North East Link Air Quality Assessment Review

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Banyule City Council, City of Boroondara and City of Whitehorse

North East Link Air Quality Assessment Review Expert Witness Statement

15 July 2019 Project No.: 0515333

www.erm.com Project No.: 0515333 Client: Banyule City Council, City of Boroondara and City of Whitehorse 15 July 2019

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Document title North East Link Air Quality Assessment Review

Document subtitle Expert Witness Statement

Project No. 0515333

Date 15 July 2019

Author Iain Cowan

Client Name Banyule City Council, City of Boroondara and City of Whitehorse

Document history

ERM approval to issue

Author Reviewed by Name Date Comments

Iain Cowan Partner in charge Damon Roddis 15.07.2019


Signature Page

11 July 2019

North East Link Air Quality Assessment Review Expert Witness Statement

Iain Cowan Air Quality Technical Director

Environmental Resources Management Australia Pty Ltd 99 King Street, Melbourne VIC 3008 © Copyright 2019 by ERM Worldwide Group Ltd and / or its affiliates (“ERM”).

All rights reserved. No part of this work may be reproduced or transmitted in any form,

or by any means, without the prior written permission of ERM.

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NORTH EAST LINK AIR QUALITY ASSESSMENT REVIEW Expert Witness Statement

CONTENTS

CONTENTS

1. PLANNING PANELS STATEMENT ............................................................................................ 1 1.1 Name and address ........................................................................................................................ 1 1.2 Qualifications, experience and areas of expertise ......................................................................... 1 1.3 Expertise in preparing this report ................................................................................................... 1 1.4 Relationship between the expert witness and the party for who the report is prepared ................. 1 1.5 Instructions that define the report .................................................................................................. 1 1.6 Facts, matters and all assumptions on which the report proceeds ................................................ 2 1.7 Referenced documents .................................................................................................................. 2 1.8 Identity and Qualifications of the person who carried out any tests or experiments upon which the

expert relied in making the report .................................................................................................. 2 1.9 Statement ...................................................................................................................................... 2 1.10 Declaration ..................................................................................................................................... 4

2. INTRODUCTION .......................................................................................................................... 5

3. REVIEW OF THE RELEVANT DOCUMENTS ............................................................................. 6 3.1 Main areas of concern ................................................................................................................... 6

3.1.1 Legislation and adopted standards ............................................................................... 6 3.1.2 Emission estimation ...................................................................................................... 9 3.1.3 Primary and secondary NO2 ....................................................................................... 13 3.1.4 Surface roads assessment ......................................................................................... 13 3.1.5 Combined impacts assessment .................................................................................. 13 3.1.6 Treatment of tunnel emissions .................................................................................... 14

3.2 Minor contentions ........................................................................................................................ 14 3.2.1 Dispersion model selection ......................................................................................... 14 3.2.2 Modelled roads ........................................................................................................... 15 3.2.3 Background data ......................................................................................................... 15 3.2.4 Noise Barriers ............................................................................................................. 15 3.2.5 Other species .............................................................................................................. 16 3.2.6 Tunnel portals emissions ............................................................................................ 16 3.2.7 Ambient air quality monitoring ..................................................................................... 16 3.2.8 In-tunnel air quality ...................................................................................................... 17

4. RESPONSE TO QUESTIONS POSED IN INSTRUCTIONS ..................................................... 18 4.1 Question 1 ................................................................................................................................... 18 4.2 Question 2 ................................................................................................................................... 18 4.3 Question 3 ................................................................................................................................... 19 4.4 Question 4 ................................................................................................................................... 19 4.5 Question 5 ................................................................................................................................... 19 4.6 Question 6 ................................................................................................................................... 20

5. ENVIRONMENTAL PERFORMANCE REQUIREMENTS ......................................................... 21

6. CONCLUSION ............................................................................................................................ 23

7. REFERENCES ........................................................................................................................... 25

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CONTENTS

List of Tables Table 3-1 Adopted and recommended criteria for surface roads or combination scenarios plus

background ......................................................................................................................... 8

List of Figures Figure 3-1 Speed curves for Euro 1 to 4 classes (Highways Agency, 2007) .................................. 10

APPENDIX A CURRICULUM VITAE APPENDIX B INSTRUCTIONS

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PLANNING PANELS STATEMENT

1. PLANNING PANELS STATEMENT

1. Dr. Iain Cowan of Environmental Resources Management Australia Pty Ltd (ERM) was instructed by Maddocks, acting on behalf of Banyule City Council (Banyule), City of Boroondara (Boroondara) and City of Whitehorse (Whitehorse), to prepare and present expert witness testimony to the Planning Panels Victoria (PPV) in relation to impact to ambient air quality impacts from the proposed North East Link development.

2. This statement is focussed on impacts from traffic emissions during operation of the project, as it is considered that any generation of dust during construction can be adequately managed through monitoring and mitigation.

1.1 Name and address 3. Dr. Iain Cowan

c/- Environmental Resources Management Level 6, 99 King Street MELBOURNE VICTORIA, 3000

1.2 Qualifications, experience and areas of expertise 4. Details of my qualifications, experience and areas of expertise are detailed in my curriculum

vitae which may be found in Appendix A.

1.3 Expertise in preparing this report 5. I have undertaken numerous studies over fifteen years in the field of atmospheric dispersion

modelling. This includes my doctorate which focussed on impacts to ambient air quality from traffic emissions and projects in relation to emissions from traffic. I prepared an expert witness statement for the independent inquiry and advisory committee on the West Gate Tunnel Project. My statement included the use of atmospheric dispersion modelling using the AERMOD dispersion model and emissions modelling using COPERT Australia. I am also currently an Independent Reviewer and Environmental Auditor for the West Gate Tunnel Project, and have undertaken updates to the air quality assessments for the WestConnex tunnels in Sydney following revision of the PIARC emission factors and gradient factors.

1.4 Relationship between the expert witness and the party for who the report is prepared 6. I am employed by Environmental Resources Management Australia Pty Ltd (ERM), who has a

commercial relationship for the provision of this expert witness statement with Banyule City Council, City of Boroondara and City of Whitehorse. This statement has been prepared independently of Banyule City Council, City of Boroondara and City of Whitehorse, and forms my opinion of the potential for impact related to ambient air quality associated with the North East Link.

1.5 Instructions that define the report 7. Copies of instructions received to prepare this report are included in Appendix B.




1.6 Facts, matters and all assumptions on which the report proceeds 8. The assessment relies on the following information:

Environment Effects Statement – Chapter 10 Air Quality;

Environment Effects Statement – Technical Report B Air quality;

Environment Effects Statement – Attachment VI Works Approval Application;

Environmental Effects Statement Map books (horizontal and vertical alignment plans and indicative cross sections).

1.7 Referenced documents 9. A list of documents referenced in this expert witness report may be found in Section 5 of this

statement.

1.8 Identity and Qualifications of the person who carried out any tests or experiments upon which the expert relied in making the report 10. No tests or experiments were undertaken in the preparation of this report.

1.9 Statement 11. Review of the documents listed in Section 1.6 indicates concern that Technical Report B has:

Not appropriately considered legislation and set assessment criteria appropriately for nitrogen dioxide and air toxics when considering surface road emissions;

Not appropriately considered the draft National Environment Protection Measure for Ambient Air Quality (NEPM (AAQ)) and how adoption of changes in the NEPM (AAQ) will necessitate change in acceptable standards in the future of nitrogen dioxide in Victoria prior to the opening of the project and whether these standards will be exceeded by the project;

Estimates of emissions are not conservative as:

- Real-world driving emissions are typically higher than those derived from laboratory tests which form the basis of the emission estimation. This is true for all road assessments from around the world, but the results of the assessment must be viewed in this context.

