WAG objects to the both the long and short-term impact that increases in noise and vibration will have on the lives of the hundreds of thousands of people who currently live, work or study in or near the route of the planned WestConnex, including the New M5. We also object to the poor analysis of these impacts in the New M5 EIS.
Noise could have a long-term impact on those who would live beside the proposed New M5, as well as in local streets and roads carrying extra traffic nearer tunnel exits and on ‘rat runs’. Construction noise from demolition, thousands of truck movements a day and rock crushers would impact heavily on local communities and businesses. In some situations this could occur for several years. In others, the impact would be over shorter periods. Research has shown that noise does have negative effects on health. Vibration from construction including tunnelling could cause cracked walls. The proponent has already begun warning residents of this risk.
The EIS does recommend noise mitigation for some buildings, although only up to the first story. It recommends noise walls and other strategies that would reduce the noise.
The EIS provides no justification for not treating residential buildings exposed to road traffic noise greater than two (2) storeys in height. It provides no information regarding cumulative noise impacts from surface and underground tunnelling construction activities, or justification for not addressing construction noise at properties greater than single storey. Assessing such impacts were outlined in the SEARS for this project. On this basis alone, these findings in the EIS should be rejected.
There are many gaps in the EIS when it comes to assessing these impacts, and much is also left to future decision making during the final design phase.
Even the way the EIS reports are presented make it difficult for residents to see whether their neighbourhoods would be affected by excessive noise levels or not. While it’s expected that technical data can be hard to understand, the summary chapter should be presented in a more accessible way. It is not. Even so, it is clear that the EIS shows hundreds of homes and thousands of residents would be affected by noise either during both the three-year construction period and after the New M5 is opened if it is built.
There are many issues in this EIS that need to be redone before any Planning approval should be granted. It is not acceptable that, given the uncertainty raised in a range of areas of the noise and vibration assessment, and the number of potentially impacted properties and people within the project area, the local community and other affected stakeholders have not been provided with the information they need to make a fully informed assessment. This must occur as part of the EIS consultation process where further comment can be sought from the community, and not simply resolved through the Submissions Report that does not allow any further community input.
Noise monitoring results and assessment
The noise monitoring results in Appendix J, Section 3.4, Table 12 show that two days of the background noise monitoring was undertaken within the St Peters/Tempe area after the start of summer school holidays, which would have had an impact on the recorded results, as traffic is generally lighter during school holidays.
Some of the noise predictions contained within various tables of Appendix J show median LAeq and maximum LAeq results as the same or very close numerical value. Given a median should be the midpoint value and the maximum should be the highest value it is not clear why they would be the same or one dBA different. For example, Table 56 shows a median LAeq of 44 and a maximum LAeq of 44 for NCA10. This information in Appendix J should be reviewed to ensure that the information has been correctly calculated as it forms part of the overall noise modelling for the proposal.
Maximum noise assessment
Section 6.1.12 of App J presents results for a maximum noise assessment undertaken for a seven day period at one location in Beverly Hills and one location in St Peters. Two nights of the results for St Peters were excluded due to rain, which equates to almost 30% of the results not being useable. This is too significant a gap to be able to have confidence in the conclusions that have been reached on the basis of these results. This is particularly concerning given the EIS acknowledges that the St Peters area is already subject to a large number of maximum noise events and that this will increase due to the project.
The maximum noise assessment must also contain consideration of maximum noise events due to aircraft as well as road traffic. While the maximum noise monitoring results would have picked up aircraft noise occurring at the time of the monitoring, there is no discussion of the cumulative impact of current and future road and aircraft noise.
Construction noise management levels
There is at least one inaccuracy in the calculation of the Noise Management Levels (NMLs) between Table 12-2 and Table 12-4 as the RBLs given in Table 12-2 for Noise Monitoring Location (NL) 02 and for Noise Catchment Areas (NCA) 02, 03 and 06 in Table 12-4 differ when they should be the same. This in turn means that not all of the construction NMLs that are given are accurate.
This section needs to be reviewed for any further errors by the Proponent so that the community can be provided with accurate information.
