Mordialloc Freeway: Submission on the Environmental Effects Statement

Expert witness statement by

Associate Professor (Dr) Vicki Kotsirilos AM, MBBS, FACNEM, FASLM,

Hon Fellow RACGP

16th February 2019 Dunstan Dental & Medical

31 Dunstan St Clayton VIC 3168

PH: 03 95445993

Expert witness for Residents Against Mordialloc Freeway (RAMF) to support its submission to

the Mordialloc Freeway Environmental Effects Inquiry.

Member (AM) in the General Division of the Order of Australia 2016

o for 'significant service to integrative medicine, to health practitioner standards

and regulations, to medical education, and to the environment'

Australia Day Environment Award, Bayside City Council 2017

o "Recognising outstanding and long-term leadership, action, and advocacy for

coastal and natural heritage protection in the City of Bayside, and generating

community awareness of the value of our Bayside environment"

Awarded Honorary Fellowship of the Royal Australian College of General Practitioners Honorary Fellow of the Australian College of Nutritional & Environmental Medicine Winner of the Australian General Practice Accreditation Excellence award 2007 Consultant to Federal Government Health bodies such as AHPRA and the Professional Services Review

Acknowledgements My sincere gratitude to Associate Professor Louis Irving Director Respiratory and Sleep Medicine, Royal Melbourne Hospital; Visiting Physician, Peter MacCallum Cancer Centre. Professorial Fellow Physiology, Professorial Fellow Medicine, University of Melbourne for providing references and material to assist with the preparation of this expert report. I, Dr Vicki Kotsirilos, am registered as a Specialist General Practitioner with the Medical Board of Australia [AHPRA] and work in Clayton, Melbourne. I reside in the suburb of Sandringham. I am an Honorary Fellow of the Australasian College of Nutritional and Environmental Medicine. I am also an Associate Professor at the University of La Trobe and Western Sydney, and

formerly held an adjunct position at Monash University Department of Epidemiology and Public Health. I have been requested to prepare an expert witness statement related to public health effects

from vehicle emission air pollution by the Residents Against Mordialloc Freeway (RAMF).

RAMF consist of concerned residents residing near the proposed Mordialloc Freeway project.

Furthermore, a number of my own patients live in the vicinity of the proposed 9.7 kilometre

Mordialloc Freeway, in the suburbs of Waterways, Aspendale Gardens and Dingley Village.

My expertise in relation to this matter includes:

1. I keep up to date with research and issues related to chronic diseases and public health, particularly related to lifestyle, physical activity, the environment and nutrition.

2. I treat patients from all age groups with a wide variety of medical conditions in clinical practice. These include patients suffering chronic diseases including asthma, respiratory diseases, cardiac disease and cancers that are directly impacted by road traffic air pollution.

3. I interpret and regularly publish articles based on research into lifestyle and environmental risks affecting general health and chronic diseases, in the general practice setting.

4. I have an interest and expertise in General Medical Health and Environmental Medicine. As a medical practitioner, I have knowledge of the current evidence and first-hand clinical experience of treating patients who are directly or indirectly impacted by poor air quality and pollution. These include children and adults with asthma, chronic lung diseases, heart disease and lung cancer. I directly treat patients who are impacted adversely from living or working near polluted regions.

I declare I have limitations in scientific knowledge on monitoring and how predictions are made

on Concentrations of Pollutants for sensitive receptors against design limits. I am trusting the

predictive values presented in the Mordialloc Bypass (Freeway) Environmental Effects

Statement, Chapter 13 Air quality and greenhouse gas are correct.

However, I do regularly review the scientific literature on epidemiological and cohort studies of

societies and cities based in Australia and in other countries similar to Australia, such as in

Europe and the United States, in relation to how air pollution is becoming a serious widespread

health related issue, and has negative impacts on human health, regardless of whether it meets

State Environment Protection Policy (Ambient Air Quality) Victorian Government SEPP(AAQ)

objectives.

For these reasons I support the local communities opposition of the construction of the

Mordialloc Freeway being built adjacent to, or near an urban environment, and favour instead

funding be diverted to improve public transport for the area. I do not object to freeways

constructed outside of urban areas, but the proposed Mordialloc Freeway would be built in one

of the few remaining green spaces in Melbourne, and adjacent to an urban environment in such

a way that I ascertain will cause short and long term health issues for the residents and workers

of these local communities.

I have attached a review paper I have prepared of the scientific evidence that addresses my

concerns of air pollution to human health to the best of my ability to support this statement,

and why freeways should not be built in urban environments. This scientific document has been

peer reviewed by other medical colleagues and experts in the field.

Members of the community are largely represented within RAMF and some are also my own

personal patients who consult me regularly at my medical clinic in Clayton. These residents

currently enjoy predominately fresh air being surrounded by local parklands and clean local

suburbs. They are experiencing great fears about the health implications of building a freeway

next to or near their homes, and the impact this would have on their health. Those with pre-

existing health conditions such as cardiac disease, lung disease and asthma, and the more

vulnerable and susceptible, such as people with pre-existing illnesses, children, the elderly and

pregnant women are most at risk of harm as demonstrated in studies included in my scientific

report attached.

The RAMF have invited me to present as an Expert Witness and have asked me to address the

following questions in relation to the EES for the construction of the proposed Mordialloc

Freeway:

1. Does the Mordialloc Freeway Project EES adequately identify and respond

appropriately to the most current scientific evidence and literature in relation to

health impacts from air pollution?

Is there evidence that the Mordialloc Freeway constructed next to an urban

residential area may impact the health of the local residents who live or work in the

area?

2. How may air pollution from vehicle emissions impact the health of the local

residents?

3. Have the potential health concerns to the local community been adequately

addressed in the submission in view that a total of 266, 450, 000 vehicles are

expected to have travelled along the freeway by the year 2031 (based on project

approximate average of 73 000 vehicles per day, over the 10 year period)?

4. Do you believe the local residents have been adequately informed of the vehicle

emissions and health impacts?

5. Does the EES address Air Quality adequately to protect human health having regard

to the evolving science in relation to health impacts from air pollution?

Relevant reports are located in these links:

Major Road Projects Victoria - View the EES

https://roadprojects.vic.gov.au/projects/mordialloc-freeway/view-the-ees

Mordialloc Bypass (Freeway) Environment Effects Statement - Chapter-13-Air-Quality-and-Greenhouse-Gas.pdf

Mordialloc Bypass - Appendix-F_Air-Quality.pdf

https://roadprojects.vic.gov.au/__data/assets/pdf_file/0011/335198/Appendix-F_Air-Quality.pdf

http://roadprojects.vic.gov.au/__data/assets/pdf_file/0006/334644/Chapter-13-Air-Quality-and-Greenhouse-Gas.pdf

Mordialloc Bypass (Freeway) Environment Effects Statement - Chapter-8-Traffic-and-Transport.pdf

https://roadprojects.vic.gov.au/__data/assets/pdf_file/0005/334634/Chapter-8-Traffic-and-Transport.pdf

Mordialloc Bypass (Freeway) Environment Effects Statement - Chapter-2-Project-Rationale.pdf

https://roadprojects.vic.gov.au/__data/assets/pdf_file/0020/334622/Chapter-2-Project-Rationale.pdf

1. Does the Mordialloc Freeway Project EES adequately identify and respond appropriately to

the most current scientific evidence and literature in relation to health impacts from air

pollution? Is there evidence that the Mordialloc Freeway constructed next to an urban

residential area may impact the health of the local residents who live or work in the area?

The Mordialloc Freeway Project EES does not include any data or new insights from the most

current scientific literature and publications within scientific and medical journals that

demonstrate clearly that road traffic related air pollution impacts human health. For particulate

matter, there is no level, below which negative impacts do not occur, therefore any increments

in air pollutants, however small, will likely result in public health issues. Vehicle emissions are a

particularly noxious sub-set of ambient particulate matter. The EES needs to fully consider all

the relevant adverse health impacts due to traffic pollution.

My scientific report attached summarises some of the evidence that demonstrates the health

concerns from exposure to road traffic related air pollution, even at levels below what is

regarded as acceptable maximum concentrations and measures as set out by the National

Environment Protection (Ambient Air Quality) Measure Schedule 2 Standards and Goals1.

These Standards and Maximum concentrations are tabled below1:

1 Australian Government, Federal Register of Legislation. National Environment Protection (Ambient Air Quality)

Measure https://www.legislation.gov.au/Details/C2004H03935

The State Environment Protection Policy (Ambient Air Quality) SEPP(AAQ) includes objectives for 24 hour average and annual readings2: PM10 concentrations of 50 μg/m3 (24 hour average) and 20 μg/m3 (one year average) PM2.5 objective of 25 μg/m3 (24-hour average) and 8 μg/m3 (one year average). The Environmental Quality Objectives for PM2.5 have been further revised and lowered to 7micrograms/cubic metre per year as tabled in the EPA website:3

There is now an abundance of worldwide literature including public health alerts by authorities such as the World Health Organisation, that highlight strong data and research outcomes demonstrating immediate and long term adverse effects on human health, from Particulate Matter traffic related air pollution, occurring at a greater magnitude of impact than previously thought, now demonstrating there is no safe lower limit of exposure4,5 . These concerns are well described in a number of studies conducted in Europe, the United States and Australia i.e. in areas of equivalent air pollution experienced in cities and urban areas of Australia that experience high traffic volumes such as Melbourne are described throughout this document and in the attached scientific report.

