Carey Baptist Grammar School - North East Link Submission 11 June 2019 - AWS
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Carey Baptist Grammar School
North East Link Submission
11 June 2019
A co-educational, independent, Christian school, committed to developing wise,
independent and motivated people.
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1. Executive Summary
In preparation of this response to the Environmental Effects Statement (EES), as issued for the North
East Link Project (NELP), Carey Baptist Grammar School (Carey) has identified a number of issues
that the School would prefer was not available in the public domain. This document has therefore
been prepared for the attention only of the Inquiry and Advisory Committee.
The remainder of the comments from Carey on the EES are contained in a separate and
accompanying document titled Carey Baptist Grammar School, North East Link Submission 7 June
2019.
This project is going to have significant adverse effects on the activities undertaken by Carey at our
Sports Complex located at 169 Bulleen Rd, Bulleen. These effects will be experienced during both the
construction phase and the long-term operation of the road project. The short and long term health
and welfare of Carey students, staff and other users including external primary schools, of the Carey
Sports Complex is of great concern to the School community. The effects during the construction
phase are particularly troubling. The Carey Sports Complex is located immediately adjacent to the
site which has been identified by the Government as one of the largest civil construction projects
ever undertaken in the State of Victoria. It will cause major disruptions to what has been, to date, a
peaceful environment in and part of the Bulleen Park recreational areas. The project is planned to
take seven years. So, for this period the users of the Carey Sports Complex will have to endure these
disturbances. This period would be longer than most student’s attendance at Carey. That means
that for many students, this disturbed situation at the Carey Sports Complex is all they will ever
experience. There is a concern within Carey that once this situation becomes more widely
recognized, that enrollments at the School will be affected, to the longer term financial and
operational detriment of the School.
These adverse effects include the following:
• Possible increase in flooding effects to the site
• Possible increased risk of the site being affected by contaminated material and ground water
• Increased risk of the site being affected by dust and air born contamination
These adverse effects not only impact current users, but will also impact the future aspirations for
the site that Carey has identified in a Masterplan as prepared in 2015. This Masterplan provides the
10 year strategic vision for Carey, guides future operations and facilities and its recommendations
are currently being implemented. The consequences of the NELP therefor need to be evaluated not
only against the current situation but also against the aspirations described in this Masterplan.
Carey purchased the land now occupied by the Sports Complex in 1959. The facility services 2,500
students from both the Kew and Donvale campuses. Facilities at the Sports Complex are used for
Physical Education classes during school hours, co-curricular sporting events and training after
school and on Saturdays. Activities can involve current students and past Grammarians. Some
facilities are also hired to a number of external government and independent primary schools and
community groups on a regular and event specific basis.
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When Carey purchased this land it was aware of the local circumstances such as the flooding from
the Yarra River and Koonung Creek and the difficulties with access and egress to Bulleen Road. These
matters have been accommodated in the operation of the facility and the design of the buildings in
the years since. However, the examination of the EES by a panel of specialist expert consultants,
appointed by Carey, have identified that these effects and other environmental and health and
safety matters, will be significantly increased by the construction and operation of the NELP.
The panel of expert specialist consultants, appointed by Carey, to review and comment on the
various disruptive aspects of the project are as follows:
• Air Quality – Point Advisory
• Contaminated Land and Groundwater – Greencap
• Surface Water Flooding – Cawood and Associates
A number of these consultants have concluded that there is insufficient information included within
the ESS to properly assess the impacts of the proposed construction and operational phases of the
NELP. Carey notes this deficiency and subsequently reserves its right to provide further feedback
should further information become available from NELP or independent sources.
Copies of the detailed reports from these consultants are included as Attachments to this
submission. A summary of their main findings is included in this report.
2. Air Quality
Our environmental engineering consultants, Point Advisory reviewed the EES, and have highlighted
the following concerns in relation to air quality:
• The Air Quality Impact Assessment (AQIA) may underestimate the potential air quality impact
at the Carey Sports Complex during operation of the NELP. This concern is based on the
following observations:
- The combined impacts of surface roads and the ventilation system are not assessed.
- The combined impact of intersecting roads is not considered (i.e. Bulleen Road and the
Eastern Freeway).
- There is a risk that emission rates have been underestimated due to the approach and
assumptions adopted.
- The ventilation system exhaust air velocity is likely to be overestimated. If this velocity
is not sufficiently high, exhaust fumes from the ventilation stack will not be projected to
an appropriately high level and then, by wind currents or temperature inversion, these
fumes could directly affect the outdoor activities at the Sports Complex.
AQIA does not assess some pollutants, such as Volatile Organic Compounds, that would
normally be assessed for a road project of this scale. Justification for this was based on
findings from the West Gate Tunnel EES AQIA. The adequacy of this justification could
normally be tested retrospectively by checking the predicted peak impacts from NELP against
the adopted criteria. There are concerns about this NELA air quality modelling approach. Due
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to the above-listed concerns with the AQIA, it cannot be concluded whether the AQIA’s
justification for this omission has held-true for NELP and hence it is recommended that further
modelling should be undertaken.
• Operational impacts have been assessed quantitatively, but construction impacts have only
been considered qualitatively. Given that the project risk assessment considered construction-
related air quality impacts to be of higher risk than operational air quality impacts, it is
believed that construction-related impacts should also be assessed quantitatively. Doing so
will facilitate the development of more targeted emissions control measures under the project
Dust and Air Quality Management and Monitoring Plan (DAQMP), which is required by
Environmental Performance Requirement (EPR) AQ1.
Due to these concerns, it is believed that the EES does not appropriately assesses the potential
impact that NELP could have on air quality at the Carey Sports Complex. As such, due to this lack of
information, a conclusion cannot be reached as to the potential air quality impact at the Carey
Sports Complex during the construction or operation of the NELP.
