Mordialloc Bypass - Environmental Effects Statement -Inquiry and Advisory Committee Hearing

Submission by Michelle Giovas, 13th March 2019

Introduction

1. My name is Michelle Giovas, I am a resident of Heidelberg and am not directly affected by Mordialloc Bypass Infrastructure Project. However I am concerned about the necessity for the Project which is already well served by major arterials in the area and which provides short term traffic congestion relief for lasting loss of amenity, community wellbeing, native vegetation and habitat, however this is the project being reviewed and assessed by the Independent Inquiry and Advisory Committee’s (IAC) Terms of Reference. What I am concerned about and what I wish to comment on is:

Fundamental error in the Assessment Location Map; Compliance with State Environmental Legislation and Policy;

i. The Surface Water Assessmentii. Noise Impact Assessmentiii. EPBC – Matters of National Environmental Significance (MNES)

Proposed Environmental Performance Requirements2. My background is that I have worked in environmental management and protection my entire

working life, first as an EPA Senior Inspector where carried out investigations, licence inspections and prepared prosecutions for water, land and air pollution offences. For the last 25 years I’ve been with Monash University as an Environmental Advisor. Part of my current role is to review and audit Environmental Management and Construction Plans for the ambitious construction program the University has underway. This is to reduce pollution impacts and attempt to maintain our existing trees and canopy. I also manage trade waste compliance with the water authorities in relation to our retail and laboratory waste. I have sound knowledge of environmental legislation, environmental auditing and surveying and pollution prevention. I am not an expert in these areas but have a sound general knowledge.

3. I am active in my local community being a committee member of environmental groups Friends of Banyule Inc. (Secretary/treasurer) Warringal Conservation Society, Banyule City Council Environmental Advisory Committee North East Link Community Liaison Group (North) North East Link Community Liaison Group (Environment)

Fundamental errors in the assessment.

4. The main error I’m referring to relates to the following Figure known as the Project Location. This Figure has been used throughout documents produced by Major Roads Projects Victoria (MRPV), still on display at this hearing and VicRoads (Mordialloc Bypass Engagement Report March 2018). It was also used without question or correction by various consultants engaged to prepare the EES and provide the IAC with expert witness statements. The error I refer to is the incorrect naming of Westall Rd.

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5. You will note that Boundary Road has been used twice to identify two major arterial roads: Correctly - West of the Project for Primary State Arterial Road, Route No.23; Incorrectly - East of the Project for the Primary State Arterial Road, Route No.49.

This road should have been identified as Westall Road

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Figure 2. Extract from Page 78, 79, 80 of Melways Online, extracted from http://online.melway.com.au/melway/ accessed by me 8th March 2019 at 5.22pm

Compliance with State environmental legislation and Policy

The Surface Water Assessment

6. The EES in Chapter 3, Legislative Framework and Approval Process noted, that MRPA and its contractor must comply with a very thorough and extensive list of construction and operating requirements in Table 3.1 Relevant legislation, policies and guidelines which

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included Environment Protection Act 1970 (and relevant State Environment Protection Policies) (SEPP) which are subordinate legislative instruments.

7. The relevant SEPP for this Project is now SEPP (Waters) which was published in the Victoria Government Gazette No. S 493 19th October 2018 as the Project EES and draft Planning Scheme Amendment (PSA) went on public exhibition 26 October 2018. After the new SEPP (Waters) was gazetted. The Project should be assessed against SEPP (Waters). This replaced two existing SEPPs (and associated Schedules) to provide a single instrument to guide water quality management in Victoria and improve the protection of our waterways, bays, coastal waters and groundwater. SEPP (Waters) replaces the following statutory policies currently referred to in the EES:

SEPP (Waters of Victoria) and associated Schedules; and SEPP (Ground Waters of Victoria)

8. The Surface Water Assessment conducted by SKM provides information on both SEPP (Waters) and SEPP (Waters of Victoria).

9. SEPP (Waters) provides a framework for the protection and management of water quality in Victoria, covering surface waters, estuarine and marine waters and groundwater across the State. It states that “Good quality water is essential for healthy and prosperous communities and support the environmental, social and economic values that are important to Victorians. This Policy seeks to protect human health and the environment by reducing the harmful effects of pollution and waste, and to contribute to the restoration and protection of the ecological integrity of Victorian waters”.