- The adopted vehicle speed for the tunnel was set within the assessment 80 km/hr at all times, with a sensitivity analysis for speeds at 40 km/hr. The EES Attachment VI Works Approval Application states that normal operations in tunnel are defined as traffic flowing with the average speed of 20 km/hr or greater. During peak periods, the vehicle speed may be lower than this where flow breaks down and congestion occurs, as is the case in other tunnels in Melbourne and Australia. It is considered that the assessment does not appropriately consider the change in vehicle speeds through the tunnel at different times of the day. Consequently, there is potential that the maximum impacts have not been assessed.

- Emissions from surface roads have been estimated assuming that the roads are at zero gradient (with the exception of the cutting at the northern end of the tunnel). It is stated within Technical Report B and shown within the map books that roads in the area have a gradient of up to 5%, at a 5% gradient, total emissions are up to 70% higher than at grade emissions, indicating there is a potential for under-estimation of impacts from the surface road network.




- Particulate emission estimates do not include resuspended dust. Studies have indicated that resuspended dust accounts for 58% of total emissions from vehicular traffic. In ignoring dust resuspension, total emissions of particulate matter have the potential to have been under-estimated by 100%.

- Technical Report B assumes that emissions in future will decrease as a result of a move to low emission and zero emission vehicles. Firstly, there is currently no policy setting for the phasing out of internal combustion engine vehicle sales in Australia and the time for replacement of the vehicle fleet in Australia is typically 20 years, compared to 10 years in the rest of the world. This means that the transformation is likely to be slower than is occurring in Europe. Secondly, the reduction of particulate matter emissions is likely not to occur. Tyre, brake and road wear as well as re-suspension of road dust account for 73% of emissions at the current time. Electric vehicles using current technology are heavier than conventional vehicles, due to the battery. The additional weight means greater tyre wear, road wear and resuspension however brake wear may be decreased due to regenerative braking systems used to recharge the battery. Overall, particulate emissions from zero emission vehicles are likely to be the same as estimated for current technology using the COPERT Australia1 model.

Technical Report B does not discuss whether the assessment has considered the conversion of NO released from the vehicles to NO2. Where this has not been undertaken there is an under estimation of the likely impacts of NO2, which when taken into account would likely exceed future standards.

When assessing surface roads and the cumulative assessment the time period corresponding to the maximum incremental contribution due to the surface road is selected and the background concentration from Alphington AAQMS added. This has the potential to under-estimate the impact from the surface road network when the background levels are already elevated and the roads only contribute a minor amount enough to cause additional exceedances of the standard. The potential risk of any additional exceedances has therefore not been considered by the assessment.

When assessing the combined impacts, there are a two of areas of concern:

- The assessment was completed at two receptors for which no scientific basis has been provided for the selection; and

- Assessment has been completed for 2016 as this was the worst year for surface road impacts, but the worst year for impacts from the stack was 2017 and 2016 has lower background concentrations than other years. Consequently, the total impact over a five year period may be under represented. Consequently, it is considered that the assessment should have been completed over five years.

Emission estimates for the sensitivity analyses appear to be higher than the in-tunnel emission limits, indicating that where the sensitivity analysis condition occurs, which is highly likely for the reduced speed scenario, the in-tunnel concentrations may have difficulty being met.

1 COPERT Australia is the result of a collaboration between EMISIA (the authors of the European vehicle emission database) and the Queensland Department of Science, Information Technology, Innovation and the Arts (DSITIA).




There is no allowance within the stack design for capability for retrofitting of treatment technology should it be required. It is recommended that space be provided for potential future treatment technology given that:

- Particulate emissions from roads are unlikely to decrease even with greater penetration of low and zero emission vehicles as the emissions from these vehicles are equal to the current emission estimates provided by COPERT Australia;

- Contribution from the tunnel stacks to ambient concentrations is projected in Technical Report B to be as high as 35 µg/m3 without accounting for conversion of NO to NO2, the surface road network and with current background concentrations reported as high as 130 µg/m3 in comparison to future 1 hour NO2 NEPM standard of 160 µg/m3 and a likely lower design criterion;

- Ambient criteria are being lowered as shown in the draft NEPM (AAQ), and the tunnel may need to respond to a need for lower impact than provided within the assessment.

12. Overall, it is considered that there is a high degree of uncertainty that the assessment accurately represents the impacts of the project to the surrounding land use and there is a high degree of likelihood that the assessment under-estimates that impact.

13. If the project is recommended to proceed, then I recommend modifications to existing and additional EPRs to address the inadequacies that have identified in this review.

1.10 Declaration 14. I have made all the inquiries that I believe are desirable and appropriate and that no matters

of significance, which I regard as relevant, have to my knowledge been withheld from the Committee.



INTRODUCTION

2. INTRODUCTION

15. Dr. Iain Cowan of Environmental Resources Management Australia Pty Ltd (ERM) has been instructed by Maddocks Lawyers Pty Ltd (Maddocks) on behalf of Banyule City Council (Banyule), City of Boroondara (Boroondara) and City of Whitehorse (Whitehorse) (collectively, the Councils) to provide expert evidence in the area of air quality in relation to the North East Link Project (Project).

16. In order to address the required scope of works, Dr. Iain Cowan undertook review of the following documents:

North East Link Environment Effects Statement – Chapter 10 Air Quality;

North East Link Environment Effects Statement – Technical Report B Air quality;

North East Link Environment Effects Statement – Attachment VI Works Approval Application; and

Environmental Effects Statement Map books (horizontal and vertical alignment plans and indicative cross sections).



REVIEW OF THE RELEVANT DOCUMENTS

3. REVIEW OF THE RELEVANT DOCUMENTS

17. The Technical Report B provides the details of the assessment undertaken in three parts through:

Use of air dispersion modelling techniques to assess the impacts of air emissions from the tunnel ventilation system;

Use of air dispersion modelling techniques to assess the base (no project) and project impacts of vehicle emissions on sensitive receptors adjacent to major surface roads, where the project is expected to cause significant changes to traffic volumes or fleet mix; and

Evaluating the combined impacts of background air quality and emissions from the tunnel ventilation system and surface roads at selected receptors in the receiving environment.

18. The reporting contained within this expert witness statement of the review of the evaluated documents has been completed by exception, meaning that only where there is concern to the approach used or the results presented are comments provided. The review of the Technical Report B identified a number of areas of concern within the assessment of the Project impacts, and as such the EES may not have adequately documented and assessed the nature and extent of the environmental effects of the Project.

3.1 Main areas of concern

3.1.1 Legislation and adopted standards

3.1.1.1 State Environment Protection Policies 19. For ambient air quality, two State Environment Protection Policies (SEPPs) exist:

SEPP for Ambient Air Quality (SEPP (AAQ)); and

SEPP for Air Quality Management (SEPP (AQM)).

20. The SEPP (AAQ) provides the statutory requirement for measurement and reporting by the Environment Protection Authority, to provide assessment against the National Ambient Air Quality NEPM, which has no basis in national legislation, but which requires legislation at a state level to enable participation alongside other states and territories.

21. The SEPP (AQM) provides the statutory requirements for emission sources in Victoria. The intent is that compliance of emission sources with the requirements of the SEPP (AQM), will result in compliance within the wider air shed with the SEPP (AAQ) and hence Victoria will be in compliance with the Ambient Air NEPM.