Carey requests further modelling be undertaken to address the concerns identified above at the
location of the Carey Sports Complex, and specifically includes pollutants listed in Schedule B of the
State Environmental Protection Policy, Air Quality Management (SEPP AQM). Carey requests that an
EPR is established that requires the location of an air quality monitoring station at the Sports
Complex as part of the project DAQMP to verify impacts and to guide construction dust
management practices. The results from this monitoring to be available to Carey.
3. Contaminated Land and Ground Water
Our environmental engineering consultants; Greencap identified a number of gaps in the EES, that
are considered to render the EES deficient in its ability to assess the impact of the NELP to the Carey
Sports Complex. Specifically, these gaps are:
• A lack of consideration of the Environment Protection Amendment Act, 2018 (new EP Act)
which becomes affective from 1st July 2020. The new EP Act is a significant change to the way
environmental responsibility must be implemented where there are potential risks to human
health and the environment. The Act will therefore become effective during the majority of
the construction of the NELP.
• Inadequate investigation of the potential for mobilisation of contaminated groundwater onto
the site during and following the NELP’s dewatering activities. Technical Report N
recommends additional ‘in field’ investigation to obtain sufficient baseline groundwater data
to enable the development of a predictive model that adequately addresses the potential for
movement of contaminated groundwater.
Former landfills surrounding the site including Bulleen Park and Freeway Golf were identified
as potential sources of ground water contamination. Potential pathways for contamination
are identified as excavation of soil, abstraction of ground water and gas migration.
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• Inadequate investigation of the potential for mobilisation of friable asbestos, odors and
landfill gases onto the site during the NELP’s excavation activities within Bulleen Park
throughout its six/seven year occupation by NELP. We understand Bulleen park was a landfill
site for ten years from the early 1960’s. Technical Report O indicated that no soil or ground
water investigations were completed in Bulleen Park Oval. It is advised that investigations
were limited to the edge and not across the oval.
Furthermore, it was noted the EES itself describes the need for additional investigation to
adequately understand the potential impact of the NELP. The EES also states that future
development of management plans would address the aforementioned gaps.
Therefore, to ensure the impacts of the NELP to Carey’s personnel, operations, reputation, property,
and finances are adequately understood, it is requested that the North East Link Authority (NELA)
complete additional investigation forthwith to close the technical gaps outlined by the EES itself and
this EES review.
Given the concerns summarized above, Carey requests that an EPR is established that requires the
location of a series of ground water wells to be installed at appropriate locations at the Sports
Complex to monitor the possible deterioration of the quality of ground water that may migrate to
the site. The results from this monitoring to be available to Carey.
4. Surface Water Flooding
Our hydrometeorological engineers; Michael Cawood & Associates reviewed the EES and have
advised that any works that either alter the ability of a floodplain or flow path to convey water or
that reduce the volume available within the floodplain or flow path to store or convey water will
have an impact on flood frequencies, levels, velocities, depths, durations and extents. Any increase
to those characteristics in relation to the Yarra River and Koonung Creek has the potential to
negatively impact the Carey Sports Complex.
The increased risk of flooding raises critical concerns for Carey:
• The safety of Carey students, staff members and visitors, and their ability to evacuate from
the site via a single access road
• The School’s ongoing ability to deliver an educational program and sporting fixtures at
Bulleen
• The increased cost of future facility developments outlined in the Masterplan to withstand
more frequent or more severe flooding events
The key flood related issues for the Bulleen Campus arise from:
• Changes to the characteristics of Yarra River floods, particularly those events that occur more
frequently and are smaller than (i.e. are not as deep as) the 1% Annual Exceedance Probability
Yarra River event;
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• Changes to the character of Koonung Creek and the resulting changes to flood characteristics
in the reach between Bulleen Road and the creek’s confluence with the Yarra River; and
• Relocation of the Campus access road to the north of its current location.
The draft EES does not adequately define and quantify issues relevant to the Carey Sports Complex
because:
• Both Yarra River and Koonung Creek 1% AEP modelling results of direct relevance to Carey are
presented in map form using colour schemes that are difficult to discriminate while modelling
results for other design events are provided at locations that are not sufficiently
representative of conditions across the Sports Complex, and
• There is no information and / or modelling results presented for the construction phase of the
project, a key issue given that there are construction compounds shown located upstream of
and in close proximity to the campus on both the Yarra River and Koonung Creek floodplains.
• The information made available is not sufficiently complete or comprehensive to enable an
informed decision on whether the additional flood consequences arising from changes to
flood characteristics as a result of NELP works can be absorbed without materially
disadvantaging users of the campus and its facilities.
• While the approach to managing the increase in flood risk associated with the NELP is
generally consistent with industry practices, in view of identified inadequacies as outlined
above, together with multiple failures to comply with Melbourne Water requirements, the
interests of Carey have not been adequately considered and / or protected.
As the NELA has committed to remedying damage resulting from the project (e.g. EPR-B3 viz: “any
damage caused to property or infrastructure as a result of the North East Link must be appropriately
remedied in consultation with the property or asset owner”), it is requested that a plan is produced
to quantify the likely increase in damage (i.e. consequences) at the Campus following final
modelling. It is also important that the final modelling is confirmed to capture the cumulative impact
of multiple small and incremental changes on the floodplain (i.e. to NELP configurations). It must
also have regard for changes to flood characteristics across the full range of design flood events for
both the Yarra River and Koonung Creek. This is important as Yarra River floods somewhat smaller
than the 1% AEP event are expected to have a damaging impact on the Carey Sports Complex.
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Attachment 1.
Peer review
Review of air quality component of North East Link Environmental
Effects Statement
PRIVATE AND CONFIDENTIAL
Prepared for:
Carey Grammar School
24 May 2019
Point Advisory Pty Ltd
Level 17, 31 Queen St,
Melbourne, VIC-3000
ABN 30 159 916 677
Andrew Gunter 24 May 2019
Hunt & Hunt Lawyers
Level 5, 114 William Street
Melbourne VIC 3000
Email: agunter@huntvic.com.au
Dear Andrew,
Re: Review of air quality component of North East Link Environmental Effects Statement
This report presents Point Advisory’s review of the Air Quality Impact Assessment (AQIA) component of the
Environmental Effects Statement (EES) for the proposed construction and operation of the North East Link (NEL)
project as it relates to the Carey Grammar School (Carey GS) Sports Complex. This report has been prepared based
on a desktop review of the EES documentation and does not represent a complete basis of preparation for expert
witness testimony.
