SUBJECT: Western Harbour Tunnel Beaches Link …...“Infrastructure NSW recommends that Transport for NSW should develop a business case for the Western Harbour Tunnel by the end

ITEM CiS05 REPORTS 4/12/17

N O R T H S Y D N E Y C O U N C I L R E P O R T S

Report to General Manager Attachments:

1.Council Submission to the Department of Planning and Environment

SUBJECT: Submission to the Department of Planning and Environment regarding the Western Harbour Tunnel Beaches Link (WHTBL)

AUTHOR: Gavin McConnell, Executive Planner Metro

ENDORSED BY: Marcelo Occhiuzzi, Acting Director City Strategy

EXECUTIVE SUMMARY

This report has been prepared to advise Councillors of a preliminary submission made to the Department of Planning in respect of the Western Harbour Tunnel Beaches Link. The RMS has applied to the Department of Planning to classify the project as State Significant Infrastructure (SSI). This would then lead to the preparation of an Environmental Impact Statement (EIS) and subsequent determination as to whether the project would proceed. The submission has been made on the basis of a Scoping Report prepared by RMS as well as draft Secretaries Environmental Assessment Requirements (SEARs). Due to time limits imposed by the Department of Planning (DPE), Council endorsement was not able to be sought prior to forwarding the submission to DPE and it is now referred to Council for endorsement and submission to the Department.

The submission at Attachment 1 is a far ranging one that includes reference to a spectrum of issues that should be addressed in any future environmental impact assessment. This includes justification for the project, environmental impacts such as emissions, impact on north Sydney’s local road network, impacts upon open space, vegetation, heritage and marine environments.

RECOMMENDATION: 1. THAT Council endorse the submission attached to this report.

Report of Gavin McConnell, Executive Planner Metro Re: Submission to the Department of Planning and Environment regarding the Western Harbour Tunnel Beaches Link (WHTBL)

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LINK TO COMMUNITY STRATEGIC PLAN The relationship with the Community Strategic Plan is as follows: Direction: 2. Our Built Environment Outcome: 2.3 Vibrant, connected and well maintained streetscapes and villages that build

a sense of community 2.5 Sustainable transport is encouraged 2.6 Improved traffic management

Direction: 3. Our Economic Vitality Outcome: 3.1 Diverse, strong, sustainable and vibrant local economy

BACKGROUND On 6 November 2017 North Sydney Council was advised the Roads and Maritime Services (RMS) had made an application to the DPE for the Western Harbour Tunnel Beaches Link (WHTBL) to be declared State Significant Development (SSI). This application was supported by a Scoping Report prepared by RMS. Council was invited to make a submission by 24 November 2017. A preliminary submission has been prepared and forwarded to the Department of Planning and Environment and is included at Attachment 1. The expected result of the SSI application is that the DPE will issue guidelines, known as SEARs (Secretaries Environmental Assessment Requirements), to inform the preparation of an Environmental Impact Statement. This in turn would inform the decision to determine the future of the project. On 1 May 2017 Council considered a report on the WHTBL and resolved; 1.THAT Council write to the Premier; the Minister for Transport; the Minister for Roads, Maritime and Freight; the Member for North Shore; the Greater Sydney Commission and Infrastructure Australia expressing its concerns regarding the Western Harbour Tunnel and Beaches Link projects, and recommend that work on both projects be suspended until the Greater Sydney Commission, in collaboration with Transport for NSW, undertake a robust options assessment that considers all possible solutions to the transport problems afflicting the Northern Beaches and the flow on effects on the Lower North Shore. That the letter include a submission that the Government undertake a formal options assessment to address a holistic transport plan for the capacity issues from the Northern Beaches through to the Harbour Bridge. 2. THAT Council maintain an information site on Council’s website, in tandem with the information on the B-line, and include any correspondence and relevant information that Council may have or acquire in relation to this project and circulate such information to all Precinct Committees. Council’s resolved position is that the WHTBL should not proceed until a holistic multi modal transport strategy developed in collaboration with the Greater Sydney Commission, Transport for NSW and all affected stakeholders be adopted. A key criticism of the project is that there

