the first thing to know is that the levels of this sort of traffic air pollution are high around busy streets, and they’re high probably for up half a kilometre each side – it depends on the topography and wind direction and various other things. Projects that involve tunnels redistribute traffic related pollution, so some places might be a bit better off, and other places might be worse off. So the tunnels themselves, the smoke stacks, the entrance points the exit point – all these places are likely to have higher levels, although you will see – and you will see on the website – it is hard to prove this because of a measurement problem that I’ll talk to you about in a second. Importantly when traffic emerges from tunnels, surprisingly, it has to go somewhere. So it goes back on to roads, and when it goes to those roads, then those roads have higher use, higher traffic, higher pollution levels.
“For a whole host of reasons, it’s incredibly hard to give a precise measure of how risky is it to live near a stack, near a tunnel entry or exit point, near a ventilation shaft, and there’s a whole lot for reasons for that. But that doesn’t refute the fact that the overwhelming evidence is that this traffic related air pollution is bad for health.
“Now many people say – and you’ll see this on the websites of every agency involved, that what should be done therefore is to monitor air quality. In fact agencies are very keen on this. But there are a lot of questions. The first is: how many of the components of some of the ones I mentioned are going to be managed? Do you measure them continuously or intermittently? How many monitors do you use? Where are they located? How does the public access this information?
“In a really big National Health and Medical Research Council review of tunnel related air pollution, the expert committee in their key summary said, and I quote, ‘We’d like to comment on how difficult it was to obtain data about some Australian tunnels.’ So if a federally funded, National Health and Medical Research Council with eminent scientists can’t access the information, how easy is it going to be for us?
“The international experience with road projects such as these is that they encourage more traffic. There are more cars, and more people use them. This is bad for population health in Sydney, not just Newtown and St Peters. Traffic and roads have an impact on health. Aside from the ones I’ve mentioned, they reduce our ability to do a bit of walking or a bit of cycling, even as part of what your daily movement has to be. The big game in here is not monitoring, it’s diverting these billions of dollars from these sorts of systems into safe and efficient public transport systems and that’s what we should be concentrating on.”
Professor Torzillo’s comments are echoed by respiratory health experts around the world, including WHO, and make it clear that this project will worsen human health for not just those people who live, work or study along the project route, but also those who live, work or study within half a kilometre of its ‘feeder’ roads; drivers who use the WestConnex tunnels (particularly those who do so regularly and/or over long distances); and commuters who are locked into greater car dependency and long-distance commutes, rather than having access to healthier public or active transport options and/or employment, education or lifestyle opportunities closer to home.
6.2 Poor analysis of impacts due to tunnels and stacks
Sydney is about to face an unprecedented growth in road tunnel construction and use, including the WestConnex M4 East, this project, and the planned M4-M5 link.
All tunnels will use longitudinal ventilation systems (air in one end, out the other – through a stack). All polluted air produced in the tunnel travels along it, increasing in concentration all the time, until it reaches the exhaust point (the stack) close to the end of the tunnel.
These are probably the longest ventilation ‘pathways’ of any urban road tunnel in the world.
The longest ventilation pathway in a Sydney tunnel is the west end of the existing M5 East, which is about 5km in total length. This is the portion of the tunnel notorious for its extreme pollution.
There are longer tunnels overseas, but these are mostly in mountainous regions. And if they carry heavy traffic, they tend to either use transverse ventilation systems or have multiple stacks to reduce pollutant build-up along the length of the tunnel.
The Calle30 tunnel recently completed in Madrid is 40km long and carries up to 120000 vpd, however it has 30 ventilation stations (stacks), all of which are filtered.
The justification for these new tunnels is to speed-up the movement of goods and services across the city, so the potential impacts of the tunnels on regular users must be examined to ensure that they are safe and free from harm both to users and to the general public.
People living in the vicinity of tunnels and their stacks are entitled to be concerned about the likely impacts and they have been led to believe that ‘monitoring’ will be able to detect any harmful impacts. But as Prof Torzillo noted, the true question that should be asked is not ‘will there be any measurable impact’ but ‘will the emissions cause me any harm’.
Commenting on the utility of monitoring, the NHMRC 2008 report observes: “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.”
WAG is aware of reports from residents who live near the M5 East stack that monitoring failed to signal problems with pollutants even when residents could clearly smell the stack emissions; that many residents have reported health problems that began only after the tunnel became operational; and that some have been forced to sell their homes and leave the area due to ill health.
Mark Curran, President of Residents Against Polluting Stacks (RAPS) and resident of Earlwood, provided this personal statement as part of his submission to this project:
"I am sometimes asked why, after 15 years of campaigning about tunnels, I am still motivated to continue. The answer is fairly simple. Prior to the M5East stack starting operations, I, always the technological optimist, had assured my neighbours that all would be well and that there would be no impact from the stack.