22. In setting the adopted standards for surface roads, the EES has implemented the criteria contained in the SEPP (AAQ) and not the SEPP (AQM). It is considered that with the exception of criteria for particulate matter, criteria for the surface roads should be adopted from the design criteria contained in Schedule A of the SEPP (AQM) as:

Schedule A of the SEPP (AQM) states that:

- “This schedule prescribes the Class 1, 2 and 3 indicators and their design criteria referred to in Clause 10 of this Policy. These criteria are to be used in the assessment of the design of new or expanded sources of emissions such as industrial premises. They are to be used in conjunction with the modelling procedures outlined in Schedule C of this Policy”.




Schedule C, Part C, Section 2a states that:

- “The predicted maximum concentration as defined in Part C1 of this schedule must not exceed the design criterion for the relevant pollutant listed in schedule A”.

Schedule C, Part C, Section 2b states that:

- “Design criteria for air quality indicators based on toxicity apply everywhere, except inside buildings. In cases where the design criteria can only be met beyond the property boundary, advice should be sought from the Authority in the assessment of the model simulation”.

Schedule C, Part D discusses the assessment of road transport corridors, but only discusses the model that should be used and does not state that alternative ambient air quality criteria should be applied other than those contained in Schedule A.

Within Schedule A, the design criteria for TSP, PM10 and PM2.5 do include a note which specifically states that for these species the criteria are only for point sources, and that for other sources, including roads, the relevant industry protocol for environmental management should be applied. The note applies to particulate species only and does not apply to the criteria for nitrogen dioxide (NO2), carbon monoxide (CO) or air toxics.

23. Thus, the design criteria PM10 and PM2.5 apply only to emissions from the stack plus background, whilst the design criteria for NO2, CO and air toxics apply equally to the stack and surface roads plus background. The use of less conservative criteria in the SEPP (AAQ) is therefore not appropriate.

24. There then follows a question as to the appropriate criteria to use for particulate matter where emissions occur from road sources, as no relevant industry PEM for road sources has been created by EPA, as was the intent at the time the SEPP (AQM) was written. As discussed, the SEPP (AAQ) enacts within Victoria the need for monitoring and reporting in accordance with agreement at a Federal level in relation to the NEPM (AAQ). The intent of the NEPM (AAQ) is to prevent population exposure to elevated levels of common atmospheric pollutants. Whilst this is measured at a location which is representative of a population of 25,000 people and away from major roads and industry, it is intended that all areas should meet these standards. As discussed the NEPM (AAQ) standards have been translated directly into the SEPP (AAQ). It is for this reason that the standards set in the design criteria in Schedule A of the SEPP (AQM) for the common air pollutants are lower than the criteria specified in the SEPP (AAQ), as this allows for multiple sources within an air shed which allows maintenance of the SEPP (AAQ). In the absence of other standards for PM10 and PM2.5, it is considered that the SEPP (AAQ) are the most appropriate assessment standards for surface road sources, however it is acknowledged that these have no basis in legislation.

25. The assessment criteria for the stack sources are considered to be correct, however there does appear to be a typographical error in Table 45 of the EES for carbon monoxide as the criteria is 29 mg/m3 which is equivalent to 29,000 µg/m3.

26. The criteria for the assessment of the surface roads and the combined scenarios, are however considered to be incorrect. Table 3-1 provides a comparison of the criteria used to the criteria, which are considered to be appropriate. Table 3-1 should be considered with the following comments:

PM10 and PM2.5, the SEPP (AAQ) criteria have been adopted and these are considered to be appropriate as the design criteria in the SEPP (AQM) apply only to point sources;

PM2.5, the SEPP (AAQ) criteria, which come into force after 2025, have been adopted and these are considered to be appropriate as the design criteria in the SEPP (AQM) apply only to point sources and the project will open in 2026;




NO2 the SEPP (AAQ) criterion has been adopted, however the SEPP (AQM) design criterion should have been adopted as it does not have a note appended which stipulates that it only applies to stack sources;

CO has not been assessed. The SEPP (AQM) design criterion should be adopted as it does not have a note appended which stipulates that it only applies to stack sources;

Air toxics (benzene, toluene, ethylbenzene, xylene isomers, 1-3, Butadiene, formaldehyde and PAHs) have not been assessed. The SEPP (AQM) design criteria should be adopted as they do not have a note appended which stipulates that it only applies to stack sources.

Table 3-1 Adopted and recommended criteria for surface roads or combination scenarios plus background

Species Averaging Period Adopted in EES (µg/m3)

Appropriate Criteria (µg/m3)

PM10 24 hours 501 501

1 year 201 201

PM2.5 24 hours 201 201

1 year 71 71

NO2 1 hour 2251 1902

1 year 561 Not required under SEPP(AQM)

CO 1 hour Not assessed 29,0002

Benzene 3 minutes Not Assessed 532

Toluene 3 minutes Not Assessed 6502

Ethylbenzene 3 minutes Not Assessed 145002

Xylene isomers 3 minutes Not Assessed 3502

1,3-Butadiene 3 minutes Not Assessed 732

Formaldehyde 3 minutes Not Assessed 402

PAH 3 minutes Not Assessed 0.732

1. SEPP (AAQ) 2. SEPP (AQM)

3.1.1.2 Proposed NEPM Variation 27. The project is due to open in 2026. At the present time, a variation to the National

Environment Protection (Ambient Air Quality) Measure (the ‘Measure’) for ozone, NO2 and SO2 is proposed (Department of the Environment and Energy, 2019). The proposed variation will be open to public consultation until 7 August 2019.

28. The updated version of the NEPM (AAQ) provides that the desired environmental outcome of the Measure is ambient air quality that minimises the risk of adverse health impacts from exposure to air pollution for all people, wherever they live in Australia. It is therefore considered that the revised NEPM (AAQ) standards should be additionally applied as non-regulatory modelling criteria for the modelling of surface roads and combined impacts. The standard for NO2 has been revised from 0.12ppm (240 µg/m3) as 1 hour average to 0.09ppm (180 µg/m3) and from 0.03ppm (60 µg/m3) annual mean to 0.019ppm (38 µg/m3). These standards are to be further reduced from 2025 to 0.08ppm (160 µg/m3) 1 hour average and 0.015ppm (30 µg/m3) annual mean. There are no changes to any other species assessed in the Technical Report B.




29. The Technical Report B states that the NEPM Ambient Air Quality (NEPM (AAQ)) standards are not applied as modelling criteria for assessing air emissions from individual sources, specific industries or roadside locations, but rather apply at performance monitoring locations with a representative measure of air quality likely to be experienced by the general population or sub-region of 25,000 people or more.

30. It is noted that in order to allow several sources within an air shed without resulting in an exceedance of the NEPM values as reported under the SEPP (AAQ), the current SEPP (AQM) design criteria for NO2 are set at 190 µg/m3 in comparison to the current NEPM value of 240 µg/m3. It would therefore be expected that where the new NEPM values are adopted the SEPP (AQM) design criteria would need to be revised to meet this new standard. Currently the SEPP (AQM) design criteria for 1 hour NO2 is approximately 84% of the SEPP (AAQ) / NEPM (AAQ) standard.

31. Where the NEPM is revised to a value of 160 µg/m3 in 2025 and the same margin retained this would indicate a revised design criteria of approximately 135 µg/m3. It is noted that for the combined scenario B1 (table 114 in the EES), the maximum reported value was 140 µg/m3. Indicating potential exceedance of future policy. As discussed in Section 3.1.3, there is also the possibility that the predicted levels of NO2 have been under-estimated meaning that greater exceedance of future standards may occur.

3.1.2 Emission estimation 32. Emissions from the North East Link ventilation system were calculated using COPERT

Australia vehicle emission factors. Given that the COPERT Australia method is well documented and used throughout the European Union, it is considered that the COPERT Australia approach provides representative emission factors for the Assessment. COPERT Australia includes algorithms that are developed from data collected in Australian test programs designed to reflect the Australian fleet and activity data (EMISIA, 2014).