10. VicRoads is required, under SEPP (Waters) 2018, to protect the beneficial uses of the water. The beneficial uses are listed below and are also consistent with environmental values recognised in Australian and New Zealand Guidelines for Fresh and Marine Water Quality, 2018 such as:

• aquatic ecosystems; • recreation and aesthetics; • cultural and spiritual values.

11. Most particularly for high conservation/ecological value systems, such as the RAMSAR listed Edithvale Wetlands, should have no change from ambient conditions, unless it can be demonstrated that such change will not compromise the maintenance of biological diversity in the system. Where comprehensive biological-effects data are not available, a monitoring program is required to show that values of physical and chemical stressors are not changing, using statistically conservative decision criteria as the basis for evaluation.

12. Stormwater, urban road runoff, can cause significant disturbance to these values when in downstream receiving waterways, often leading to a decrease in ecological health and a loss of habitat diversity:

• disturbance of aquatic habitats through increased magnitude, frequency and duration of high discharges;

• poor water quality due to the export of pollutants generated from road construction and operation.

13. Erosion from construction sites has the potential to contribute large sediment loads to downstream aquatic environments, altering the nature of flora and fauna habitats. In addition, elevated turbidity concentration reduces the penetration of light through the water, impacting on feeding and respiration of aquatic fauna. To effectively manage this issue, consideration needs to be given to the impacts and appropriate mitigation measures during the planning and design phases, and later during construction. Methods to control sediment on construction sites are described in detail in EPA Publications No 275 “Construction

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techniques for sediment pollution control” (1991), No.480 BPEM “Environmental Guidelines for Major Construction Sites” (1996) and No.960 “Doing it Right on Subdivisions – Temporary Environmental Protection Measures for Subdivision Construction Sites”.

14. The WSP report of Surface Water Quality is an analysis of surface water flows and quality but mostly on water flows. There is minimal sampling and analysis of water quality throughout the project area and the various wetlands. The extent of sampling sites dates and parameters that I have been able to glean from the “MRPA Mordialloc Bypass Surface Water Impact Assessment” October 2018 prepared by WSP are collated in Table 1 below, while actual sample locations are as per Images 3 to 5 extracted from the WSP Water Impact Assessment.

Table 1 Water Sampling Events Summary

15. It’s quite clear that insufficient sampling has been done for the Project proponent to accurately determine background water quality impacting and in the Ramsar listed Edithvale Wetlands. Inflows into the southern section of Edithvale Wetlands and potentially may be impacted by Project works were not been sampled. Edithvale Wetlands location can just be discerned in my Figure 3. While Figure 4, provides the location of sampling points in the Edithvale Wetlands. How can the project proponent purport to protect water quality to any measure of certainty when background water quality levels have not been properly established? Or established over the seasons?

16. Testing for heavy metals, a toxicant well known to be a product of road runoff, has been sampled at one site only, while hydrocarbons, another common road pollutant has not been

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tested for at all, likewise there has been no testing at all in the EES for biological indicators. The use of a number of indicators to measure ecosystem health is desirable as it improves the robustness and reliability of the assessment. The water quality assessment we have to date is piecemeal and fragmented. No amount of flow water modelling can make up for the scarcity in an actual sampled data.

17. Not to have the date, time and flow rate recorded for sampling is a significant failing as these parameters provide context and meaning to the results. Without this what can actually be read into the results is problematic. Ie was the drain flowing when samples were taken, had it been raining? Was it early in the morning when oxygen levels are depleted, was algae present etc. Consequently we don’t actually know from the EES what the water quality in the Edithvale and other Wetlands is. How can the project proponent purport to protect water quality to any measure of certainty when background water quality levels have not been established? Or established over the seasons or over years?

18. The results for Mordialloc Creek at Wells Road, Appendix F of the Surface Water Assessment indicates generally reasonable pH and dissolved oxygen levels. High but improving nutrient levels, nitrogen and phosphorus but high and variable turbidity and salinity. Data for heavy metals, zinc, cadmium, copper, lead and nickel were all high but with evidence of improving trend results for copper, nickel, lead and chromium. Arsenic results were acceptable.