I have an ineradicable memory of walking around streets in Undercliffe, close to the stack, soon after the tunnel opened and passing into and out of patches of air which stank of stack emissions.
Almost immediately I started getting reports of people getting ill, of people with controlled asthma reverting to an acute state, of people finding it impossible to tolerate the impacts and putting their houses up for sale.
All this occurred in an area which air quality modeling suggested there would be low but acceptable impacts of less than 0.5µg/m3 PM10.”
The calculations and modelling of impacts, be it of PM10 or PM2.5, as done in the EIS documents, are fundamentally misleading and claims made about the ‘results’ are disingenuous.
It is NOT scientifically valid to simply ‘add’ the tunnel PM10 and PM2.5 to the background as a predictor of adverse impacts because the tunnel exhaust is made up almost entirely of carcinogenic diesel emissions.
Experience with other tunnels in Sydney has not established a clear pattern of health impacts from the stacks, although it should be noted that both the tunnels built in the aftermath of the M5 East (the CCT and the Lane Cove Tunnel) were relatively short and had significantly over-designed and over-sized ventilation systems.
It is clear that the same cannot be said for the current tunnel designs which envisage relatively low ventilation volumes (in proportion to length) when compared to others.
The potential for a tunnel to cause harm exists both inside and outside the tunnel.
The NHMRC 2008 report on air quality in and around tunnels found that the pollution conditions inside some tunnels in Sydney were ‘clearly dangerous to health’ and noted specifically that ‘Guideline values or health-based exposure limits should be developed for the priority pollutants—including particulates and nitrogen dioxide—based on transit times through tunnels, and realistic estimates of total trip and daily exposure.’
In spite of the government setting up an ‘Advisory Committee on Tunnel Air Quality’ under the NSW Chief Scientist, these guideline values were not determined, nor is there any evidence that an attempt was made to do so.
As a consequence, the in-tunnel limit values in use are based on the PIARC (World Road Authority) design guidelines which, according to the latest version of the PIARC publication, assume that “a tunnel passage generally lasts for only a few minutes”.
The extent of tunnel development in Sydney is such that it is certain that many tunnel passages, even under ideal conditions, will not fall into the category of ‘a few minutes’.
One such trip would be that from Hornsby (or further north) to Port Botany, which would involve a total of about 24 km in tunnels and that from City-West link to Beverly Hills, which involves 16 km in tunnels.
Considering that most trips involve both directions, this means that some drivers will travel more than 50km in tunnels a day, trips which, even with moderate traffic congestion, could take over an hour.
As all major tunnel pollutants (carbon monoxide, nitrogen dioxide and particulate matter) have cumulative effects which take more than 24 hours to clear, the impacts of pollutants inside the tunnels will inevitably be harmful if the tunnels are operated under the PIARC guidelines.
This is a serious concern which has not been addressed in the assessment of health impacts.
The claims made in the EIS about improved tunnel design and the reduction of pollution levels, specifically the advantages of wider, larger tunnels, are disingenuous.
The larger internal volume does help to reduce local peaks of pollution, such as those occurring at a change of slope in the tunnel, but does not reduce the total exposure of motorists. This is entirely dependent on the time spent traversing the tunnel, the total quantity of pollution produced inside the tunnel and its rate of removal through the stack (which determines the concentration).
Although reducing the slope of up-grades in the tunnel does reduce the rate of pollutant emissions, especially for particulate matter, the overall improvement is not as great as is implied. In total, the existing M5 East tunnel has about 450m of 8% upgrade and 330 m of 4%, so the improvement obtained by keeping grades under 4% is unlikely to be more than 10%.
The predictions of traffic volumes appear to be low (resulting in low predictions of emissions) and one is entitled to ask if such traffic volumes really justify the expense of building the tunnel.
In addition, the design of the ventilation systems depend entirely on the accuracy of predicted vehicle emission levels into the future, an assumption drawn into severe doubt by the recent scandals relating to the faking of vehicle emission tests and the apparent inability of modern vehicles to actually meet the required emission standards. On this basis, in-tunnel conditions are likely to vary from simply unpleasant to positively dangerous.
WAG also has significant concerns for the health and wellbeing of those forced to use the tunnels on a regular basis or as part of their employment. Because while harmful impacts from stack pollution do occur in the vicinity of poorly designed stacks such as the unfiltered ones proposed for this project, and they can be severe enough to force people to move away from the area, major harmful impacts occur inside the tunnel.