The EES considers the potential impacts from the construction and operation of NEL on air quality (affecting amenity
and human health) at the Sports Complex. The Sports Complex, a nominated sensitive receptor, is one of the most
exposed sensitive receptors due to its proximity to the southern ventilation structure, the Eastern Freeway and
Bulleen Road.
Point Advisory’s review of the EES has highlighted the following concerns:
● The AQIA may underestimate the potential air quality impact at the Carey GS Sports Complex during
operation of the NEL. This concern is based on the following observations:
− The combined impacts of surface roads and the ventilation system are not assessed.
− The combined impact of intersecting roads is not considered (i.e. Bulleen Road and the Eastern Freeway).
− There is a risk that emission rates have been underestimated due to the approach and assumptions
adopted.
− The ventilation system exhaust air velocity is likely overestimated.
● The AQIA does not assess some pollutants that would normally be assessed for a road project of this scale.
Due to Point Advisory’s above-listed concerns with the AQIA, we cannot conclude whether the AQIA’s
justification for this has held-true for NEL.
● Operational impacts have been assessed quantitatively, but construction impacts have only been considered
qualitatively. Given that the project risk assessment considered construction-related air quality impacts to be
of higher risk than operational air quality impacts, Point Advisory believes that construction-related impacts
should also be assessed quantitatively. Doing so will facilitate the development of more targeted emissions
control measures under the project Dust and Air Quality Management and Monitoring Plan (DAQMP), which is
required by Environmental Performance Requirement (EPR) AQ1.
Due to these concerns, Point Advisory does not believe that the EES appropriately assesses the potential impact that
NEL could have on air quality at the Sports Complex. As such, a conclusion cannot be reached as to the potential air
quality impact at Carey GS Sports Complex during the construction or operation of the NEL.
Point Advisory suggests that further modelling be undertaken to address the concerns identified above at the
location of the Carey GS Sports Complex, and that the modelling be undertaken for all pollutants listed in Schedule B
of the SEPP AQM. Detailed follow-up actions are provided on this matter in Table 2 of this report.
Regarding the presently-defined EPRs, Point Advisory is of the opinion that these provide an adequate framework to
stimulate a response (by the successful project tenderer) to project air quality issues based on the current AQIA
Integrated sustainability solutions www.pointadvisory.com
Point Advisory Pty Ltd
Level 17, 31 Queen St,
Melbourne, VIC-3000
ABN 30 159 916 677
conclusions. However, should additional air quality modelling result in changes to the AQIA conclusions, the EPRs
may also require revision.
Finally, it is recommended that an air quality monitoring station be located at the Sports Complex for as part of the
project DAQMP to verify impacts and to guide construction dust management practices.
Should you have any questions on any aspect of our assessment, please contact me on 0401 675 045 or at
ben@pointadvisory.com.
Kind regards,
Ben Sichlau
Senior Manager
Point Advisory
Integrated sustainability solutions www.pointadvisory.comDISCLAIMER This report has been prepared for Carey Grammar School (Carey GS) as outlined in the Proposal and scope of works. The services provided in connection with this engagement comprise an advisory engagement, which is not subject to Australian Auditing Standards or Australian Standards on Review or Assurance Engagements, and consequently no opinions or conclusions intended to convey assurance have been expressed. These review works have been based solely on the subject documents. No supporting calculations or modelling have been provided to Point Advisory to test the assertions made within the subject documents. This report has been prepared based on a desktop review of the EES documentation and does not represent a complete basis of preparation for expert witness testimony. Point Advisory acts in a professional manner and exercises all reasonable skill and care in the provision of its professional services. The reports are commissioned by and prepared for the exclusive use of (Carey GS). They are subject to and issued in accordance with the agreement between (Carey GS) and Point Advisory. Point Advisory is not responsible for any liability and accepts no responsibility whatsoever arising from the misapplication or misinterpretation by third parties of the contents of its reports. Except where expressly stated, Point Advisory does not attempt to verify the accuracy, validity or comprehensiveness of any information supplied to Point Advisory for its reports. We have indicated within this report the sources of the information provided. We are under no obligation in any circumstance to update this report, in either oral or written form, for events occurring after the report has been issued in final form. The findings in this report have been formed on the above basis. VERSION CONTROL Version Date Author Project Director Final v0 09 May 2019 B McKay B Sichlau Final v1 24 May 2019 B McKay B Sichlau Page 4 of 19 www.pointadvisory.com
CONTENTS Version control .............................................................................................................................................................. 4 1 Introduction........................................................................................................................................................ 6 1.1 Background .................................................................................................................................................................6 1.2 Documents reviewed ..................................................................................................................................................6 2 Review methodology .......................................................................................................................................... 7 3 Findings .............................................................................................................................................................. 7 3.1 Risk assessment ..........................................................................................................................................................7 3.2 Air Quality Impact Assessment ...................................................................................................................................8 3.3 Environmental Performance Requirements .............................................................................................................18 Integrated sustainability solutions www.pointadvisory.com
1 INTRODUCTION
1.1 Background
This report summarises Point Advisory’s review of the Air Quality Impact Assessment (AQIA) component of the North
East Link (NEL) project Environmental Effects Statement (EES) as it relates to the Carey Grammar School (Carey GS)
Sports Complex, located at 169 Bulleen Road, Bulleen.
The objective of the review was to develop an opinion as to whether the NEL EES:
● Appropriately assesses the potential impact that NEL could have on air quality at the Sports Complex.
● Specifies Environmental Performance Requirements (EPRs) that are sufficient to control for risks to air quality at
the Sports Complex.
