NORTH SYDNEY telephone (02) 9936 8100 focsimile (02) 9936 8118 eddress 200 Miller Street North Sydney NSW 2060 oll correspondence “Mayor North Sydney Council PO Box 12 North Sydney NSW 2059 email council@vorthsydncy.nsw.gov.an Dx10587 internet www northsydney.nsw.gov.au ABN. 32.353 260 317 3 January 2007 The Hon. Eric Roozendaal MLC Minister for Roads Level 30 Governor Macquarie Tower 1 Farrer Place SYDNEY. NSW 2000 ie Dear MjetiSter RE: LANE COVE TUNNEL PROJECT - SURFACE TRAFFIC MODIFICATIONS Council has recently been forwarded a copy of the Lane Cove Tunnel Project Surface Traffic Modifications: Environmental Assessment Report December 2006. North Sydney Council strongly objects to a number of the proposed changes outlined in this report. Jn particular, Council objects to the following: * The proposed change in Minister’s Condition of Approval 238 * The proposed staged implementation of public and alternative transport options; and transit lanes along the corridor (proposed Minister's Condition of Approval 3A) Merlin Street Bus Stop North Sydney Council strongly objects to the proposed change in Minister’s Condition of Approval 238: The Proponent shall install investigate the provision of a bus indent bay on Military Road to the east, or in the vicinity of Merlin Street north. The location and design of the any bay shall be to the satisfaction of the State ‘Fransit Authority Public Transport Committee. This proposed change means that the RTA is no longer obligated to install the bus stop. Council is a strong supporter of public transport, and believes that public transport must be readily accessible for ease of use and to encourage people to use it. This bus stop is the first stop off the freeway and is essential for the residents in this area of Military Road, and also to service residents living west of the Warringah Freeway. 100% recycled paperNorth Sydney Council requests that the RTA and the Public Transport Committee &/or the State Transit Authority finalise the location and design of this bus stop, and proceed with its installation as soon as possible. Delayed Surface Works North Sydney Couneil objects to the proposed staged implementation of public and alternative transport options; and transit lanes along the corridor, including: * Delaying the T3 lane on Epping Road, between Pittwater Road and Mowbray Road Delaying the eastbound T2 lane on the Gore Hill Freeway Delaying the bus lane on Epping Road until 10 months after the Tunnel opening © Delaying the shared pedestrian/cycleway on the southem side of Epping Road Council disagrees with the statement on Page 5 that the staging of the implementation of the surface works would be consistent with the EIS objectives, All of the facilities listed above improve access for people in alternatives to the single occupancy vehicle. By delaying these works, public and alternative transport users once again make way for the single occupancy private motor vehicle. Further, once these changes have been delayed it will be much more difficult for the State government to implement these changes at a later date. Page 30 states that the EIA Documents assessed the social impacts for the Approved Project would be mainly negative during construction and mainly positive during operation. The operational noise and air quality improvements in Epping Road will ‘be delayed until the approved surface changes are made. Therefore, the local residents who have already been subjected to over 2.5 years of construction impacts associated with this project, will have to wait another 11 months for the positive impacts to commence. The comment on page 7 that there may be illegal usage of bus lanes by general traffic seeking to avoid extensive queuing is an absurd reason to delay the implementation of the bus lanes. This can be controlled through adequate enforcement, through Police presence or more practically through fixed cameras and cameras on buses. The MWT report acknowledges that during the EIS assessment the traffic modelling assumed full patronage potential of the tunnel and did not allow for a transition period. This is a serious and significant defect in the RTA’s EIS process. MWT and the RTA have argued that by delaying the restriction of capacity to the private motor vehicles on Epping Road, this will allow for demand to reduce to match that of the capacity. North Sydney Council does not have access to the detailed modelling for this project, however this argument is fundamentally flawed. If surface capacity is not restricted from day one, and thus total net capacity increases along this corridor, motorists who previously used another route, motorists who previously chose to travel at another non-peak time, will fill this additional capacity. Worse still, there is likely to be increased induced demand along this corridor. ‘Thus the netvolume of vehicles along this corridor will increase, making the restrictions to capacity in the future just as difficult. Phrases such as that on page 23, “the expected reduction in demand along Epping Road during the ramp-up period (emphasis added)” highlight that it is by no means certain that there will be a reduction in demand. What does the State Government intend to do should there be no reduction in demand? It will be much more difficult for the