Comments on Air Quality Impact Statement

By Kerry Barlow

The Air Quality Impact statement is in Appendix H (This will shortly be published on this site.)

Executive Summary:

  • this Air Quality Impact Statement relies too heavily on the WestConnex Road Traffic Model (WRTM) forecast of reduced traffic on Parramatta Road for its claim that there will be negligible impact on the overall air quality in the vicinity of the WestConnex project; in what should have been an independent study, the EIS needed to model a fuller range of traffic scenarios for the corridor, including possible “rat runs” used to avoid tolls and thus changing the air quality at those points.
  • the fact that the Parramatta Road corridor has numerous traffic “hot spots”, where levels of dangerous pollutants are already elevated, is glossed over, and the dangers of adding to these “hot spots” and creating more of them is not taken into account by the overly conservative (ie optimistic) induced traffic forecasts
  • there has been no modelling of estimates for any pollutants in a scenario where the traffic on Parramatta Road is more than the modelled forecast of a “53% reduction” (by 2021) along the Concord to Haberfield section.
  • the new (to be endorsed) National Environment Protection (Ambient Air Quality) Measure (NEPM) standard (of 20ug/m3 for average 24-hours)should have been used, rather than the current standard (25ug/m3)
  • there has been no comparison between the project and other cleaner forms of transport. In other words there has been no cost-benefit analysis.
  • the EIS Statement makes no mention of the possibility of phasing out diesel fuel passenger vehicles as one way of assisting with the problem of elevated levels of PM2.5 and NO2 in the corridor
  • the final length of 33kms of unfiltered tunnels could be dangerous for regular users of the full tunnel; this is especially true for motor cycle riders

Key findings from the EIS report

  • the contribution of tunnel ventilation to pollutants is calculated as negligible for all receptors (ie locations where pollutants were measured)
  • there will be general improvements in air quality along Parramatta Road as a result of the project, due to reduction in traffic along the road and improved dispersion of emissions from diverted traffic through tunnel ventilation outlets
  • predicted concentrations of pollutants are dominated by existing background levels, both short-term readings and longer-term readings; with background concentrations particularly dominant for PM10 and PM2.5
  • whilst exhaust emissions from some pollutants from road transport have decreased as legislation has tightened, over the longer term levels will start to rise again as increases in annual vehicle activity begin to offset reductions achieved by legislation and improved technology
  • there are no controls or legislation for non-exhaust particles emissions, which are significant in Sydney and these will increase as vehicle activity increases
  • the NSW Office of Environment and Heritage (OEH) Sydney Basin air quality monitoring stations are collecting data on PM2.5 from 3 out of 7 sites (Vol 2B, part 6, Appendix J, Table F2); the three sites show both annual mean PM2.5 concentrations and maximum 1-hr concentrations are above the advisory reporting standards of 25ug/m3 and 8ug/m3 (respectively)
  • time-series for PM2.5 only available at Chullora and Earlwood; there are considerable uncertainties in measurement of PM2.5 (but has been more accurately measured since 2012 – using USEPA-equivalent monitoring)
  • long-term mean nitrogen oxide concentrations at the RMS roadside sites (F1, M1 = Flat Rock Rd Kingsgrove, M5E tunnel portal) substantially higher than at the background sites at 106 and 107 ug/m3; “illustrates the ongoing contribution of NOx emissions from road transport” (Vol 2B, part 6, Appendix J, Table F2, p F-12)
  • long-term trend in NO2 shows some background decreases at OEH sites, but increases or no change at several RMS urban background sites
  • the ambient air quality in this part of Sydney has PM2.5 levels well above the advisory standard for both 24-hr (25ug/m3, moving to 20ug/m3) and annual (8ug/m3 moving to 7ug/m3) concentrations, judging by the readings at Edward Street Concord and the Bill Boyce Reserve Homebush and the levels at the 31 community receptors (Table K-47, p K-83). The modelled data of forecasted PM2.5 increases and decreases shows one locality is traded against another. The top 10 ranked receptor readings, 2014 (Table K-47, pK-83) for annual mean concentrations show a range from 14.1 ug/m3 to 12.5ug/m3 (all well above the advisory standard of 8ug/m3), with the “do minimum” and “do something” scenarios still showing modelled data above the advisory standard. With the completion of all stages of the project by 2031, these modelled readings are still above the advisory standard and will be well above the recommended new standard of 7ug/m3 (to be adopted possibly by end of 2015)
  • the top 10 ranked receptor readings, 2014 (Table K-51, p K98) for maximum 24-hr concentrations show a range from 26.5ug/m3 to 24.3ug/m3 (all above the advisory standard of 25ug/m3) with the “do minimum” and “do something” scenarios still showing modelled data above the advisory standard. With the completion of all stages of the project by 2031, these modelled readings will still be above the new advisory standard (20ug/m3)
  • data reported against the current standard of 25ug/m3 (24-hour average) does not give an accurate picture of the peak hour traffic emissions, which would be well above the standard; the fact that children are walking to school near several of these sites in the morning peak hour means they are being daily exposed to dangerous emission levels. If their classrooms are also located near the sites with elevated emissions, they are exposed for lengthy periods. Dobroyd Point and Haberfield Public Schools will be particularly affected, and Homebush Public School slightly less so.
  • the thirty one community receptors used to indicate changes to emission levels at 2021 and 2031 already show levels of PM2.5 are above the new proposed NEPM standard of 20 ug/m3 (24 hour average), with most sitting just below the current standard (25ug/m3) (page K100). If the WestConnex project induces more traffic to the area by 2031 (or the population grows faster than planned or more diesel vehicles use the road or tunnel) then PM2.5 levels will be well over the current standard, let alone the new standard