As evidenced from the EES map book (maps 22, 23 and 32), the Sports Complex will have the following interactions
with the project:
● The surface works boundary enters the Sports Complex at the eastern section and borders Dunshea Oval.
● Two indicative construction compounds are adjacent to the Complex to the north and around 70 metres to the
NNE.
● Two new double lane surface roads are planned adjacent to Dunshea Oval.
● The southern ventilation system will be approximately 110 metres to the NE of the Campus boundary.
1.2 Documents reviewed
Point Advisory reviewed the following documents to inform this assessment:
● North East Link Attachment III – Risk report
● North East Link Project Environmental Effects Statement – Summary Report
● North East Link Project Environmental Effects Statement – Chapter 10 – Air Quality
● North East Link Project Environmental Effects Statement – Chapter 27 – Environmental management framework
● North East Link Project Environmental Effects Statement – Technical Report B – Air Quality
Point Advisory also reviewed relevant aspects of the following reports given their importance to the determination of
air quality impacts:
● North East Link Project Environmental Effects Statement – Chapter 9 – Traffic and transport
● North East Link Project Environmental Effects Statement – Technical Report A – Traffic and transport
● North East Link Project Environmental Effects Statement – Technical Report O – Contamination and soil
Page 6 of 19 www.pointadvisory.com2 REVIEW METHODOLOGY
Our review covered three key aspects of the AQIA:
1. The risk assessment that informed the scoping and boundaries of the AQIA.
2. The AQIA itself, and whether it appropriately assesses and communicates the potential air quality risks to the
Carey GS Sports Complex.
3. The Environmental Performance Requirements (EPRs) that are specified as control measures for the identified
risks, and whether these are appropriate.
3 FINDINGS
3.1 Risk assessment
A total of 19 risks were identified in the preliminary risk assessment. The assessment was qualitative in nature (by
necessity and due to its preliminary nature) and concluded that large dust particles from construction of NEL were
more likely to present a significant risk than are other air pollutants during operation. This preliminary finding is
reasonable, and should influence the scoping, boundary and focus of the AQIA.
Attachment III to the EES identifies 13 risks to air quality (AQ1-AQ13) during the construction of the project and 6 risks
to air quality (AQ14-AQ19) during operation of NEL. Two of these are not relevant to the Sports Complex (AQ12 and
AQ18). Of those risks that are relevant, the following six risks were classed as medium risk:
● AQ2: Earthworks – deposition of larger dust particles causing physical discomfort.
● AQ6: Construction of surface roads and other infrastructure - deposition of larger dust particles causing physical
discomfort.
● AQ7: Construction of surface roads and other infrastructure - deposition of PM10 and PM2.5 causing health
impacts1.
● AQ8: Construction of surface roads: generation of odour from asphalting.
● AQ11: Construction of tunnel - deposition of larger dust particles causing physical discomfort.
● AQ15: Underestimation of traffic volumes resulting in higher than anticipated ambient air quality impacts on
sensitive receptors.
All other risks were assessed to be low, including the risks related to air quality impacts during operation of NEL.
Given the preliminary and qualitative nature of the risk assessment, Point Advisory is comfortable with the risk
definitions and the relative significance of assessed risks.
As noted in Section 3.2.2 of this review, the AQIA adopts a quantitative assessment approach for operational
emissions (which were initially assessed as being of low risk) and a qualitative assessment approach for construction
emissions (which were initially assessed as being of medium risk). Point Advisory agrees with the decision to assess
operational impacts quantitatively but believes that construction-related impacts should be assessed in a similar
manner.
–
1 PM10 and PM2.5 refer to particulate matter that has an equivalent aerodynamic diameter of 10 and 2.5 micrometres or less respectively.
Page 7 of 19 www.pointadvisory.com3.2 Air Quality Impact Assessment
3.2.1 Application of legislation, policy & guidelines
The AQIA does not assess some pollutants that would normally be assessed for a road project of this
scale. Based on the AQIA, Point Advisory cannot test whether the AQIA’s justification for this has held-
true for NEL.
We therefore suggest that any additional air quality modelling should consider the impacts of surface
roads and the ventilation structure (combined) at the Carey GS Sports Complex (being the most exposed
receptor) for all pollutants listed in Schedule B of the SEPP AQM.
EPA Victoria agreed to limit the range of pollutants assessed by the AQIA to sub-set of those that would normally be
assessed for a road project of this scale. Justification for this was based on findings from the West Gate Tunnel EES
AQIA. The adequacy of this justification could normally be tested retrospectively by checking the predicted peak
impacts from NEL against the adopted criteria. However, Point Advisory has concerns regarding the NEL air quality
modelling approach. Hence, we are not confident that the exclusion of certain pollutants from the assessment (e.g.
VOCs from surface roads) is justified. Therefore, any additional air quality modelling that is undertaken for the EES
should consider the impacts of surface roads and the ventilation structure (combined) at the Carey GS Sports Complex
(being the most exposed receptor) for all pollutants listed in Schedule B of the SEPP AQM. Findings from this could
then be used to test the appropriateness of pollutants assessed along the full NEL alignment.
A summary of relevant standards and guidelines is provided in Table 1, along with comments as to their application in
the AQIA
Table 1 Standards & guidelines reviewed
Standards & Guidelines Comments
National Environment Protection The AAQ NEPM sets national standards and goals for common pollutants. A recent
(Ambient Air Quality) Measure amendment to the Air NEPM removed any allowances for the exceedance of the goal
(AAQ NEPM) for PM10 annually.
Adoption of the Air NEPM for the assessment of construction-related particulate
emissions is common practice.
National Environment Protection The Air Toxics NEPM sets national standards and goals for common pollutants and
(Air Toxics) Measure (Air Toxics defines monitoring and reporting protocols for specific pollutants, including PAHs,
NEPM) benzene and toluene.