State government to implement the positive benefits of this project once it has already been put off for 11 months. Inappropriate Tolling The “ramp-up” described throughout the report would be unnecessary if standardised per kilometre basis tolls were used on major civil infrastructure works such as the Lane Cove Tunnel Project. The imposition of tolls results in different pattems of behaviour, and should therefore be used for the management of private motor vehicle transportation rather than purely for the method of financing major civil engineering projects such as the Cross City Tunnel and Lane Cove Tunnel Project. ‘The problems associated with unrealistic traffic volumes on the tolled roads and congestion and queuing on the nearby surface roads because of high toll costs would not occur if toll rates were set appropriately. The current inequitable imposition of tolls in Sydney has resulted in some of these major civil engineering projects not delivering the expected positive outcomes. Tolls on existing motorways and new toll roads should be imposed on a per kilometre basis, such as that for the M7 motorway. Further, tolls should be imposed on a consistent and regular basis. That is, they should not be seemingly randomly applied to some roads and not to other major roads. The opening of the Lane Cove Tunnel Project with its excessive toll charges was always going to result in congestion and delays while motorists determined their preferred route, The delay in the surface works seems to be a means for the State Government to delay these impacts until after the next State election. Once again, it is the sustainable and alternative transport modes that lose out to the car lobby. Further, this is at a cost to the tax payer of $25 million. This is a huge amount of money which could be spent to further improve pedestrian and cyclist facilities in the North Shore area, In particular, the RTA seems unable to fund pedestrian and cyclist facilities at North Sydney without advertising dollars. Director General’s Report ‘The Director General’s own report in November 2002 found that the benefits to motorists from the Lane Cove Tunnel Project could only be justified if there were also benefits achieved for high occupancy vehicles, public transport, cyclists and pedestrians, The report in November 2002 found that “The Department agrees that the broad objectives as stated [by the Lane Cove Tunnel EIS] would be achieved by the Proposal. However, it is considered that Proposal may potentially induce traffic movements, in particular new trips (as opposed to redistributed trips) due to theseimprovements.” The Director General’s report went on to say that the potential for these induced movements was removed to a significant extent by the provision of bus lanes in both directions on Epping Road and the Pacific Highway. “The Department concurs that measures to improve routes for public transport and high occupancy vehicles (HOVs) is appropriate where additional capacity is provided and opportunities to encourage induced traffic may otherwise occur.” The Director General’s report found that “A key benefit of the Proposal would be the anticipated traffic reductions on Epping Road. This provides an opportunity to ‘downgrade’ Epping Road to provide less of a regional function and provide better facilities to improve public transport efficiencies and local traffic functions. Additional facilities proposed by the RTA include T2 and bus lanes, a pedestrian/cycle path, landscaping of the surface corridor to create a “boulevard” experience, reducing traffic speeds...these measures provide a positive message that the creation of additional roadspace need not necessarily be for the sole use of private vehicles.” The report goes on to state that, “In order to achieve the desired long term and strategic outcomes, the Department has, in particular, placed significant emphasis, on maximising public transport enhancement opportunities, ensuring net improvement to regional air quality and the downgrading of Epping Road. ‘Without improvements to the public transport system and travel demand measures, additional road capacity provided by major road infrastructure will be taken up and will lead to further congestion downstream. Once road capacity has been improved and congestion and travel times reduced there is less incentive for people to change their mode of travel to public transport. The only effective way to manage this is to incorporate an efficient mass public transport system with any proposal to increase road capacity. Impact on North Sydney Council has always maintained that without proper controls the Lane Cove Tunnel Project will result in additional capacity along this corridor, which will be taken up and will lead to further congestion on the approaches to the Harbour Bridge and Tunnel. The delay of surface works to the north-west of North Sydney will further increase the net capacity along this road corridor, thus leading to even greater levels of congestion on the approach to the Harbour Bridge and Tunnel. This is acknowledged for example on page 23, where it states, “the deferral of the T2 transit lanes on the Gore Hill Freeway and the bus lanes along Epping Road increases corridor capacity in the interim.” The Harbour Bridge and Tunnel