Report of Gavin McConnell, Executive Planner Metro Re: Submission to the Department of Planning and Environment regarding the Western Harbour Tunnel Beaches Link (WHTBL)

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has been no detailed, transparent justification for the project. Any modelling or analysis supporting the proposal that may have been carried out, has not been made available. CONSULTATION REQUIREMENTS Community engagement is not required. SUSTAINABILITY STATEMENT This report deals with the establishment of a twin tunnel roadway under Sydney Harbour and North Sydney with a tunnel/motorway extending to the northern beaches. If the project proceeds there is expected to be substantial implications for sustainability. Sustainability issues are addressed in the submission appended to this report. A detailed summary of sustainability issues will be reported to Council when additional details are released by the proponent. At this point in time there are no direct implications for established sustainability guidelines or benchmarks of North Sydney Council. DETAIL The current application to the DPE to declare the project to be State Significant Infrastructure (SSI) has resulted in the release of a Scoping Report and draft SEARs. Council has been invited to make a submission on the basis of these two documents. At the time of writing there has been no detailed justification released in support of the WHTBL. The Scoping Report addresses potential environmental issues. The draft SEARs contain matters that would need to be addressed in the preparation of an EIS. Key Issues Identified The submission has identified the following areas of concern regarding the SHTBL:

• The lack of justification for the proposed project. • The lack of a holistic approach to the planning of transport infrastructure. • The negative traffic impacts on the local road network impacts resulting from the

realignment of the Warringah Freeway and the Cammeray Interchange. • The loss of open space in North Sydney • Loss of vegetation and habitat. • Impacts on the marine environment • Impacts on Aboriginal heritage

A submission has been made to the Department of Planning and Environment detailing Councils concerns regarding the WHTBL. A copy of the submission is included at Attachment 1.

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Attachment 1

Glenn Snow Director Transport Assessments

NSW Department of Planning and Environment

GPO Box 39

SYDNEY NSW 2001

GHM (CIS)

24 November 2017

Dear Sir,

RE: WESTERN HARBOUR TUNNEL BEACHES LINK

RESPONSE TO SCOPING REPORT AND SEARS

Please find below a submission from North Sydney Council identifying issues of concern

regarding the Western Harbour Tunnel Beaches Link (WHTBL). This submission is made

in response to the Scoping Report and the draft Secretaries Environmental Assessment

Requirements (SEARS).

It is noted that the short time frame for responding to the Scoping Report means that the

response contained below is preliminary in nature. The submission will be formally

reported to Council for endorsement. Any changes or additions will then be referred to

the Department of Planning and Environment.

Strategic Justification

To date, there has been no detailed justification for the project presented for consideration

by affected stakeholders. This is a fundamental flaw in the planning of this very

significant piece of infrastructure. It is noted that the draft SEARs includes a requirement

that alternatives to the project be analysed in the EIS. This is welcomed, however, any

such justification should include detailed modelling demonstrating the impact of the

project as well as a detailed comparison with alternative transport projects/modes. In this

regard, it is not adequate to limit the consideration of ‘alternatives’ to a brief consideration

of alternate road tunnel routes.

In a report responding to the announced WHTBL and considered by North Sydney

Council on 1 May 2017, it was found that;

The provision of multiple motorway projects undermines. (a) .vision for a connected

Sydney both in terms of the opportunity cost of delivering road based transport instead

of public transport and encouraging further car dependency in an already car dependent

and quickly growing city. (WHT&BL Report to North Sydney Council, 1 May 2017)

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While section 17(3) of the INSW Act was used to add various motorway projects to the

State Infrastructure Strategy 2012 (SIS 2012), North Sydney Council does not agree

that this constitutes a “strategic justification” for the WHT&BL projects.