19. A more thorough assessment would have included additional sample points, influenced by Project works such as sampling of Woodlands Industrial Estate, Sampling of southern drainage inputs into Edithvale Wetlands and drainage inflows into Waterways and Woodlands Industrial Estate Wetlands

20. Due to the sensitivity of the Ramsar Listed Edithvale wetland any runoff any runoff from Project construction or operation must ensure that Water Sensitive Urban Design/Water Sensitive Road Design WSUD/WSRD provides localised mitigation treatment methods and that are of an order to remove roadway pollutants including heavy metals and hydrocarbons. Grass swales can’t achieve this. Bioretention systems are required as per advice contained in “Austroads Guide to Road Design” section 3.5 Water Sensitive Urban Design. This is also consistent with the expert witness advice provided to this IAC by Rob Leslie, Principle Water Resources Engineer, WSP in Slide 18 of his presentation dealing with Submission responses:

• Vegetated swales to treat runoff from the road corridor; • Additional bio-retention systems at road drainage outfalls into Edithvale, Waterways and Woodlands Industrial Estate Wetlands; • Spill containment within swales and separate containment systems.

21. VicRoads have produced VicRoads Integrated Water Management Guidelines, June 2013. These look like effective guidance material yet they have not been referenced.

22. MRPV have specified 20,000L spill containment tanks at strategic locations along the freeway. Standards referred to in Austroads Guide to Road Design in Section 3.4.3 Spill Management specify that 40,000L (double 20,000L) tanks for spill containment is required for B-double and Higher Mass Load truck types to fully contain any spills. This design standard is being utilised by VicRoads, so it will then need to either ban B-double type trucks from the Project Freeway or ensure that spill capacity is at 40,000L.

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Figure 3 Surface Water Impact Assessment Mordialloc Bypass Surface Water Impact Assessment Major Road Projects Authority P34

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Figure 4 Surface Water Impact Assessment Mordialloc Bypass Surface Water Impact Assessment Major Road Projects Authority P38

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Figure 5 Surface Water Impact Assessment Mordialloc Bypass Surface Water Impact Assessment Major Road Projects Authority P36

23. In Appendix E of the Water Impact Assessment, Page E-1, it was identified by SKM that sites EN3a-A (North) and ES1 (South ) “were fresh water habitat for ducks and Australasian bittern, and shallow and deep fresh – brackish marsh, mudflats for migratory waders during summer dry down” respectively. These brief comments by the unknown water sampler give a clue to the significance of these wetlands for migratory birds and for Australia’s compliance with the International Treaty the Ramsar Convention on Wetlands of International Importance (1971) which is discussed later.

24. Also to note that during the 1994 to 2017 sampling periods Melbourne experienced the Millennium Drought 1997 to 2010. This impact of this is shown in Figure 6 and indicates the substantial decline in rainfall and subsequent decline in river flow, water quality and the life forms it enables. It is well known that with Climate Change rainfall events are less frequent and more intense. So we get our rainfall in short sharp flooding bursts. These Climate Change impacts will be exacerbated by the undisputed Project impacts on water quality and flow.

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Figure 6 From P29 Mordialloc Bypass Groundwater Impact Assessment VicRoads – WSP, September 2018

Noise Impact Assessment

25. The World Health Organisation in a 2018 publication, “Environmental Noise Guidelines for the European Region” strongly recommends reducing noise levels produced by road traffic below 53 dB Lden, as road traffic noise above this level is associated with adverse health effects. For night noise exposure, the Guideline Design Group strongly recommends reducing noise levels produced by road traffic during night time below 45 dB Lnight, as road traffic noise above this level is associated with adverse effects on sleep. WHO considers that a strong recommendation can be adopted as policy in most situations” from Pg.XVI in the Executive Summary. The Who Guidelines methodology Lden Day-evening-night-weighted sound pressure as per international standards ISO 1996-1:2016 Acoustics -- Description, measurement and assessment of environmental noise. Lnight is the equivalent continuous sound pressure level when the reference time interval is the night and refer to a measurement or calculation of noise exposure at the most exposed façade or outdoors of the home in question, reflecting the long-term average exposure. For direct comparisons to be made for this project more noise readings would be required to establish current backgrounds

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26. Elsewhere in Australia, the following policy limits are in place from South Australia:

Table 2 extract from South Australian Department of Planning Transport and Infrastructure “Road Traffic Noise Guidelines” Fourth Update October 2016 pg18 of 38.