3.1.2.1 Real-world emissions 33. The emission factors contained in COPERT Australia are based on test programs, which are

standardised driving cycles in a laboratory setting. In recent years, it has come to be more widely known that the test driving cycles do not reflect real world emissions especially for diesel vehicles. A recent study in Australia found that:

Real-world fuel consumption of vehicles was on average 25% higher than Australian driving cycle laboratory tests:

- When compared to Federal emission limits set via the laboratory tests:

- CO was exceeded by 20% of petrol vehicles tested (two out of ten vehicles). These vehicles emitted more than three times the laboratory limit for CO.

- NOx was exceeded by 83% of diesel vehicles tested (five out of six vehicles). The highest of these emitted almost nine times the laboratory limit for NOX.

- PM was exceeded by 17% of diesel vehicles tested (one out of six vehicles). This vehicle emitted 40% more CO than the laboratory limit (ABMARC, 2017).

34. It must therefore be considered that emission estimates based on laboratory tests under-estimate the likely impact during use. Unfortunately, this limitation applies to all road evaluations worldwide, until such time as emission estimates based on real-world driving are available. At this time all that can be done is to consider the results of the model and acknowledge this limitation and the potential for deviation in reality compared to the predicted results.

35. This limitation applies to all road assessment studies undertaken for approval in Australia, however it is a limitation which must be acknowledged when considering the projected impact.




3.1.2.2 Adopted vehicle speeds 36. Technical Report B states that in the absence of the level of detail the North East Link model

was configured on a state based level, including vehicle fleet mix and mean fleet mileage statistics for Victoria in 2010. It is stated in Section 9.4.3 of the Technical Report B that emission factors for each vehicle class in grams per vehicle kilometre travelled were derived assuming all vehicles travelling at 80 kilometres per hour. It is further discussed in Section 11.4.5 (the surface roads modelling section) that the hourly speed dependent emission factors were generated for each modelled road. It therefore appears that 80 kilometres per hour was applied only to tunnel / freeway emission rates, although it is neither explicitly stated nor there is a justification as to why 80 kilometres per hour should be adopted. In contrast, the EES Attachment VI Works Approval Application states that normal operations in tunnel are defined as traffic flowing with the average speed of 20 km/hr or greater. Whilst it is acknowledged that the assessment did consider a worst case condition with flows at 40 km/hr, during peak hours other tunnels in Melbourne frequently have speeds below this level, meaning that emissions are likely to be higher during these peak periods than estimated.

37. Figure 3-1 shows the emission speed curves for different classes of vehicles from the UK Design Manual for Roads and Bridges. Euro classes signify the technology requirements of the European Union, these technology standards are adopted in Australia, with Euro 5 adopted for petrol passenger vehicles in 2016. As it takes approximately 20 years, for the vehicle fleet to be replaced in Australia the penetration of the Euro 5 standard will be approximately 50% of the petrol passenger vehicle fleet in the opening year This indicates that for some species at very low speeds the emissions are much higher than faster speeds.

Figure 3-1 Speed curves for Euro 1 to 4 classes (Highways Agency, 2007)

38. It is considered that if normal operations are defined as an average speed of 20 km/hr, then this lower limit should be considered in the sensitivity analysis, as this will result in higher emissions per vehicle for most species considered.




3.1.2.3 Gradients of surface roads 39. Technical Report B states that for surface roads, gradients have not been considered in the

assessment with the exception of the cutting just before the northern end of the tunnel. Technical Report B also states, and the map books show, that for roads within the area, gradients are a maximum of 5%. For a 5% road with two way traffic (assuming equal traffic flow both ways) the total emissions accounting for the gradient are approximately 70% higher than a flat road. Consequently, by ignoring gradients for the surface roads the assessment has potentially under-estimated impact to the surrounding environment.

3.1.2.4 Future Year Factors 40. The Technical Report B further states that the derived COPERT emission factors were later

adjusted to World Road Association (PIARC) factors for gradient (where applicable) and the future years 2020 and 2025 sourced from World Road Association (PIARC) and Brisbane City Council (2016) respectively.

41. Adoption of World Road Association (PIARC) 2020 year factors results in:

51%-64% reduction of PM10 and PM2.5 emissions across four vehicle classes (passenger car petrol, passenger car diesel, light commercial D and HCV);

49%-58% reduction of CO emissions across the same four vehicle classes;

39%-69% reduction of NOx emissions across the same four vehicle classes.

42. The PIARC future years emission factors were influenced by fleet renewal of vehicles with more stringent emission standards taken into account, and also include degradation of exhaust gas after-treatment systems during the life of a vehicle (World Road Association Mondiale De La Route, 2012). There is no discussion within the Technical Report B as to how these factors, developed during 2008-2011 working cycle, reflect progress towards more stringent emission standards to date.

43. The PIARC emission factors and future year factors were updated earlier this year (Comité technique D.5 Exploitation des tunnels routiers Technical Committee D.5 Road Tunnel Operations, 2019). The most recent update does not include a specific set of future year factors for Australia which were included in the 2012 version of the report. It is therefore not possible to know whether the factors have changed significantly. The most appropriate approach to determining whether the factors used remain appropriate and representative of future uptake in technology is through either through development of a model for current road use within the project area and comparison to measured roadside air quality data, or use of in-stack concentrations from one of the other Melbourne tunnels for the known fleet passing through at various speeds. This comparison would provide confidence that the future emission predictions are accurate. This approach is typically undertaken internationally as standard practice to understand the inaccuracy of the emission estimation and methods used in the assessment. Given the additional monitoring that is now occurring in the project area, it is recommended that this is completed prior to authorisation of the Works Approval Application to the satisfaction of EPA Victoria.

44. ERM was unable to retrieve the document by the Brisbane City Council to assess how the factors were derived. Adoption of Brisbane City Council (2016) 2025 year factors result in:

60%-79% reduction of PM10 emissions across four vehicle classes (passenger car petrol, passenger car diesel, light commercial D and HCV);

69%-84% reduction of PM2.5 emissions across the same four vehicle classes;

82%-85% reduction of NO2 emissions across the same four vehicle classes.




3.1.2.5 Under-estimation of particulate matter 45. The Technical Report B states that emission factors for particulate matter contain emissions

from the tailpipe, tyre and brake wear, however there is no consideration of resuspension of dust from the road. As a vehicle passes along the road, any dust which is lying on the surface of the road is lifted into the air by the vehicle wake and is then available for dispersion and impact to sensitive receptors. The literature states that resuspension is an important consideration which is equal to emissions, with studies indicating that at the roadside the relative share of PM10 was 27% exhaust, 15 % tyre, brake and road wear and 58 % resuspension (38%, 8% and 54% respectively for PM1) (Green Car Congress, 2016). Thus there is potential the emissions of particulate matter from the roads have been under-estimated by as much as 100%. This under-estimation has a flow on effect to the health impact assessment which is based on the air quality assessment results.

46. It is noted in the Technical Report B that comparison of tunnel measurements to COPERT emissions indicates that there is a potential under-estimation of approximately 40%, but that the conservative assumptions including in the emission estimation is considered to compensate for this under-estimation. These conservative assumptions include the fact that vehicle emission factors for earlier years than assessed have been used and the fact that Hybrid and EVs which have lower emissions have not been included in the assessment. As discussed, emissions from tyre, brake, road and resuspension are expected to remain the same in the future and currently comprise more than 50% of total emissions from the vehicles. Thus it is considered that for particulate matter the assessment has under-estimated emissions.