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Furthermore, the descriptions of the WHT&BL projects in SIS 2012 vary significantly to the

current proposals.

In SIS 2012, the “Inner West Bypass and enhanced north-south links to the M2” is described

as:

“…from the airport to the Victoria Road corridor, with a potential extension North to the M2.

The road would form a Western bypass of the CBD to relieve pressure on the harbour

crossings. No reservation or detailed alignment exists and construction costs are likely to be

very high.”

The “Northern Beaches Link” is described as:

“…a lower priority for Government funding support because of the lower traffic volumes, the

lack of through traffic, limited population growth on the Peninsula and the limited role of

Military Road in the freight distribution network.”

The SIS Update 2014 recommends the following:

“Infrastructure NSW recommends that Transport for NSW should develop a business case for

the Western Harbour Tunnel by the end of 2015 to enable the project’s procurement and

delivery as a tollway with, or immediately after, the delivery of WestConnex Stage 3.”

“Infrastructure NSW recommends that Transport for NSW undertake further review and

development of Beaches Link, with a view to a potential investment being made over a 10 to

20 year timeframe.”

In addition to suggested delivery timeframes seemingly pre-empting business case justification

even in the SIS Update, a business case for the WHT and further review and development of

BL was not released previous to the Premier’s announcement of the WHT&BL projects in early

2017.

Traffic Function

The Greater Sydney Commission has confirmed that Sydney is growing at a faster rate than in

previous decades. In this context and stage in Sydney’s evolution, it is an opportune time to

seriously question a car based future for our city from a productivity, liveability and

sustainability perspective.

(WHT&BL Report to North Sydney Council, 1 May 2017)


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In developing a Strategic Justification for the WHT&BL projects, consideration should be

given, primarily, to how these projects will affect the functioning of Sydney’s Strategic Traffic

Network as this would seem to be the primary justification for these motorway projects.

Consideration should be given to how these projects address current and predicted future travel

demand as well as their impacts in terms of induced traffic demand (the Lewis-Mogridge

Position). Particular attention should be given to how the provision of BL might affect traffic

demand and resultant Level of Service at the Sydney Harbour Bridge Tunnel pinch point as

well as demand for a western CBD by-pass (WHT). It is suggested that the WHT should not

be seen as an alternate route into the city due to up-stream and down-stream capacity

constraints around the Rozelle Interchange.

The SEARs should also require a detailed analysis of the impacts of the WHT&BL projects on

walking, cycling and public transport (particularly Metro) uptake/mode share. Consideration

of the “public transport benefits” of these projects should demonstrate how the Downs-

Thompson Paradox is likely to affect travel demand and mode share of public transport on

routes running parallel to the WHT&BL.

Options Assessment

In the context of the proposed motorways, a Chatswood-Dee Why Metro line extension is cost

effective, more efficient and ultimately represents a longer term, sustainable transport solution

that the proposed Motorway project cannot deliver. Such a Metro extension has the major

advantage of building on existing public transport investment and represents the building

blocks of an actual network of Metro, which Sydney’s residents will be increasingly reliant

upon in the longer term as the city continues to grow. “ (WHT&BL Report to North Sydney Council, 1 May 2017)

It is noted that the draft SEARs includes a requirement that alternatives to the project be

analysed in the EIS. This is welcomed. However, it is noted that it will not be adequate to limit

the consideration of ‘alternatives’ to a brief consideration of alternate road tunnel route

alignments as described in the Scoping Report.

Summary

“Without a robust approach to project development grounded in due process and stakeholder

consultation, the Western Harbour Tunnel and Beaches Link projects lack credibility, appear

poorly conceived and is devoid of the required basic levels of governance and transparency

required to determine the best long-term transport solution for the northern beaches.