We agree with the observation made by the NHMRC in its 2008 report that, in relation to the vehicle pollutants nitrogen dioxide and particulate matter, “the potential for harm appears to lie strongly on the side of particulate matter”.
We are concerned that the EIS states the following in section 6.1 - In-tunnel air quality:
“The three pollutants assessed in-tunnel are nitrogen dioxide (NO2), carbon monoxide (CO) and particulate matter (PM). For the operating years of the WestConnex project, NO2 will be the pollutant that determines the required airflow and drives the design of ventilation for in-tunnel pollution.”
The NSW Department of Planning and Environment issued a report that included discussion on this topic for the NorthConnex project in January 2015. From the Secretary’s Environmental Assessment Report2 for the NorthConnex project: “The Department considers that nitrogen dioxide (NO2) is now the key pollutant of concern for in-tunnel air quality. While carbon monoxide has historically been the basis for in-tunnel criteria in NSW and internationally, improvements in modern vehicle technology mean that NorthConnex will comply with existing health based carbon monoxide standards. By contrast, vehicle emissions of NO2 have fallen less quickly, and uptake of diesel vehicles (which produce more NO2 than petrol based vehicles) has risen.”
The position of the authors of the report and of the EPA relating to the relative importance of particulate matter and nitrogen dioxide is clearly at variance with the position of the NHMRC, which we regard as authoritative and a true representation of the current state of scientific and medical knowledge.
The air-flow in the M5East has been determined by the need to limit particulate matter for most of its operational life and we see little reason why this would be different in the proposed tunnel.
The much vaunted ‘Advisory Committee on Tunnel Air Quality’ was requested to resolve this problem and provide a proper mass concentration/exposure standard for particulate matter but failed to do so.
In the absence of this guidance, the operator appears to believe that there is no compelling reason to maintain particulate matter at demonstrably safe levels, levels which can be directly compared with the levels of pollutants quoted in medical literature.
The current predictions of in-tunnel levels show a number of scenarios where in-tunnel particulate matter concentrations are above 1000µg.m-3, a level noted by the NHMRC to be “clearly dangerous to health”.
Although large amounts of NOx (total oxides of nitrogen) are emitted in concentrated form from tunnels it seems unlikely that the impact of this will have a local effect, considering the time it takes for the relatively harmless nitrogen oxide to be converted to Nitrogen dioxide in the atmosphere.
The tunnel design proposed in this EIS does not represent a conscientious response to modern medical knowledge, nor to does it give proper consideration to health, wellbeing and general amenity of ordinary members of the public.
WAG also finds it disappointing that both the RMS and the tunnel proponents continue to deny the potential in these tunnels to use progressive in-tunnel filtration to alleviate adverse conditions, choosing to misrepresent the costs and the potential benefits of such systems.
When discussing the relative importance of nitrogen dioxide and particulate matter inside the tunnel, the NHMRC report noted that ‘the potential for harm appears to lie strongly on the side of PM’, a component which can be removed easily and economically by the use of electrostatic precipitator filtration.
WAG is aware that Leightons, one of the main construction contractor for this project, is installing “a state-of-the-art air purification system (APS) and tunnel ventilation system (TVS)” in its current tunnel project in Hong Kong, the 3.5 km Central Wanchai Bypass.
Leighton’s claim that “Hong Kong’s planners and our Leighton Asia JV have spared no effort to ensure the city’s latest major road and tunnel project leaves residents breathing easy”. If this system is good enough for Hong Kong and Madrid, then why is it not good enough for the residents of Sydney?
6.2.1 Accuracy of the estimation of particulate matter in tunnels and in stack emissions
Motorway and tunnel construction in Sydney has occurred in several phases, with significant pauses between each phase.
Since the first major tunnel was built under Sydney Harbour there have been significant changes in the nature and quantity of vehicle emissions and in the guidelines adopted to limit the exposure of motorists and the general public.
2 x 2
2 x 3
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The reduction of carbon monoxide in vehicle exhaust (now about 12% of 1992 levels) has produced a massive decrease in the acute toxicity of tunnel air and the volume of air used to ventilate tunnels has been reduced accordingly.
The fact that other harmful exhaust components have not fallen proportionately has meant that they have actually increased as a proportion of the now reduced volume of vitiated air inside tunnels.
The actual performance of the tunnel ventilation systems in relation to motorist safety and comfort has been variable and in some cases is far from satisfactory.
The relatively short Eastern Distributor is moderately smoky and causes significant localised pollution around Palmer, Burke and William St.
The M5 East tunnel is notorious for its in-tunnel conditions drawing adverse comment from multiple health authorities. It has been noted that “congested conditions in the west end of the westbound tunnel give rise to significant elevations in PM10 levels (sometimes to over 2000 µg m–3) for short periods.” NHMRC 2008
Both the Cross City and the Lane Cove tunnels have never had their ventilation systems ‘stress tested’ because their traffic volumes have never approached the design predictions.
