Noise, vibration, air emission and light spill impacts

In general CIS does not adequately address impacts of noise, vibration, air emission and light spill, nor how they will be managed or minimised, because:

  • Many of the proposed measures are unknown and not stated in the CIS. Too many elements of the reference design presented in the CIS are to be referred to “the contractor” for a decision.  The CIS must re-issued after the final design is known so that all stake-holders and independent experts can be informed of exact measures proposed to manage the expected noise, vibration, air emission and light spill problems and determine whether they would be adequate.

  • The proposed tunnel ventilation structure emissions are unclear as well as well as details of which modelling tool will be used: the obsolete AUPLUME or ‘state of the art’ AERMOD due to be employed from 1 January 2014? No details or assurances made in CIS to indicate AERMOD will be used consistently throughout entire process.

  • The theoretical ‘reference design’ does not state absolute values for adverse impacts but instead refers to meeting standards, guidelines and policies that are (worryingly) subject to change. Consequently, the eventual, finalised contracted design will not be known until after the conclusion of the CIS. This is illogical leading to misguided analysis and assessment of the management of noise, vibration, air emission and light spill.

  • Standards, guidelines and policies are controlled by entities of the Victorian Government (eg. Environmental Protection Authority, VicRoads) and potentially subject to change by the Victorian Government to ensure the proposed EWL meets “the standards”. This sets up an untenable and weak framework for ensuring noise, vibration, air emission and light spill will be appropriately managed by unknown measures that will be dictated by an unknown contractor.

Noise and Vibration (Ch 12, App J)

Precinct 1 (Clifton Hill/Collingwood)

  • ‘temporary’ exposure to higher levels of traffic noise during demolition and construction is 5 years (so the term temporary is a misnomer used to justify prolonged period of time)– no detail of how it will be appropriately managed

  • CIS state “If blasting is required” and then proceeds to nominate a vague ‘blasting management plan’ with no detail on how personal amenity will be maintained for properties (and residents! – CIS fails to include these stakeholders in its commentary) making it impossible to objectively assess how it will be managed in any effective manner

  • CIS does not provide any details or specific measures on how impacts of vibration and regenerated noise exceeding performance requirements will be managed:

  • What actions will real-time monitoring make available to residents and business owners?What are noise amelioration measures?What is the timeframe and process for enacting these measures in a manner that is acceptable to the impacted parties? How will vibration and regenerated noise levels be measured for residences in the vicinity during construction? Will all properties within a certain radius be provided with noise and vibration monitors?  We suggest that they should be.  What actions will be undertaken and assurance given prior to commencement if structural damage occurs to homes in the surrounding areas (susceptible to movement) as a result of the disturbances that the project will cause?

  • Noise barriers of 4.5m not discussed in terms of impact natural light, neighbourhood character, heritage overlay and community amenity

  • CIS claims there will be “reduction in traffic noise due to lower traffic volumes on Alexandra Parade” – What is the evidence of this assertion? What about increased noise from heavy freight and truck traffic along the Eastern Freeway into the tunnel portal?

  • Noise policy not applied to recreational land use (according to VIcRoads) so no mitigation of noise near Yarra Bend Park –public amenity to be violated and ignored

Precinct 2:

  • CIS does not confirm location of ventilation stack housed in a ‘building’ fabric – to be confirmed by contractor – which means CIS does not comprehensively address noise impacts at this stage of the process for appropriate commentary by stakeholders

  • CIS downplays impact of tunnel construction methodology on vibration and noise levels by claiming it has ‘potential ‘ to generate such impacts, and then offers no detail on acceptable mitigation measures which renders the entire analysis meaningless

  • CIS claims contractor will need to consider ‘alternative construction methods’ for tunnel under cemetery – Why are these alternatives not outlined in the CIS so that thorough analysis can occur?