27. In New South Wales the following policy limits are in place

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Table 3. extract from NSW Published by: Environment Protection Authority “Environmental criteria for road traffic Noise” May 1999, p6 of 42 https://www.environment.nsw.gov.au/resources/noise/roadnoise.pdf accessed by me 8th March 2019 at 7.40pm

28. Unfortunately our own EPA (Vic) has chosen not to develop a SEPP or policy that cover traffic noise. In this policy vacuum Vic Roads developed their own. “The VicRoads Traffic Noise Reduction Policy” 2005 which has been referred to and relied on substantially to set permissible noise levels at residential premises and parklands was developed in house in 2005, some 15 years ago.

29. This policy is now being used by the project proponent MRPV under the auspices of VicRoads to effectively regulate and protect themselves. It’s hardly surprising that this policy seems lax when measured against international and other Australian States’ standards. How useful a policy or quasi accepted standard it actually is for residents’ health and sensitive noise area amenity is really open to debate.

30. The use of in house noise policy is curious given that for spill management VicRoads now use:

Austroads Guide to Road Design (Part 5, Section 3.4.3 - Spill management) and NSW Roads & Maritime Services, Water sensitive urban design guideline.As provided by William Bartley, Senior Associate Clayton Utz, in his email to the IAC,

dated 5th March 2019 re the Mordialloc Bypass Project.

31. In Tabled Document 10, “Submission s on Behalf of MRPV Part B Opening” paragraph 18 the following comment has been made:“A key aspect of the Amenity Objective is that it requires the IAC to conduct its assessment of amenity impacts ‘having regard to relevant limits, targets and standards.’ This is reflected in the approach taken by the EES which has applied the following standards: (a) The VicRoads Traffic Noise Reduction Policy 2005 and Road Design Note 06-01 in the identification of appropriate Project Objective Noise Levels as well as the assessment and management 7 of noise impacts from the Project on noise-sensitive receivers as defined in the Traffic Noise Reduction Policy. “

32. It’s fairly clear to see that when regulatory bodies within Australia, New South Wales and South Australia and when international health science bodies like the World Health Organisation have set more stringent noise limits from roads it’s apparent that the so called standards of VicRoads Traffic Noise Reduction Policy is substandard and should be renamed the VicRoads Traffic Noise Acceptance Policy.

33. The VicRoads Traffic Noise Acceptance Policy has not be accepted as the appropriate standard by the community for a new freeway passing through established housing estates and sensitive community parkland. It is incumbent upon this IAC to set a noise standard that might be termed commonly available and accepted interstate and internationally. I would argue that the IAC would not be arbitrarily establishing new standards but carrying out its role to assess the environment effects of the Project using readily available standards applied in many other jurisdictions. The IAC might also recommend these well accepted lower noise level limits should be achieved by the Project proponent to deliver a project in the 2020s and that this recommendation is well within existing legislative and policy context.

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34. EPA on its web page notes in the following extract

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Figure 7: Extract from https://www.epa.vic.gov.au/your-environment/noise/motor-vehicle-train-and-tram-noise accessed by me 11/3/19 at 7.30pm

And then when we click on the link to the VicRoads review we find it’s in the too hard or never never basket.

Figure 8 http://consult.vicroads.vic.gov.au/trafficnoise Accessed by me 11/3/19 7.35pm.Worth noting that the Vic Roads home page was working perfectly well.

35. A colleague of mine has also noted that the proposed transparent noise walls to offer noise reduction measures for Parks Vic buildings in Braeside Park. These barriers erected to shield residents or Parks Vic staff from the noise of busy roads are also a major source of bird strike impacting parrots and particularly migratory birds. “There are reports of birds, especially parrots, smashing into the glass or fibreglass barriers in an attempt to reach the trees on the opposite side of the road. The situation is worst for birds which tend to fly at or below tree-top level, which puts it at particular risk of window collisions. As a result its

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incumbent upon road architects and engineers to now construct road barriers that are visible to wildlife

EPBC – Matters of National Environmental Significance (MNES)

36. EPBC Act covers potential impacts on MNES. Relevant to this project are the Ramsar wetlands such as Edithvale Wetlands, listed threatened species and communities, and listed migratory species. The Convention on Wetlands, called the Ramsar Convention, is an intergovernmental treaty that provides the framework for national action and international cooperation for the conservation and wise use of wetlands and their resources.