The ventilation systems of the three most recently completed tunnels were built according to the PIARC (World Road Authority) guidelines for “Road tunnels: Emissions, Ventilation Environment” 1995 (variously updated)
It describes a method for estimating the total emissions of the various gaseous vehicle pollutants under various operating conditions.
Emission rates for ‘turbidity’ or smoke (which is not regarded as a health risk but as a nuisance limiting clear vision inside the tunnel) are also provided.
This document has been replaced by a further updated version (2012) which uses the same methodologies but updates some of the information including new emission rates for types of vehicles likely to be encountered into the future.
The varying degrees of success of the designs of Sydney’s tunnels would lead a prudent person question whether these guidelines are, in fact, suitable for use as a design guide into the future.
Of greatest concern is the fact that even the latest document does not treat particulate matter or (more specifically) diesel exhaust as a health issue and does not allow for a determination of the components of particulate matter most implicated as the causes of health impacts such as cancer.
The calculation method is the basis for the estimation of the quantity of pollutants which will be emitted from tunnel stacks and is the crucial input required for all of the various air quality modelling which is carried out to determine likely adverse impacts on both tunnel users and on residents and workers surrounding the tunnel.
This approach does not provide any direct method for estimating particulate matter mass, nor does it allow for the direct estimation of nitrogen dioxide (as opposed to total oxides of nitrogen).
The estimation of nitrogen dioxide depends on assumptions about the rate of conversion of the nitrogen oxide component of total NOx into nitrogen dioxide.
For particulate matter, the guidelines provide a conversion factor to relate particulate matter concentration (as mg.m-1 PM2.5) to observed light extinction (K in m-1): Diluted exhaust gas (tunnel): K = 0.0047µ.
According to this relationship, the commonly quoted ‘limit’ to maintain acceptable visibility, K=0.005m-1, is equivalent to a PM2.5 concentration of approximately 1000µg.m-3.
The EIS document notes the direct usage of this relationship: P 5-128 In-tunnel air quality design criteria.
“For measurements of visibility or in-tunnel haze, an extinction coefficient of 0.005m-1 based on the recommendations of PIARC for free flowing peak traffic travelling speeds of 50 to 100 kilometres per hour. Based on the correlation factor recommended by PIARC, this extinction coefficient is equivalent to an in-tunnel particulate matter concentration of 1.06 milligrams per cubic metre.”
If this conversion factor is incorrect, then all of the air quality estimates are necessarily flawed, as are any assumptions or decisions based on them.
But soon after the M5 East tunnel opened, and long before it reached anywhere near its planned capacity, it was obvious that something was severely wrong and that smoke levels in the tunnel were unacceptable to users.
There were frequent reports of motorists suffering distress inside the tunnel and these reports were sufficiently consistent for the NSW Dept of Health to carry out a study of in-tunnel conditions.
It is worth noting that, so far as is known, the notoriously dysfunctional M5East tunnel has always operated well within the PIARC guidelines, including those for visibility.
As the Cross City tunnel was in the planning stage, it was necessary that this apparent anomaly was examined and its cause determined. What happened is best summarised by this transcribed extract from the EIS document for the Cross City Tunnel.
2.7 Extinction coefficient
Experience by RTA indicates that haze in the M5 East tunnel becomes unacceptable when the extinction coefficient, reported by the M5 East tunnel stack opacity monitor exceeds 0.003m-1. Assuming that the particulate in the CCT will have similar properties to the M5 East tunnel, the relationship between extinction coefficient and PM10; concentrations can be applied to calculate an equivalent extinction coefﬁcient in the CCT.
This relationship was derived from data measured in the M5 East tunnel as shown in Figure 3.
Figure 3. Correlation of extinction coefficient and PM10, concentration obtained from M5 East tunnel discharge stack data.
The relationship shown in Figure 3 differs from that defined by PIARC (1995). PIARC (1995) indicates that an extinction coefficient of 0005m-1 corresponds to a PM10, concentration of l000µg/m3. However, the same PM10, concentration in the M5 East tunnel suggests an extinction coefficient of 0.0025m-1, i.e., approximately half that predicted by PIARC (1995). Unless stated otherwise, all extinction coefficients predicted in this report are based on the M5 East relationship shown in Figure 3. A discussion of the relationship between visibility and fine particles in tunnels is attached in Appendix A.
This conclusion was based on an analysis carried out by the environmental engineering firm Synergetics for the NSW RTA.