State Environment Protection The SEPP AAQ mirrors the requirements of the Air NEPM and aims to protect the
Policy (Ambient Air Quality) (SEPP beneficial uses of the environment as they relate to air quality.
AAQ) The SEPP AAQ is primarily intended for the monitoring and assessment of ambient air
quality, as opposed to the assessment of emissions from particular sources. However, in
cases where there is a lack of specific guidance from EPA Victoria on appropriate
assessment criteria for particular sources (as is the case for road projects) the SEPP AAQ
is often adopted as a backstop.
Page 8 of 19 www.pointadvisory.comStandards & Guidelines Comments
State Environment Protection The SEPP AQM is the main standard used for the assessment of impacts from particular
Policy (Air Quality Management) sources. Note 1 to Schedule A of the SEPP AQM states that for roads, applicable
(SEPP AQM) assessment criteria are specified in the relevant industry Protocol for Environmental
Management (PEM).
Section 40 of the SEPP AQM commits EPA Victoria to the development of a PEM for
road construction and operation, which should include specific assessment criteria.
However, such a PEM has not yet been developed.
In its absence, the Protocol for Environmental Management: Mining and extractive
industries (Mining PEM) is often referred to as an indicator of EPA Victoria’s intent. The
Mining PEM refers directly back to Schedule B of the SEPP AQM, which lists intervention
levels for the assessment of monitoring data for particular sources. In 2001 (when the
SEPP AQM was gazetted) these intervention levels were broadly in-line with the
environmental quality objectives of the SEPP AAQ. However, the SEPP AAQ has since
evolved, and so to have its environmental quality objectives.
Therefore, Point Advisory is of the opinion that:
▪ The adoption of Schedule A of the SEPP AQM is appropriate in determining
assessment criteria for the tunnel ventilation structure. The AQIA does this
but does not include criterion for Sulphur Dioxide.
▪ Schedule B of the SEPP AQM should be adopted in determining assessment
criteria for surface roads, except in cases where the SEPP AAQ has recently
implemented more stringent environmental quality objectives, in which case,
these should be adopted as assessment criteria. The AQIA only adopts
assessment criteria for three pollutants covered by the SEPP AAQ (NO2, PM10
and PM2.5). It is Point Advisory’s opinion that the remaining eight pollutants
listed in Schedule B of the SEPP AQM (which include Volatile Organic
Compounds – a known toxic component of vehicle exhaust) should be
assessed against the therein listed intervention levels.
However, the NEL EES Technical Report B Air quality, p15 states “it was… agreed with
EPA Victoria that surface roads and combined impacts modelling would be limited to the
major pollutants, particulate matter and NO2.” Justification for this was that in the
West Gate Tunnel EES, predicted impacts for Carbon Monoxide and “the various air
toxics” were below 60% of the adopted assessment criteria, and that impacts for “PM10,
PM2.5 and NO2 ranged from 62 to 130 per cent” of the adopted criteria.
The adequacy of this justification could normally be tested retrospectively by checking
the predicted peak impact from NEL against the adopted criteria for PM10, PM2.5 and
NO2. However, given Point Advisory’s concerns related to the modelling approach (refer
to Sections 3.2.2 and 3.2.3), confidence cannot be gained in this manner.
Point Advisory is therefore of the opinion that any additional air quality modelling that
is undertaken for the EES should consider the impacts at the Carey GS Sports Complex
of all pollutants listed in Schedule B of the SEPP AQM.
EPAV Environment Guidelines for These Guidelines will apply to NEL during construction and include multiple measures
Major Construction Sites (1996) to reduce the impacts of dust during construction.
Page 9 of 19 www.pointadvisory.com3.2.2 Air quality model modelling Point Advisory is concerned that predictions may underestimate the potential air quality impact at the Carey GS Sports Complex during operation of the NEL. Importantly, the combined impacts of surface roads and the ventilation system are not assessed. Further, the combined impact of intersecting roads is not considered (i.e. Bulleen Road and the Eastern Freeway), there is a risk that emission rates have been underestimated, and the ventilation system exhaust air velocity is likely overestimated. Each of these factors can result in further underestimation. Point Advisory believes that construction-related impacts should be assessed quantitatively. The original risk assessment considered construction-related air quality impacts to be of higher risk than operational air quality impacts. A similar level of assessment is therefore warranted. These items require further investigation to enable the air quality impacts of the construction and operation of the NEL to be fully assessed at the Carey GS Sports Complex. A review of the modelling approach and methodology is detailed in Table 2. Tailored follow-up items are provided. Page 10 of 19 www.pointadvisory.com
Table 2 Air quality modelling review
Area Report Comments & Findings Recommendations
sections
Modelling Technical Construction impacts from unsealed areas, stockpiles, and truck exhaust and tyre emissions should be modelled Undertake modelling
approach: Report B: quantitatively for particulate matter PM10 and PM2.5, total suspended particles (TSP) and deposited dust. Consideration of construction
Construction 10.2 should be given to whether excavations of historic landfills adjacent to the Sports Complex have the elevate air quality risks impacts, particularly
impacts (Ventilation during construction. This will assist tenderers to develop more targeted Dust and Air Quality Management and Monitoring from haul trucks,
structure) Plan (DAQMP), as required by EPR AQ1 (refer to Section 3.3 of this report). stockpiles and
11.2 Large dust particles were identified as medium risk in the initial risk assessment; however construction impacts were assessed earthworks.
(Surface qualitatively because emissions are ‘complex’ in terms of range, type, number of activities and geographic extent (Technical
roads) Report B Air quality p18). 3,500 daily trips by trucks per day were estimated during construction in January 2023 if the tunnel Include in the
boring machine is launched from the southern site (Chapter 9 Traffic and Transport p48), which would be expected to cause assessment
adverse air quality impacts. Other sources of emissions noted in the EES include stockpiles and earthworks and modelling would consideration of the
be able to quantify the expected impacts from construction dust. air quality risks
Furthermore, the proposed construction works, adjacent to the Sports Complex, will like see excavation through former landfills associated with
sites at Bulleen Oval, Freeway Golf and at Musca Street Reserve (Technical Report O Contamination and soil p36-36). There is excavation of historic
therefore a risk of disturbinb and releasing hazardous material to air during excavation. The AQIA notes that this will be landfill sites near the
managed via the Spoil Management Plan to be developed under EPR CL1 (Technical Report B Air quality p72). Point Advisory Sports Complex.
suggests that the Dust and Air Quality Management and Monitoring Plan (DAQMP), as required by EPR AQ1, should also
canvass this risk.