Precinct 3 (Royal Park, Parkville West, Moonee Ponds Creek, Travencore, Flemington)

  • CIS analysis of vibration and noise impacts due to Elliot Avenue works based on use of road header excavation – Fails to address whether contractor has option for alternative methodology and what they might be

  • CIS fails to address what appropriate vibration levels will be in mitigating impacts on animals at Melbourne Zoo so there is no scope to respond in an informed way to management measures as none are stated in CIS and, instead, will be determined by contractor – When will community and stakeholders be able to respond to the appropriateness of measures proposed for implementation by contractor?

  • CIS proposes “indicative noise mitigation measures as including relocated noise barriers up to 8 metres high on the Travancore side, and four metres high on the east side (Parkville West) to reduce combined noise to 63dB or less” without adequate assessment of impact on natural light, neighbourhood character, heritage overlay and community amenity.  CIS provides no detailed maps to show extent and alignment of noise barrier walls.

  • CIS acts as an advisory document for the contractor with no evidence, justification or assurance that the commercially driven contractor ‘must’ rather than ‘should’ implement noise mitigation for the proposed project

  • CIS claims there are no ‘sensitive receptors located within 200 metres of the limit of the works at Elliott Avenue’ that will experience noise impacts over 68db.  200m radius is meaningless if it overrides impact on Zoo animals

  • CIS states “There would be some increase in local traffic noise on Elliott Avenue near the project ramps.” – no measures proposed describing how this will be managed at a sensitive site

  • The CIS states “Predicted noise levels in Ross Straw Field are typically 60 – 65 dB LA10(18h) and up to 70 dB near the portals. This may limit the use of this section of Royal Park to noise-tolerant activities such as running or cycling.” (Chapter 12, p24)  There is no indication that of appropriate measures for noise mitigation or the fact that enormous areas of Royal Park will be unsuitable for ‘noise-intolerant’ activities such as passive, recreational walking, bird-watching, talking, playing as well as formal sporting activities

Precinct 4:

  • CIS claims “Only a small portion of Precinct 4 just north of Brunswick Road would be affected by noise from the project, as this is the most northerly extent of any new road structures being proposed.” (Chapter 12, p25).  This is inaccurate and superseded by proposed changes to the reference design at Ormond Road.

  • CIS states “Some residences and Ormond Park are currently affected by high noise levels from CityLink. It is expected that the operation of the project would only marginally increase noise levels in these locations.”  What does this mean for noise mitigation measures for nearby residences?  Are they deemed irrelevant to properties in this area?  Who decides what is acceptable?

  • CIS states “The CityLink Concession Deed does not provide for protection of recreational open space and it is not proposed to mitigate noise in this area with the construction of the project.” (Chapter 12, p25)”  Why is this relevant to the proposed works?  Why are noise impacts not assessed according to the impacts relevant to the implementation proposed project?  Why is this given credence to the scope of the proposed EWL and its impacts?  Meaningless assertion.

Air Pollution

There is no baseline monitoring of air quality before the project commences so can there be meaningful comparison?

·         Should the contractor be tasked with deciding what measures will be taken to maintain reasonable air quality?

·         Why has data from Alphington been used when traffic there is quite different in type and scale to that using the proposed tunnel?

·         Why have only selected pollutants and particulates been mentioned in this section? For example, there is no mention of the highly dangerous PM 2.5s

·         There is no mention of addressing air quality levels near the Clifton Hill Primary School and the Royal Children’s Hospital, despite their proximity to the ventilation structures

·         What are “acceptable levels of dust during construction? How will the effects of this pollution be mitigated?

·         There is no reference to the use of technology, either in the proposed tunnel itself or in the vent stacks, to deal with the noxious substances emitted from the accumulated vehicle exhausts.

·         How high will the vent stacks be?

·         Will the proposed 2 vent stacks mean that emissions are concentrated to unhealthy levels? Does this project need more ventilation if it is to proceed without endangering nearby residents and others who spend time in the area?

·         Should so many decisions affecting public health (ventilation technology, height of the stacks and their location) be left to the company contracted to build the road? Shouldn’t the Victorian Government set benchmarks to protect Victorians?3