It is clear that the PIARC relationship between visibility and particulate matter concentration DID NOT HOLD UNDER THE CONDITIONS FOUND IN THE M5 TUNNEL and that the extinction coefficient to be used for the control inside the tunnel needed to be significantly less if acceptable conditions were to be maintained.
Logic would compel us to assume that it is at least possible that these conditions still exist and that a similar set of investigations would produce a similar result.
The actual methods used are summarised in section 9.4 ‘Particulate matter’ contained in the Stacey Agnew ‘Appendix L - Ventilation report’.
Although the discussion is both confused and largely circularly argued, it does, however, confirm that the PIARC method and the particulate matter conversion factor 4.7m2/g is used as the basis its calculations for particulate matter.
The PIARC method ultimately determines the rate of particulate emissions from the values of visibility reduction (‘K’ or extinction factor) by summing the contributions of the various numbers and types of vehicles using the tunnel, each vehicle contributing to the total reduction in visibility.
Particulate emissions are calculated from this estimate by use of the conversion factor.
The factor is not an absolute measure like mass or length and there is no ‘theoretical’ or mathematical relationship between the entities.
Rather it is an empirical value which was determined by actual measurement in tunnels in Europe prior to the publication of the 1995 PIARC document.
There is no actual reason why it should remain constant and not vary over time or location or with changes in the composition of exhaust gases.
It is hardly surprising that it may vary under different conditions, due to variations in engine type and design, emission standards, variation in weather conditions and the various types of non- vehicle sourced particulate matter.
It should be a matter of serious concern that the PIARC conversion factor has been used in spite of the experimental evidence based on local conditions and experience, which demonstrate that it is, in fact, unsuitable and inaccurate.
This problem arises, at least in part, from the resistance by tunnel designers to treat particulate matter as a serious health risk and that this risk is best assessed based on an accurate measure of the gravimetric concentration of PM10 or, more importantly, PM2.5.
It is essential that the approach taken by the designers of the Cross City (and the Lane Cove) tunnel be adopted and that all relationships between visibility and gravimetric concentration be based on a locally determined empirical relationship.
A failure to do this could conceivably lead to significant underestimates of likely pollution quantities and concentrations inside the tunnel, which would have serious consequences in a tunnel design which is already pushing the limits of established norms of tunnel ventilation design.
6.2.1 Poor analysis of filtration
According the EIS document (p4.5) community and stakeholder feedback identified the following issues as being of paramount concern:
· In tunnel air quality, including consideration of filtration as part of ventilation systems
· Location of ventilation outlets. Feedback from the community suggested positioning ventilation outlets within industrial areas was preferred
Given this clearly expressed concern, which is not unique to this project, the cursory way in which the proponents have addressed the issue of filtration shows a disregard of the views and desires of the public, especially considering that the company which is to build the tunnel is intending to install a complex filtration system in the tunnel which it is currently constructing in Hong Kong.
The public is at least entitled to expect that the current capabilities of filtration equipment are accurately reported and discussed and that some evidence be given that the potential use of filtration has been considered and not rejected out of hand.
The comments, conclusions and claims made in the executive summary of the technical paper relating to air quality about the possible utility of ‘filtration’, its cost, usage, operational efficiency and cost cannot go unchallenged.
Many of the claims and assessments made are either incorrect, tendentiously reported or show a misunderstanding of modern usage.
The EIS states at pp xxi - xxii Filtration
“The provision of a tunnel filtration system does not represent a feasible and reasonable mitigation measure and is not being proposed. The reasons for this are as follows:
· The project’s in-tunnel air pollutant levels, which are comparable to best practice and accepted elsewhere in Australia and throughout the world, will be achieved without filtration
In fact the comparison is with the PIARC norms which are not claimed to be “best practice” but rather to an attempt at defining “the minimum air requirement that is required to ensure adequate in-tunnel air quality and visibility thresholds”
The in-tunnel air pollution levels are not ‘accepted in Australia’ by tunnel users. Although the M5East tunnel meets the PIARC criteria, the NHMRC (2008) report notes that “current levels of PM in some tunnels in Australia (ie the M5East) are in excess of 1000 µg m–3 which is clearly dangerous to health.”
It is WAG’s belief that the current ‘allowable’ pollution levels, especially for particulate matter in the presence of nitrogen dioxide, are not adequate to protect the health and comfort of tunnel users.
The EIS also states that:
· Emissions from the ventilation outlets of the project tunnel will have a negligible impact on existing ambient pollutant concentrations
This may well be true in the sense that they are not able to be detected by the methods in use supposedly to monitor them but in the past, local impacts from stacks such as the M5East stack at Turrella have caused severe distress to sensitive individuals, in spite of the fact that no impact of pollutants could be detected in the immediately adjacent monitoring station, which was specifically located to attempt to detect such impacts
The NHMRC 2008 report notes '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.’