37. I have attached a copy of the Information Sheet on Ramsar Wetlands regarding the Edithvale-Seaford Wetlands from the following site to my submission for the IAC information. Extracted from https://rsis.ramsar.org/RISapp/files/RISrep/AU1096RIS.pdf extracted 10th

March 2019.

38. Extracted from the information sheet is the following; “these Wetlands are the last remnants of the once extensive Carrum Carrum Swamp and support very rich biodiversity including bird species and populations of international importance. They comprise two separate wetlands: Edithvale and Seaford. Both are similar in morphology and ecological characteristics and both have been subject to an extensive program of rehabilitation and active hydrological management by Melbourne Water. They are of great significance as examples of the cost-effective management of wetlands in an urban setting to provide conservation benefits, manage stormwater, and for environmental research and education”.

39. Justification for the Edithvale Wetlands remaining a RAMSAR listed site are the following criteria; 1. “Criterion 1: A wetland should be considered internationally important if it contains a

representative, rare, or unique example of a natural or near-natural wetland type found within the appropriate biogeographic region. The site contains the last remaining representative examples of the Carrum Carrum Swamp, a large southern Australian freshwater wetland, largely drained in the late 19th Century.

2. Criterion 2: A wetland should be considered internationally important if it supports vulnerable, endangered or critically endangered species or threatened ecological communities. The site supports State-significant populations and foraging and potential breeding habitat for the Australasian Bittern Botaurus poiciloptilus. The Australasian Bittern is listed as endangered in Victoria and as vulnerable on ‘The 2000 IUCN Red List of Threatened Species’.

3. Criterion 6: A wetland should be considered internationally important if it regularly supports 1% of the individuals in a population of one species or subspecies of waterbird. The site regularly supports more than 1% of the flyway population of Sharp-tailed Sandpiper (Calidris acuminata). A waterfowl count in summer 1987 recorded 3000 Sharptailed Sandpipers at Seaford Swamp (Watkins 1993). Regular monthly counts at Edithvale and Seaford Wetlands, since 1990, show 2007 Sharp-tailed Sandpipers were recorded at the Edithvale Wetland in December 1991. Discussions indicate that the 1% population estimate for Sharp-tailed Sandpiper is probably exceeded about one year in three, on average. Sharp-tailed Sandpipers use a wide variety of coastal and inland habitats in Australia. Population fluctuations at coastal sites, such as Edithvale-Seaford, are significantly influenced by the availability of suitable inland habitat. The availability of inland habitat is marked by a high degree of rainfall variability associated with long term climatic cycles. In addition, the habitat suitability for the species at the Edithvale-Seaford Wetlands also varies, depending on rainfall”.

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40. “Physical features: The Edithvale-Seaford Wetlands are remnants of the once extensive Carrum Carrum Swamp that occurred between Mordialloc and Frankston at the time of European Settlement. These are freshwater wetlands underlain by peat beds that limit the saline groundwater entering the wetlands. Each wetland has a small, local catchment of no more than 500ha. The catchment is generally bounded in the east and west by low (<3m AHD) sandy rises. Generally there has only been minimal interference with the remnant bed morphology of the wetlands.”

41. “Noteworthy fauna: Remnant habitats support a variety of native bird, mammal, frog, reptile, fish and invertebrate populations, several of which are of regional and state conservation significance. Since 1990, 25 species listed on the Japan and China Migratory Bird Agreements (61% of the total listed under these treaties) have been recorded. The Sharp-tailed Sandpiper is recorded in most years, in greatest numbers at Edithvale South and Seaford Wetlands. Five species listed under the Victorian Flora and Fauna Guarantee Act 1988 (Great Egret Ardea alba, Australasian Bittern, Baillon’s Crake Porzana pusilla, Lewin’s Rail Rallus pectoralis and White-bellied Sea Eagle Haliaeetus leucogaster) have been recorded. State-significant populations and foraging and breeding habitat for the Australasian Bittern and Baillon’s Crake, and regionally significant populations and habitat for 19 other species occur.”