Flaws in the methodology of the EIS report

  • relies on the traffic modelling for its claim receptors will, generally, be improved – this traffic modelling did not include a scenario where traffic on Parramatta Road is greater than model estimates. Independent experts are predicting that this will be the case.
  • the WRTM traffic forecasts rely on the Bureau of Transport Statistics (BTM) population model, which uses the main inputs from the Department of Planning and Environment’s (DP&E) 2014 NSW population, household and dwelling projections and Australian Bureau of Statistics’ (ABS) 2011 Census data on population and dwellings. The model makes adjustments to incorporate known major developments and future plans. Given that the EIS uses BTM data from 2013, before the Parramatta Road Renewal Plan was released, the model may not allow for an estimated additional 40,000 units (80,00 – 100,000 people) along the Parramatta Road corridor, most of whom will own at least one vehicle.
  • the estimations for “induced demand” in traffic (claimed as between 2%-7% – Vol 2A, Traffic and Transport Assessment, p4-6) are very conservative, given they rely on population forecasts which may underestimate population growth along the corridor (collected prior to the Parramatta Road Renewal Plan)
  • the planned height of the ventilation stacks is not modeled to show other scenarios, including effects of greater heights on dispersal of pollutants; there is a lot of international research that indicates a greater height of stack results in better dispersion
  • the model claims the data from the OEH monitors and the WDA St Lukes Park Concord (M4E:05) is representative of the air quality of the project; the data from the other 4 WDA (road-side) monitoring sites is down-played, yet there are currently many residents living within 200-300 metres of these “hot spots”
  • the statement seems to downplay the key findings from the Human Health Risk Assessment (Volume 2D, Appendices J-L) including:

by 2021, without the project, the maximum (residential and commercial) 1-hour concentration of NO2 estimated to be (in micrograms per cubic metre) 375ug/m3 and 360ug/m3 (respectively) – which is well above the guideline (of 246ug/m3); with the project completion, the levels estimated as 307ug/m3 and 286ug/m3 (respectively) – still well above the guideline

by 2021, without the project, the maximum (residential and commercial) 24-hr average concentration of PM2.5 estimated to be 29.3 ug/m3 and 30.5ug/m3 (respectively) – which is significantly above the guideline (25ug/m3); with the project completion, the levels estimated as 28.2ug/m3 and 26.6ug/m3 (respectively)-still above the guideline

by 2031,with the project, PM2.5 levels estimated as above the guideline

by 2021, without the project, the maximum (residential and commercial) 24-hr average PM10 concentration estimated as 54ug/m3 and 55.4ug/m3 (respectively) – above the current guideline (50ug/m3) and well above the recommended (from the 2014/15 review) of 40-50ug/m3

by 2021, with the project, the maximum (residential and commercial) 24-hr average PM10 concentration estimated as 52 ug/m3 and 50ug/m3 (respectively) – above both the current guideline and recommended (review) guideline

by 2031, both without and with the project, PM10 will be above both guidelines

  • the claim there will be no emissions from portal sites is questionable, given that any congestion on the feeder road into a portal entrance or the exit point will produce concentrated sites of emissions
  • Bureau of Metereology data from Canterbury Racecourse is used to model the atmospheric conditions for dispersion of the plume at Wattle Street Haberfield; this may not be appropriate, given the location of the very large Parramatta River to the East of the stack and thus different terrain compared to Canterbury; more suitable local data should have been collected for such a major project

Flaws in Model’s Assumptions

  • the benefits from the project, in terms of some reduced pollutant concentrations at particular points (as shown on contour maps (Fig K-98, K-99, K- 100), depend on completion of stage 3 of the project, which may not eventuate if tolling of stage 1 does not meet estimated revenue. If stage 3 is not completed, the levels of PM2.5 throughout many parts of Haberfield, Ashfield and Leichhardt will exceed current advisory and new standards.