are at capacity during peak periods. The Harbour Bridge effectively acts as a funnel for traffic during the peak hours for north-south travelling vehicles. This causes a traffic congestion point on the bridge, which then translates into increased noise and air pollution for North Sydney residents as well as an increased potential for “rat running” vehicles to use local North Sydney streets. Projects such as the Lane Cove Tunnel Project serve only to get vehicles to the Harbour Bridge bottleneck faster.LATM Should the RTA’s proposed changes to the project be approved, some clarification is required to determine the impact on LATM plans and the timing of their implemeniation. North Sydney Council would be opposed to any delays in the implementation of the LATM plans without consultation with Council and the residents. 4.1 on page 36 should be changed to read, “the operational monitoring timeframes of the Local Area Traffic Management Plans prepared under Condition 37 and 38 shall be reviewed by the RTA, in consultation with the relevant Council, and revised, if considered necessary.” Pedestrians Page 25 and page 36 refer to proposals to delay the review of pedestrian walk times at key intersections. North Sydney Council strongly opposes any delay in implementing, the proposed pedestrian changes at Falcon Street and Merlin Street. Couneil has forwarded a detailed response to the Review of Environmental Factors for these works to the RTA in a letter dated 14 December 2006. North Sydney Council hopes to work closely with the RTA so these works can commence as early as possible. Should you wish to discuss this further, please don’t hesitate to contact me on 9936 8112. Yours sincerely Coo th Genia McCaffery MAYOR cc The Hon. Frank Sartor MP, Minister for Planning Ms Jillian Skinner MP, Member for North Shore Ms Gladys Berejiklian MP, Member for Willoughby Mr Les Wielinga, CEO, Roads and Traffic Authority Mr Sam Haddad, Director-General, Department of Planning~ NSW@HEALTH HO6/18227, Ms L Mitchell AiDitector Major Infrastructure Assessment Department of Planning GPO Box 39 SYDNEY NSW 2001 Dear Ms Mitchell ‘Thank you for the opportunity to provide comments on behalf of NSW Health about the proposed modifications to the Lane Cove Tunnel Conditions of Approval (06_0268 MOD 2). | note that the proposal to stage implementation of surface road changes over eleven months does relain the benefits to public transport, walking and cycling and reduction in surface road traffic largely as originally approved. These elements are key to achieving reduced population exposure to air pollutants and increasing opportunities for physical activity ‘The proposal to amend Condition 216 to allow an interrupted crossing of Epping Road at Mowbray Road is of concern. Other options to facilitate pedestrian usage, such as an overhead bridge, are not discussed in the assessment report. NSW Health would support the incorporation in the project of a safe and efficient means for pedestrians to cross Epping Road. The staging of the surface road changes effectively means that the full changes in air pollution and noise distribution wil not commence until 11 months after the opening of the tunnel. In the approved proposal the reduction in surface road capacity to two lanes each way would have ‘occurred with tunnel opening. The report anticipates that road usage patterns, and thus air pollution and noise distribution, will not reach equiibrium until 18 months to 2 years after tunnel opening This raises concems regarding the monitoring period and auditing interval for noise and air quality impacts. In particular, Condition 186 regarding monitoring of elevated receptors requires: “Monitoring shail be undertaken over a period of at least 12 months from opening of the Project to traffic to correlate and verily impacts with the air quality modeling predictions” This condition should be amended to require monitoring for ‘at least 12 months afer the completion of Stage 2 works' so that the full impact of stack emissions on the elevated receptors can be monitored as intended. Similarly, Condition 60 (operational noise) and Condition 168 (verification of air quality assessment) should be timed to occur 12 months after the completion of Stage 2 works to be consistent with the intent ofthe original conditions. The delay in implementation of the surface road changes creates an additional concer for NSW Health in relation to the Lane Cove Tunnel Health Investigation. This study has been designed to measure the health impacts of the maximal changes in air pollution expected to NSW Department of Health [ABN 92 657 899 630 73 Miller St North Sydney. NSW 2060 Locked Mail Bag 961 North Sydney NSW 2058 Tel (02) 9391 9000 Fax (02) 9391 9101 Wiebsite wwwzhealthnsw.govau‘occur in relation to the project, including significant reductions in ar pollution exposure for people living near Epping Road. Baseline health assessments have already been completed in approximately 2000 local residents and were to be repeated in the second half of 2007. Ifthe proposed modification is approved then the study design may have to be modified, which could reduce the power of the study to detect an effect and result in additional costs. Alternatively the study may have to include a third round of assessment