(WHT&BL Report to North Sydney Council, 1 May 2017)

As per Council’s Resolution of the 1 May, 2017, it is recommended that: “…work on both

projects (WHT&BL) be suspended until the Greater Sydney Commission, in collaboration with

Transport for NSW, undertake a robust options assessment that considers all possible solutions

to the transport problems afflicting the Northern Beaches and the flow on effects on the Lower

North Shore.”


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The views expressed in the 1 May WHT&BL Council Report quoted above remain the adopted

position of North Sydney Council. All matters listed above should be addressed prior to the

preparation of the Environmental Impact Statement.

Protecting the North Sydney CBD and the St Leonards/Crow’s Nest Priority Precinct

In developing the business case for WHT&BL, consideration should be given to the negative

impacts of traffic growth on the North Sydney CBD and the St Leonards/Crow’s Nest Priority

Precinct.

North Sydney centre and Crows Nest St Leonards are currently undergoing a radical

transformation with the construction of the Metro rail line as well as significant property

developments. This change provides an opportunity for significant improvements in urban

amenity within this significant employment centre. The realignment of the Warringah Freeway

is also a significant undertaking and will result in redirecting a large volume of traffic onto

nearby roads. This will be required in order to facilitate the Cammeray tunnel/freeway

interchange. The redistribution of traffic volumes will have a significant negative impact on

the local road network including increased congestion and loss of amenity. Information

available indicates that the North Sydney CBD as well as key roads will be particularly

impacted by redirected traffic from the Warringah Freeway. This will undermine the benefits

in urban amenity arising from the Metro project. The resulting negative impact on the local

urban environment is a very serious concern for the North Sydney community and should be

assessed in detail in the EIS. Again, this underlines the need to support our more sustainable

transport projects, like Metro, that can add to the amenity and liveability of centres. The

WHTBL project should not undermine the gains that can be made in this regard by Metro.

It is noted that a stated benefit of the WHTBL project is to reduce traffic congestion in Sydney,

however, the same project will dramatically increase congestion in and around the North

Sydney CBD and the Pacific Highway corridor. The final SEARS guiding the EIS should

specify that the area of the North Sydney CBD, Crows Nest/ St Leonards as well as arterial

roads are to be subject to detailed modelling and analysis regarding traffic flows. Any negative

impact in this regard, will be clearly contrary to the draft North District Plan which specifically

identifies one its actions as

“grow economic development in North Sydney CBD to improve amenity by reducing the impact

of vehicle movements on pedestrians,

The draft Plan also identifies the following priority:

Infrastructure investments which enhance walkability and cycling, particularly those focused

on access to the transport network and within five kilometres of any strategic centre or 10

kilometres of the Harbour CBD.


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It is further noted that the draft SEARs includes a requirement for consideration of alternatives

to the project. This is an essential part of the consideration of the merit of any project of this

importance and should occur (in an inclusive and transparent manner) as part of the initial

business case prior to the preparation of an EIS.

The SEARs should require that the EIS include a detailed analysis of the impacts of the

SWHTBL on the Metro rail project as well as pedestrian and bicycle movements. The WHTBL

should demonstrate a substantial positive impact on these alternate transport modes. As noted

above it is important that the WHTBL should only proceed if it is demonstrated to be an integral

part of a holistic, multi modal metropolitan transport plan.

Environmental Considerations

A number of the important environmental issues have been identified as not being ‘Key’

considerations, instead they have been designated as ‘other’ considerations. This is important

as the scoping report (p.107) states that:

“The environmental impact statement would include the following:

…A comprehensive assessment of the potential impacts on the key issues including a

description of the existing environment, assessment of potential direct and indirect and

construction, operation and staging impacts…

It appears that the focus of the EIS is intended to be the six bullet points in Sect 5.1 identified

as key issues:

Traffic and transport, including road safety

Air quality, including in-tunnel and ambient air quality

Noise and vibration

Human health risks

Non-Aboriginal heritage

Cumulative impacts.

In contrast those issues designated as ‘other’ would be given less scrutiny. These issues

include:

Biodiversity

Aboriginal Cultural Heritage

Soil and Water Quality (including contaminated harbour sediments)

Socio-economics, Land use & Property’ (includes impacts on parks etc.)

