Chairmans Foreword

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The M5 East motorway project has been in the pipeline since at least the 1940s. It is a project of a Government road building department that I believe needs close community scrutiny on its road building plans.

Once the Roads and Traffic Authority realised that a motorway through the Wolli Creek Valley was not acceptable to the community, it commenced plans to build a road tunnel through this area. The original preferred option of the RTA was to build three ventilation exhaust stacks for this tunnel on elevated sites and the environmental impact study was based on the three stack proposal. The communities in those areas vehemently opposed the three stacks and the proposal was dropped. The final decision was to construct the tunnel with just one ventilation exhaust stack at Turrella. This is on industrial land owned by the RTA but within proximity to housing and businesses.

The final decision to exhaust tunnel air through just one emission stack was made both hastily and with no public consultation. There were no published environmental studies or a supplementary environmental impact statement undertaken to support the decision to build a single stack.

It is apparent that the original three stack option was the more scientifically valid option, though

unacceptable to the community. It is equally apparent that the single stack option is also

unacceptable to the community. The current stack, located in a valley, is likely to be 25 metres

high, yet has ridges of the valley surrounding it 40 metres high. It is clearly an inappropriate

The single stack as currently planned will concentrate the tunnel emissions into one source and add to the pollutant load of the valley. The adverse health effects of this increased pollution on the surrounding community must be acknowledged, but the RTA fails to do so.

The world's best practice has not been incorporated in the design of the tunnel ventilation and

exhaust system. The technology exists to fit particulate and gaseous pollutant control technologies either on the stack or within the tunnel.

The Committee recommends that the Roads and Traffic Authority immediately call for international expressions of interest for the installation of world's best treatment processes for particulate and nitrogen dioxide removal in the M5 East Motorway tunnel. The NSW Government should establish an independent panel of experts, including a community representative, to evaluate and report on the submissions which have been received by 31 March 2000. The report should identify accurate and if possible final costs for the installation of such equipment.

The Committee recommends that the Roads and Traffic Authority continue with construction work on the stack in a manner which can incorporate and make provision for alternative ventilation systems which might be recommended as a result of the assessment of responses to the call for international expressions of interest.

The Committee further recommends that following the publication of the report identified

The Committee recommends that the NSW Government complete the development of the draft subregional air quality management plan, for the area surrounding the motorway, by 30 June 2000. The Government agencies responsible for the development of the plan should consult with the Community Consultative Committee, established in relation to the ventilation stack, as well as relevant local councils, in the formulation of a draft plan, which should then be released for public comment and input. The plan must have specified targets, goals, dates for achievement, identified sources of funding and clear responsibilities for implementation.

The Committee recommends that at six monthly intervals from 30 June 2000 an information paper be published outlining the steps taken to implement the draft air quality management plan, focussing on the specified goals and dates for achievement.

The Committee recommends that six months before the conclusion of the five year term during

which the Roads and Traffic Authority is required to provide $0.5 million per year funding for the implementation of the air quality management plan, a review of funding sources and

The Committee recommends that in any future discussion of the impact of the proposed

ventilation stack upon air quality, the Roads and Traffic Authority and the Environment Protection Authority adopt the statements of the Minister for the Environment and the Minister for Urban Affairs and Planning that it is intended that emissions from the stack and tunnel should not result in any exceedences of air quality goals in their vicinity, and not suggest that up to five exceedences per year are allowable within these goals, excluding natural and extraordinary disasters.

The Committee recommends that the Environmental Planning and Assessment Act be amended to

prevent a determining authority from approving a development with modifications, which have any significant impact upon the environment or which have a significant impact upon a different group of citizens to those affected by the proposed development, unless those modifications have been exhibited for public comment. The modifications must be subject to adequate public consultation before the proposal is determined.

The Committee recommends that no matter what form of tunnel ventilation or emission control is finally implemented, the Road and Traffic Authority, in conjunction with the Department of

Health, fund an epidemiological study of the health of the community in the area of any tunnel

emissions, commencing this financial year and continuing for 5 years after the commencement of operation of the motorway, or as long as the Department of Health recommends. The technique and operation of the study should be approved by the Department of Health, with results published on an annual basis.