3.1.2.6 Future reductions in emissions 47. There are multiple statements in the Technical Report B which state that with the increase in

low and zero emissions vehicles in the future, there will be a reduction of emissions and therefore impacts are likely to be less than presented. Firstly, it should be noted, that unlike Europe and Japan there is no clear policy setting for the replacement of the internal combustion engine with low and zero emission vehicles. Secondly, the replacement of the vehicle fleet in Australia typically takes around 20 years, compared to around 10 years in Europe. Thus the change in the vehicle fleet will be slower than in Europe and Japan. When the change does occur, reductions in emissions for products of combustion such as CO, NO2 and air toxics will occur, however for particulate matter the future is not as simple.

48. As stated in Section 3.1.2.5, tyre, brake and road wear as well as re-suspension of road dust account for 73% of emissions at the current time. Electric vehicles using current technology are heavier than conventional vehicles, due to the battery. The additional weight means greater tyre wear, road wear and resuspension however brake wear may be decreased due to regenerative braking systems used to recharge the battery. A recent literature review by the University of Edinburgh determined that:

“…when factoring in the additional weight and non-exhaust PM factors, total PM10 emissions from electric vehicles (EVs) are equal to those of modern internal combustion engine vehicles (ICEVs); for PM2.5 emissions, EVs deliver only a negligible reduction in emissions” (Green Car Congress, 2016).

49. This means that in contrast to the statements in Technical Report B, as uptake of low and zero emission vehicles continues, the amount of particulate matter released from the project will not decrease and may, in fact, increase.




3.1.3 Primary and secondary NO2 50. Emissions from vehicles consist of both nitric oxide (NO) and nitrogen dioxide (NO2). NO is

rapidly oxidised to NO2 on exposure to oxidants within the atmosphere and NO2 can be disassociated on reaction with sunlight to form NO and an oxygen radical that can then be oxidised to NO2 again. As a result of this circular reaction the two are often summed and termed oxides of nitrogen (NOx). Photo-disassociation does not occur at night, which is why NO2 concentrations tend to be higher at night than during the day. Photo-disassociation will also not occur within tunnels due to the lack of sunlight.

51. It is unclear whether the oxidation of NO to NO2 was considered in the assessment however where this has not been considered it has the potential to underestimate the concentration of NO2 from the surface road network and the tunnel stacks.

3.1.4 Surface roads assessment 52. While the Technical Report B presented both incremental and cumulative results for scenarios

A1 and B1 (2020 emission factors with 2026 and 2036 traffic volumes respectively), it is stated that the background concentrations used are Alphington AAQMS data for the time period corresponding to the maximum incremental contribution due to the surface road. It therefore appears, than no cumulative assessment was completed on an hour by hour basis and such there is potential that the concentrations presented in Tables 107 and 108 of the Technical Report B are not the maximum predicted for each road link. This is in contrast to Schedule B of the SEPP(AQM) which requires that either a contemporary cumulative assessment is undertaken where sufficient background data is available or the 70th percentile of background concentrations. Moreover, no cumulative (surface roads and background) concentrations are provided for scenarios A2 and B2.

53. As further discussed in Section 3.1.1, the Technical Report B considered that there is no regulatory criteria related to surface roads impacts, which is not considered to be a correct interpretation of the SEPP (AQM).

3.1.5 Combined impacts assessment 54. Combined impact assessment as a result of Project emissions from tunnel ventilation system

and surface roads and background concentrations was undertaken using one meteorological year (2016) and at two receptors. 2016 was chosen to assess the combined impacts on the basis that 2016 was considered to reflect the worst case year for surface road emissions, and due to the proximity of the selected receptors to surface roads, they are primarily impacted by surface road emission rather than road ventilation system emissions. The two receptors for which combined impacts were considered were chosen based on their proximity to the Project surface roads and a ventilation structure such that they are likely to be impacted significantly by both.

55. It is considered that there is potential for underestimation of cumulative Project impacts, as:

Only one year was modelled, and not five years as required by the EPA Publication 1551 (Environment Protection Authority Victoria, 2013); and

There is appears to be no scientific justification for selection of the receptors, only a qualitative opinion that they are likely to be the most exposed receptors. A better approach would be to review the results of all receptors and report the worst impacted locations. Consequently, the selected receptors for the analysis may not be representative of the worst cumulative impact.

56. In relation to the tunnel ventilation system, it is stated in the Technical Report B that the worst impact occurred in 2017 and the percentage difference in the maximum impacts between years was approximately 10 per cent.




57. It should be further noted that in relation to background concentrations of NO2, the average and maximum hourly and annual mean concentrations in 2016 were lower than in other years. Similarly, the average and maximum 24 hour average and annual mean PM10 and PM2.5 concentrations are lower than in other years.

58. Based on the previously discussed aspects, it is considered that the cumulative assessment should have been undertaken over a five year period and combined the results at all road sensitive receptors on an hour by hour basis. There is potential that cumulative assessment in its current form underestimated the Project impacts to the surrounding land use. In-tunnel limits may not be achievable

59. Table 42 provides the in-tunnel air quality limits and equivalent emission rates. Comparison of the proposed in-tunnel air quality limits to emissions estimated in the sensitivity analyses indicates that the in-tunnel limit for NO2 may not be able to be met. For example, the northbound emission limit for NO2 is 1.3 g/sec at a flow rate of 1,290 m3/sec. It would be expected that these maximum flow rates would occur during the day. Whilst it is difficult to say for certain as the figures don’t provide exact numbers, figures 57 and 63 in Technical Report B appear to indicate that mass rates will be higher than this level.

3.1.6 Treatment of tunnel emissions 60. Technical Report B considers the potential for the use of treatment systems and considers

that for tunnels where treatment systems around the world have treatment systems these systems are rarely used. In Australia it is noted that no permanent pollution control equipment has been installed, thus it is considered that a treatment system is not warranted for the proposed tunnel.

61. As discussed, there is potential that the emissions have been under-estimated, the conversion of NO to NO2 has not been accounted for and consideration has not been given to future tightening of standards following review of the NEPM (AAQ). Consequently, it is recommended that space be made within the stack system for future retrofitting of mitigation technology should it be. It would be easier, and more cost effective, to include this provision within the design at this stage, rather than the need to dismantle the stacks to rebuild them with the capability at a later date should treatment technology ultimately be required.

3.2 Minor contentions

3.2.1 Dispersion model selection 62. In accordance with the requirements of the State Environment Protection Policy for Air Quality

Management (SEPP(AQM)) and EPA Publication 1551 (Environment Protection Authority Victoria, 2013), dispersion modelling was undertaken using the regulatory air pollution model AERMOD. The modelling used AERMOD version 15181, which was released in 2015. Another two versions have been released since 2015 with the version 16216 released in 2016 and the version 18081 released in 2018. The versions evolve to accommodate the best available science, and specifically have improved the ability of the model to handle low wind speeds, meaning that wind speeds below 0.3 m/sec can now be evaluated. Whilst it is unlikely that the use of a newer version would change the outcomes of the assessment, it is worth consideration.




3.2.2 Modelled roads 63. Surface roads included in the dispersion modelling were selected on the following basis:

Number of vehicles with or without project in 2036 is greater than 30,000 vehicles per day, with the change in total vehicles (no project or project base) greater than an increase or decrease of 25 percent; or

Heavy commercial vehicles (HCV) volume with or without project in 2036 is greater than 1,000 vehicles per day, with the change in HCVs (no project to project case) greater than an increase or decrease of 25 percent.