Urban Design & Visual Amenity

Spoil and Waste Management

Flooding & Hydrology

Climate Change Risk

Sustainability


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Many of these issues identified as “other” in the scoping report should be considered to be key

issues due to their environmental, social and economic importance. Significantly among these

other issues is water quality and impacts on urban design/ urban function. The SEARs should

be amended to reflect the importance of these “other” issues.

In addition to the priorities of the EIS, the following matters have been inadequately covered

in the scoping report or the draft SEARs;

The exhaust ventilation from the tunnel is a significant concern. The EIS should include

a detailed analysis of baseline air quality and expected impacts resulting from the

WHTBL. In order to properly assess the environmental impacts of the Tunnel the location

and technical details of the proposed tunnel ventilation should be determined prior to the

preparation of the EIS. Air quality assessment should be carried out by an independent

expert and the details of all modelling, testing and analysis should be made available to

the public. A minimum of 12 months of air sampling should be carried out in the vicinity

of Cammeray prior to the EIS being prepared.

The maps contained in the report omit the significant landmark of the coal loader wharf

as well as the navy wharves. The maps in the report include wharves on the southern side

of the harbour. The coal loader wharf is scheduled as a ‘Strategic Foreshore Site’ under

SREP(Sydney Harbour Catchment) 2005 and should be shown on the maps.

Under SREP 2005, Part 4 there is a requirement to prepare masterplans and for the

consent authority to take into account the masterplan. In this case, the masterplan that

would apply is the Waverton Peninsula Strategic Masterplan (WPSMP), as the wharf is

included in the WPSMP. This should be addressed in the EIS.

In Section 5.4.3 pg. 58, it notes a number of further studies in respect of vibration impacts

to heritage items. Whilst the precise route has not been identified in respect of the coal

loader sea-wall, the coal loader seawall is founded on sandstone bedrock which by its

nature has many fault planes and areas of variability. It is understood that the top of the

tunnel is proposed to intersect with the land only 20m below the water level, it is possible

that the tunnelling could cause localised settlement of rock strata, upon which the massive

seawall is founded (this would be disastrous to the seawall and hence council’s assets

that are supported behind the seawall).

The shipwrecks off the coal loader wharf (refer Balls Head Coal Loader Wharf Maritime

Archaeological Assessment and Inspection, September 2013) are potentially significant

marine archaeological items. Advice from NSWHO Maritime Archaeologist (c. 2015)

confirms that the shipwrecks need to be properly surveyed and dated to determine their

historical importance.

The maps with respect to Terrestrial Biodiversity Features Figure 6-1a pg. 76 is

incorrect. These label foreshore areas of bushland adjacent to the coal loader as ‘weeds

and exotic’. Much of this area has been replanted with native flora and serves to support

native wildlife.


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There is no mention of the Large-footed Myotis (Fishing Bat) under Threatened Species

pg. 77, despite there being a significant roost in the head of Balls Head Bay and the bat

having been recorded as feeding in the vicinity of the coal loader.

On the bottom of page 77, the report notes that ‘Marine habitat features are shown in

Figure 6-2’. This map is titled “Marine biodiversity features within and nearby the

harbour crossing between Birchgrove and Waverton”. However, the map itself only

shows what is described in the legend as ‘seagrass meadows’. It shows no Marine Habitat

features for most of Balls Head. This is incorrect. Aside from the extensive rocky

foreshore habitat around Balls Head, the coal loader wharf (400 submerged timber piles

and above water structure) is a substantial marine habitat and the site of significant

marine biodiversity.

The maps referenced in the scoping report fail to show significant natural and manmade

features of the area.

The Scoping Report appears to be inconsistent with the maritime and ecological values

identified in the SREP (Sydney Harbour Catchment) 2005 and various other studies.