The Committee recommends that the Roads and Traffic Authority, when investigating international developments in tunnel emission treatment systems as required by the condition of approval number 79 for M5 East motorway, not only survey the relevant literature but directly contact the suppliers of such equipment.

The Committee recommends that the Roads and Traffic Authority immediately call for

international expressions of interest for the installation of world's best treatment processes for

particulate and nitrogen dioxide removal in the M5 East Motorway tunnel. The NSW Government should establish an independent panel of experts, including a community representative, to evaluate and report on the submissions which have been received by 31 March 2000. The report should identify accurate and if possible final costs for the installation of such equipment.

The Committee further recommends that following the publication of the report identified above, a decision be made to either:

The Committee recommends that air quality data reports, both before and after commencement of the motorway be made available "real time" on the Internet so that those members of the population who are vulnerable to air pollutants may more easily become aware of any exceedences of air quality goals and take appropriate action. Further, it is recommended that air quality reports are published monthly, including on the Internet.

The Committee recommends that the Department of Urban Affairs and Environment, in

consultation with the Community Consultative Committee, at six monthly intervals review all the sources of information, as identified in Condition 74, to assess whether pollution control

equipment should be installed on the emission stack. The results of these reviews should be made public no later than six weeks after the end of the six month period, with reasons stated for the conclusions reached.

The Committee recommends that the Roads and Traffic Authority, in consultation with the

Community Consultative Committee, prior to the operation of the motorway, develop a

contingency plan for instances of air quality exceedences at the Turrella site. This contingency plan must be approved by the Minister for Urban Affairs and Planning and made publicly available.

The Committee recommends that the Department of Urban Affairs and Planning release any risk assessment done of the impact of the stack on the implementation of urban consolidation policies in the vicinity of the stack. If no such assessment has been undertaken to date, the Committee recommends that an open and rigorous risk assessment of the impact of the ventilation stack on urban consolidation policies be performed without delay, with the results to be published.

P16. After listening to community concerns about air quality, and abandoning the (1996) three stack proposal , the Committee believes that it is at this time the RTA should have put all its resources into developing proposals for a "no stack option".

The Committee accepts that on a regional basis, the amount of pollutants emitted into the

However, the analysis of the bigger regional air shed must not be allowed to draw attention away from the impact of the single ventilation stack on the residents and businesses in the Wolli Creek Valley. The single stack is likely to have other impacts on the environment, including visual and possibly noise.

P18. The Committee notes that a significant argument used in support of the single stack option is that particulate pollution is a regional problem, and therefore must be solved by a regional approach.

The Committee is concerned that a regional response may prove to "fall between the cracks" of government department responsibility. Mr Noonan of the DUAP expressed the following

Conditions of Approval numbers 80 and 81 require the RTA to participate with DUAP, the EPA,

the Department of Transport and the Department of Health in developing a plan to improve subregional air quality and provide $0.5 million per year for five years to fund implementation of the plan.

The Committee is concerned that Mr Noonan of the DUAP specifically mentioned the importance of councils in formulating regional air quality plans, but the Conditions of Approval ignored this sector of government that the RTA must consult.

P25. the RTA in their submission notes that the PM10 goal allows for five exceedences per

year, and that a ten year time frame has been set for compliance with this goal by the National

Environment Protection Council'. Similarly, the EPA in their submission to the Inquiry noted theNEPM for PM10 allowed for five exceedences per year.

The Committee does not accept this interpretation of NEPM exceedences as provided by the RTA and other government agencies.

P25. The Committee was presented with evidence from other practitioners that conflicted with the above RTA and Government agency views that air quality goals could be met with the single stack option with no pollution control equipment installed.

P27. Noting these differing opinions, the Committee remains concerned the stack may lead to exceedences of air quality goals.

p28. It is evident that the RTA fully conducted community consultation proceedings for the 1994 and 1996 environmental impact statements. However, it is equally apparent that no consultation with affected parties to the current project was made. The RTA in neither its submission or evidence to the Inquiry made any reference to community consultation with parties affected by the current proposal.

P29. The Committee is concerned that the residents and businesses potentially affected by the single stack proposal either apparently had limited or no opportunity to make their concerns known to the appropriate regulatory authorities until after the stack was approved by the Minister.

P30. The Committee accepts that the operation of the stack in the Wolli Creek Valley will result in an increase in the air pollution levels in the locality, and this will occur no matter how high the stack is constructed.

