Noise, vibration, air emissions and light spill

From YCAT: East West Link Comprehensive Impact Statement Submission
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4. Noise, vibration, air emissions and light spill - 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) (d) Whether the noise, vibration, air emission and light spill impacts of the project will be appropriately managed by proposed measures.


EWL CIS documents for reference

All CIS documents

Draft notes

Extract: This report assesses the potential noise and vibration impacts and benefits of the proposed East West Link – Eastern Section to inform the Comprehensive Impact Statement (CIS). It focuses on the potential noise and vibration impacts during the project’s construction and the potential noise impacts and benefits once the project is operating.

As noise impacts are predicted to impact the study area only, no regional assessment of noise impacts was undertaken. The relevant Applicable Approval under the Major Transport Projects Facilitation Act 2009 is a Works Approval under Section 19B of the Environmental Protection Act 1970 for the tunnel ventilation system air and noise emissions.

Possible project impacts

The proposed East West Link – Eastern Section is located in a highly urbanised environment that already features high to very high levels of traffic and other noise. Construction of the project has potential to increase noise in the study area for the duration of construction activities. Once operating, the project could reduce traffic noise in some areas and would increase it in other locations.

Air Pollution

Air Pollution in the district is currently very bad. Not so bad that international standards are broken - but what does 'international standard' really mean when it comes to air pollution - are they more or less stringent than Australian standards? Are they the same standards used in China?

The Linking Melbourne CIS asserts air pollution will be improved due to faster speeds and the vent stacks dispersing the toxins further into the heavily populated community. However this assertion is based on the assumptions built into the questionable traffic modelling. This predicts that Alexandra Parade and "local streets" will have less traffic, but there is no plan to reduce lanes on Alexandra Parade, or even to provide a bus service. If the tunnel was merely diverting traffic from the surface and not inducing new traffic, why the need to widen the freeway?

Getting any actual measurements of the current air pollution is restricted by the EPA. Even Gold Street Primary can't get data on what the air quality is like. They can only guess by wiping the grime off their window ledges. If this was a wind turbine proposal we would be getting an automatic 2km buffer for health concerns. Unfortunately roads do produce real pollution and it does have a real and measurable health impact on populations. Air Pollution particularly impacts people in lower socio-economic groups. Unfortunately these are concentrated close to major roads. One day, a premier will apologise for what the road lobby inflicted on this population.

The location of the vent stack close the Gold Street Primary School should not be supported.

The very high flyover from Hoddle Street above the train line will add to both pollution and noise in the valley due to the change in grade.

Hoddle St Existing Conditions Report Summary This report includes data or air pollution close to Hoddle Street Collingwood. There is no PM2.5 data (soot). EPA would not permit release of data except for 2008. NO2 is approaching SEPP intervention levels.

Senate Committee on Impacts on health of air quality in Australia

The NEPC Review argued that an exposure reduction framework would be to reduce exposure for communities living in close proximity to large emission sources: Under the current monitoring protocol in the NEPM, people who live near major sources of pollution such as roads do not have air quality monitoring data and are likely to be exposed to higher levels of air pollution than that measured at performance monitoring stations. The exposure reduction approach would drive improvements in air quality across the whole population and not focus on meeting standards at the designated monitoring stations.- Citing National Environmental Protection Council, Ambient Air Quality NEPM Review, Adelaide, 2011, p. 29.

There appears to be significant merit and across-the-board stakeholder support for an exposure reduction framework…the air quality standards do not provide absolute protection and any reduction in exposure will have a net positive health benefit. The introduction of an exposure reduction approach will align Australian air quality management policy with international best practice approaches - Citing National Environmental Protection Council, Ambient Air Quality NEPM Review, Adelaide, 2011, p. 19.

Committee view 3.20 As the previous chapter showed, there is no safe level for exposure to most pollutants, and as was explained above, some pollutants that were previously thought to have threshold effects are now deemed to have no safe limit. This evidence, along with the findings of the NEPC Review, indicates that the exposure reduction model is the best approach to protect human health from harmful air pollutants. The committee notes the efforts of governments around Australia to move towards the exposure reduction approach to ensure the health of all Australians is adequately protected.

Determining potential population health risk resulting from ambient air quality exposure has been complicated by the fact that epidemiology studies are now indicating there is no clear threshold for effect for the current NEPM pollutants, with exposures below the standards still representing a statistically significant and measurable health risk to the Australia population…when the NEPM was made it was thought sulfur dioxide and carbon monoxide had an identified threshold effect, and nitrogen dioxide and lead had an apparent threshold effect. - National Environmental Protection Council, Ambient Air Quality NEPM Review, Adelaide, 2011, p. 14.