64. No justification is given for selection of these criteria for inclusion of roads.

65. The United Kingdom undertakes a high degree of air quality modelling for road networks as the ambient air quality is significantly impacted by this source due to density of population. The Institute of Air Quality Management (IAQM) suggests that where air quality is below acceptable standards, an air quality assessment is required for a change of 500 vehicles or 100 HCV (IAQM, 2017). Meanwhile the main guide for the design and construction of major roads in the United Kingdom (the design manual for roads and bridges (DMRB)) suggests that an air quality assessment is needed where there is a change of:

1,000 vehicles flow on average per day;

200 HCV flow on average per day;

Daily average speed of 10 kph or more; and/or

Peak speed of 20 kph or more.

66. Use of the IAQM criteria for local roads, and DMRB criteria for highways would have included many more roads within the assessment. Despite this however, the roads that have been considered appear to be the main arterial routes within the area of interest and whilst inclusion of additional roads would make the assessment more accurate, it is not considered that it would result in substantial changes to the predicted air quality impacts.

3.2.3 Background data 67. Air Quality Assessment for the EES (Technical Report B) states that five temporary ambient

air quality monitoring stations have been established in the vicinity of North East Link to support the project assessment. This data however did not inform the technical report and will be presented at the EES Panel Hearing to enable comparison with EPA Victoria Alphington AAQMS data. It would have been more advantageous had this monitoring been commenced earlier and incorporated into the assessment. The results of the assessment should be re-evaluated with the updated data.

3.2.4 Noise Barriers 68. There is some evidence in the literature that noise barriers generally result in a decrease in

pollutant concentrations behind the barrier when the wind were directionally from the road, but that under certain wind conditions (when the wind direction was towards the road) can result in a slight increase in ambient air concentrations on the receptor side of the noise barrier compared to the situation with no noise barrier (Baldaulf, et al., 2008). Overall it is considered that the omission of consideration of the noise barriers in the modelling is acceptable.




3.2.5 Other species 69. The Technical Report B states that surface roads and combined impacts modelling was

limited to particulate matter and NO2 upon discussion with EPA. As discussed in Section 3.1.1, the SEPP (AQM) design criteria for NO2, CO and air toxics are considered to apply to all sources. Thus for compliance with the SEPP (AQM) assessment should have been undertaken for all of these species. It is acknowledged, however, that typically surface roads do not give rise to exceedance of CO and air toxics and consequently exclusion of these species is considered acceptable.

3.2.6 Tunnel portals emissions 70. As vehicles enter a tunnel, the air in-front is pushed forward creating a ‘piston effect’. This

means that the emissions generated in the tunnel are pushed from the entrance to the exit at the tunnel portal. As the tunnel portals are often depressed compared to the surrounding land, this can lead to very high concentrations around the tunnel portal which spill onto the surrounding land.

71. The Technical Report B states that prior to the tunnel exit portal, air is withdrawn from the tunnel into a ventilation structure and discharge to atmosphere. It is further stated that additional jet fans are installed immediately prior to the exit portal to reverse the air flow and prevent emissions from the portal. Given this description, the omission of tunnel portal emissions in the modelling is considered acceptable, however it is important that zero emissions from the tunnel portals requirement is realised.

72. The EES Attachment VI Works Approval Application states a desire in the early hours of the morning, subject to regulatory approval, for the mechanical ventilation system to be minimised to conserve energy. This will result in emissions from the tunnel portals. Emissions from tunnel portals can result in significant impacts to sensitive receptors immediately adjacent to the portals themselves, however when vehicle flow is low the concentrations to which those receptors are exposed is also consummately low. It is agreed therefore that subject to acceptable assessment future use of portal emissions during low flow periods could be an option.

3.2.7 Ambient air quality monitoring 73. The EES Attachment VI Works Approval Application states that ambient air quality monitoring

would be undertaken in consultation with EPA Victoria including at least one year of monitoring before operation and five years post opening of North East Link, or such lesser period as agreed with EPA Victoria.

74. For ambient monitoring, it is recommended that:

The period of monitoring should also be allowed to be extended in consultation with EPA Victoria as required, where monitoring has shown a number of exceedances of the standards;

Monitoring should be reported on a live basis in a similar manner to that provided by EPA’s Air Watch website; and

Where an exceedance of a standard is recorded, an investigation should be completed by a suitably qualified professional to determine whether the affected road network or tunnel is the major cause of the exceedance and, if so, what can be done to prevent future exceedances.




3.2.8 In-tunnel air quality 75. The EES Attachment VI Works Approval Application states that in-tunnel air quality would be

monitored to demonstrate compliance with in-tunnel air quality objectives. The monitoring results would be reported publicly on a quarterly basis for five years post opening of North East Link, or such lesser period as agreed with EPA Victoria.

76. It is recommended that:

The period of monitoring should have the flexibility to be extended should exceedances be recorded

Where an exceedance of the in-tunnel air quality standard is recorded, an investigation should be completed by a suitably qualified professional to determine the cause and what can be done to prevent future exceedances.



RESPONSE TO QUESTIONS POSED IN INSTRUCTIONS

4. RESPONSE TO QUESTIONS POSED IN INSTRUCTIONS

4.1 Question 1 77. At section 4a of the provided instructions the following question was asked:

Does the EES adequately document and assess the nature and extent of the environmental effects of the Project? In addressing this question please explain where you are satisfied with the content of the EES and why, and if not, what if any deficiencies exist in the documentation and/or assessment of the nature and extent of environmental impacts contained in the EES.

78. For the reasons outlined in Section 3 of this expert witness statement, in terms of the assessment of air quality there is a high degree of uncertainty that the assessment accurately represents the impacts of the project to the surrounding land use and there is a high degree of likelihood that the assessment under-estimates that impact.

4.2 Question 2 79. At section 4b of the provided instructions the following question was asked:

Can the Project as described in the EES achieve a level of environmental performance which is consistent with relevant legislation, documented and endorsed policy or acknowledged best practice?

80. Due to high background concentrations on several days a year, predictions indicate that current particulate matter standards will be exceeded when the project is in operation, but that the contribution by the tunnel stacks on that day will be negligible. With surface roads, the same detailed analysis considering the periods of highest background has not been undertaken, but the highest contributions from the surface roads for PM10 and PM2.5 are 4.9 µg/m3 and 4.0 µg/m3 in 2026 and 5.4 µg/m3 and 4.5 µg/m3. These maximum impacts represent between approximately a 130% to 150% increase in contribution to ambient concentration. This indicates that on days with elevated concentrations, there is potential for the project to contribute to additional exceedances of the standards at specific sensitive receptors. Due to the locations in which compliance monitoring is undertaken under the SEPP (AAQ) for reporting against the NEPM (AAQ), these additional exceedances are unlikely to be detected within the monitoring data as monitoring is not completed at each sensitive receptor.

81. For NO2 from the tunnel stacks, predicted contributions to ambient concentrations are predicted to be as high as 71 µg/m3 at maximum tunnel capacity. At the time of the prediction, the background concentration was 66 µg/m3 resulting in compliance with the current 190 µg/m3 standard. Technical Report B, also states that the maximum measured concentration of NO2 at Alphington was 123 µg/m3 (0.06 ppm converted at 0ºC at 1 atmosphere). If the highest contribution at maximum tunnel capacity occurs on a day of high NO2 concentration then there is potential for exceedance of the standards.

82. For NO2 at the surface roads, predicted contributions more than treble as a result of the project from 20 µg/m3 to 69 µg/m3. Under current criteria, these contributions are not likely to result in exceedance of the air quality standards, however as criteria decrease in concentration as a result of the implementation of the NEPM (AAQ) and flow through to State based legislation there is a high degree of likelihood that the project will result in exceedance of the standards in some locations.




