(Ed: This contribution is by retired TAFE NSW researcher and University of Sydney academic Kerry Barlow)
From the perspective of an ordinary local resident, the NSW government’s whole M4 East EIS process has lacked transparency and integrity. A project currently costed at $16b should have its planning and EIS process conducted in a timely and measured way. This has not been the case with this EIS. The local “information sessions” were staged in an individualistic way that meant locals couldn’t ask critical questions to a panel and listen to all responses. Residents, childcare, schools and business owners were only given 45 days to make submissions to an EIS that was a highly technical series of documents with a word count of 5,000 pages.
The WDA received about 4500 submissions, and has treated those by residents and community groups with contempt by scanning them into numerous PDFs and posting them with just a list of submitters on a top page. As part of the EIS process the WDA is supposed to report back on how it is going to deal with the substantive issues raised in the submissions. The way they have posted the submissions makes to very difficult to find the issues raised by particular groups for our follow-up in the EIS report. Processes with transparency and integrity treat all citizens respectfully – none of us feel it has happened in this case.
Despite concerns, Government Departments make only minimal comments
To add insult to injury, the three key NSW organisations expected to make submissions as part of their important role in a democratic society, ie NSW Health, the Environmental Protection Agency and the Chief Scientist and Engineer have all put in fairly minimal comments on this EIS. This is disappointing, given the huge cost of the project, and the fact that their own budgets will no doubt suffer over time if the NSW government has to subsidise further project cost blow-outs.
The NSW Health submission made no attempt to analyse the methodology of the Human Health Risk Assessment component of the EIS. If they had done so, they would have made comment on several flaws, including:
- the mortality data used in the EIS for three key factors (COPD, lung cancer, cardiovascular disease) shows that Sydney Area Health Service has rates higher than the average NSW rate for all three indicators, yet the risk assessment does not question whether exposure to already elevated levels of NO2 and PM2.5 may be a cause of these elevated rates
- the reliance on data that is five (5) years old for the key health indicators is problematic, given background sources of key pollutants (NO2 and PM2.5 and PM10) have increased in that five (5) year period, as evidenced by vehicle fleet data. According to the Sydney Morning Herald (March 15-16 2014) the number of diesel vehicles on the road in Australia has more than doubled since 2005. ABS data shows that in 2015 there are 3.6 million diesel powered vehicles, accounting for 19.7% of the fleet; and over the five year period from 2010, the number of Passenger vehicles and Light Commercial vehicles registered with diesel fuel increased by 96.4% and 62.9% respectively (ABS, Motor Vehicle Census, Australia, cat no 9309.0). This increase in diesel fuel use would have had both short term and longer term impacts on health in the period since this health data was published and has not been captured by it, nor has this health risk assessment mentioned increased risks from the growing diesel fleet.
- the current Sydney Area Health Service collects data on health risk factors, published for each Local Health District. The risk factor model is one that can be called a “personal behaviour” model (ie includes risky alcohol drinking, smoking, consumption of fruit & vegetables, being overweight or obese, and adequate physical activity) which does not include external risk factors, like living within a few hundred metres of a busy road. The fact that the Area Health Services in NSW do not collect data for external risk factors, although they are known (eg exposure to coal dust (mainly PM10) and road pollution (notably NO2 and PM2.5) means that more meaningful data is not available to these types of Human Health Risk Assessments. NSW Health is negligent in not acknowledging the known risks of exposure to these dangerous emissions and should be collecting data related to them via methods that collect cancer and other registry information based on people’s home and workplace location.
NSW EPA lacks technical expertise to assess data
The EPA’s admission in their submission that they do not have in-house expertise to assess the air dispersion model (the Graz Mesoscale Model/Graz Lagrangian model) because they do not have the relevant technical expertise to provide a meaningful review is of huge concern. This is the main agency this state relies on for reviews of major projects like WestConnex, yet it is forced to admit to lack of expertise.
Although minimal, their submission did pick up several issues of concern in the EIS, which included:
- the air dispersion modelling is not satisfactory, due to insufficient justification and validation for the selection of Canterbury Racecourse meteorological data; recommends provision of justification for choice of meteorological data and revision of GRAMM modelling to more accurately simulate the meteorology of the sites
noted issues with the methodology of calculating the 1-hour average conversion of NOx to NO2; noting two different methods used for the community receptors and residence/workplace receptors based on an empirical method (that may underestimate actual conversions of NOx to NO2) rather than a method listed in the NSW approved methods; recommended further analysis and justification is required
results for the regulatory worst case scenario for NO2 and air toxics was not presented the predicted “hot spots” on contour map don’t appear to match traffic volumes
noted the model used to estimate in-tunnel emissions (the PIARC model) assumes light diesel vehicles will only be 50% of the fleet by 2031, when realistically they would be more likely be 80% – thus under-estimating PM2.5 (and finer) and NO2 emissions in-tunnel; recommends more realistic fuel-mix types are required for the 2031 estimates
notes the heavy vehicle exhaust PM factors used in the in-tunnel emissions are estimated 80% below the PIARC data; recommended the reason for the variation be provided and justified
The Chief Scientist and Engineer provided a very minimal submission which only picked up a few issues of concern. They appear to have accepted the Air Quality Impact Statement claim that there would be no emissions at the portals, without testing whether the congestion points near portals might prove to be new sources of pollution.
This submission found:
- the construction (as opposed to operational) impacts assessment has been treated in a summary and cursory manner, with no attempt to quantify emissions of critical air pollution, eg NOx/NO2, PM10, PM2.5 during construction; recommends stronger emphasis on mitigation to reduce the high risks of increased exposure to PM10 and annoyance from dust from the construction phases
some issues with the use of the GRAL model, which it says the EIS does not evaluate sufficiently. It states the GRAL model appears to underestimate some emission readings and over-estimate others, depending on the time of day; recommends the proponents comment on and confirm (or refute) the Chief Scientist’s claim that GRAL is slightly under-estimating vehicle emissions in congested traffic conditions and the implications for the health risk assessment
All the concerns raised by these submissions do need to be taken seriously so that residents’ health is not further compromised by the increased volume of traffic (which, by definition, will add to the total background volumes of emissions) and by the increase in the number of “hot spots”.