"Monitoring was not designed to measure the variability in pollutant levels within a specific airshed. As a consequence, the air monitoring that is undertaken under the current [NEPM] is likely to significantly underestimate real-life exposures for many sections of the population." - Australian Medical Association, Submission 114, p. 11

"3.50 As a result of the use of ambient standards, the committee heard that many communities that are collocated with industrial sites, mines, or major transport routes and infrastructure are being exposed to air quality that does not meet the NEPM standard's object of protecting health, and that currently 'monitoring of pollution and health impacts locally is unsatisfactory and a cause for concern among the local community.'

Recommendation 4 3.68 The committee recommends that pollution monitoring should accurately capture population exposure for communities and homes proximate to pollution point sources.

Recommendation 5 3.69 The committee recommends that providing monitoring and real-time data of air quality be a condition of environmental approvals issued by the Australian Government unless an operator can demonstrate that air pollution created by the development will not impact upon human health.

Health Impacts

Long-term particulate matter exposure and mortality: a review of European epidemiological studies

[ Health Effects of Particulate Air Pollution Douglas W. Dockery] the Environmental Protection Agency reported “Inhalation of fine particles is causally associated with premature death at concentrations near those experienced by most Americans on a daily basis".

Studies Show Exposure to Diesel Exhaust May Increase Lung Cancer Mortality The New England Jounral of Medicine 2007, 357, 11: pp1075-82 Journal of the National Cancer Insitute see

Noise Pollution

"Existing noise walls are of poor quality" - CIS Technical Appendix C pg 24 (Urban Design)

Extract from Yarra CIS forum: Summary of table comments from info session – 7 Nov 2013 (pdf)

  • Noise during construction – Lots of trucks during construction and there will be more trucks when it is finished. That’s why it is being built – for the trucks.
  • Impact on individual homes/ lifestyle
  • Noise, pollution, vibration, commercial impacts, destruction of local neighbourhood community facilities, local school, removal of bridge, impact on local pedestrian connectivity, local services, negative impact on well-beings
  • Noise from traffic on flyover – need protective shield like Flemington
  • During construction over several years
  • Noise from construction over 5 years – too noisy, lack of sleep
  • Animals affected as well
  • Major concern during and after construction. We need condition and independent reports, not from LMA. Again it’s for evidence for future impacts on properties.
  • Noise/ vibration impacts on Gold Street during construction and ongoing – possible damage to Shot Tower.
  • Noise/ visual amenity – flyovers, noise will proliferate. Sound barriers to mitigate noise where possible
  • Ongoing impact of construction – noise, vibration and air emissions, impact on environment
  • Exhaust fans cause health issues and noise * Acoustic impact during construction and after completion - noise inside homes and businesses
  • The Zoo – impact on factors such as noise, pollution, vibration
  • Increased noise pollution – no clarity around sound barriers

Impact on lifestyle

  • Working in Collingwood at the North Yarra Community Health Centre
    • Concerns about accessibility to NYCH
    • Noise, pollution and access for patients
    • Alternative centre is in Carlton


Light Spill

Feature Lighting of the Eastern Gateway tower

Impact on Residents

  • Impact on Darling Gardens (200m from gardens)
  • Impact on wildlife - Yarra Bend Park (250m from park)
  • Impact on wildlife - remnant vegetation near end of Eastern Freeway.

Residents Against the Tunnel - 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?

Media References

Melbourne residents face 5-year Link build. October 31, 2013 Residents near Melbourne's East West Link face a five-year construction nightmare, but the road will reduce traffic volumes on inner city streets, an impact statement has found.

A total of 105 homes and 34 commercial properties will be acquired to make way for the road, which will connect the end of the Eastern Freeway to Citylink. The iconic Royal Park will also be affected with 1.36 hectares to be lost. The road, which is expected to carry 100,000 vehicles a day by 2031, will reduce traffic volumes on some of the city's major roads including Hoddle Street and Victoria Parade, a comprehensive impact statement, released on Thursday, shows. Traffic volumes would increase on those roads without East West Link. Overall East West Link is forecast to reduce peak travel times between east and west by up to 20 minutes. The impact statement also acknowledged the significant effect the road will have on residents, despite the fact that they will be compensated. It said the greatest impacts on residents will be felt around the interchange with Hoddle St and the interchange with Citylink where homes will be acquired. The tunnel will also create a risk of disturbing contaminated ground water, the report said.

East-west link prompts fears for primary school, Henrietta Cook, The Age July 17, 2013

The east-west smog factory should never be built, The Age September 17th, 2013 From Brendan Gleeson, professor of urban policy studies and director of the Melbourne Sustainable Society Institute at Melbourne University.