Vegetation Issues

The following points will require detailed consideration in the full EIS and additional impact

assessment.

The North Sydney Natural Area Survey (NAS) identified four distinct vegetation communities

within Balls Head Reserve. These have not been recognised in the Scoping Report. These

communities are:

o Angophora Foreshore Forest (derivative of Coastal Sandstone Foreshore Forest);

o Kunzea Scrub (derivative of Coastal Headland Banksia Heath);

o Sandstone Foreshore Scrub (derivative of Coastal Teatree Banksia Scrub);

o Disclimax Sandstone Scrub (highly disturbed Coastal Sandstone Foreshore Forest

Additional communities identified in the NAS, including endangered ecological

communities, occur in close proximity to the design development corridor:

o Forest Red Gum Foreshore Forest (derivative of Sydney Foreshores Shale Forest;

eastern coastal form of EEC Sydney Turpentine-Ironbark Forest) situated in

Badangi Reserve, Wollstonecraft

o Estuarine Saltmarsh EEC situated in Gore Cove, Wollstonecraft

o Estuarine Swamp-oak Forest EEC situated in Gore Cove, Wollstonecraft

o Blackbutt Gully Forest (derivative of Coastal Enriched Sandstone Moist Forest)

situated in Gore Cove Reserve & Smoothey Park, Wollstonecraft

o Sandstone Gallery Rainforest (derivative of Coastal Sandstone Gallery Rainforest)

situated in Badangi Reserve, Wollstonecraft


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These communities support threatened species reliant on the marine environment (e.g. Large-

footed Myotis), the WHTBL project could have serious adverse impacts on the ecological

health of these remnant environments.

With respect of the bushland vegetation that runs along the eastern edge of St Leonards

Park it is considered it to be a significant patch of habitat in an otherwise highly built up

section of North Sydney. This area provides a stepping stone of vegetative cover and

foraging resource for a number of native species – including listed threatened species

(including Eastern Bent-wing Bat & White-striped Freetail Bat).

The strip of vegetation in Cammeray Park adjacent to the Warringah Freeway appears

most likely to host a significant work site and depot. This area provides significant

ecological values as a habitat refuge in an otherwise largely cleared area of North Sydney.

The vegetation also provides habitat for a limited number of native species including

listed threatened species (including Eastern Bent-wing Bat & White-striped Freetail Bat).

As this patch of vegetation fringes the Cammeray Dam, it would hold additional

importance as complimentary habitat to the water body.

Section 6.2.1 -Threatened flora species

The only endemic threatened flora species known to occur in the design development

corridor is Acacia terminalis subsp. terminalis. This species is recorded in Balls Head

Reserve as well as Gore Cove and Smoothey Park in Wollstonecraft. The Scoping report

identifies this species but then states that “No threatened flora species have been

recorded in the design development corridor during preliminary field surveys conducted

to date”. This statement requires clarification.

6.2.1 Fauna habitat

The scoping report states that there is little remnant vegetation remaining in the design

development corridor. This statement dilutes the importance of those remnants that do

occur within the corridor and in close proximity to it. The Scoping Report also incorrectly

states that these remnants likely provide habitat for common urban fauna species. This

fails to recognise the Coal Loader’s winter roosting colony of Eastern Bent-wing Bats

and seasonal foraging/roosting of Grey-headed Flying Fox and Powerful Owl

The scoping report failed to identify several other threatened species that are known to

occur within, and in close proximity to the design development corridor. These include:

o Large-footed Myotis (Myotis macropus) – permanent breeding roost in Balls Head

Bay; foraging habitats in Balls Head Bay and Berrys Bay

o White-bellied Sea Eagle – often recorded foraging over Balls Head Bay, Berrys

Bay and the Western Harbour

o Little Penguin (North Head Endangered population, often recorded foraging in

Berrys Bay and Balls Head Bay)

The three species listed above are marine foraging specialists, hence, any disturbance to

the marine environment – especially to sediments that are known to contain heavy


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pollutant loads – will have a direct impact on predator/prey relationships and may lead

to bioaccumulation of toxic substances through food chain uptake. These species should

be included in the Scoping Report and assessed through the EIS process.