P36. the Committee notes that improvements to air quality from improved vehicle emission standards may take up to 20 years.

The Committee therefore does not necessarily accept the argument of the RTA that the introduction of new emission standards as has happened in Europe, will render the introduction of road tunnel emission control equipment unnecessary in Australia.

p 37 The Committee notes that what the RTA refers to as "world's best practice" from an engineering view may not equate to what communities around the world class as "world's best practice". Nevertheless, the Committee accepts that past engineering practice has been to dilute tunnel air pollutants and vent them via an elevated stack. However, the Committee is disappointed that the RTA, having been "overwhelmed" by community opposition to the three stack proposal, did not fully investigate alternative technologies, for instance through direct contact with suppliers.

P 40. The Committee would like to highlight that the 1997 independent report from DUAP noted 'in regard to the treatment of nitrogen dioxide from road tunnels that "trial systems demonstrate good conversion/treatment of nitrogen dioxide (NO2) with some suppliers guaranteeing such conversions. The technology appears established in this regard".

4.4 Costs and obligations in regard to installation of pollution control equipment on the single stack

Overall, addition of precipitators in the tunnel is estimated to add $55 to $70 million to the

project cost. Opening of the motorway will also be substantially delayed with consequential

In contrast, the work by DUAP on international technologies as noted in section 4.3.2 noted the broad figure of installation of an electrostatic precipitator at $8000 - $8500 per m3/sec of exhaust air (although presumably not including infrastructure costs). Using the RTA supplied exhaust air figure of870 m3 /sec, this would result in a cost of $6.9 million to $7.4 million.

P45. RAPS' preferred option involves no emission stack. This option envisages the installation of by-pass type air cleaning stations close to the exits of the two tunnels containing electrostatic precipitator and nitrogen dioxide catalytic removal systems, and electrostatic precipitators ceiling mounted about half way along each tunnel. The total capacity of the cleaning system in each tunnel would be between 300 and 350 m3/sec.

This capacity should be able to ensure that emitted air is close to air quality goals for PM10 and nitrogen dioxide, and the ceiling mounted electrostatic precipitators would reduce the amount of smoke in the tunnel in the case of fire. RAPS have estimated this option to cost approximately $25.6 million.

If pollution control equipment needs to be retrofitted to the stack as possibly required by DUAP, then we would have the situation of a tunnel designed around high ventilation air flow rates, which would not be required when the pollution control equipment is in place. RAPS have costed this option at $56.6 million. RAPS concludes that to build the stack as currently planned will cost $36 million, and stated: It seems to me, and the people overseas agree, that we have a potential saving of $10 million, and we get clean air and do not have to build the stack. What are we doing? Why are we not seriously looking at this?

The Committee notes the worldwide debate on what constitutes best practice in regard to road tunnel ventilation and emission systems. However, this debate cannot detract from the fact that communities in Sydney are not prepared to live with a ventilation stack with no emission treatment within their neighbourhood.

5 A rigorous and open risk assessment integrated as part of any ventilation proposal

p49. The Committee notes the difficulty in prescribing a "formula" to mark the point at which pollution control equipment must be installed. Equally, the Committee notes the frustration in segments of the community who would like a definitive answer as to at what point exceedence in air quality goals attributable to the ventilation stack triggers an automatic requirement to install emission control equipment.

P52. The Committee understands that the assessment process for the single stack was challenged and found to be valid in the Courts. However, the Committee, as noted in Chapter 3, notes that there was no open risk assessment as part of the single ventilation stack. The RTA impact assessment (and hence their risk assessment), was done as part of the Representations Report, which was done in secret between government agencies and neither invited nor involved further public input. On this basis, the Committee rejects the assertion of the RTA that the project has been the subject of an open risk assessment process.

It would appear to the Committee that the only group of people who believe that a rigorous and open risk assessment of the project has been undertaken are those representatives from the RTA and other government departments.

p55. Residents and businesses adjacent to the ventilation stack itself have had no opportunity to join the Property Value Guarantee scheme [available to property owners above the tunnels or within 100m or the tunnel portals] if they wished, or if it is shown that their properties are directly affected by the stack.

The Committee notes the good intention of the Property Value Guarantee but does not consider that it should be extended.