4.3 Question 3 83. At section 4c of the provided instructions the following question was asked:

If the Project, as described in the EES cannot achieve a level of environmental performance which is consistent with relevant legislation, documented and endorsed policy or acknowledged best practice, are there any recommendations that you would make as to specific measures which you consider necessary and/or appropriate to prevent, mitigate and/or offset adverse environmental effects? If so, please explain your reasoning in detail. To the extent that it is within your expertise to comment upon the feasibility of any of your recommendations, please state whether or not any recommendations are feasible, explaining your reasoning.

84. Impacts from the surface road networks cannot easily be mitigated. The prime method of mitigation is through improvement of emission and fuel quality standards at a Federal level, however as discussed, this will take approximately 20 years to fully progress through the fleet. As discussed in the EES, there is some evidence that noise walls have the potential to reduce overall pollutant concentrations adjacent to the road network and these could be used in the area where the highest levels of impact from surface roads. This should be further investigated for existing noise walls, and where reduction is determined in Melbourne, then noise walls should be incorporated to the design. As noise walls are frequently used on roads throughout Victoria, it is considered that this is a feasible proposition.

85. Considering that a decrease in NO2 criteria likely prior to the opening year, the elevated contribution of NO2 to ambient concentrations from the modelling at maximum tunnel capacity, which may not incorporate consideration of NO to NO2 conversion, it is considered prudent to provide capacity within the tunnel exhaust structure for future retrofitting of mitigation technology. Space has been left within every other tunnel ventilation structure in Melbourne, and thus this proposition is considered feasible.

4.4 Question 4 86. At section 4d of the provided instructions the following question was asked:

How does the Project as described in the EES respond to the principles and objectives of “ecologically sustainable development” as defined in the Ministerial Guidelines for assessment of environmental effects under the Environmental Effects Act 1978 (2006).

87. Subject to undertaking further modelling, which addresses each of the concerns outlined in this statement, and then undertaking an environmental health risk assessment based on complete data, the impacts for the project may be acceptable. In the absence of this further work, I am unable to determine whether the project meets the objectives of ecological sustainable development as defined under the ministerial guidelines.

4.5 Question 5 88. At section 4e of the provided instructions the following question was asked:

Are there any recommendations that you would make as to specific measures which you consider necessary and/or appropriate to improve the response of the Project to the principles and objectives of “ecologically sustainable development”? If so, please explain your reasoning in detail. To the extent that it is within your expertise to comment upon the feasibility of any of your recommendations, please state whether or not any recommendations are feasible, explaining your reasoning;

89. See response to question 3 at Section 4.3.




4.6 Question 6 90. At section 4f of the provided instructions the following question was asked:

To the extent that the content of the draft planning scheme amendment, works approval application or environmental performance requirements (EPRs) lies within your expertise, do you have any recommendations for changes that should be made to the draft planning scheme amendment, works approval or planning approval and/or EPRs in order to improve the environmental outcome of the Project.

91. See Section 5 of this expert statement.



ENVIRONMENTAL PERFORMANCE REQUIREMENTS

5. ENVIRONMENTAL PERFORMANCE REQUIREMENTS

92. If the project is considered to be acceptable and proceeding then the following additions to the EPR AQ1 contained in Technical Report B are recommended.

Monitoring to be undertaken using the same instrumentation type, in consultation with EPA Victoria, across the entire project in order that results are accurate and comparative.

Ensure that ambient monitoring for the protection of sensitive receptors is implemented prior to the start of construction in that location to understand baseline and to ensure that sensitive receptors are protected during all phases of construction.

Implement trigger levels for short time periods in consultation with EPA Victoria to ensure that longer term criteria are protected.

Where exceedances of ambient criteria are detected, report these exceedances to EPA Victoria and instigate and investigation by a suitably qualified professional to determine the cause of the exceedance. Where the Project is found to be the cause of the exceedance determine methods to prevent future exceedance of the ambient air quality standards, with the report to be provided to EPA Victoria within 2 months of the exceedance occurring. Any identified methods should then be incorporated to the CEMP, WEMP and OEMP of the entire Project.

93. The following EPRs are recommended to be added:

Modelling must be re-completed to the satisfaction of EPA Victoria accounting for:

- Current requirements of the SEPP (AQM);

- Likely future changes to legislation that will occur prior to the opening of the project;

- Five consecutive years without using screening to isolate a single year for analysis;

- NO to NO2 conversion;

- Gradients of roads on the surface road network;

- Actual vehicle speeds expected within the tunnel for each hour of the day;

- Dust resuspension;

- Consideration of all sensitive receptors when completing the cumulative assessment; and

- Consideration of periods of maximum background concentration and concurrent project contribution as well as maximum project contribution and concurrent background concentration, do demonstrate non-exceedance of standards.

Modelling must be completed to the satisfaction of the EPA using the same adopted method (described above) for a year for which there is local ambient air quality monitoring adjacent to the project area to understand the level of accuracy of the method.

Ambient air quality monitoring is to implemented using real-time monitors measuring at a minimum PM10, PM2.5 and NO2 at the locations of maximum predicted impacts from the surface road network and the stack impacts prior to the start of construction. Monitoring must be completed using instrumentation which is compliant with the relevant which have an Australian Standard, or for which EPA Victoria is satisfied that the technology is equivalent to the relevant Australian Standard. Monitoring may cease following a period of five years post commencement of operation of the Project subject to no exceedances of ambient air quality standards being attributed to the project. Removal of air quality monitoring must be completed in consultation with EPA Victoria. Air quality data from



ENVIRONMENTAL PERFORMANCE REQUIREMENTS

these instruments must be made available via a website, providing live data and historical data.

Where exceedance of air quality standards is detected at any of these instruments, EPA Victoria is to be notified and investigation by a suitably qualified professional must identify whether the exceedance was as a result of the project. Where the exceedance is found to be the result of the project, recommendations for preventing future exceedances of the standards as a result of the project must be identified where possible. The report is to be provided to EPA Victoria and placed on the air quality website providing access to the monitoring data within 2 months and 3 months of the exceedance occurring respectively.

In tunnel air quality concentrations to be published live on a website. Where an exceedance of the in-tunnel air quality criteria occurs, EPA Victoria is to be notified and investigation by a suitably qualified professional must identify the cause of the exceedance. The report is to be provided to EPA Victoria and placed on the air quality website providing access to the monitoring data within 2 months and 3months of the exceedance occurring respectively.



CONCLUSION

6. CONCLUSION

94. In relation to the North East Link, Dr Iain Cowan of ERM has reviewed the following documents:

Environment Effects Statement – Chapter 10 Air Quality;

Environment Effects Statement – Technical Report B Air quality; and

Environment Effects Statement – Attachment VI Works Approval Application.

95. There are a number of areas of concern in relation to the technical approach of the assessment including:

The current legislation has not been appropriately considered;

Likely changes to legislation as a result of the published draft NEPM (AAQ) currently out for public consultation, which will come into force before the opening of the project have not been considered to ensure that the project will be in compliance during operation.

Estimates of emissions are not conservative and are likely to be understated as:

- Real-world driving emissions are typically higher than those derived from laboratory tests;

- The adopted vehicle speed for the tunnel was set within the assessment 80 km/hr at all times, whilst the EES Attachment VI Works Approval Application states that normal operations in tunnel are defined as traffic flowing with the average speed of 20 km/hr or greater, which will result in higher emissions;

- Emissions from surface roads have been estimated assuming that the roads are at zero gradient (with the exception of the cutting at the northern end of the tunnel). Emissions from a road at 5% gradient are up to 70% higher than at grade emissions;

- Particulate emission estimates do not include resuspended dust, and thus have the potential to have been under estimated by up to 100%;

- Emissions of particulate matter are unlikely to decrease in future even with penetration of low and zero emission vehicles. This is because emissions of particulate resuspension currently account for 58% of emissions, and these emissions have not been accounted for in the assessment. Thus particulate emission estimates are actually more representative of period with high penetration of low and zero emission vehicles.