The impact of vegetation removal within bushland and supporting revegetated natural

areas (adjoining core bushland) is not acknowledged or adequately discussed in the

Scoping Report. The report fails to recognise the extent of this vegetation, it’s role in

ecosystem function/connectivity or the long-term role community volunteers (e.g.

Bushcare; Streets Alive; Harbourcare) have played it its conservation, rehabilitation and

expansion.

Section 6.2.2- Summary of potential issues

o Terrestrial Biodiversity – impacts of vegetation clearance need to be considered in

a wider context; such as the Waverton to Wollstonecraft Green Corridor and the

North Sydney Urban Forest Strategy

o Terrestrial Biodiversity – impacts of vegetation clearance need to consider the 20+

years of community volunteer effort in the design development corridor which has

focussed on bushland conservation, rehabilitation and expansion

o Terrestrial Biodiversity – impacts of the WHT on terrestrial fauna dependent on a

healthy, undisturbed marine environment for foraging requirements

o Terrestrial Biodiversity – impacts of pollutant bioaccumulation caused by marine

sediment disturbance

o Marine Biodiversity – need for fine scale ground truthed mapping & species

diversity of seagrass meadows

o Marine Biodiversity – impacts for marine fauna (including invertebrates) caused

by seabed disturbance and pollutant release

o Water Quality – the Scoping Report has not identified Quarry Creek catchment in

Cammeray as being within the design development corridor however the catchment

would definitely be within the corridor. Quarry Creek provides habitat for

important threatened species including the Large-footed Myotis; Powerful Owl;

Yellow-bellied Sheathtail Bat and Grey-headed Flying Fox. Changes to water

quality in this reserve would have implications for native fauna and in particular

the Large-footed Myotis as its main prey species are marine/estuarine aquatic

invertebrates.

Cammeray Stormwater Harvesting and Re-Use

North Sydney Council has established an extensive stormwater harvesting scheme, which

includes a storage dam at Cammeray Golf Course, adjacent to the Warringah Tollway reserve.

The dam receives stormwater harvested from the surrounding catchments, that is then used to

irrigate a number of community parks and the golf course itself. Harvested water is also piped

through the existing stormwater system, under the tollway and back to St Leonards Park, which

is used to irrigate the public parklands and North Sydney Oval. The dam also serves as a

sediment settlement pond which improves the quality of water re-entering the catchment and

harbour. The construction of the Cammeray Interchange will disable the operation of this

valuable water recycling scheme.


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Heritage

State-Listed Heritage Items

There are seven heritage items listed on the State Heritage register noted within the design

development corridor:

Tarella (SHR 00270)

North Sydney Sewer Vent (SHR 01641)

St Leonards Park (SHR 01941)

Milsons Point Railway Station Group (SHR 01194)

Sydney Harbour Bridge, approaches and viaducts (SHR 00781).

The following sites have also been nominated for state heritage listing and may fall within the

project works site and buffer zones. Except for the Coal Loader, these sites have been omitted

from diagram 5.2.:

Coal loader at Balls Head

Carradah Park, Waverton and

Wollstonecraft Bushland including Gore Cove Reserve and Badangi Reserve

Locally Listed Heritage Items

The document has not considered impacts to locally listed heritage items. There are over 1000

heritage items in the Municipality many of which will be affected by the WHTBL.

Additionally, the document has not considered impacts to the Conservation Areas including,

but not limited to:

Holtermann Estates A-D Conservation Areas

Cammeray Conservation Area

Walker/Ridge Streets Conservation Area

Whaling Road Conservation Area

Oaks Avenue Conservation Area

Concern is also raised regarding the impact of vibration on heritage items during the

construction phase, particularly to heritage located in close proximity such as the North Sydney

Sewer Stack and to fragile elements within heritage items.

