Works Approval Application

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Summary of document

Overview

North East Link is a proposed new freeway standard road connection that would complete the missing link in Melbourne’s metropolitan ring road, giving the city a fully completed orbital connection for the first time. North East Link would connect the M80 Ring Road (otherwise known as the Metropolitan Ring Road) to the Eastern Freeway, and include upgrades to the Eastern Freeway. The project would also support the provision of a range of complementary and associated works, separate from the project. The project includes twin tunnels with associated tunnel ventilation systems. The tunnel ventilation system would include two ventilation structures located in the vicinity of the northern portal, located at Blamey Road, and the southern tunnel portal, located south of the Veneto club. The emergency smoke exhaust system would consist of exhaust points at the northern and southern portals as well as an emergency smoke discharge structure at the Manningham Road Interchange.

The Scheduled Premises Regulations under the Environment Protection Act 1970 (EP Act) specify that road tunnel ventilation systems are scheduled activities under Schedule 1, L03 of the regulations. Therefore, a Works Approval is required prior to the construction of the North East Link tunnel ventilation system.

It should be noted that this Works Approval Application is limited specifically to the approval of the tunnel ventilation system. A Works Approval from EPA Victoria is not required for the other elements of the reference project.

The Minister for Planning has determined that an Environment Effects Statement (EES) is required for North East Link. The project would be delivered in line with the Environmental Performance Requirements (EPRs) developed and exhibited as part of the EES. A number of these EPRs are relevant to this Works Approval Application as they relate to the tunnel ventilation system. This performance-based approach aims to achieve acceptable outcomes for the community and environment, while providing a delivery model with sufficient flexibility to encourage innovation and address specific challenges and issues.

Project definition

The project definition for North East Link includes the following key concepts:

  • Environmental Performance Requirements
  • Reference Project
  • Variations.

Influenced by the environmental assessments undertaken, EPRs have been developed to satisfy environmental standards and any other requirements for the construction and operation of the project contained in legislation, policy or the scoping requirements.

The Reference Project is a concept design that demonstrates a feasible way for the project to achieve the Victorian Government’s objectives and the EPRs. It has been used in this Works Approval Application to demonstrate the project’s feasibility and ability to achieve acceptable outcomes. It provides a basis for assessing the expected potential environmental risks and impacts, while recognising that the project could be configured differently.

The Reference Project may not be the design ultimately adopted for the project. Firms tendering to construct and/or operate the project may offer variations to its scope, design or route alignment that deliver better value for money or that incorporate innovative approaches in design, technology operations or financial structuring that are not considered in the Works Approval Application. However, these variations would need to comply with the conditions on any applicable Works Approval decisions and the EPRs set out in the EES.

The final detailed design of the ventilation system, prepared by the successful tender would be subject to EPA’s review to assess compliance against the EPRs and the conditions of the specific project approvals.

Relevant environmental considerations

The Works Approval Application considers the following key environmental aspects with regard to the tunnel ventilation system:

  • greenhouse gas emissions
  • air quality
  • noise and vibration
  • climate change.

The Works Approval Application also provides a detailed discussion to demonstrate that the proposed project reflects best practice.

Other environmental aspects such as surface water, groundwater, land and waste would be considered as part of the EES as they are not related to the tunnel ventilation system which is the subject of this Works Approval Application. Similarly, greenhouse gas emissions, air quality, noise and vibration and climate change impacts associated with the project both including and beyond the tunnel ventilation system are considered as part of the EES.

Stakeholder and community engagement

A wide range of engagement activities and communication tools have been used to support engagement on North East Link and to provide the best opportunities for stakeholders and the community to be involved in the consultation process.

The stakeholder and community responses which are specific to the ventilation system include concerns about visual impacts, emissions and air quality and noise impacts in the immediate and surrounding areas which include residences, schools community clubs and facilities, parklands, wetlands and a retirement village.

The feedback received from the community and stakeholders throughout the engagement process directly informed the investigations undertaken by technical specialists for the project and design development for the Reference Project.

Land use planning

The northern ventilation structure is located on Commonwealth Land, which is not subject to the provisions of Victoria planning schemes. The emergency smoke discharge structure and southern ventilation structure are located on land within the municipality of Manningham and are subject to the Manningham Planning Scheme. A range of planning provisions and potential planning permit requirements are associated with the tunnel ventilation structures.