For comparison, Point Advisory notes that the Melbourne Metro Environmental Effects Statement (Chapter 12) assessed
construction dust quantitatively using air dispersion modelling (12-5), although the West Gate Tunnel EES Technical Report G
Air Quality (p22) also assessed construction dust qualitatively.
Modelling Technical The Sports Complex was not assessed in the surface road impact modelling. In addition, the surface road impact modelling Expand the surface
approach: Report B does not appear to consider the cumulative effect of intersections and as such the impact at Bulleen Road and the Eastern road modelling to
Surface roads 11.6.6 Freeway would be higher than current modelling suggests. assess impacts at the
The nearest two transects assessed in the surface road assessment were (1) residences to the south of the Eastern Freeway and Sports Complex,
(2) residences along Ben Nevis Grove on the opposite side of Bulleen Road. The Sports Complex is identified and defined as a accounting for impacts
sensitive receptor (#105) and as such should be assessed for air quality impacts from surface roads. from the Eastern
Importantly, the air quality impacts from road projects are most pronounced near intersections, where vehicles have a higher Freeway and Bulleen
residence time and multiple traffic flows interact. The modelling approach adopted in the AQIA (i.e. longitudinal transects of Road.
receptors along single roads) is not likely to capture these peak impacts at intersections. Air quality modelling should use
gridded receptors to assess pollutant dispersion at major intersections such as the Eastern Freeway and Bulleen Road
intersection.
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Modelling Technical The combined impact of the surface roads and ventilation system have not been assessed at the Sports Complex. Assess the combined
approach: Report B Air Given the Sports Complex has the highest impact from the ventilation system (Chapter 10 Air quality, p34), the combined impact of the surface
Combined quality: 12.3 impacts from the surface roads should be assessed at this location. The combined assessment requires quantifying impacts roads and the
impacts from surface roads (as discussed above) and adding this to the ventilation system impacts and background levels. ventilation system at
the Sports Complex.
Model Technical EPA Victoria approved the use of AERMOD to model traffic emissions as volume sources. In conjunction with the sensitivity test None
selection Report B Air using CalRoads, the AQIA argues that the model selected is suitable for this assessment for both the surface road and
quality: ventilation structure. A peer review of the AQIA (Technical Report B Air quality, Appendix B) arrived at the same conclusion.
11.2.1 Point Advisory agrees with this model choice and model sensitivity test.
Meteorology Technical The impact of using AERMET on model results is unknown and is not discussed in Technical Report B Air quality. Golder notes Clarify why AERMET is
Report B Air that AERMET was used to generate five 12-month meteorological files. EPAV Guidance (publications 1550 and 1551) specifies used in contravention
quality: 6.4 that AERMET is not suitable for use outside of the USA. to EPAV Published
The use of Viewbank meteorology for the modelled years (2013-2017) is appropriate for use in the air quality study. Viewbank Guidance (1550 and
meteorology captures the katabatic flow from Plenty River and the Yarra River, which is important to accurately model 1551), and a
pollutant dispersion from both the ventilation structure and surface roads modelling. The use of Melbourne and Airport statement of possible
Essendon data for cloud cover and radiosone data is also appropriate. impacts on modelled
Given that this review is based solely on publicly available EES documentation (rather than the data files underpinning the results.
modelling), Point Advisory has not evaluated certain meteorological inputs to the model, namely mixing heights and the Monin
Obukhov Length, two important parameters in modelling pollutants from ventilation systems.
Traffic Technical The impact of all vehicle types was modelled by the AQIA. This covered passenger cars, light commercial vehicles and heavy- None
modelling Report B Air duty vehicles (trucks). No issues were found with traffic modelling.
quality: 9.4 It should be noted that the stated benefits of NEL causing a decrease in trucks along Bulleen Road is not likely to be realised at
the Sports Complex given its proximity to the tunnel portal and Eastern Freeway, both of which will experience a large increase
in truck movements.
Emission rates Technical Golder’s estimates of the reduction in vehicle emission rates in the future may be overly optimistic. Future vehicle emission Validate the 2020
Report B Air rates are calculated based on factors published in Road Tunnels: Vehicle Emissions and Air Demand for Ventilation (PIARC, future year factors
quality: 9.4 – 2012). The future factors are based on 2012 figures and may be outdated. using the 2015
9.5 PIARC forecasted a decrease in particulate matter emissions by 63% from passenger diesel cars and 51% from heavy duty forecast before factors
vehicles between 2010 and 2020. The same report forecasted a decrease in particulate matter emissions by 36% from are used in modelling.
passenger diesel cars and 27% from heavy duty vehicles between 2010 and 2015. These projected decreases in vehicle
emissions over time have a significant impact on pollutant modelling and should be examined in more detail. The projected
decrease stated by PIARC (2012) can be assessed for 2010 to 2015 using existing data to validate the 2020 forecasts.
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Emission rates Technical Point Advisory questions the balance of ‘conservative’ assumptions used to justify other assumptions affecting emission Quantify the potential
Report B Air rates, and is concerned that future emission rates may be higher than those stated in the assessment. Golder states impacts of (or
quality: 9.4 – (Technical Report B Air quality, p84) “the conservative assumptions included in the estimation of the emission rates (refer sensitivity to)
9.5 Section 9.5) are considered to compensate for any potential underestimation by COPERT Australia”. assumptions.
A review of these assumptions suggests they may not be as conservative as asserted:
▪ Using 5 years of meteorological data to model impacts is a requirement by EPA Victoria for all air quality modelling
(publication 1551) and does not impact the conservatism of emissions estimates.