2 Extracted pages 23-25 of Appendix F Government of Victoria, 1999, February. State Environment Protection Policy

(Ambient Air Quality) Victorian Government Gazette, No S19. Government of Victoria, 2001, & State Environment Protection

Policy (Air Quality Management), SEPP(AQM). Victorian Government Gazette, No S240.

3 EPA Victoria SCHEDULE 2 – ENVIRONMENTAL QUALITY OBJECTIVES AND GOAL. Table 1: Environmental quality

objectives for environmental indicators. https://www.epa.vic.gov.au/about-us/legislation/~/media/Files/About%20us/Legislation/Air/160726consolidatedvariedSEPPAAQ.pdf

4 Qian Di, M.S, Wang Y, Zanobetti A, Wang Y, Koutrakis P, Choirat C, Dominici F, Schwartz JD. Air Pollution and

mortality in the Medicare Population. N Engl J Med 2017, June 29; 376(26):2513-2522. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5766848/

5 Barnett A. It’s safe to say there is no safe level of air pollution. Australian and New Zealand Journal of Public

Health. 2014;38:5:407-408 https://onlinelibrary.wiley.com/doi/full/10.1111/1753-6405.12264

Recent studies now demonstrate even level of PM2.5 exposure below National Environment Protection (Ambient Air Quality) Measures and SEPP (AAQ) Objectives (as described above) are considered to cause detrimental impacts on health6. The World Health Organisation air quality guidelines state, “there is little evidence to suggest a

threshold below which no adverse health effects would be anticipated”7.

Therefore we should be aiming at ensuring the cleanest air possible.

The Environmental Protection Agency has also provided comment on the technical and

scientific aspects of the Mordialloc Bypass (Freeway) EES8. On page 10 of their submission

under section 3.1 titled "Air Quality EPR AQ1" they acknowledge: "There is well established

scientific evidence that traffic related air pollution, even at concentrations well below the current air

quality standards, is associated with adverse health effects."

"(Air quality (operation)). Traffic is a significant contributor to air pollution in Melbourne. It generates air

pollution from both exhaust emissions and non-exhaust emissions (from tyres, brakes and road). There is

well established scientific evidence that traffic related air pollution, even at concentrations well below

the current air quality standards, is associated with adverse health effects. As stated above in Section

2.2.7, EPA recommends the use of the SEPP (AAQ) Schedule 2 - environment air quality objectives to

compare and assess air pollution levels measured near roads. EPA also recommends proponents to

adopt best practice design and controls to reduce air pollution and human health impacts. For new or

upgrades of major roads, the requirement of applying demonstrated best practice design and controls

that reduce air pollution impacts with risk assessments using the SEPP(AAQ) objectives should be

adopted. This is consistent with the regulatory approach in other jurisdictions in Australia and

internationally. The feasibility and viability exist to implement best practice design and controls to

reduce air pollution impacts to meet the SEPP(AAQ) objectives."

6 Diana Phillips Even 'Safe' Levels of Air Pollution Tied to Higher Mortality -Medscape–Dec 27, 2017.

https://www.medscape.com/viewarticle/890636

7 World Health Organization. Air Quality Guidelines for Particulate Matter, Ozone, Nitrogen Dioxide and Sulfur

Dioxide: Global Update 2005. Geneva (CHE): WHO; 2006. https://go.galegroup.com/ps/i.do?p=AONE&sw=w&u=googlescholar&v=2.1&it=r&id=GALE%7CA174061909&sid=classroomWidget&asid=acec1d40

8 EPA Submission Regarding Mordialloc Freeway Environmental Effects Statement (EES) https://s3.ap-southeast-

2.amazonaws.com/hdp.au.prod.app.vic-engage.files/7915/4501/3669/Submission_98_EPA_Victoria.pdf EPA's

submission uploaded as an attachment [Accessed 27 January 2019].

So just to explore in more detail a few significant studies to understand these concerns:4 Di Qian

et al NEJM 2017:

The lack of an apparent safe lower limit of exposure to PM2.5 (and to ozone) has been

underscored by a remarkably large study from the USA involving almost 61 million adults

followed for 12 years recently published in the New England Journal of Medicine by Di and

colleagues4 (Di Qian et al NEJM 2017). The aim of the study was to estimate the risk of death associated

with exposure to increases of 10 μg per cubic meter for PM2.5 and 10 parts per billion (ppb) for

ozone. They demonstrated a linear increase risk of death with increases in concentration levels

of exposure to PM2.5 and ozone. This study also identified that there were groups of people,

who were more susceptible to the adverse effects of air pollution than the rest of the

population. In this study the risk of death was higher in men, dark skinned people, and people

with Medicaid eligibility, illustrating important biological and sociological principles that might

be relevant to the Mordialloc Freeway project.

Their results:

"Increases of 10 μg per cubic meter in PM2.5 and of 10 ppb (parts per billion) in ozone were

associated with increases in all-cause mortality of 7.3% (95% confidence interval [CI], 7.1 to 7.5)

and 1.1% (95% CI, 1.0 to 1.2), respectively. When the analysis was restricted to person-years

with exposure to PM2.5 of less than 12 μg per cubic meter and ozone of less than 50 ppb, the

same increases in PM2.5 and ozone were associated with increases in the risk of death of 13.6%

(95% CI, 13.1 to 14.1) and 1.0% (95% CI, 0.9 to 1.1), respectively. For PM2.5, the risk of death

among men, blacks, and people with Medicaid eligibility was higher than that in the rest of the

population."

As illustrated in the figure below, the researchers demonstrate that the risk of harm i.e. vertical

axis- "hazard ratio"= higher risk than average of all-cause mortality [death], is dose dependent

and increases with greater exposure to PM 2.5 concentration (micrograms per cubic metre) and

ozone emissions (parts per billion) even below accepted national levels:

Figure 3 Concentration–Response Function of the Joint Effects of Exposure to PM2.5 and

Ozone on All-Cause Mortality Source

https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5766848/figure/F3/?report=objectonly

Hence the researchers concluded:

"In the entire Medicare population, there was significant evidence of adverse effects related to

exposure to PM2.5 and ozone at concentrations below current national standards. This effect

was most pronounced among self-identified racial minorities and people with low income."

Extrapolating these figures to the residents, recreational users and workers near the project area

So as an example if we look at Table 13.10 Predicted peak values for PM2.5 per hour at the Hawthorn Football club in Heatherton (location number 1 in Table 13.10) the expected peak level of exposure is 16 micrograms per cubic metre in a 1 hour period. The football club attracts children and families. The players exercise in this environment. Exercise results in deep breathing and increase in respiratory rate.

Drawing from the Hazard risk chart above9 the risk of harm to these individuals being exposed to PM2.5 at 16 micrograms/m3 is nearly 1.10. That is there is a 10% chance of increasing their risk of mortality (earlier death) above expected general population mortality due to air pollution alone! However, the population at the Football club is transient. People come and go to observe, train, exercise and play football. The age groups vary from young to old, and the health status of those people also varies. So the risk and impact is hard to determine in a transient changing community.

However, when we explore Table 13.10 for other locations, the residents of Waterways [note Aspendale Gardens is a misprint in this location 11], ), the workers at Commercial Dingley (location 3), Parks Victoria office lunchroom (location 8), the elderly residing at Ritchfield Retirement (location 14) and Chelsea Village Retirement Village (location 15) are exposed at or above the levels of 20 micrograms PM2.5 per cubic metre in a 1 hour period. Their risk of harm (mortality) exceeds 1.10 ie possibly a greater than 10% chance of increasing their risk of mortality (earlier death) compared to the general population due to exposure of air pollution alone! Again there are variables and a direct conclusion cannot be made, but the elderly would be a particularly high risk group due to most having pre-existing health conditions, they are not a transient group i.e. they remain on site at all or most times, and are a susceptible group for impacts to health from air related traffic pollution. People working in the Commercial Dingley region who spend the whole day at work with ongoing daily exposure to traffic related air pollution are also a high risk group. If any of the workers have other risk factors such as smoking or pre-existing lung conditions such as asthma, would be a high risk for exacerbation of asthma, risk of lung infections or chronic lung disease.

Furthermore the level of air pollution will vary during the day with peak hour traffic creating the higher levels, and most likely will increase over time as the population grows leading to a rise in Total Vehicle Numbers and consequently impact air quality.