Based on the strategic significance of the project, a planning scheme amendment is considered to be the most appropriate approval mechanism to facilitate the use and development of land for North East Link in an integrated and consistent manner across all affected planning schemes.

Forming part of the suite of documents which comprise the draft planning scheme amendment are an Incorporated Document and associated Specific Controls Overlay (SCO) which introduce project-specific planning controls. An Incorporated Document is a commonly used planning approvals tool in major Victorian transport (and other) infrastructure projects which has the effect of ‘switching off’ permit triggers subject to the project meeting a range of specified conditions. The planning scheme amendment also proposes the introduction of a Design and Development Overlay (DDO) that would be applied to the tunnel alignment to protect tunnel infrastructure assets from incompatible development.

Application of best practice

Sources of emissions or discharges to the environment must be managed in accordance with ‘best practice’ as set out in the relevant State Environment Protection Policies (SEPPs).

In determining what constitutes best practice for a certain activity or industry sector, EPA Publication 1517.1 puts forward the defining elements of best practice to be considered when interpreting requirements and provides guidance on how to demonstrate compliance with these elements of best practice.

All of the relevant defining best practice elements from the EPA publication 1517.1 have been addressed for the proposed project. This includes the use of preventative measures for environmental management through an environmental risk assessment and the development of EPRs, undertaking all practicable measures with regard to proportionality and cost-effectiveness, and the consideration of local and international evidence of best practice measures in similar projects.

Climate change

To assess the climate change risks relevant to North East Link, including the potential impact of climate change on tunnel ventilation, and potential adaptation measures for risks considered high and significant, a Climate Risk Workshop (the workshop) was held. The workshop brought together 25 North East Link Project and Technical Adviser personnel working across the project.

The most significant climate risks identified with a potential to impact on tunnel ventilation systems were power failure in the tunnels due to extreme heat or wind, rendering the ventilation system inoperable and potential damage to ventilation structures from extreme rainfall. Adaptation measures have been considered to reduce the impact of both these risks. They include both design considerations and future contingencies. As the project moves through to detailed design there may be an opportunity to also consider adaptation measures for medium and low risks.

Greenhouse gas and energy use

An assessment of greenhouse gas emissions and energy use for the North East Link tunnel ventilation system was conducted. Factors and methods used to estimate emissions were taken from the National Greenhouse Accounts Factors 2018 (NGA Factors) and the National Greenhouse and Energy Reporting Measurement Determination (NGER Measurement Determination). These are recognised nationally as guidance documents in the development of greenhouse gas inventories.

For the purpose of the Works Approval Application, the greenhouse gas assessment was required to consider the energy use and greenhouse gas emissions associated with the scheduled activity, the operation of the tunnel ventilation system. Emissions from some other activities associated with the operation of the tunnels such as lighting, dewatering and the operation of signs were also included in the greenhouse gas assessment. Other activities such as maintenance activities and embodied emissions in raw materials were assessed but are not included in the scope of the Works Approval Application as they do not relate to the operation of the ventilation system.

The assessment results indicate that the operation of the ventilation system would generate 74 kt CO2-e per annum of scope two emissions and 7 kt CO2-e per annum of scope three emissions. These emissions are generated through the consumption of electricity.

It is noted that this represents the maximum operational emissions associated with the tunnel ventilation system. It is anticipated that actual emissions would be reduced through the application of best practice as outlined in the EPRs.

In previous similar projects, EPA has applied approval conditions to account for possible changes made by the successful tenderer to the design. For example, in relation to greenhouse gas and energy use, Works Approval conditions of the West Gate Tunnel have required that:

“Before commencing construction of the following components of the works, you must provide to EPA a report or reports with the plans and specifications of those components, including details of: … (d) the tunnel ventilation and lighting systems, showing compliance with best practice requirements of the Protocol for Environmental Management ‘Greenhouse Gas Emissions and Energy Efficiency in Industry’ …”

It is anticipated that the conditions of approval for the North East Link tunnel ventilation system would include a similar provision.

As such, an updated evaluation of best practice would be undertaken during the detailed design phase to confirm that the contractor’s design meets the requirements of the Protocol for Environmental Management ‘Greenhouse Gas Emissions and Energy Efficiency in Industry’.