▪ EPA Victoria predicts a significant reduction in background CO and NO2 concentrations over the next 20 years.
However, this will not have eventuated by the time NEL is operational.
▪ No evidence has been provided to support assertions that vehicles have reduced exhaust emissions of relevant
pollutants over time.
▪ Excluding low emissions vehicles and hybrids from future fleet mix (as the AQIA does) is not overly conservative, given
the modelling by Energeia of EV uptake referenced in the AQIA (Technical Report B Air quality, p81) notes that EVs are
likely only 0.5% of the fleet mix in 2025 and 4% in 2030 under a ‘no intervention’ scenario.
Conversely, Golder refer to a validation study of COPERT (Smit et al 2015) which finds COPERT underestimates emissions by 7 to
37 %.
On balance, Point Advisory thinks it is unlikely that Golders’ conservative assumptions are sufficient to counteract this potential
for COPERT to underestimate emissions.
Background Chapter 10 Point Advisory agrees with the approach used to consider background air quality. Background data was used from the None
air quality Report: Alphington EPA Ambient Air Quality Monitoring Station (AAQMS). PM10 and PM2.5 are flagged as the pollutants with the most
data 10-3 exceedances of air quality standards from the SEPP AAQ. Time-varying concentrations were used for main pollutants CO, NO2,
PM10 and PM2.5 for the modelled years since data was available. Table 10-3 of the Chapter 10 Air Quality Report summarises the
number of exceedances at Alphington AAQMS.
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Model inputs Technical Ground-level concentrations of pollutants from the ventilation system may be underestimated due to the high exhaust Confirm exhaust
(General) Report B Air velocity modelled, which would only represent maximum exhaust velocity and would be much higher than standard velocity and re-model
quality: operation of the ventilation system. ground-level impacts if
10.3.2 Technical Report B Air Quality (p 89) states a modelled exhaust velocity of 18 to 22 m/s. This is contradicted in Technical Report exhaust velocity is
C Surface noise and vibration (p 148) which notes an exhaust velocity of between six and eight m/s. Sensitivity testing should be likely to be lower.
conducted on the modelling to show the impacts of reducing the exit velocity on GLCs. A high exhaust velocity from the
ventilation system increases vertical dispersion and would lower any predicted GLCs. A lower velocity is likely to increase
impacts at ground level.
For reference, Point Advisory notes that the existing East Link stack has an exhaust velocity of 9 to 15 m/s, with morning peak
periods reaching a velocity of ~19 m/s2.
We also note that some level of conservatism has been introduced into modelling the ventilation system by assuming that the
exhaust is ambient temperature, thereby removing any plume buoyancy.
–
2 Broadspectrum, 2017, Report for East Link Ventilation Stack Emissions Monitoring Report January – March 2017
Page 14 of 19 www.pointadvisory.com3.2.3 Impacts noted at Carey Grammar Sports Complex The AQIA notes that the Carey GS Sports Complex is the discrete receptor noted to be the most impacted from the southern ventilation system (EES Chapter 10 Air Quality-p 34). Impacts from the ventilation system alone are predicted to be low, relative to the adopted assessment criteria. However, this does not include the impact of surface roads. Cumulative impacts As noted in Table 2, the cumulative air quality impacts at the Sports Complex have not been assessed from the surface roads and southern tunnel ventilation system. The nearest sensitive receptor assessed for combined impacts was Ben Nevis Road (350-400 metres east of the Sports Complex), which was noted to have the maximum predicted concentrations from the combined sources for scenarios A1, A2, B1 and B2. Results for this receptor are summarised in the Chapter 10 Report (Table 10-11 and Table 10-12). The tables list the maximum impact for PM10, PM2.5 and NO2, and shows that the maximum Ground Level Concentration (GLC) for PM2.5 exceeds the SEPP AAQ criteria. However, the results do not demonstrate how many exceedances were recorded as a result of the impacts from the ventilation structure and surface roads, nor does it assess the impacts against the SEPP AQM criteria. The ventilation system and surface roads were assessed against two different criteria: ● Surface roads were assessed against the SEPP AAQ. ● The ventilation system impacts were assessed against SEPP AQM. ● Combined impacts were assessed against SEPP AAQ criteria. As stated in Schedule C, Part C 2(a) of the SEPP AQM, toxicity-based Design Criteria (such as that for PM2.5) apply everywhere. Schedule C, Part B 3(a) of the SEPP AQM states that background information must be included in the model simulation, and 3(c) states that adjacent existing sources of the same pollutant must be included in the model. Technical Report B – Air Quality, Section 12.2 shows that exceedances of the assessment criteria for PM2.5 are predicted at two locations when ventilation system and surface road emissions are combined with background levels. It cannot be determined from the AQIA whether this would also hold true for the Sports Complex. It is noted that in cases where Schedule C, Part C 2(d) of the SEPP AQM allows the proponent to carry out a health risk assessment to demonstrate that there will be no adverse impact from the proposal. This has not been undertaken for NEL. Ventilation system The Sports Complex is the discrete receptor noted to be the most impacted from the southern ventilation system (EES Chapter 10 Air Quality-p 34). This is due to its proximity to the southern ventilation system. The predicted ground- level concentrations at the Sports Complex from the ventilation system are given in Appendix C of Technical Report B for Air Quality. Table 3 summarises the impacts from the ventilation system on Carey GS. Page 15 of 19 www.pointadvisory.com
Table 3: Summary of Ventilation system impacts at Carey GS
Ground level concentrations (µg/m3) from the PM10 PM2.5 NO2 Benzene
southern ventilation system
1 hr 1 hr 1 hr 3 minutes
Criteria assessed
SEPP AQM criteria 80 50 190 53
Maximum, as a percentage of criteria 4% 6% 12% 9%
Scenario A1 2.9 2.5 20 4.8
Scenario A2 2.0 1.3 6.4
Scenario B1 3.3 2.9 22 4.8
Scenario B2 2.2 1.4 7.4
Sensitivity analysis scenarios:
Maximum tunnel capacity 5.7 5 40 8.8
Increased ratio of diesel to petrol cars 3.7 3.2 27 n/a
Surface Roads
The Sports Complex was not assessed in a transect to assess the impacts from surface roads (refer to Figure 89 of the
Technical Appendix Report – p 155). The nearest two transects assessed in the surface road assessments were (1)
residences to the south of the Eastern Freeway and (2) residences along Ben Nevis Grove on the opposite side of
Bulleen Road. Results from these two transects are shown in Table 4. As noted in Section 3.2.2 of this report, these
locations are not likely to be representative of the impacts at the Sports Complex.