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Table 4. Extract from WSP Flora and Fauna Assessment Mordialloc Freeway Pg. 20, XX

42. Species unlikely to be significantly impacted with mitigation actually means “will be impacted even with mitigation, the amount of which impact we just don’t know” Words to that affect are used for the critically endangered and migratory Curlew Sandpiper, the endangered Australasian Bittern, the migratory Sharp-tailed Sandpiper and the critically endangered Seasonal Herbacious Wetlands (Freshwater) of the Temperate Lowlands Plains. Which is 50 % of the Matters of National Environmental Significance that was identifies in the EPBC Act referral later from the Federal Minister for the Environment. Clearly impacts from this Project on four Matters of National Environmental Significance, on a Ramsar Listed Wetland and on bird species subject to international bilateral agreements is unacceptable on all three counts. I think it brings into doubt the validity of this project to go ahead at all when it results in likely

43. I haven’t really noted this elsewhere but the project is also in contrary to the intent of recent Sate Government Biodiversity Policy Protecting Victoria’s Environment – Biodiversity 2037, particularly the Vision that Victoria’s biodiversity is healthy, valued and actively cared for. While its Goals include Victoria’s natural environment is healthy and that we have an

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increase in the collection of targeted data for evidence-based decision making and make all data more accessible. Biodiversity 2037 is a good document, the pity of it is that it is ignored.

44. I draw your attention to Latham’s Snipe which breeds in Japan and China and summers in the South East of Australia. The greatest threat to it and all species–habitat groups is direct and indirect habitat loss both in Australia and overseas. Australia’s Wildlife Conservation Plan for Migratory Shorebirds confirms that loss of coastal habitat in Australia due to development and ‘reclamation’ is a significant threat to species (Commonwealth of Australia, Department of Environment 2015). More wide-ranging shorebird species in inland Australia such as the Latham’s Snipe, Double-banded Plover and Sharp-tailed Sandpiper continue to be threatened by loss of suitable ephemeral habitat with increasing salinisation a potential threat to snipe species.

45. Apart from being threatened with habitat destruction and disturbance from this freeway project, Latham’s Snipe habitat is also under threat from the proposed North East Link Tollway project which gas an EES being prepared as we speak for release mid- April. Its habitat at Banyule Wetlands is under threat from the NEL project. The dilemma that should be facing our Environment Department DEWLP is how realistically do the cumulative and compounding, if not multiplied impacts realistically get assessed? I would be seeking the advice of the IAC and the relevant Ministers on this one as it seems a scenario that the legislation and EES process have not really dealt with or addressed.

• Proposed Environmental Performance Requirements

46. In general I concur with City of Kingston comments Version 3 particularly with new EM3 Environmental Compliance

47. B3 Native Vegetation and Habitat vegetation clearance off sets are not well understood and seem of dubious value if not proven additional, of same vegetation type and within the impacted community or LGA of Kingston

48. NV1 Noise and vibration (design) Noise limits are too high and should be reduced to 55dB(A) for daytime noise and 50dB(A)

49. NV4 Construction noise targets are excessive and unacceptable for active and passive recreation and should be reduced by at least 5dB respectively 60 dB and 55 dB. Noise limits proposed for industrial premises and office retail outlets of 75dB and 70dB are excessive especially considering the time range, 7am to 6pm (M-F) 7am to 1pm Sat

50. W1 Waterbody health Establish pre-existing waterbody and stream health by extensive sampling of inflows into all wetlands. Sampling points to be upstream and downstream of proposed project area. As a minimum sampling should consist of observations including sampling date, time and accurate location, comment on flow rate, appearance, odour, wastes, presence of animals, etc., insitu testing for pH. Dissolve Oxygen, temperature and

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turbidity. Actual samples for analysis should be taken at each in flow drain if flow is apparent and in all standing water bodies for Suspended Solids, Total Dissolved Solids, Biochemical Oxygen Demand, Surfactants, Range of Nutrients, Suite of Heavy Metals, Escherichia coli and sampling for aquatic flora. Monthly sampling regime should commence as soon as possible to build up a true and accurate water quality baseline

51. W3 Surface water management (construction) should also reference EM2, EM3 and EM4. It should be very clear to the public that if they observe sediment or spills to drains that they must have a quick and effective reporting mechanism to report such events.

52. EM4 Environmental complaints management should also be linked to B4 Fauna Construction, B5 Native Vegetation Construction and B6 Flora and Fauna Operation so that community members know where to go to voice their concerns, get solutions and get effective feedback.

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