Table 13.10 does not explore childcare and kindergarten centres located near the vicinity of the proposed Mordialloc Freeway, and calculating the Predicted peak concentrations of air pollutant exposure to the local children. A simple google search of the internet locates a number of childcare centres in the nearby vicinity that may be impacted with changes in air quality from the proposed Freeway:

9 Figure 3 Concentration–Response Function of the Joint Effects of Exposure to PM2.5 and Ozone on All-Cause

Mortality Source https://www.ncbi.nlm.nih.gov/pmc/articles/PMC5766848/figure/F3/?report=objectonly

Concerning all cause mortality, studies by Lepeule 201210 and Beelan11 2014 are also large

cohorts that give robust estimates of mortality due to long term exposure to air pollution. Both

of these more recent studies included relatively low levels of exposure to small particulate

matter (PM 2.5) similar to locations near the proposed Mordialloc Freeway project. However,

the researchers demonstrated an increase in mortality related to exposure to PM 2.5, even at

lower concentrations.

10

Lepeule J., Laden F., Dockery D. and Schwartz J. (2012). Chronic exposure to fine particles and mortality: an extended follow-up of the Harvard Six Cities study from 1974 to 2009. Environ Health Perspect 2012 Jul;120(7):

965-970. https://www.ncbi.nlm.nih.gov/pubmed/22456598.

11 Beelen R., Raaschou-Nielsen O., Stafoggia M., Andersen Z.J., Weinmayr G., Hoffmann B. et al. (2014a). Effects of

long-term exposure to air pollution on natural-cause mortality: An analysis of 22 European cohorts within the multicentre ESCAPE project. The Lancet 383(9919): 785-795. https://www.ncbi.nlm.nih.gov/pubmed/24332274

The Lupeule study based in Harvard USA for instance found since 2001, average PM2.5 levels, for

all six cities studies, were < 18 µg/m3. Each increase in PM2.5 (10 µg/m3) was associated with an

adjusted increased risk of all-cause mortality (PM2.5 average on previous year) of 14% , and with

26% and 37% increases in cardiovascular and lung-cancer mortality (PM2.5 average of three

previous years), respectively. The concentration–response relationship was linear down to

PM2.5 concentrations of 8 µg/m3.

Pope et al JAMA 2002

A study published by Pope et al JAMA 2002 demonstrated similar concerns that are well illustrated in the diagrams below which demonstrate increase mortality and morbidity with increasing level of exposure to PM2.5 well below current Australian Government standards and Objectives12:

12

Pope CA 3rd, Burnett RT, Thun MJ, Calle EE, Krewski D, Ito K, Thurston GD. Lung cancer, cardiopulmonary mortality, and long-term exposure to fine particulate air pollution. JAMA. 2002 Mar 6;287(9):1132-41. https://www.ncbi.nlm.nih.gov/pubmed/11879110

Mordialloc Freeway Project EES data Data listed in Table 13.3 in chapter 13 page 13-5, listing predicted vehicle emissions of the proposed project route using SEPP (AQM) design criteria concentrations (1 hour averaging period) are still concerning when there is research to demonstrate that any level of pollutants are a risk to human health i.e. there is no safe level of PMs: Chapter 13, page 13-10

Australian and International studies demonstrate air pollution harms human health, particularly

in susceptible people, are well below the current levels of pollutants as listed in Table 13.3.

There is no safe lower limit of air pollution - even below SEPP(AQM) 1 hour design criteria

(microgram/m3) concentration guidelines for pollutants.

The EES page 13-1 asserts that "...Carbon monoxide and PM (PM10 and PM2.5) are expected

to have minor to negligible air quality impacts.."

My response to the EES conclusions:

I do agree that vehicle emissions may be less than the SEPP (AAQ) Objectives and Goals, but I

do not agree with the above statements as stated on pages 13-1 and 13-13 that ""...Carbon

monoxide and PM (PM10 and PM2.5) are expected to have minor to negligible air quality

impacts..". I believe the studies as described above demonstrate that the levels quoted in table

13.3 (page 13-10) and Table 13.10 (page 13-19) as illustrated above are concerning.

It is likely there will be regions with less air pollutant levels along the proposed freeway, such as

when vehicles are cruising at the same speeds but with the increase in population and

consequent increase in total number of vehicles on the freeway, weather and wind influences ,

breaking and accelerating there is likely to be certain areas that are "hot spots" i.e. more

pollutant load.

Whilst vehicles are likely to reduce emission rates per vehicle [table 13-9 page 13-19], there is

likely to be higher levels of total emissions overall brought about by the increase in number of

vehicles from the increase in population despite improvement in emissions generated by each

vehicle.

With the expected growth of the number of vehicles on the road, areas such as Waterways,

Dingley and Aspendale Gardens will experience a substantial growth in Total Vehicle Numbers,

which will result in significant rise in total vehicle emissions in these areas especially with

expected population growth.

Hibrid and Electric cars

The claim on page 13-18 of Chapter 13 states:

"Calculated average fleet emission factors for 2031 are shown in the Table 13.9. There is potential for

emission rates from 2031 to be considerably lower than shown in Table 13.11 as vehicles become more

fuel efficient and especially if hybrid and electric vehicles become more widely used. There has been a

substantial reduction in vehicle emission rates over the last decade and a further reduction is projected

until the year 2021. Based on this trend, it is reasonable to expect a further substantial reduction by the

year 2031."

It is correct that each vehicle emissions are improving overall, but I cannot find the evidence for claiming

"reasonable to expect a further substantial reduction" when currently Australia is lagging in terms of

electric vehicle take-up, now making up only just 0.2 per cent of Australian cars according to data from

Australia's Electric Vehicle Council (EVC).

The studies cited above are further extrapolated and discussed within my scientific report

attached.

2. How may air pollution from vehicle emissions impact the health of the local residents?

There is clear evidence that air pollution due to vehicle emissions is a cause of a number of

health problems including increased risk of mortality. Harm to human health occurs at levels

below National Environment Protection (Ambient Air Quality) Measures and SEPP

(AAQ) Objectives that are currently . This is well described above and in my scientific report

attached.

Traffic related air pollution, even at low levels contributes to and/or causes a number of health problems especially for individuals living and working near freeways. Studies conducted in Europe, the United States and Australia i.e. in areas of equivalent air pollution experienced in cities of Australia such as Melbourne, are described throughout this document even when considered "safe" thresholds demonstrating detrimental impacts on health13.

None of the studies cited in this document or the attached scientific paper are cited in the Mordialloc Freeway Project EES warning local residents, particularly susceptible groups who will experience an unprecedented rise in air pollution levels from the proposed freeway eg residents living and working in Aspendale Gardens, Waterways and Dingley village. There are also a number of international studies in countries experiencing enormous growth in traffic congestion such as China. These studies demonstrate real health risks. We need better 21st century solutions to avoid Australia falling into the same situation. Short and long term exposure health effects to ambient PM exposure

Below is tabled a summary of potential health effects from short and long term exposure to ambient PM exposure14:

13

Diana Phillips Even 'Safe' Levels of Air Pollution Tied to Higher Mortality -Medscape–Dec 27, 2017.

https://www.medscape.com/viewarticle/890636

14 Hime, H., C. Cowie, and G. Marks, Review of the health impacts of emission sources, types and levels of

particulate matter air pollution in ambient air in NSW, N.E.P. Authority and E.H.B. NSW Ministry of Health,

Editors. 2015, Woolcock Institute of Medical Research, Centre for Air Quality and Health Research and Evaluation

(CAR).

Table 2. Summary Health effects attributed to exposure to ambient PM (source Hime et al,

2015)

Long-term Short-term

All cause (non-accidental) mortality

Cardiovascular

All cause (non-accidental) mortality

Cardiovascular

Cardiovascular-related mortality

Atherosclerosis

Ischaemic heart disease

Complications of diabetes

Cardiovascular-related mortality

Ischaemic heart disease

Ischaemic stroke

Myocardial infarction

Congestive heart failure

Respiratory Respiratory

Respiratory-related mortality

Asthma symptoms

Reduced lung function in children

Reduced lung function in susceptible adults

(elderly, people with COPD or asthma)

Respiratory infections in children

Respiratory-related mortality

Asthma symptoms

Respiratory infections

Bronchitis in children

COPD symptoms

Cancer

Lung cancer mortality

Neurological

Neurological disorders in adults

Impaired cognitive function

Development

Lung development

Neurological development in children

Reproduction

Adverse birth outcomes

Sperm quality and quantity

Allergies Allergies

Exacerbation of allergies

Allergic sensitization

Exacerbation of allergies

Vulnerable and susceptible groups

The studies also demonstrate that there are vulnerable and susceptible groups that are likely to

be more harmed by exposure to vehicle related air pollution. The following studies were

conducted in areas of low pollution considered "safe" below cut offs (similar to Australia) and

demonstrated negative impacts on health in vulnerable groups:

Air pollution effects on children

Concerning the adverse respiratory impacts of traffic pollution on children, there are a number

of very important studies that are not included in the EES. Children are particularly vulnerable

to vehicle emissions due to a number of factors including having a higher respiratory rate,

narrower airways, larger surface areas of their lungs compared to the rest of the body, and

increased exposure during school hours, their commute to and from school, and spending more

time outdoors with play15.