The EIS also claims that:
· Of the systems that have been installed, the majority have subsequently been switched off or are currently being operated infrequently
It is hard to see this comment as other than an attempt to mislead as exactly the same comment could be made about the jet fans in the tunnel. In any sensible system, equipment is not operated when it is not needed. If the systems are operated infrequently then they are presumably operated as they are needed. The history of the development and use of electrostatic precipitator equipment is long and complicated and cannot be summarized as is attempted here.
Similar can be said of this statement from the EIS:
· Incorporating filtration in the ventilation outlets would require a significant increase in the size of the tunnel facilities to accommodate the equipment. It would result in increased project size, community footprint, and capital cost. The energy usage would be substantial and does not represent a sustainable approach.
This is misleading as it implies that filtration in the ventilation outlets would be the appropriate way to deploy such equipment. The problem likely to occur in this tunnel is excessive particulate matter concentrations inside the tunnel (and high cost relating to increased air volumes required to clear it). The most appropriate way to deal with this is by the use of progressive in-tunnel filtration.
The size of the installation depends on the way in which the equipment is deployed. Equipment suitable for use in an exceptionally long tunnel such as the proposed M5 duplication could be installed above the carriage-way in an enlarged fan niche.
The cost of both installation and operation of filtration has been vastly and irresponsibly overstated. The going price, world wide for electrostatic precipitator equipment supplied and installed is around $A2-3 million per 100m3/sec treated. Energy consumption excluding fans is about 1.5kW per 100m3/sec treated.
The EIS also states that:
· If compliance with in-tunnel air quality limits cannot be achieved with the proposed ventilation system, the most effective solution will be the introduction of additional ventilation outlets and additional air supply locations. This is a proven solution and more sustainable and reliable than tunnel filtration systems.
The addition of extra ventilation outlets introduces new issues of external impacts and community resistance. Additional air supply does little to alleviate the problem as no pollutant is removed from the tunnel by this alone.
And it is hardly a “proven solution”. The proposed tunnel is exceptionally long for an urban, heavy traffic tunnel and is aiming to use a ventilation technique untested on this scale. The countries with most experience with tunnel filtration (Japan and Norway) both claim that progressive in-tunnel filtration has the capacity to reduce the cost of ventilation. In addition it has the capacity to reduce the exposure of drivers to pollution. Reliability is not an issue in properly designed and maintained equipment.
The proposed tunnel is exceptionally long and will carry a relatively heavy load of medium and large trucks. The intention of the operators to depend on basically passive ventilation systems is of concern as, so far as we are aware this system has not been used on this scale anywhere else.
6.2 Failure to meet SEARS
There are several areas in which the HHRA either does not meet the Secretary’s Environmental Assessment Requirements (SEARs) related to human health, or it is unclear whether relevant SEARS have been adequately addressed.
How the design, e.g. relative to other design options, minimises adverse health impacts is unclear.
There is no specific reference to how the design, or as yet unconfirmed mitigation measures, minimises adverse health impacts.
It is difficult to objectively assess how the design of the tunnel minimises adverse health impacts.
Given the proposed scale and longevity of the WestConnex project, including the New M5, additional detail for how the chosen project design, relative to other options, minimises adverse health impacts should have been included in this EIS.
6.3 Issues with the HHRA
There are a number of areas in which the HHRA fails to consider significant health impacts and risks associated with the New M5 project, and therefore cannot be considered fit for purpose.
6.3.1 Failure to assess impact of filtering ventilation stacks
Air quality (and resulting health impacts) once the tunnels are in operation was not assessed with the inclusion of filtration, or other pollutant reduction measures, in the tunnel exhaust stacks. As a result, the potential benefit to human health of including filtration has not been objectively assessed.
In addition to providing potential physical and clinical benefits from reducing pollution exposure, there are psychological health benefits that should also be taken into consideration when evaluating the worth of installing pollution abatement measures in the stacks.
Furthermore, the Protection of the Environment Operations Act 1997 of NSW (1997) states that, amongst its objectives, are: “to protect, restore and enhance the quality of the environment in New South Wales, having regard to the need to maintain ecologically sustainable development”, and “to reduce risks to human health and prevent the degradation of the environment by the use of mechanisms that promote the...making of progressive environmental improvements, including the reduction of pollution at source.”
Omission of in-stack pollution reduction measures in the air quality and HHRA considerations of the HHRA is not consistent with the policy objectives of the Protection of the Environment Operations Act 1997 of NSW. It is not appropriate to use logic that relies on existing bad (and non-compliant) air quality, and the attending health risks not getting any worse to justify the project or not evaluating the inclusion of pollution abatement equipment.