Construction noise impacts
Tables 12-17 to 12-29 show that there will be large numbers of receivers that would be highly noise affected during standard hours construction works along the alignment and Table 12-30 to 12-39 show that very large numbers that would be affected during out of hours works, with correspondingly high numbers of receivers that would be exposed to sleep disturbance, particularly for local roads upgrades around Alexandria Canal. Given the construction program in Chapter 6 of the EIS indicates that these works could continue for more than two years, this is an unreasonable burden to place on the community when the resulting project will also leave these receivers highly impacted and when better transport solutions could be found.
Page 12-60 states that “…no activities would occur outside of standard construction hours during site establishment.” However page 12-61 states that there will be out of hours site establishment works for tunneling works, with the assessment for this shown in Table 12-39. Table 12-39 lists a number of activities under tunneling site establishment that would not appear to be related to site establishment but to construction works themselves ie piling and excavation. Given the numbers of receivers that are proposed to be exposed to noise with the potential for sleep disturbance during these out of hours works, there needs to be more justification given for why it is necessary to undertake these activities out of hours.
Section 5.2.1 of Appendix J shows that not enough information is available to make an assessment of the impacts for construction works that would be undertaken concurrently but states that the maximum noise level increase would be 3dBA on the maximum noise level that is predicted for individual construction scenarios. Without information on the numbers and locations of equipment and plant and what activities could be undertaken concurrently, it is unclear what information has been used to come to this conclusion.
The proposal to undertake tunneling activities 24 hours per day, seven days a week, including associated activities such as spoil handling and haulage will place great pressure on significant numbers of nearby receivers throughout day and night-time periods as shown in Table 80 of Appendix J and is not justified.
Construction vibration impacts
In s12.3.2 on page 12-39 there is discussion about the application of blast vibration criteria with a statement:
“For projects such as this, with a shorter duration of blasting of 12 months or less, a higher vibration criterion may be reasonable. For this project, the location of the blast moves along the alignment such that any one receiver is affected for only a short period of time.”
With no detail given about how long ‘a short period of time’ is, there is no way to determine whether it is appropriate that a higher vibration criterion be permitted, irrespective of whether or not the referenced standard was developed for mining operations rather than road tunnel construction. Given the range of sensitivities to vibration within any one community, it would be more appropriate to apply a conservation measure in the first instance.
Page 12-87 discusses construction vibration impacts for potential cosmetic damage and to human comfort, however the proposed mitigation measures only address potential cosmetic damage and not human comfort. Given the human comfort criteria are lower than those for cosmetic damage, then more information must be given to show how potential human comfort impacts will be managed, particularly for more vulnerable members of the community.
Page 12-88 states that during tunneling activities around 163 receiver locations are predicted to experience temporary vibration above the preferred vibration dose value during night-time periods and that vibration would be discernible at each of these receivers for around five days, with exceedences likely for around two days. Longer durations of impact are predicted at receivers near the tunnel portals.
More direct consultation must be undertaken with each of these potentially impacted receivers before approval for night-time tunneling works is given to determine whether or not this is an acceptable impact to impose on people during the night-time period. The justification for out of hours works should be the need to undertake the works out of hours due to safety considerations or in cases where there will be no or minimal impact to nearby receivers, as this is the industry standard for undertaking out of hours works. It is not acceptable to make a decision for 24 hours works purely on the basis of construction program. Additionally, the proposed noise and vibration management measures in Section 12.5 do not address this issue as they do not specify consultation with affected receivers prior to works commencing, nor do they contain any specific limitation on size of equipment to mitigate vibration impacts during works of close proximity. Proposed mitigation measure NV30 only requires the preparation and implementation of community consultation protocols, and does not give any certainty that the protocols would actually address this issue.
Cumulative impacts
The assessment of noise contained within the EIS does not discuss existing aircraft noise and potential future airport expansion in any detail, and how this relates to cumulative impacts in the proposal area. Aircraft and airport noise is already a significant aspect to the existing environment, particularly in St Peters, Sydenham and Tempe, and consideration of cumulative impacts between the proposal and the airport should be included as both are within the purview of the Government.