Children are also at increased risk of developing and suffering exacerbations (triggers) of

asthma with high exposure to vehicle exhaust fumes. A systematic review and meta-analysis of

the literature found childhood exposure to PM2.5 and black carbon was associated with

increasing risk of subsequent asthma in childhood and allergic diseases. 16

Another meta-analysis of studies based in the US demonstrated exposure to nitrogen dioxide,

nitrous oxide, and carbon monoxide were positively associated with a higher prevalence of

childhood asthma. Exposure to sulfur dioxide and particulate matter PM was associated with a

higher risk of wheeze in children. A meta-analysis of 19 other studies of children by Gasana et

al demonstrated that increased exposure to particulate matter was associated with wheeze17.

The researchers concluded “Living or attending schools near high traffic density roads exposes

children to higher levels of motor vehicle air pollutants, and increases the incidence and

prevalence of childhood asthma and wheeze”.

This data is very important because there is already a higher than average incidence of

childhood asthma, and asthma admissions in the surrounding residential areas and in other

regions that will result in increase traffic from the freeway. Asthma pathogenesis is a complex

mix of genetic and environmental factors. If there is already a susceptible population in the

region of the proposed Mordialloc Freeway project, it is essential that environmental factors

relevant to the development of asthma, such as air pollution, are mitigated.

15

Mazaheri, Mandana, Clifford, Sam, Jayaratne, Rohan, Mokhtar, Megat, Fuoco, Fernanda, Buonanno, Giorgio, &

Morawska, Lidia (2014) School children’s personal exposure to ultrafine particles in the urban environment.

Environmental Science & Technology (including News & Research Notes), 48(1), pp. 113-120

16 Bowatte, G., et al., The influence of childhood traffic‐related air pollution exposure on asthma, allergy and

sensitization: a systematic review and a meta‐analysis of birth cohort studies. Allergy Cochrane Library. 2015. p. 245-256. https://onlinelibrary.wiley.com/doi/full/10.1111/all.12561

17 Gasana J, Dillikar D, Mendy A, Forno E et al. Motor vehicle pollution and asthma in children: a meta-analysis.

Environ Res. 2012, Aug; 117: 36-45. https://www.ncbi.nlm.nih.gov/pubmed/22683007

Another systematic review of epidemiological studies in children whose mothers were exposed

to air pollution [prenatal exposure] found the child was at increased risk of developing asthma:

"The overall and subgroup risk estimates from the meta-analyses showed statistically significant

associations between prenatal exposures to NO2, SO2, and PM10 and the risk of wheezing and

asthma development in childhood."18

The European Study of Cohorts for Air Pollution Effects (ESCAPE) project analyzed data from

birth cohort studies situated in Germany, Sweden, the Netherlands, and the United Kingdom

that measured lung function at 6-8 years of age (n = 5,921)19. The researchers found children

exposed to NO2, NOx, PM2.5 absorbance, and PM2.5 from air pollution traffic was associated

with reduced lung function and lung development at an early age. A second ESCAPE study in

2014 showed an increase in respiratory infections in early childhood for some components of

traffic pollution20.

Decreases in adverse health outcomes such as hospital admissions for asthma, the prevalence

of bronchitis in children and improved lung function in children, have been observed with

decreases in particulate matter following major interventions to reduce air pollution21,22,23.

Systemic inflammation in children

Systemic inflammation of the body can be measured by a blood test called C-Reactive Protein.

This is an inflammatory marker and an Australian, Brisbane study found high levels in children

18

Hehua Z, Qing C, Shanyan G, Qijun W, Yuhong Z. The impact of prenatal exposure to air pollution on childhood wheezing and asthma: A systematic review. Environ Res. 2017 Nov;159:519-530. doi: 10.1016/j.envres.2017.08.038. https://www.ncbi.nlm.nih.gov/pubmed/28888196

19 Gehring U, Gruzieva O, Agius RM, Beelen R, et al. Air pollution exposure and lung function in children: the

ESCAPE project. Environ Health Perspect. 2013 Nov-Dec;121(11-12):1357-64. doi: 10.1289/ehp.1306770. Epub 2013 Sep 27. https://www.ncbi.nlm.nih.gov/pubmed/24076757/

20 MacIntyre E, Gehring U, Fuertes E, Klumper C et al. Air pollution and respiratory infections during early

childhood: an analysis of 10 European birth cohorts within the ESCAPE project. Environ Health Perspect. 2014 Jan;122(1) 107-13. https://www.ncbi.nlm.nih.gov/pubmed/24149084

21 Pope C.A. (1989). Respiratory disease associated with community air pollution and a steel mill, Utah Valley.

Am J Public Health 79: 623-628. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC1349506/

22 Heinrich J. (2003). Nonallergic respiratory morbidity improved along with a decline of traditional air pollution

levels: A review. European Respiratory Journal 21(Supplement 40): 64S-69s. https://pdfs.semanticscholar.org/381c/dcf4b6e305a8b3459c5ecdce05a842410b1a.pdf

23 Gauderman WJ, Urman R, Avol E, et al. Association of Improved Air Quality with Lung Development in Children

NEJM 2015;372;10:905-913 https://www.nejm.org/doi/full/10.1056/NEJMoa1414123

aged 8-11 years caused from exposure to the ultrafine particles smaller than 0.1 μm that

penetrate deeper into the lung and circulatory system24. The implications of chronic

inflammation found in children are enormous as the long term effects of chronic systemic

inflammation are known to contribute to a number of health conditions.

Pregnancy exposure & Low Birthweight

Data from the ESCAPE study in 2013 demonstrated that exposure to PM 2.5 during pregnancy

was associated with an increased risk of low birthweight on infants born at term, even at levels

of PM 2.5 less than the current EU annual limit of 25 ug/m3 25. This study concluded that “a

substantial proportion of cases of low birthweight at term babies could be prevented in Europe

if urban air pollution was reduced”.

Air pollution effects on elderly

In the US Medicare population from 2000 to 2012, short-term exposures to PM2.5 and warm-

season ozone found elderly to be of significant risk of mortality even at levels below current

national air quality standards, suggesting that these standards may need to be reevaluated26.

A proposed shared-use trail for cyclists and pedestrians built beside the Mordialloc freeway

Those more at risk to health impacts from traffic related air pollution are cyclists and

pedestrians on trails built along the proposed Freeway, residents living adjacent to these roads

and occupational workers working in close proximity to heavy traffic causing air pollution.

There is no evidence within the EES that warns these residents or workers or cyclists or

pedestrians using the trail of potential harms to their health from exposure of higher

concentrates of air pollution that will occur with the proposed Mordialloc Freeway particularly

in regions of 'hot spots' and in areas of higher volume of vehicle traffic.

There is evidence that exercising in traffic pollution increases the risk of cardiovascular disease

so constructing a pedestrian and bike path along the proposed Mordialloc freeway is

24

Clifford S, Mazaheri M, Salimi F, Ezz WN, Yeganeh B, Low-Choy S, Walker K, Mengersen K, Marks GB, Morawska L. Effects of exposure to ambient ultrafine particles on respiratory health and systemic inflammation in children. Environ Int. 2018 May;114:167-180. doi: 10.1016/j.envint.2018.02.019. Epub 2018 Mar 4. https://www.ncbi.nlm.nih.gov/pubmed/29514111

25 Pedersen M, Giorgis-Allemand L, Bernard C, et al. Ambient air pollution and low birthweight: a European

cohort study. Lancet Respir Med. 2013 Nov;1(90: 695-704. https://www.ncbi.nlm.nih.gov/pubmed/24429273

26 Di Q, WS, Dai L, Wang Y, Zanobetti A, Choirat C, Schwartz JD, Dominici F. Association of Short-term Exposure to

Air Pollution With Mortality in Older Adults. JAMA. 2017 Dec 26;318(24):2446-2456. doi:

10.1001/jama.2017.17923. https://www.ncbi.nlm.nih.gov/pubmed/29279932

detrimental to users of the path. A systematic review of 18 studies calculated the health

impacts based on exposure-response of cyclists to air pollution and found significant health

concerns were associated with exposure to ozone, black carbon or nitrogen oxides from cycling

on heavily polluted roads.27

Motorists also at risk of Vehicle related Air Pollution

Not considered by the Mordialloc Freeway Project EES is also the potential harm to motorists being exposed to air pollution particularly those who rely on transport for work, whose vehicles do not have appropriate air filters, and use heavily congested roads such as freeways frequently. A study found overall, car commuters had higher exposure to all pollutants than those who commuted by bus, motorcycles, followed by a car with controlled ventilation settings and those who use public transport [ie, train, subway, or metro]28. A randomised double-blind study was conducted in men with a known history of stable coronary heart disease found exposure to dilute diesel (300 micrograms/m3) exhaust in patients during 1 hour of moderate exercise had a direct effect on myocardial function [ECG changes], vascular, and fibrinolytic function29. The study found cardiac changes ie angina with ECG changes when breathing air with a small amount of diesel exhaust compared with breathing clean filtered air.