6.3.2 Over-reliance on vehicle emission exhaust data
Given the recent revelation of vehicle manufacturers to significantly (perhaps by as much as 50%) understate pollutant emissions, WAG questions whether vehicle exhaust data used in the dispersion modelling to predict levels of community exposure are sufficiently robust to provide an accurate estimation of exposure.
6.3.3 Compliance vs risk assessment
Health effects of all other compounds chosen for assessment have been evaluated largely by compliance with air quality guidelines. Such a screening compliance assessment does not necessarily evaluate the actual risks or impacts to health. It is not sufficient or appropriate for a project of this scale.
Other serious concerns regarding the method of assessment used to evaluate risks and impacts to human health in the HHRA include:
● The justification for choosing the guidelines is not in the HHRA. For a project of this scale, it would be expected that a detailed explanation of the data underpinning the guideline value and why it is appropriate for judging the health effects (and not only compliance with a guideline) to people be provided. Included should be a scholarly exposure-response assessment (i.e. the effects that a substance may cause at exposure concentrations other than the effect used to set the guideline). The EIS should have included appropriate justification for choosing a guideline over a different one. A scholarly justification should also have been provided for the selection of the guidelines used in the HHRA with regards to what health effects are associated with a substance and how the guidelines are protective of acute and chronic health effects.
● For a number of the pollutants that may be in stack emissions, the averaging times of the guideline may not be pertinent for assessing short term health impacts – particularly for the assessment of eye and respiratory tract irritation from exposure to individual substances, and as a mixture. For example, acetaldehyde and formaldehyde were assessed against 1-hour guideline values derived by different states in the USA, but elicitation of sensory irritation can occur with very brief exposure, i.e. within 5-10 minutes (NHMRC 2006). Even though the irritation may be relatively mild, manifested as itchy eyes or a tingling nose, it can affect general amenity and wellbeing if it happens often and in conjunction with odour (see below). In this situation the effect should be considered adverse (NHMRC 2006). The risk of sensory irritation be assessed for all relevant compounds, and as a mixture.
● Missing from the HHRA is a serious evaluation for odour impacts. Repeated, unwanted odour can have significant bearing on the amenity of communities. It is well recognised that the health effects associated with malodour or unwanted odour are not of a clear toxicological nature but are an effect on wellbeing and include such non-specific symptoms such as headache, mental fatigue, stress and perceived irritation (NZ MfE 2002, TCEQ 2015). Providing the air concentration of odour is sufficient, only very short exposure times are required to experience an odour event, in the order of a few seconds. The assessment is deficient in that biologically relevant exposure concentrations (brief exposures to peak concentrations) of mixtures of air pollutants have not been considered. Odour impacts be assessed for the mixture of relevant compounds.
● Also missing from the HHRA is consideration of elicitation of an asthma response that does not necessarily requiring a visit to a hospital emergency department. A wide range of other health effects and health measures including mortality for different age groups, chronic bronchitis, medication use by adults and children with asthma, respiratory symptoms including cough, restricted work days, work days lost, school absence, and restricted activity days have also been associated with PM exposure. The report indicates while these associations have been identified the exposure-response relationships established are not as strong as those used in the assessment for quantitative evaluation. The available baseline data do not include information for many of these health effects, making it impossible to undertake a quantitative assessment. Other indicators of acute health effects to PM (i.e. <24 hours in duration) than hospitalisation or respiratory mortality should have been considered as part of this EIS, because substantially more persons are likely to be affected (NHMRC 2006). Notwithstanding that the health impacts from PM have apparently been agreed in consultation with the NSW Department of Health, we believe such consultation established the minimum health effects that should be examined, and should not limit health risk assessment to only those ‘agreed’ effects. This could be done by acknowledging that exposure to PM (and NO2) should be somewhat less than the 24-hour guideline. The assessment for PM should include effects other than hospitalisation prevalence and mortality for shorter-term exposures.
6.3.4 Choice of chemicals included in HHRA
Not all pollutants relevant for assessing the impact of tunnel emissions have been included in the HHRA, or have been reasonably/objectively dismissed as having possible negligible impact.
For example the Australian Motor Vehicle Emission Inventory for the National Pollutant Inventory (NPI) (Smit 2014) lists 116 pollutants, included are metals and 14 carbonyl compounds. However the HHRA does not consider metals at all, and only two carbonyls (acetaldehyde and formaldehyde) are included. Of note is the inventory does not include the wear release of compounds entrained within tyres and brake pads that become resuspended in air and emitted from the tunnel stacks. Various authors (e.g. Sternbeck et al. 2002, Lough et al. 2005, Grigoratos and Martini 2015) have found brake wear to be a major emission pathway for some metals. A consensus statement from an international workshop held in June 2011 concluded that wear-related PM emissions that contain high concentrations of metals may (despite their limited contribution to mass of non-exhaust emissions) cause significant health risks for the population, especially those living near intensely trafficked locations (Denier van der Gon et al. 2012).