Air quality

An air quality assessment for North East Link tunnel ventilation system was conducted. The operational impact of emissions to air was assessed using the approved regulatory model AERMOD for the tunnel ventilation structures. The model inputs were characterised by using traffic modelling data and converting this information to total emissions with reference to vehicle emissions factors developed from the COPERT Australia road transport air pollutant emission inventory model and 2020 future year factors from PIARC. Three uniform Cartesian receptor grids were used with all gridded receptor points input at ground level. An additional 191 sensitive receptors were modelled based on those identified in the EES social impact assessment.

Emissions from the tunnel ventilation structures were shown to comply with relevant air quality criteria for normal operation. While PM2.5 and PM10 exceeded air quality criteria, this was determined to be a result of high background concentrations, with the tunnel ventilation structures making a small contribution to ground level concentrations.

Sensitivity analysis was conducted based on the following scenarios:

  • maximum lane capacity, 24 hours per day, 365 days per year
  • emissions at in-tunnel air quality limits
  • increased diesel to petrol fuelled car ratios – doubled portion of diesel fuelled cars
  • alternative ventilation structure locations in the immediate vicinity of the reference project location
  • 2025 future year adjusted vehicle emission rates.

Sensitivity analyses demonstrated no change in compliance for the scenarios modelled. The use of conservative assumptions around traffic forecasts and air modelling means that the predicted ground level pollutant concentrations and associated air quality impacts in the report are likely to be overestimated.
In previous similar projects, EPA has applied approval conditions to account for possible changes made by the successful tenderer to the design. For example, in relation to air quality, Works Approval conditions of the West Gate Tunnel have required that:

“Before commencing construction of the following components of the works, you must provide to EPA a report or reports with the plans and specifications of those components, including details of: (a) the tunnel ventilation system and exhaust stacks, showing measures to be taken to ensure compliance with State environment protection policy (Air Quality Management) and ensure impacts are equivalent to or less than the Reference Project assessed for this Works Approval; …”

It is anticipated that the conditions of approval for the North East Link tunnel ventilation system would include a similar provision.

As such, further air quality assessment is likely to be required during the detailed design phase to confirm that the contractor’s design, including the final location of ventilation structures, is compliant with the relevant air quality criteria.

An air quality monitoring plan has been developed for ambient air quality post project completion, continuous emission monitoring from ventilation structures, ventilation structure verification testing, and in-tunnel air quality monitoring.

Noise and vibration

A noise and vibration assessment for the reference project North East Link tunnel ventilation system was conducted. The potential noise and vibration impacts during operation, including operation of the tunnel ventilation system, were assessed. Technical investigations were undertaken to determine the existing environmental conditions and background noise levels by undertaking attended and unattended noise monitoring.

Modelling predicts that the noise from the ventilation system with the proposed silencers would comply with the requirements of State Environment Protection Policy (Control of Noise from Commerce, Industry and Trade) No. N-1 (SEPP N-1). SEPP N-1 provides for the establishment of noise limits based on background noise levels.

It was concluded that tunnel ventilation noise can achieve compliance with SEPP N-1 through conventional means such as selection of suitable equipment and attenuation measures.
In previous similar projects, EPA has applied approval conditions to account for possible changes made by the successful tenderer to the design. For example, in relation to noise, Works Approval conditions of the West Gate Tunnel have required that:

“Before commencing construction of the following components of the works, you must provide to EPA a report or reports with the plans and specifications of those components, including details of: … (d) the tunnel ventilation system, showing measures to be taken to ensure compliance with the State environment protection policy (Control of Noise from Commerce, Industry and Trade) No. N-1”

It is anticipated that the conditions of approval for the North East Link tunnel ventilation system would include a similar provision.

As such, additional noise modelling would be undertaken during the detailed design phase to confirm that the contractor’s design is compliant the SEPP N-1 requirements. Noise monitoring would be conducted post commissioning of the ventilation system to demonstrate operational compliance with SEPP N-1 requirements.

Environmental management

North East Link environmental impacts during construction and operation would be managed in accordance with the North East Link Project Environmental Management Framework (EMF), incorporating EPRs. Contractors would be required to develop environmental management documents including a Construction Environmental Management Plan (CEMP), an Operation Environmental Management Plan (OEMP) and Worksite Environmental Management Plans (WEMPs) that address potential environmental impacts and requirements of the EMF, including EPRs.

More information about the EES can be found in the planning section of the website.