The discussion of cumulative impacts from the proposal and other projects on Page 12-90 is merely token as in reality it will be extremely difficult if not impossible to “coordinate mitigation and management of construction noise form concurrent construction activities based on the programmed works” as stated as there is likely to be different contractors working under different conditions of approval for each project. This means there is potential for some areas, such as around the Kingsgrove Upgrade and the St Peter Interchange, to be subject to ongoing and disruptive construction works over a long period of time. The EIS also acknowledges that “there is potential for localized cumulative construction works around the St Peters interchange as a result of the future M4-M5 Link or Sydney Gateway.” This shows that the Government would expect these receivers to have to endure ongoing impacts from construction in this area. The statement that this is unlikely to lead to significant cumulative noise impacts as construction of the different projects would be staggered is misleading as there is likely to be cumulative operational impacts that have not been considered or included in this EIS.
Operational noise impacts
In the discussion on operational noise impacts, page 12-93 states that this project would be subject to greater volumes of traffic “…once the full Westconnex program of works is complete, than if only the project were to be implemented.” This shows just how disastrous not only this project would be on the local community, but also how much worse the full Westconnex program would be if it were allowed to go ahead.
While some parts of the project, such as the western surface works area, are predicted to have improvements in road noise impacts (along with some exceedences for this area), page 12-94 sets out just how badly affected receivers in St Peters interchange and local roads area would be, particularly those along Campbell Street and Campbell Road. As stated on page 52 of Appendix J, these roads would go from being classified as collector roads to being classified as sub-arterial roads with unjustifiable impacts to the local communities.
To propose an increase from around 13,000 traffic movements per day currently on Campbell Street to around 59,000 movements per day in 2031 is completely unacceptable, given the impact this will have not just on operational noise emissions, but also other factors such as traffic congestion, air quality, visual amenity, and community leisure activities.
There is a large number of receivers within close proximity of the St Peters interchange that are predicted to experience day-time (133 receivers) and night-time (145 receivers) operational noise impacts that are above the applicable criteria. The predicted impact to St Peters Public School is expected to exceed the internal noise criteria with windows open.
The proposed significant operational noise impacts to a number of receivers in St Peters, (over 17dBA increase in at least one case) would not be the case if the project did not go ahead, as shown in Table 90 of App J.
Given the “…further consideration of feasible and reasonable noise mitigation measures..”, as set out in Section 12.5, states that open grade pavement and noise barriers will not be used around the St Peters Interchange, the proposed property treatment is likely to include measures such as double glazing and/or fresh air ventilation which will result in school children having to be shut up in closed window classrooms to meet the criteria and residential receivers having to keep doors and windows closed to avoid noise impacts. There will be no way to mitigate the operational noise and air quality impacts for school children and residents during outdoor periods.
This number of affected receivers is unacceptable and the proposal should not be allowed to include such a significant interchange in an area in which residential and educational receivers are already subjected to high levels of road and aircraft noise impacts. A well designed transport solution should aim to decrease negative impacts on the community it serves, not increase them as is clearly the case with this proposal.
Parallel routes
App J Section 6.1.11 provides predictions for impacts to “parallel routes” that are likely to be affected by traffic redistribution due to the project, however it does not include Unwins Bridge Road which is a significant parallel route within the St Peters/Tempe area and one that already experiences high levels of congestion, in the mornings, afternoons and evenings.
Environmental management measures
A number of environmental management measures for noise and vibration are proposed in the EIS. Of particular concern are the following:
NV05
“Property treatments identified for the operational phase of the project will be considered for installation before or early in the construction period, where they would improve noise levels”
NV06
“Permanent noise barriers will be scheduled for completion as early as possible in order to minimise construction noise”
Given the number of areas where the EIS delays the detailed assessment of noise and vibration impacts, presumably until after project determination, it is most likely that construction will commence well before information is available to base noise barrier design on, let alone construct them. Detailed noise and vibration assessment should be included in the EIS rather than deferred to after the project has been assessed and determined so that a more accurate picture of what is proposed is presented to the community for consideration and so that management measures such as these can be realistically implemented.
9.3 Conclusion
WAG formally and strongly objects to the increase in noise and vibration that will be experienced if WestConnex, including the New M5, is built, and to the inadequate and not fit for purpose analysis of the same undertaken in this EIS. We ask the Minister for Planning to reject the WestConnex New M5 project.