Potential Impacts to Heritage significance

Construction Phase

Concern is raised about the possibility of using heritage-listed parks and reserves for

construction and spoil compounds. The following parks have been identified as potentially at

risk:

Foreshore areas such as Balls Head Reserve

Berrys Bay foreshore/Coal Loader/Carradah Park, Waverton


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Waverton Park, Waverton

Brennan Park, Waverton

St Leonards Park, North Sydney

ANZAC Park, Cammeray

Cammeray Park

Cammeray Golf Course, Cammeray

Forsyth Park

The loss of any open space/ bushland will adversely affect the environmental values of this

heavily urbanised area. Such impacts as diminished water quality and loss of flora and fauna

habitat should be considered in detail in the EIS.

Ongoing Impacts

Vibration to heritage items, particularly those located close to the works

The location of the vent stacks is not determined. These are generally designed to be

functional and not aesthetic and may be visually intrusive if located in the vicinity of a

heritage item or within a conservation area.

Similarly, the location of other associated structures that are required for the functioning

of the tunnel and should be located away from the visual catchment of heritage items and

conservation areas including:

o Any motorway control centre building

o Gantry illuminated signage

o Large road signage

o An operational water treatment facility

o Ventilation facilities, including ventilation outlets and tunnel air intake

infrastructure

o Tolling infrastructure

o Electricity supply infrastructure including project substations

o Flood lighting

o Firefighting suppression and firefighting systems

o Electricity supply and communications infrastructure.

Where such structures cannot be re-located in the design phase, the structure should be

designed in accordance with the Conservation Area and/or Planning Area Character Statements

to ensure that the character of the area is retained and enhanced, that an appropriate and

sympathetic palette of materials is used and that visual impacts are minimised and ameliorated.

Aboriginal Heritage

The impacted sites are known to host a range of Aboriginal heritage items. It is assumed that

the document has been forwarded to the Aboriginal Heritage Office for comment. If not, it is

recommended that they be included on the stakeholders list.

Consultation

The draft SEARs includes reference to a consultation process. This is welcomed however the

extent and nature of the consultation should be clearly defined in accordance with best practice


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community engagement principles. The SEARs requirements for consultation should include

a requirement for key stakeholders (including local government) to be involved in formulating

the preferred transport solution for serving the northeast of the Sydney metropolitan area. It is

noted that local knowledge can greatly improve the quality of the consideration of context,

issues and solutions. The degree of stakeholder input should be equivalent to the

‘collaborative’ level of participation described in the International Association for Public

Participation IAP2 Public Participation Spectrum.

Conclusion

Concern is raised at the apparent lack of a holistic approach to transport systems serving

Sydneys’ future needs. The Scoping Report appears to have omitted a number of important

issues and has been prepared without reference to a number of relevant resources. Without a

defensible justification for the project and without best practice project development the

WHTBL should not be considered for approval.

The SEARs should include a requirement that the project be reconsidered in line with the

Transport Planning Decision Matrix contained in the North Sydney Transport Strategy (see

attached). In addition, the SEARs should include a requirement that the Greater Sydney

Commission and the TfNSW Sydney Coordination Office provide independent detailed

consideration of the project as appendices to the EIS.

The issues identified in this submission do not represent a comprehensive review of the

potential impacts resulting from the WHTBL. Additional issues are likely to be identified when

additional information becomes available. It is also noted that the time constraints placed on

stakeholders has prevented a thorough consideration of the Scoping Report and the project

generally.

It is requested that the issues identified in this submission are adopted for consideration in any

further deliberations regarding the WHTBL.

Yours faithfully,

MARCELO OCCHIUZZI

A/DIRECTOR CITY STRATEGY


SUBJECT: Western Harbour Tunnel Beaches Link …...“Infrastructure NSW recommends that Transport for NSW should develop a business case for the Western Harbour Tunnel by the end

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