As the number of vehicles on the proposed Mordialloc Freeway increases, it will be impossible

for pedestrians and cyclists to use the shared trail due to air pollution emitted from vehicles,

combined with noise pollution.

Specific diseases caused by Air Pollution exposure:

Lung Cancer

The EES has not incorporated any studies that demonstrate that air pollution is an important

cause of lung cancer. Lung cancer incidence is rising in Australia. The Australian Government

27

Raza W, Forsberg B, Johansson C, Sommar JN. Air pollution as a risk factor in health impact assessments of a

travel mode shift towards cycling. Glob Health Action. 2018;11(1):1429081. doi:

10.1080/16549716.2018.1429081. https://www.ncbi.nlm.nih.gov/pubmed/29400262

28 Cepeda M, Schoufour J, Freak-Poli R, Koolhaas CM, Dhana K, Bramer WM, Franco OH. Levels of ambient air

pollution according to mode of transport: a systematic review. Lancet Public Health. 2017 Jan;2(1):e23-e34. doi:

10.1016/S2468-2667(16)30021-4. https://www.ncbi.nlm.nih.gov/pubmed/29249477

29 Mills NL, Törnqvist H, Gonzalez MC, Vink E, Robinson SD, Söderberg S, Boon NA, Donaldson K, Sandström T,

Blomberg A, Newby DE. Ischemic and thrombotic effects of dilute diesel-exhaust inhalation in men with coronary

heart disease. N Engl J Med. 2007 Sep 13;357(11):1075-82.

https://www.ncbi.nlm.nih.gov/pubmed/?term=N+Engl+J+Med+2007%3B357%3A1075-82

state air pollution amongst other risks as a cause of lung cancer30. International Agency for

Research in Cancer (IARC), a division of the World Health Organisation (WHO), raised the alarm

in 201331. Also in 2013, one of the studies from the European Study of Cohorts for Air Pollution

Effects (ESCAPE), by Raaschou-Nielsen et al32, showed that exposure to PM 10 and PM 2.5

increased the risk for lung cancer. A meta-analysis of 18 studies by Hamra in 201433 confirmed

the carcinogenic nature of outdoor exposure to PM 10 and PM 2.5. A second meta-analysis by

Chen et al in 201534 included 22 studies involving occupational exposure to air pollution among

professional drivers. Again exposure to fine particulate matter increased the risk of lung cancer,

and the risk was greater in professional drivers than in other people. IARC currently lists diesel

engine exhaust and particulate matter as class 1 carcinogens. Because of the poor survival from

lung cancer in Australia (< 14% of sufferers are alive after 5 years), it is essential that

preventable causes, including air pollution, are minimized.

Cardiovascular disease

There are a number of other significant adverse health effects of traffic pollution that have not

been explored or considered in the EES. Important examples are the acute and chronic

cardiovascular effects from exposure to pollution35,36. Dennekamp et al is a study performed in

Melbourne in 2010, and confirmed studies from other cities (including Perth) showing that

30

What are the risks of Lung Cancer? Australian Government, Cancer Australia https://lung-cancer.canceraustralia.gov.au/risk-factors 31

IARC Monograph 109, 2013.

32 Raaschou-Nielsen, Andersen, Beelen, Samoli, Stafoggia, Weinmayr, et al. (2013). Air pollution and lung cancer

incidence in 17 European cohorts: Prospective analyses from the European Study of Cohorts for Air Pollution Effects (ESCAPE). Lancet Oncology, 14(9), 813-822. https://www.thelancet.com/journals/lanonc/article/PIIS1470-2045(13)70279-1/fulltext

33 Hamra, G., Guha, N., Cohen, A., Laden, F., Raaschou-Nielsen, O., Samet, J, Loomis, D. (2014). Outdoor Particulate

Matter Exposure and Lung Cancer: A Systematic Review and Meta-Analysis. Environmental Health Perspectives, 122(9), 906-911. https://www.ncbi.nlm.nih.gov/pubmed/24911630

34 Gongbo Chen,

1 Xia Wan,

2 Gonghuan Yang,

2 and Xiaonong Zou

1 Traffic-related air pollution and lung cancer: A

meta-analysis Thorac Cancer. 2015 May; 6(3): 307–318. Published online 2015 Apr 24. doi: 10.1111/1759-

7714.12185 https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4448375/

35Cesaroni G, Forastiere F et al. Long term exposure to ambient air pollution and incidence of acute coronary

events: prospective cohort study and meta-analysis in 11 European cohorts from the ESCAPE Project. BMJ. 2014 Jan 21;348:f7412. https://www.ncbi.nlm.nih.gov/pubmed/24452269

36 Dennekamp M, Akram M, Abramson MJ, Tonkin A, Sim MR, Fridman M, Erbas B. Outdoor air pollution as a

trigger for out-of-hospital cardiac arrests. Epidemiology. 2010 Jul;21(4):494-500.

https://www.ncbi.nlm.nih.gov/pubmed/20489649

when the ambient concentration of PM2.5 increased, there was a corresponding increase in

out-of-hospital cardiac arrests. There is now a possible biological explanation for this

association, with recent data from the Framingham Heart Study showing that short term

exposure to air pollution generates a systemic inflammatory response, which is linked to

cardiac disease37.

Stroke

A major study published by Feigin et al in 2016 looked at risk factors for stroke in 188 countries.

The researchers estimate that globally, nearly one third of all strokes are attributable to air

pollution38.

In summary the evidence clearly demonstrates air pollution has the following effects:

1. Increases morbidity and mortality especially from fine particulate air pollution ie earlier

deaths from global studies performed in cities exposed to ambient air pollution39,40,41,42

2. Increase mortality associated with long-term effect of nitrogen dioxide NO2 as great as

that of PM2.543

37

Li W, Dorans K, Wilker E, Rice M et al. Short-term exposure to ambient air pollution and biomarkers of Systemic inflammation: The Framingham Heart study. Arterioscler Thromb Vasc Biol 2017. July 27. https://www.ncbi.nlm.nih.gov/pubmed/28751572

38 Feigin, Valery L., et al. Global burden of stroke and risk factors in 188 countries,during 1990–2013: a systematic

analysis for the Global Burden of Disease Study. 2013. The Lancet Neurology 15.9 (2016): 913-924. https://www.ncbi.nlm.nih.gov/pubmed/27291521

39 Qian Di, MS; Lingzhen Dai, ScD; Yun Wang PhD; et al Antonella Zanobetti, PhD; Christine Choirat, PhD; Joel D.

Schwartz, PhD; Francesca Dominici, PhD Association of Short-term Exposure to Air Pollution With Mortality in

Older Adults JAMA. 2017;318(24):2446-2456. doi:10.1001/jama.2017.17923

https://jamanetwork.com/journals/jama/article-abstract/2667069

40 C. Arden Pope III, Ph.D., Majid Ezzati, Ph.D., and Douglas W. Dockery, Sc.D. Fine-Particulate Air Pollution and

Life Expectancy in the United States. New England Journal of Medicine 360;4 nejm.org january 22, 2009 pages 376-386. https://www.nejm.org/doi/full/10.1056/NEJMsa0805646

41 Romieu I, Gouveia N, Cifuentes LA, de Leon AP, Junger W, Vera J, Strappa V, Hurtado-Díaz M, Miranda-Soberanis

V, Rojas-Bracho L, Carbajal-Arroyo L, Tzintzun-Cervantes G; HEI Health Review Committee. Multicity study of air

pollution and mortality in Latin America (the ESCALA study). Res Rep Health Eff Inst. 2012 Oct;(171):5-86.

https://www.ncbi.nlm.nih.gov/pubmed/23311234

42 Pope CA & Dockery DW (2006). Health effects of fine particulate air pollution: lines that connect. Journal of the

Air and Waste Management Association 56:709–742. https://www.tandfonline.com/doi/abs/10.1080/10473289.2006.10464485

3. Increased risk of mortality, particularly for the elderly, even in areas of air pollution

considered at "safe levels"44. Exposure to air pollution at levels well below current

quality standards is linked to an increased risk of death. Increased risk of cardiovascular

disease and deaths, such as cardiac arrests and deaths, heart failure onset and mortality

associated with heart failure, deep vein thrombosis [blood clots], heart disease, and

myocardial infarction (heart attacks) 45,46,47,48,49.