6.3.5 High-rise exposure
There is no discussion in the HHRA regarding the potentially different exposure profile for people who may be living above ground in medium-to high-rise apartments. The air quality modelling has projected ground level concentrations. Current and future development of the area with more people inhabiting apartment buildings could affect the exposure profile for this sector of the population, particularly if windows are open to allow air flow through the apartments. This is particularly significant given the large numbers of people who already live in such developments along the route, and plans for thousands of new dwellings in medium-to-high-rise apartments along or near the project route. The HHRA in this EIS cannot be considered fit for purpose unless it considers how exposure and resulting risk profile for people living above-ground level in apartment buildings may be different from that discussed in the HHRA.
6.2.6 Lack of quantitative assessment of construction scenarios
Quantitative assessment of construction scenarios and lay-down areas has not been undertaken in the HHRA. The question arises how the construction management plan will ensure negligible health effects from potential dust impacts on nearby residents. For example drilling and grinding sandstone or other hard rock creates small biologically active silica particulates which have carcinogenic potential (QLD WH&S 2009, Safe Work 2013). Public exposure to these particulates has not been considered in the HHRA.
As a result, the EIS contains no details as to how public exposure to such substances is to be minimised or preferably avoided entirely throughout the construction process if the project proceeds. Such conditions should include, at a minimum, requirement for measurement of respirable crystalline silica and adherence at the construction boundary to the Victorian ambient air standard (VIC EPA 2007) of 3 µg/m3 as PM2.5 (as NSW does not have an equivalent criteria); installation of vehicle washes, especially wheel washes, before leaving construction areas and entering public roads; and a minimum moisture content of trucked spoil of 10%.
6.2.7 Averaging time used for calculation of incremental risk of NO2 and PM
The calculation of incremental change in individual risk from modelled change in NO2 and PM concentrations has been undertaken in the HHRA using several short-term and long-term health endpoints. Many of the concentration-response functions from the literature which have been used in the HHRA are related to a daily maximum concentration (for NO2) or daily average concentration (for PM). However, the HHRA has used a change in annual average NO2 and PM for assessment against the short-term health endpoints. This is inappropriate, and is likely to be diluting the exposure and therefore the estimation of potential risk.
6.2.8 In-tunnel health risk assessment
The modelled in-tunnel concentration data are provided as maximum 1-hour average concentrations. However, the in-tunnel criteria which are used to judge the potential for health impacts are related to shorter averaging times. Comparing the two is inappropriate. In addition, the HHRA states the ventilation system in the tunnel has been designed so as not to exceed the in-tunnel criteria. However for NO2, it is clearly evident that the in-tunnel criteria would be exceeded, since there are instances where the modelled maximum 1- hour average already exceeds the 15-minute criteria chosen as the guideline for HHRA.
The HHRA rightly concludes there may be a health risk for people who travel through the tunnel. The advice for management of this risk to asthmatics is to keep windows up and air conditioning on recirculation. This management approach is inadequate, as it does not protect motorcyclists or other people not travelling in fully enclosed vehicles. Perhaps more importantly, the first point of exposure management should be improving the tunnel design and engineering controls to minimise exposure by reducing pollutant concentrations in the first place.
An ‘in-tunnel’ worst-case exposure scenario that addresses ventilation decrease, or failure, has not been included in the HHRA. It is also noted that NSW Health commented in their requirements that in-tunnel exposures for vehicle occupants and motorcyclists be assessed, and that the assessment should include consideration of all reasonable and feasible mitigation measures. An objective assessment of all feasible mitigation measures does not seem to have been provided.
6.2.9 Combining suburbs
In relation to health impacts, various suburbs have been combined and reported as one area without any explanation as to why this is the case provided in either the Appendix or the rest of the HHRA - for example, Marrickville, Sydenham and Petersham. St Peters is one of most impacted suburbs, but it has not been separately assessed in this EIS with respect to health impacts, though it contains areas from the dispersion modelling with higher concentrations. Again, no explanation has been provided for this decision.
These unexplained and, in WAG’s opinion, unjustifiable decisions are likely to obscure the potential health impact to the project area as a whole, and on individual suburbs – particularly the ones that are likely to be the most heavily impacted by the New M5.
WAG formally and strongly objects to both the health impacts of the WestConnex including the New M5, and to the way in which this HHRA has been conducted. We ask the Minister for Planning to reject the WestConnex New M5 project.