Table 4: Results of the surface road assessment
Difference between Project and Base scenario in 2026 Reference PM10 PM2.5 NO2
(µg/m3) (Technical
24 hr 24 hr 1 hr
Report B)
2026: Ben Nevis Grove from the Eastern Freeway – noted to have the Table 85 2.8 2.3 28
highest combined impact (EES Chapter 10: page 50) (+130%) (+136%) (+87%)
2026: Increase in traffic from Eastern Freeway (Bulleen Road to Table 86 +0.5 +0.5 +6
Bourke Rd (Table 86) (+27%) (+33%) (+25%)
Page 16 of 19 www.pointadvisory.com3.2.4 Assessment of conclusions
A conclusion as to the impact of surface roads at Carey GS Sports Complex cannot be drawn from the
AQIA. Should any additional air quality modelling be undertaken for the EES such that construction is
assessed quantitatively, and combined operational impacts of surface roads and the ventilation structure
at the Carey GS Sports Complex are assessed, the stated AQIA conclusions could change.
The Chapter 10: Air Quality (10.6) report draws the following conclusions of relevance for Carey GS at the Sports
Complex:
Construction impacts
● Particulate matter generated during construction has the potential to impact health if emissions are not
mitigated.
● Odours are expected to be localised and only detectable close to the source.
● Products from combustion of heavy machinery and equipment may cause impacts during construction, however
the impacts from these activities would be minor.
Operational impacts
● Air quality would be impacted along some roads.
● Impacts would exceed the SEPP AQM criteria when modelled with background concentrations of particulate
matter, however the predicted exceedances “are not considered to conflict with the intent of the SEPP AQM given
the small contribution that emissions from the tunnel ventilation systems would make compared with the
background concentrations”.
● There is relatively little change in maximum predicted ground level pollutant concentrations due to the project
contribution.
Point Advisory note that:
● The conclusions related to construction impacts should be considered to be indicative only until:
− A quantitative assessment of these is undertaken, and mitigation and control measures are specified and
assessed for effectiveness.
− Consideration has been given to air quality risks associated with excavation of historic landfill sites near the
Sports Complex.
● Should any additional air quality modelling be undertaken for the EES such that combined impacts of surface
roads and the ventilation structure at the Carey GS Sports Complex are assessed, the stated AQIA conclusions
could change.
Page 17 of 19 www.pointadvisory.com3.3 Environmental Performance Requirements Based on the conclusions presented in the AQIA, the presently-defined EPRs provide an adequate framework to stimulate a market response to project air quality issues. However, should additional air quality modelling result in changes to the AQIA conclusions, the EPRs may also require revision. The EPRs are too generalised to articulate precisely how risks will be managed. However, this is to be expected given that EPRs at this stage in the tender process are developed to stimulate a more detailed response from the market. The successful tenderer for the project will be required to specify exactly how the EPRs will be met. Point Advisory is of the opinion that the presently-defined EPRs provide an adequate framework to stimulate an appropriate market response. Point Advisory also recommends that an air quality monitoring station be located at the Sports Complex for as part of the project DAQMP to verify impacts and to guide construction dust management practices. The EPRs refer to the following as-yet-undrafted documents with no specific mitigation measures nor reference documents: ● Dust and AQ Management and Monitoring Plan. ● Environmental Strategy and Management Plan. ● Spoil Management Plan to meet EPA requirements. ● Tunnel ventilation requirements from EPAV. ● In-tunnel air quality standards. Specific controls will need to be defined as part of these documents, but such detail is not expected at this stage of assessment. Table 5 summarises our review of the NEL documentation relating to Environmental Performance Requirements (EPRs). Page 18 of 19 www.pointadvisory.com
Table 5 Review of EPRs listed in Chapter 27 Table 27-4
# Environmental Performance Requirement Timing Comments
AQ1 Implement a Dust and Air Quality Management and Construction The Sports Complex is one of the most exposed sensitive receptors to construction dust
Monitoring Plan (DAQMP) to minimise air quality due to its location adjacent to the construction site for the southern tunnel portal and is
impacts during construction. thus an appropriate choice of location for an air quality monitoring station.
This plan will describe the monitoring requirements Carey GS should review the monitoring plan when available to ensure it sets an
for key sensitive receptors. appropriate baseline, monitors for the relevant pollutants, and is set up according to
applicable standards.
The monitoring plan should also include appropriate actions for the appropriate
authority or construction company to take in the event of a dust exceedance.
AQ2 Design tunnel ventilation system to meet EPA Construction and Noting Point Advisory’s comments regarding appropriate EPA requirements, this EPR is
requirements for air quality. operation otherwise adequate.
AQ3 In-tunnel air quality performance standards. Operation Not applicable to Carey GS.
AQ4 Monitor ambient air quality: Construction and Refer to AQ1 for comments on monitoring ambient air quality.
At least 1 year of monitoring before operation operation
Designed in consultation with EPA Victoria.
AQ5 Monitor compliance of in-tunnel air quality and Operation Monitoring for compliance refers (indirectly through AQ2, AQ3) to the correct sources
ventilation structure emissions. and criteria.
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