  • the overall benefits rely on the traffic on Parramatta Road being significantly reduced, as claimed in the EIS. The WRTM traffic model depends on the BTR population forecasts (which use ABS Census of Population & Housing data) and the toll-resistance modelling estimations. Traffic forecasting is a major issue in Australia, given the number of projects with significantly incorrect forecasts of volume, including the Brisbane N-S By-Pass, Sydney Cross City Tunnel, Brisbane Connections, Lane Cove Tunnel and East-Link Melbourne. As the Australian Bureau of Transport and Communication Economics, Canberra states, traffic models are … “radical simplifications of real urban systems” (cited in Black, J (2014) Traffic Risk in the Australian Toll Road Sector, Public Infrastructure Bulletin, Vol 1, Issue 9, Art 3). So all the claims of improvements in overall air quality, or at best negligible impacts on air quality, are reliant on the accuracy of the traffic modelling. As Black (ib id, p5) shows, the eight most recently built toll-roads in Australia have all had significant underestimation of traffic volumes by an average ratio of .48 (total traffic from the 8 projects forecast as 945,286 vehicles, but actual volume was 455,939 vehicles). The WDA must be very optimistic that this project will be the first one in many years to get the traffic forecasts correct. The problem is that local residents lives are about to be severely interrupted and possibly have the air quality worsened if this project attracts more traffic than estimated onto the surface roads, particularly Parramatta Road. Following a review of local and international reports and data, the Australian Department of Infrastructure and Transport, Bureau of Transport and Regional Economics (BITRE) in its Review of Traffic Forecasting Performance Toll Roads (2011) sets out what it sees as the major sources of errors in toll road forecasting. These errors include both technical (inadequate models, data limitations, unrealistic model input assumptions and ramp-up risk) and non-technical (optimism bias and strategic misrepresentation) sources of errors. Given that the Project Manager of the WDA stated at an Ashfield Council Forum (23/09/2015) that a key element of the business case for the project is ..”as an enabler for the Parramatta Road Renewal Plan”, one would have to wonder whether the traffic forecast that the M4 will reduce surface traffic on Parramatta Road by 53% by 2021 is an error of misrepresentation (to cite the BITRE classification of errors). The robustness of the WRTM model is crucial to the claims that the air quality will not be adversely affected by the project, and this Air Quality Report should have included a worst-case scenario of more than projected traffic on Parramatta Road.

  • this assessment ignores the fact that the air quality standards or guidelines used in the EIS may be superseded by stricter ones at the end of 2015 when the new National Environment Protection (Ambient Air Quality) Measure (NEPM) standards are passed
  • this assessment appears to ignore some of the actions recommended in the new National Clean Air Act, including initiatives to reduce localised emissions. This WestConnex project will not only increase levels of NO2 and PM2.5 at several community receptors, it also runs the risk (if estimated traffic flows are greater on Parramatta Road than predicted) of increasing these levels across the Corridor.

  • five air quality monitors have been collecting data for about eight months, yet the WDA has only very recently posted three months of data (June/July/Aug 2015) on the website. The data indicates there were exceedences of PM2.5 as follows:

    o 6 occurrences at Wattle Street (the maximum one on 7 June being 9.4ug/m3 above the average 24-hour standard of 25ug/m3); 2 occurrences at Concord Oval (maximum one 30 June, 11ug/m3 above standard)
    o 2 occurrences at Concord Oval (maximum one on 5 July 1.5ug/m3 above standard)
    o 1 occurrence at Wattle Street (21 Aug 12.9 ug/m3 above standard); 1 occurrence at Edward St (21 Aug 10.8ug/m3 above standard); 1 occurrence at Bill Boyce Res (21 Aug 11.9ug/m3 above standard); 1 occurrence at Concord Oval (21 Aug 14.8ug/m3 above standard); 1 occurrence at St Lukes Pk (21 Aug 8.6ug/m3 above standard) – there was back-burning in national parks in Sydney on 21 Aug which would account for higher readings, but it shows that the air quality is readily affected in these parts of Sydney which have already elevated readings; once the new NEPM is adopted (20ug/m3), there will be many more average 24-hour readings for the WestConnex corridor that will exceed the standard

  • This assessment appears to ignore some of the actions recommended in the new National Clean Air Act, including initiatives to reduce localised emissions. This WestConnex project will not only increase levels of NO2 and PM2.5 at several community receptors, it also runs the risk (if estimated traffic flows are greater on Parramatta Road than predicted) of increasing these levels across the Corridor. This project will not be future-proofing Sydney.

(Ed:This post was updated on October 31,2015)

For other posts relevant to Air Quality read Westconnex and Air Pollution from Environmental Justice and the Critique of the Health Risk assessment, also by Kerry Barlow

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