Environmental management framework

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9. Environmental management framework - Department of Planning and Community Development The Minister for Planning has issued Terms of Reference, under which the Assessment Committee will assess the CIS and submissions in response.

Extract: (7) Terms of Reference: Conduct a Public Hearing, in accordance with Division 2 of Part 8 of the Act, to hear properly made submissions confined to the following matters.

(7) (i) Whether the Environmental Management Framework in the CIS will provide an effective integrated approach to manage the environmental performance of the project.


EWL CIS documents for reference

All CIS documents


The Environmental Management Framework (EMF) provides a transparent, effective and accountable means of managing environmental aspects of the project. The EMF outlines the environmental management governance for implementing the performance requirements for the project, as well as requirements for the Environmental Management System (EMS) and environmental management plans (EMPs) to be adopted by the contractor. The project would be delivered in line with the performance requirements developed and exhibited as part of the CIS and any approval conditions set by the Minister for Planning. Adherence to the performance requirements would be achieved through the EMF. Compliance with the EMF by the contractor would be a requirement of the contractual arrangements entered into with the State. This chapter presents the EMF that would be adopted for the project. The EMF outlines the overarching environmental management governance for implementing the performance requirements throughout the delivery of the project and describes requirements for:

  • Governance, including roles and responsibilities (Section 17.1)
  • Risk and impact assessment (Section 17.2) *Performance requirements (Section 17.3)
  • Environmental management documentation (Section 17.4)
  • Performance management (Section 17.5).

Environmental management framework draft submission notes

  • Dangers to shared road users (pedestrians, cars, cyclists) local streets from tipper trucks and heavy machinery during and after construction.
  • Damage to local streets local streets from tipper trucks and heavy machinery during and after construction.
  • Increased rat running from vehicles taking alternative routes during and after construction.

Can a road tunnel reduce air pollution?

Attendees at the Linking Melbourne information sessions were told that the tunnel will reduce air pollution. This is an argument often used by the road lobby.

The argument is that by taking cars of congested roads and putting them in free flowing tunnels, there will be less pollution. Furthermore, the ventilation in the tunnel pushes the pollution up the vent stacks and away from the road, bringing further benefits. Cars travelling at a constant 50km/hr do emit slightly less pollution that cars that are idling, and the mixture of pollutants is different. And vent stacks do push a lot of pollution higher into the ‘air shed’, where it has a better opportunity to be dumped somewhere else or dispersed. Also, car emissions are improving, as the fleet is renewed with stricter emission controls.

Residents Against the Tunnel - Environmental Management Framework

Here are some suggestions for the sort of things you might like to include about The Environmental Management Framework in your submissions to the CIS Assessment Panel due 12 December 2013:

(i) Whether the Environmental Management Framework in the CIS will provide an effective integrated approach to manage the environmental performance of the project. CIS Chapter 17 describes how the LMA will ensure that the contractor is meeting performance requirements. This is the Environmental Management Framework (EMF).

1. The EMF is intended to provide “Transparent, effective and accountable means of managing the environmental aspects of the project” (Chapter 17, p1).

It is difficult to understand how the process proposed in any way meets the transparent, effective and accountable requirements that it sets for itself. The entire process is set up and run by a closed group of the proponent (the Government), the delivery agency (the LMA) and the contractor with no genuine independent oversight apparent. Given that many environmental impacts are permanent and cannot be undone it is surely essential that the review process be strong, independent and immediate, preferably reviewing actions before they are taken where they cannot be undone. The proposed requirement for monthly reports (Section 15.5.1, p31) to include forward looking reporting on the proposed actions for the coming month is a good start but it needs to be provided to a genuinely independent reviewer.

2. The EMF proposed does not provide any requirement for publication of:

  • the Environmental Management Plans developed by the contractor and approved by the Minister;
  • detailed risk assessments developed by the contractor;
  • compliance reports by the contractor, in particular notifications of non-compliance;
  • reports by regulators and agencies in respect of any non-compliance by the contractor;
  • audit results;
  • reviews or reports by the Independent Reviewer in relation to contractor’s compliance with the EMF; or
  • LMA advice, particularly in relation to any amendments deemed necessary for the construction EMP.