4. Increase risk of heart failure due to a possible threshold of PM2.5=4 µg/m3 is far below

the daily Australian national standard of 25 µg/m3 50

5. Higher risk of developing hypertension [high blood pressure]51,52.

43

Faustini A, Rapp R, Forastiere F. Nitrogen dioxide and mortality: review and meta-analysis of long-term studies.

Eur Respir J. 2014 Sep;44(3):744-53. https://www.ncbi.nlm.nih.gov/pubmed/24558178

44 Qian Di, MS; Lingzhen Dai, ScD; Yun Wang, PhD; et al Antonella Zanobetti, PhD; Christine Choirat, PhD; Joel D.

Schwartz, PhD; Francesca Dominici, PhD Association of Short-term Exposure to Air Pollution With Mortality in Older Adults JAMA. 2017;318(24):2446-2456.doi:10.1001/jama.2017.17923 https://jamanetwork.com/journals/jama/article-abstract/2667069

45 Zhao R, Chen S, Wang W, Huang J, Wang K, Liu L, Wei S. The impact of short-term exposure to air pollutants on

the onset of out-of-hospital cardiac arrest: A systematic review and meta-analysis. Int J Cardiol. 2017 Jan 1;226:110-117. doi: 10.1016/j.ijcard.2016.10.053. Epub 2016 Oct 25. https://www.ncbi.nlm.nih.gov/pubmed/27806308

46 Shah AS, Langrish JP, Nair H, McAllister DA, Hunter AL, Donaldson K, Newby DE, Mills NL. Global association of

air pollution and heart failure: a systematic review and meta-analysis. Lancet. 2013 Sep 21;382(9897):1039-48. doi: 10.1016/S0140-6736(13)60898-3. Epub 2013 Jul 10. https://www.ncbi.nlm.nih.gov/pubmed/23849322

47 Baccarelli A, Martinelli I, Zanobetti A, et al. Exposure to Particulate Air Pollution and Risk of Deep Vein

Thrombosis. Arch Intern Med. 2008;168(9):920–927. doi:10.1001/archinte.168.9.920 https://jamanetwork.com/journals/jamainternalmedicine/fullarticle/414214.

48 Mustafic H, Jabre P, Caussin C, Murad MH, Escolano S, Tafflet M, Périer MC, Marijon E, Vernerey D, Empana JP,

Jouven X. Main air pollutants and myocardial infarction: a systematic review and meta-analysis. JAMA. 2012 Feb 15;307(7):713-21. doi: 10.1001/jama.2012.126. https://www.ncbi.nlm.nih.gov/pubmed/22337682

49 Lim S, Vos T, Flaxman AD, Danaei G, et al. (2012). A comparative risk assessment of burden of disease and

injury attributable to 67 risk factors and risk factor clusters in 21 regions, 1990–2010: a systematic analysis for the Global Burden of Disease Study 2010. Lancet 380:2224–2260. https://www.ncbi.nlm.nih.gov/pubmed/25035875

50 Huynh QL, Blizzard CL, Marwick TH, et al. Association of ambient particulate matter with heart failure incidence

and all-cause readmissions in Tasmania: an observational study. BMJ Open 2018;8:e021798. doi: 10.1136/bmjopen-2018-021798 https://bmjopen.bmj.com/content/8/5/e021798

51 Cai Y, Zhang B, Ke W, Feng B, Lin H, Xiao J, Zeng W, Li X, Tao J, Yang Z, Ma W, Liu T. Associations of Short-Term

and Long-Term Exposure to Ambient Air Pollutants With Hypertension: A Systematic Review and Meta-Analysis. Hypertension. 2016 Jul;68(1):62-70. doi: 10.1161/HYPERTENSIONAHA.116.07218. Epub 2016 May 31. https://www.ncbi.nlm.nih.gov/pubmed/27245182

6. Increase risk of stroke and mortality associated with stroke30 Pope,53,54

7. Reduced survival from long-term exposure to traffic-related air pollution and cancer

among survivors of myocardial infarction (heart attacks)55.

8. Higher risk of out-of-hospital cardiac arrest associated with elevated ambient PM2.5 and

CO56

9. Reduced lung function, increase respiratory symptoms and diseases, respiratory related

deaths, chronic obstructive airways disease, cardiopulmonary disease, lung infections,

and asthma30 Pope,57,58,59,60,61,62

52

Yang BY, Qian Z, Howard SW, Vaughn MG, Fan SJ, Liu KK, Dong GH. Global association between ambient air pollution and blood pressure: A systematic review and meta-analysis. Environ Pollut. 2018 Apr;235:576-588. doi: 10.1016/j.envpol.2018.01.001. Epub 2018 Jan 11. https://www.ncbi.nlm.nih.gov/pubmed/29331891

53 Shah AS, Lee KK, McAllister DA, Hunter A, Nair H, Whiteley W, Langrish JP, Newby DE, Mills NL. Short term exposure to air pollution

and stroke: systematic review and meta-analysis. BMJ. 2015 Mar 24;350:h1295. doi: 10.1136/bmj.h1295. https://www.ncbi.nlm.nih.gov/pubmed/25810496 54

Yang WS, Wang X, Deng Q, Fan WY, Wang WY. An evidence-based appraisal of global association between air pollution and risk of stroke. Int J Cardiol. 2014 Aug 1;175(2):307-13. doi: 10.1016/j.ijcard.2014.05.044. Epub 2014 May 17. https://www.ncbi.nlm.nih.gov/pubmed/24866079

55 Cohen G, Levy I, Yuval, Kark JD, Levin N, Broday DM, Steinberg DM, Gerber Y. Long-term exposure to traffic-related air pollution and

cancer among survivors of myocardial infarction: A 20-year follow-up study. Eur J Prev Cardiol. 2017 Jan;24(1):92-102. https://www.ncbi.nlm.nih.gov/pubmed/27625155

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Evaluating the impact of air pollution on the incidence of out-of-hospital cardiac arrest in the Perth Metropolitan Region: 2000–2010 https://jech.bmj.com/content/68/1/6.short

57 Brunekreef B, Beelen R, Hoek G, Schouten L, Bausch-Goldbohm S, Fischer P, Armstrong B, Hughes E, Jerrett M, van den Brandt P.

Effects of long-term exposure to traffic-related air pollution on respiratory and cardiovascular mortality in the Netherlands: the NLCS-AIR study. Res Rep Health Eff Inst. 2009 Mar;(139):5-71; discussion 73-89. https://www.ncbi.nlm.nih.gov/pubmed/19554969 58

Benjamin D. Horne, Elizabeth A Joy; Michelle G Hofmann; Per H Gesteland; John B Cannon, Jacob S Lefler, Denitza P Blagev; E. Kent Korgenski, Natalie Torosyan, Grant I Hansen, David Kartchner; et al. Short-term Elevation of Fine Particulate Matter Air Pollution and Acute Lower Respiratory Infection Published Online: April 13, 2018 https://doi.org/10.1164/rccm.201709-1883OC https://www.atsjournals.org/doi/10.1164/rccm.201709-1883OC 59

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HEI Collaborative Working Group on Air Pollution, Poverty, and Health in Ho Chi Minh City1, Le TG, Ngo L, Mehta S, Do VD, Thach TQ,

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61 Kim H, Bernstein JA. Air Pollution and Allergic Disease. Curr Allergy Asthma Rep. 2009 Mar;9(2):128-33

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Paul Cullinan, Mark J. Nieuwenhuijsen, James Stewart-Evans, Eleni Malliarou, Lars Jarup, Robert Harrington, Magnus Svartengren, In-Kyu Han, Pamela Ohman-Strickland, Kian Fan Chung, and Junfeng Zhang. Respiratory Effects of Exposure to Diesel Traffic in Persons

10. Increase risk of asthma in children.(29 Bowatte et al)

11. Systemic Inflammation from exposure to ambient NO2 in Chronic Obstructive

Pulmonary Disease (COPD) patients, especially in former smokers63.

12. Increase risk of inflammation and cardiovascular disease in adults64.

13. Carcinogenic and lung cancer risk including in non-smokers65,66. Lung cancer risk occurs

due to deep penetration into the lungs of the fine particulates of 2.5 microns or less

from diesel or petrol exhaust fumes67,68. Air pollution shortens survival from lung

cancer69. PM2.5 particles or less are more toxic and carcinogenic as they penetrate

deeper into the lungs and vascular system of the body.

14. Poor cognition and concentration70. The researchers found that long term exposure to

air pollution impacted human cognitive performance, concentration, verbal and math

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skills, particularly in the elderly, potentially resulting in significant health and economic

costs. Multiple studies suggest air pollution contributes to cognitive impairment71,72,73

15. Increased mortality due to residents working or residing in industrial areas of high air

pollution resulting in increase cancers, lung cancer, mortality and neurological

diseases74.