in the second half of 2008 to include the full impact of the changes in distribution of air pollution. Should this be the case to ensure a valid result there will be considerable additional costs. NSW Health is of the view that the proponent should be required to contribute to the additional costs of the Lane Cove Tunnel Health Investigation that arise from the delayed implementation of surface road changes, | hope that this input is of assistance to you in considering the modification proposal. Should you require clarification of any of the points raised please do not hesitate to contact either myself or Dr Vicky Sheppeard on 9816 0256. Yours sincerely Denise Robinson Chief Health Officer Deputy Director-General, Population HealthYour reference: S0a02765 ea ‘Qurreference — : DOCN7/293 22 JAN 2007 Contact Jacinta de Jong, 985 6867 Ms M Gibbs Major Infrastructure Assessment Department of Planning GPO BOX 39 SYDNEY NSW 2001 Dear Ms Gibbs PART 3A - LANE COVE TUNNEL ~ PROPOSED MODIFICATION 06 0268 MOD 2 | refer to the Department of Planning's (DoP) request for advice in relation to the proposed modifications to the Minister's planning approval for the Lane Cove Tunnel. The Department of Environment and Conservation (DEC) has no statutory role in relation to the operation of the project; however, DEC has previously provided technical advice to DoP on the project, including detailed submissions during the project's environmental impact assessment phase. Modifications Environmental In Strategy — Operational Air The following documents: Lane Cove Tunnel Surface Traffic Assessment Report December 2006 and Surface Traffic Transit Quality Additional Information, 10 January 2006 have been reviewed. The existing approval requires surface road changes to be completed within six months of tunnel opening. However, based on DEC's experience with similar projects, it is likely that measures to reduce surface road capacity would have been implemented contemporaneously with or shortly after tunnel opening. The existing approval also requires an assessment of noise mitigation and air quality monitoring to be undertaken at set times/ for set periods to assess the project's operational performance. RTA's proposed modification to the consent would allow staged implementation of surface road changes over an eleven month period after tunnel opening. The final operational road network configuration and traffic flow conditions would therefore not occur until 2008. DEC considers that any amendment of the project planning approval should be consistent with the underlying environmental objectives of the existing approval, including the intent of the monitoring requirements (Conditions 60, 166 and 168). Condition 60 requires an assessment of noise mitigation measures per the Operational Noise Management Sub Plan to be undertaken one year from the opening of the project. RTA is proposing a change in timing to six months after the completion of the surface works. An PO Box 666, Parramatta NSW 2124 4 Level 7,79 George St, Parramatta NSW Department of Environment and rvation NSW. Tel: (02) 3995 5000 Fax: (02) 9995 6900 oe ‘ABN 30 841 $87 271 \wwm.environment.nsw.gov.auassessment of noise mitigation measures can be undertaken once the final operational road network configuration is implemented and traffic flow conditions have stabilised and the monitoring results are representative of typical noise impacts. Condition 166 requires the operation of elevated air monitoring stations for at least twelve months after project opening. Despite the delay in full project implementation, RTA is not proposing to extend the period of monitoring beyond twelve months after tunnel opening. This position is based on modeling results which indicate that air quality impacts at ‘these locations are incremental and indiscemible from normal variations in background air quality. DEC concurs that there is no technical basis for undertaking extended monitoring at the elevated air monitoring stations. DEC understands that the intent of the air monitoring network (including the two elevated monitoring stations) was ‘to provide a high degree of assurance’ to the community by providing confirmation of the model predictions. It is not clear whether retention of the existing condition would fuffl this objective with the proposed delay in full project implementation. Condition 168 requires validation of the ambient air quality modelling predictions for the project using monitoring data following twelve months of operation of the project. As the ambient air quality assessment is based on emissions from full project implementation, DEC suggests that the validation required by Condition 168 incorporate twelve months of emissions due to the operation of the full project, and be undertaken following twelve months of full project implementation. DEC understands that the tunnel operator proposes to voluntarily implement a toll free period after the tunnel opens. Comprehensive air monitoring during this period could be beneficial in determining whether any early fine tuning of the ventilation system is warranted. Please contact Jacinta de Jong on 9995 6867 should you wish to discuss this matter further. Yours sincerely Gye ce a reife 2 SELLE HOWARD Director Metropolitar ment Pt ulation Page 2