As the Victorian public has so far been denied access to the critical information underpinning the business case for the project, it is to be expected that these shortcomings will be reinforced by future commercial confidentialities that are placed around the project.

3. The CIS fails to specify the remedies, sanctions or compensation mechanisms that will be available to the LMA, Government or wider community in the event of EMF requirement breaches. This means that, except where any breach falls under a sanction provided for under an applicable legislative requirement, there is little incentive for the contractor to avoid such a breach in the future. It also means that the public is denied any assurance that its interests are being considered – interests that could significantly impact health, quality of life, safety, etc

4. Community consultation as defined in Chapter 17, section 17.1.1. The LMA has responsibility to“Conduct stakeholder engagement and community consultation activities (the contractor would be responsible for for community and stakeholder consultation arising from construction and operation activities)(Table 17-1). The contractor has responsibility to: “Consult with the community and stakeholders in relation to construction and operation activities.”

In light of the community engagement and consultation conducted by the LMA to date, which has been superficial and meaningless, this is clearly an inadequate requirement. LMA have provided information and promotional material only. Meaningful engagement and consultation require seeking participation, feedback and input and then responding to it.

The EMF should be rewritten prior to commencement of the proposed project to include specific requirements for both the LMA and the contractor to actively engage the community in consultation, both prior to and after construction has commenced and to report publicly on the matters raised and the proposed responses to them.

The requirement for consultation should set out that the community must be properly consulted about, in addition to construction and operation activities, the Design Framework, any changes and amendments to the Design Framework, any non-compliance with the EMF, and any variations to the scope of works.

The EMF should also include the requirement for such consultation to take place on a regular basis, say monthly, and be widely publicised so that the community is aware of and can attend these consultations. Matters raised and proposed response to them should also be required to published within a specified and short time after each consultation.

Media References

Pollution Threats - July 17th, 2013The Age: East-west link prompts fears for primary school (July 17 2013) Parents and teachers fear Clifton Hill Primary School could be forced to relocate during construction of the east-west link road tunnel due to noise, ground vibrations and pollution. They have also raised concerns about the tunnel’s ventilation station, which could be located a block away from the historic school.

Principal Geoffrey Warren said he was worried the school would have to move during the project’s construction. ”It would have a significant impact. What we don’t know is if that means forever or a temporary removal.”

An entire row of mainly commercial properties on the northern side of Alexandra Parade is set to be bulldozed – further exposing the 130-year-old school to the massive construction site. Toxic DumpWorkmen on the corner of Queens Pde and Alexandra Parade,The former Gasworks is visible in the background The Linking Melbourne plans show another danger for the locals. The tunnel will bore directly under the most highly contaminated part of the former Fitzroy North Gasworks.

This 6 Ha site bounded by Alexandra Parade, Smith St, George St and Queens Parade, is so contaminated that nothing can be built there. The contamination is believed to be kept in check underground by a concrete capping on the site. Plans show the tunnel will likely disrupt the toxic plume, risking a leak into the Merri Creek via the main drain under Alexandra Parade.

Near-roadway air pollution a major contributor to L.A. asthma September 26th, 2012 Research conducted at the University of Southern California (USC) indicates that at least 8 percent of the more than 300,000 cases of childhood asthma in Los Angeles County can be attributed to traffic-related pollution at homes within 75 meters (a little less than 250 feet) of a busy roadway. The study also indicates that previous estimates of childhood asthma exacerbation related to air pollution may have underestimated the true burden of exposure on society. The research was published online Sept. 24, 2012, in Environmental Health Perspectives and was conducted in collaboration with the Swiss Tropical and Public Health Institute and Sonoma Technology, Inc. The study focused on the Los Angeles basin.