16. Increase sick leave from work75.

17. Greater healthcare utilisation by both children and adults for respiratory infections76.

18. Increased risk of hospitalisation due to pneumonia in children77.

19. Increased risk of type 2 diabetes and diabetes associated mortality78,79,80

20. Pregnancy risks -fine particulate chemicals from air pollution impact the blood vessel

barrier of the vascular system of the placenta causing low birth weight, preterm birth,

71

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21. small for gestational age, and adverse birth outcomes81,82,83 and may increase

stillbirths84,85.

22. Poor sperm quality and infertility86.

23. Non-lung cancers: PM2.5 was significantly positively associated with death from cancers

of the kidney and bladder. NO2 was positively associated with colorectal cancer

mortality87.

81

Dadvand P, Parker J, Bell ML, Bonzini M, et al. (2013). Maternal exposure to particulate air pollution and term birth weight: a multi-country evaluation of effect and heterogeneity. Environmental Health Perspectives 121(3):367–373. https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3621183/

82 Dirga Kumar Lamichhane, Jong-Han Leem, Ji-Young Lee, and Hwan-Cheol Kim A meta-analysis of exposure to

particulate matter and adverse birth outcomes Environ Health Toxicol. 2015; 30: e2015011. Published online 2015 Nov 3. doi: [10.5620/eht.e2015011] https://www.ncbi.nlm.nih.gov/pmc/articles/PMC4722965/

83 Zhu X, Liu Y, Chen Y, Yao C, Che Z, Cao J. Maternal exposure to fine particulate matter (PM2.5) and pregnancy

outcomes: a meta-analysis. Environ Sci Pollut Res Int. 2015 Mar;22(5):3383-96. doi: 10.1007/s11356-014-3458-7.

Epub 2014 Aug 28. https://www.ncbi.nlm.nih.gov/pubmed/25163563

84 Siddika N, Balogun HA, Amegah AK, Jaakkola JJ. Prenatal ambient air pollution exposure and the risk of stillbirth: systematic

review and meta-analysis of the empirical evidence Occup Environ Med. 2016 Sep;73(9):573-81. doi: 10.1136/oemed-2015-103086. Epub 2016 May 24. https://www.ncbi.nlm.nih.gov/pubmed/27221104 85

Air Pollution 'Could Raise Stillbirth Risk' May 25, 2016 Medscape https://www.medscape.com/viewarticle/863844

86 Shereen Lehman Air Pollution Fine Particles Linked to Poor Sperm Quality-Medscape-Dec 11, 2017.

https://www.medscape.com/viewarticle/889932 SOURCE: http://bit.ly/2AaYoxz BMJ Occupat Environ Med 2017. Reuters Health Information © 2017.

87 Turner MC, Krewski D, Diver WR, Pope CA 3rd, Burnett RT, Jerrett M, Marshall JD, Gapstur SM. Ambient Air

Pollution and Cancer Mortality in the Cancer Prevention Study II. Environ Health Perspect. 2017 Aug

21;125(8):087013. doi: 10.1289/EHP1249. https://www.ncbi.nlm.nih.gov/pubmed/28886601

3. Have the potential health concerns to the local community been adequately addressed in the

submission in view that 266, 450, 000 vehicles are expected to travel along the freeway by the

year 2031 (based on project approximate average of 73 000 vehicles per day, over the 10 year

period)?

No potential health concerns are addressed in the Mordialloc Freeway Project EES.

As I have described above and outlined in my attached report air pollution from vehicle

emissions impact health even below what is considered "safe levels" i.e. below National

Environment Protection (Ambient Air Quality) Measures

and State Environment Protection Policy (Ambient Air Quality) SEPP(AAQ) Objectives that

includes objectives for 24 hour average and annual PM10 concentrations of 50 μg/m3 and 20

μg/m3 respectively, and 24 hour average and an annual PM2.5 objective of 25 μg/m3 (24-hour

average) and 8 μg/m3 (one year average), or even the revised level of 7 μg/m3 (one year

average) on the EPA website. Studies demonstrate harm to humans with ambient exposure to

PMs even below these levels.

The research demonstrates there are real risks to human health with even low levels of air

pollution that are considered "safe". None of these studies are contained within the EES report

considering the enormous growth in Total Vehicle Numbers for some regions near the

proposed Mordialloc Freeway region.

Table 8.7 of page 8-20 within the EES forecasts the growth of vehicles compared with and

without the project to 2031:

See table 8.7 below:

2031 forecast demand (daily two-way volume) – 2031 with project versus 2031 without project

The Traffic data is shown in the Traffic section of the EES Report Table Chapter 8.7 section

clearly shows a total of 76,700 vehicles per day projected by 2031 will use the Mordialloc

Bypass Freeway [see above].

The growth in traffic volume is sure to increase air pollutants as Predicted in the table 13.10

(page 13.19) below extracted from the EES report- many of these levels are still quite

concerning.

The figures demonstrated in the above Table for PMs 2.5 per hour are concerning as they are

still high and a risk particularly to susceptible individuals.

This is quite concerning for the local residents who live near the Mordialloc Bypass Freeway

project where there is little traffic exposure at present e.g. Waterways who will experience a

very large volume of traffic growth. Based on the figures above, residents and workers along

South Rd, parts of Springvale Rd and Governor Road, North of Lower Dandenong Road and the

Dingley Bypass will experience significant increase in Total Vehicle Counts which will ultimately

increase their exposure to air pollution and consequently cause more harm to their health.

4. Do you believe the local residents been adequately informed of the vehicle emissions and

health impacts?

No, I do not believe the EES has adequately informed the local residents of the possible health

impacts of vehicle emissions particularly in susceptible groups.

The Mordialloc Freeway Project EES instead asserts on page 13-1 that:

“Carbon monoxide and PM (PM10 and PM2.5) are expected to have minor to negligible air

quality impacts and are predicted to be below the relevant State Environment Protection Policy

(SEPP) Air Quality Management (AQM) design criteria. Nitrogen dioxide concentrations are

predicted to increase above existing background levels, up to 20m from the roadway. However,

beyond 20m of the roadway, NO2 concentrations are below the SEPP (AQM) design criterion

and no residential or commercial receptors would be adversely affected”.

This assertion is inconsistent with the conclusions of the studies I have described above. I do

not believe that levels of "...PM (PM10 and PM2.5) are expected to have minor to negligible air

quality impacts..." on air pollution levels and consequently to human health.

5. Does the EES address Air Quality adequately to protect human health having regard to the

evolving science in relation to health impacts from air pollution?

There does not appear within the EES to warn motorists, pedestrians, cyclists, and residents

living nearby [as described above] of traffic related air pollution effects on health.

It is quite possible that the project will have significant effects on local PM 2.5 concentrations –

increases or decreases depending on design, traffic flow and other factors.

I cannot find within the body of the EES any provision to monitor the levels of PM 2.5 on or

adjacent to the Freeway and in surrounding areas, despite overwhelming evidence that

particulate matter from traffic pollution causes very significant immediate and long term

adverse health effects. Appropriate monitoring should be placed at the site of the project or at

the adjacent nearby residential properties to assess before and after levels of pollutant

concentrations generated by the increase in traffic volume.

The EES has not assessed the existing health of the local communities as a baseline to assess

the impact of freeway-related air pollution on their health. There are no apparent provisions to

monitor health effects on residents or workers or response plans should monitoring show that

air pollution from the freeway is damaging local community health.

Attending childcare centres, schools, living or working within close proximity to the proposed

Freeway

The residents who will be exposed to more air pollution from increases in Total Vehicle

numbers have not been well informed of the potential harm to their health due to potential

rise in air pollution exposure. The European Study of Cohorts for Air Pollution is a meta-analysis

of data from 17 cohort studies consisting of 312 944 people from nine European countries and

found increase exposure to Particulate Matter (PM) from vehicle emissions causes a significant

risk of lung cancer among people even living within 100 metres of a major road88! Page 13-11

table 13.6 from the EES demonstrates the proximity of residents and industrial regions to the

proposed freeway. Most of these are located within 100 metres of the freeway:

Page 13-11 (next page) Table 13.6

88

Dr Ole Raaschou-Nielsen, PhD, Zorana J Andersen, PhD, Rob Beelen, PhD, Evangelia Samoli, PhD, Massimo

Stafoggia, MSc, Gudrun Weinmayr, PhD, et al. Air pollution and lung cancer incidence in 17 European cohorts:

prospective analyses from the European Study of Cohorts for Air Pollution Effects (ESCAPE) The Lancet Oncology

Volume 14, ISSUE 9, P813-822, August 01, 2013 Published:July 10, 2013DOI:https://doi.org/10.1016/S1470-

2045(13)70279-1 https://www.thelancet.com/journals/lanonc/article/PIIS1470-2045(13)70279-1/fulltext

Page 13-12 Figure 13.4 Air quality sensitive receptors, EES Chapter 13 (next page):

Note distance of the residents and commercial regions in illustration above Figure 13.4 Page

13-12 of EES Chapter 13 those at highest risk due to proximity to the proposed freeway:

Commercial Dingley number 3 situated at 25 metres

Residential Dingley numbers 4/5 at 36 metres

Commercial Dingley number 6 at 33 metres

Residential Waterways number 11 at 30 metres

Richfield Retirement, Aspendale Gardens number 14 at 32 metres

Retirement Village, Chelsea Heights number 15 at 30 metres

Those most susceptible living in these retirement centres is the elderly

The EES Mordialloc Freeway project EES has not listed the locations of the local schools and

childcare centers. In view of the high risk to children, it is paramount, that the distance of

these are calibrated, included in the chart and determine the Predicted levels of PM2.5 for

these.

Page 13-15, Figures 13.5 and 13.6 below only measures Total Suspended Particles and Peak PM10 assessed to distance but not for PM2.5 load which is much more harmful to human health in relation to distance from the edge of the proposed roadway. PM2.5 is the smaller particles that will remain airborne for longer and penetrate deeper into the lungs potentially causing more harm to health. Why haven’t the assessors shown PM2.5 as a function of distance from the road?

The EPA state on page 9 of their submission regarding the Mordialloc Freeway Environmental

Effects Statement (EES) under section titled 2.2.7. State Environment Protection Policy (Air

Quality Management) that assessments are made near roads: "In accordance with emerging

scientific evidence and best practice, EPA recommends the use of the SEPP (AAQ) Schedule 2 -

environment air quality objectives to compare and assess air pollution levels measured near

roads, instead of the SEPP (AQM) Intervention Levels."6

An Indoor Air Quality Study of residential dwellings that was carried out in Melbourne, Australia

found that dwellings in close proximity to major roads (less than 50 metres) found high levels of

indoor air pollutants89. Independent of gas cooking, "indoor NO 2 was elevated in Near Road

89 Sarah J. Lawson*, Ian E. Galbally, Jennifer C. Powell, Melita D. Keywood, Suzie B. Molloy, Min Cheng, Paul W.

Selleck. The effect of proximity to major roads on indoor air quality in typical Australian dwellings. Atmospheric

Environment, April 2011, Volume 45, Issue 13, p. 2252-2259.https://doi.org/10.1016/j.atmosenv.2011.01.024

http://adsabs.harvard.edu/abs/2011AtmEn..45.2252L

dwellings relative to Far Road dwellings by approximately 4 ppb and this can be attributed to

infiltration of outdoor air." They concluded "outdoor NO 2, and hence roadway emissions can

potentially contribute a significant proportion to the indoor NO 2 concentration.... Findings

elsewhere suggest that a similar outdoor enhancement of traffic related NO 2 (˜5 ppb) increases

risk of lung cancer and childhood asthma (Brauer et al., 2000; Nyberg et al., 2000)."

Furthermore, there are possibly incorrect findings on the graph in Figure 13.6 - if they are an

indication of the distances as outlined for the nearest houses, retirement villages and Parks

Victoria in Figure 13.4 [distance from project boundary].

Unless there is an additional buffer zone, the arrow for the nearest house is pointing just

below 45 metres part of the graph from the freeway but Figure 13.4 notes:

Residential Waterways (number 11) is situated 30 metres from the Project boundary

Unless there is an additional buffer zone, the arrow for the nearest retirement villages is

pointing near the 80 metre part of the graph from the freeway but Figure 13.4 notes:

Richfield Retirement, Aspendale Gardens number 14 at 32 metres [not 80 metres]

Retirement Village, Chelsea Heights number 15 at 30 metres [not 80 metres]

There is no arrow demonstrating distance of the commercial buildings in the area which is

important as there is a risk to the workers being exposed to daily traffic related air pollution.

Figures 13.4 notes:

Commercial Dingley number 3 situated at 25 metres from the Project boundary

Commercial Dingley number 6 at 33 metres from the Project boundary

Furthermore it is an omission to not include childcare centres and schools from this graph as

like elderly, children are particularly vulnerable and susceptible to harmful effects even to

low level of air pollution.

Nonetheless the distances of residential homes, retirement villages, commercial buildings,

and Parks Office are in close proximity of the proposed freeway within 100 metres.

Furthermore it is a significant omission why Figure 13.6 does not demonstrate Peak PM 2.5

concentrations which are much more harmful to health than PM10 using the worst two day

in years 2013-2017 (next page):

The EES states on Page 13-16

I do not agree with this statement in view of the proximity of the Retirement villages being

situated within 100 metres of the freeway and containing mostly elderly residents, a

susceptible and vulnerable sub-population often with chronic diseases including lung and heart

disease who will experience potentially greater harm from chronic exposure to increases in

traffic related air pollution. Elderly also spend more time at Retirement villages [usually the

whole day except for outings] compared with say families who are commuting to work and

school, and occupational workers in the commercial precinct who go are only on site during

work hours. Of greater concern, PM2.5 concentrations were not assessed.

If childcare centres and schools are situated nearby this would be of great concern!

Modeling for PM2.5 at these sites is required to assess potential harm of the proposed

Project with consequent increase in Total Vehicle Numbers causing increased level of air

pollution.

Mitigation of air pollutants

Barrier walls and vegetation barriers lining heavy traffic roads

Thick dense appropriate vegetation and wall barriers along traffic roads and freeways are

considerably helpful in reducing pollutant load, and mitigating urban air pollution90, however

residents are still exposed to air pollutants depending on direction of wind and changing

weather patterns as can be viewed in the following illustration:

90 K.V.Abhijith, PrashantKumar, John Gallagher et al Air pollution abatement performances of green infrastructure in open

road and built-up street canyon environments – A review Atmospheric Environment Volume 162, August 2017, Pages 71-86

https://www.sciencedirect.com/science/article/pii/S1352231017303151

Figure 1. Description of flow and pollutant dispersion patterns in a street canyon and open road with

and without different type of vegetation91

Motorists, cyclists and pedestrians are still at risk due to close proximity and exposed to the

traffic related air pollutants and barriers may even create a built up "canyon effect" as

demonstrated above.

91 K.V.Abhijith, PrashantKumar, John Gallagher et al Air pollution abatement performances of green infrastructure in open

road and built-up street canyon environments – A review Atmospheric Environment Volume 162, August 2017, Pages 71-86

https://www.sciencedirect.com/science/article/pii/S1352231017303151

Conclusion

The proposed freeway and attendant growth in vehicle emissions will expose local residents to

greater air pollution and health risks.

I am particularly concerned that the increase traffic related air pollution will affect the health of

susceptible groups; the elderly, children and pregnant women cyclists and pedestrians using the

freeway trail as well as workers in the local industrial region and the wider community.

There is strong evidence for causation or association of traffic related air pollution with

multiple adverse health outcomes, being dose dependent [even below current Government

standards] with different health outcomes depending on the duration of exposure:

Different health outcomes depending on duration of exposure - eg:

• Day(s), hours, minutes: Acute asthma, heart attacks, sudden death

• Weeks: Low birth weight pregnancy

• Chronic exposure: Cancer, cardio-vascular and chronic respiratory diseases

• There are multiple sources of air pollution but traffic related air pollution is an

important contributor

• Some people are more susceptible than others

• Australian research is consistent with international studies

Worldwide efforts by health authorities highlight concerns of communities living next to or

near highways or freeways, and impacts on health 92,93,94.

92

Living Near Highways and Air Pollution | American Lung Association https://www.lung.org/our-initiatives/healthy-air/outdoor/air-pollution/highways.html

93 Health Effects Institute https://www.healtheffects.org/ & https://www.healtheffects.org/air-pollution/traffic-

related-air-pollution

94 Issue air-pollution-and-its-health-impacts-changing-panorama | The Medical Journal of Australia Volume 177

https://www.mja.com.au/journal/2002/177/air-pollution-and-its-health-impacts-changing-panorama

Please find attached my scientific evidence based report and relevant appendices that highlight

the concerns of air pollution from vehicle emissions on heavy congested roads and its impact to

human health.

Furthermore, the freeway will attract a greater number of vehicles on the road, and this

exposes the local residents to greater air borne pollution when there are regions that are

currently exposed to significantly less air pollution e.g. Dingley, Waterways and Aspendale

Gardens. PM2.5 is particularly of concern as the smaller mass particles are likely to remain

airborne longer than the higher mass particles such as PM 10 which settle quicker.

Statement of completeness

I have made all inquires that I believe are desirable and appropriate and no matters of

significance which I regard as relevant have to my knowledge been withheld from the Panel.

For the reasons outlined above, I ask our politicians to divert the funding for this proposed

Mordialloc Freeway into affordable public extensive transport system that offer ongoing work

to Victorians, such as rail links for Melbourne, to help it become a sustainable green urban

environment for our future generations and children to enjoy.

Associate Professor Vicki Kotsirilos AM, MBBS, FACNEM, FASLM, Awarded Honorary

Fellowship of the Royal Australian College of General Practitioners