There appears to be no consideration of conversion of nitric oxide to nitrogen dioxide following emission from the tunnel or the surface road network.

When assessing surface roads and the cumulative assessment the time period corresponding to the maximum incremental contribution due to the surface road is selected and the background concentration from Alphington AAQMS added. This has the potential to under-estimate the impact from the surface road network when the background levels are already elevated and the roads only contribute a minor amount enough to cause additional exceedances of the standard. The potential risk of any additional exceedances has therefore not been considered by the assessment.



CONCLUSION

When assessing the combined impacts, there are a two of areas of concern:

- The assessment was completed at two receptors for which no scientific basis has been provided for the selection; and

- Assessment has been completed for 2016 as this was the worst year for surface road impacts, but the worst year for impacts from the stack was 2017 and 2016 has lower background concentrations than other years. Consequently, the total impact over a five year period may be under represented. Consequently, it is considered that the assessment should have been completed over five years.

Emission estimates for the sensitivity analyses appear to be higher than the in-tunnel emission limits, indicating that where the sensitivity analysis condition occurs, which is highly likely for the reduced speed scenario, the in-tunnel concentrations may have difficulty being met.

There is no allowance within the stack design for capability for retrofitting of treatment technology should it be required. It is recommended that space be provided for potential future treatment technology given that:

- Particulate emissions from roads are unlikely to decrease even with greater penetration of low and zero emission vehicles as the emissions from these vehicles are equal to the current emission estimates provided by COPERT;

- Combustion emissions and possible non-consideration of conversion of NO to NO2 means that actual emissions may be higher than estimated; and

- Ambient criteria are being lowered, and the tunnel may need to respond to a need for lower impact than provided within the assessment.

96. Overall, it is considered that there is a high degree of uncertainty that the assessment accurately represents the impacts of the project to the surrounding land use and there is a high degree of likelihood that the assessment under-estimates that impact.

97. If the project is recommended to proceed, then I recommend modifications to existing and additional EPRs to address the inadequacies that have identified in this review.



REFERENCES

7. REFERENCES

ABMARC. (2017, March). Real-World Driving - Fuel Efficiency & Emission Testing. Retrieved June 8, 2017, from Australian Automobile Association: http://www.aaa.asn.au/storage/2017-abmarc-aaa-rde-report-executive-summary-first-17-v5.pdf

Baldaulf, R., Thoma, E., Kylystov, A., Isakov, V., Bowker, G., Long, T., & Snow, R. (2008). Impacts of noise barriers on near-road air quality. Atmospheric Environment, 7502-7507.

Department of the Environment and Energy. (2019). National Environment Protection (Ambient Air Quality) Measure. Retrieved from http://www.nepc.gov.au/system/files/consultations/8710bdfb-ed01-4df9-8697-bc75956991a1/files/aaq-nepm-draft-varied-2019.pdf

Environment Protection Authority Victoria. (2013, October). EPA Publication 1551 Guidance notes for using the regulatory air pollution model AERMOD in Victoria. Retrieved July 27, 2016, from http://www.epa.vic.gov.au/~/media/Publications/1551.pdf

EPA Victoria. (2013, October). Construction of input meteorological data files for EPA Victoria's regulatory air pollution model (AERMOD). Retrieved from Publication 1550: https://www.epa.vic.gov.au/~/media/Publications/1550.pdf

Green Car Congress. (2016, May 2). The importance of considering non-exhaust traffic emisssions, the role of EVs. Retrieved from Green Car Congress: https://www.greencarcongress.com/2016/05/20160502-nonehaust.html

IAQM. (2017, January). Land-Use Planning & Development Control: Planning for Air Quality. Retrieved from Guidance from Environmental Protection UK and the Institute of Air Quality Management for the consideration of air quality within the land-use planning and development control processes: https://iaqm.co.uk/text/guidance/air-quality-planning-guidance.pdf

World Road Association Mondiale De La Route. (2012). Road Tunnels: Vehicle Emissions and Air Demand for Ventilation PIARC Technical Committee C4 Road Tunnels Operation. World Road Association Mondiale De La Route.


APPENDIX A CURRICULUM VITAE


Experience: 19 years’ experience in odorous industries, transport sources, mining and quarrying, power generation and oil & gas processing LinkedIn: https://www.linkedin.com/in/iain-cowan-056a1332/ Email: [email protected] Professional Affiliations & Registrations ■ Member of the Clean Air Society of Australia and

New Zealand ■ Certified Air Quality Professional by the Clean Air

Society of Australia and New Zealand since inception in 2016

Fields of Competence ■ Dispersion modelling using CALPUFF, AERMOD,

TAPM, Ausplume, AusRoads, ADMS and Charm. ■ Transport related emissions ■ Measurement and monitoring of ambient air quality ■ Mining emissions ■ Industrial emissions ■ Power generation emissions ■ Odorous emissions ■ Emissions Inventory Generation ■ Expert witness testimony ■ Flux hood measurements

Education ■ PhD Environmental Engineering, University of

Surrey, UK, 2004 ■ BSc Honours, Environmental Geology, Royal

Holloway College, University of London, UK, 2000 Languages ■ English, native speaker ■ French, conversational Key Industry Sectors ■ Transportation ■ Mining ■ Oil and gas ■ Power generation ■ Chemical production ■ Manufacturing ■ Contaminated land ■ Waste (landfills, composting and water) ■ Expert Witness Testimony Honours & Awards ■ Clean Air Society of Australia and New Zealand

Young Achiever Award ■ EPSRC Stipend for PhD Research

Iain Cowan Technical Director

Dr. Cowan is a Certified Air Quality Professional by the Clean Air Society of Australia and New Zealand and provides more than 19 years’ experience in the estimation of emissions, dispersion modelling and monitoring of ambient air quality, greenhouse gas species and odour. Iain has extensive experience with several advanced atmospheric dispersion modelling packages including CALPUFF, Ausplume, AERMOD, TAPM, ADMS-Urban, EDMS, CHARM, and AusRoads. In addition, Iain has extensive experience with measurement of ambient air quality for the establishment of baseline in remote locations.

https://www.linkedin.com/in/iain-cowan-056a1332/

https://www.linkedin.com/in/iain-cowan-056a1332/

mailto:[email protected]

Iain Cowan

www.erm.com 2

Publications ■ Cowan, I., Balanova, E., 2017. Use of AERMOD

for the Evaluation of Odour Impacts During Low Wind Speed Conditions. Clean Air Society for Australia and New Zealand Conference, 15-18 October 2017

■ Balanova, E., 2017. A Comparison of Meteorological Data Generated by Prognostic Model TAPM and a Diagnostic 3-Dimentional Model CALMET for the Generation of AERMOD Compatible Meteorological Files. Clean Air Society for Australia and New Zealand Conference, 15-18 October 2017

■ Cowan, I., Garrison, M., 2015. A comparison of default and regulatory settings when using TAPM to generate AERMOD files. Clean Air Society for Australia and New Zealand Conference, 20-23 September, 2015

■ Todoroski, A., Cowan, I., 2015. Odour measurement data for composting of green waste with the addition of food organics or grease trap waste using gore covers. Clean Air Society for Australia and New Zealand Conference, 20-23 September, 2015

■ Cowan, I.M., Lo, S., 2013. Development of an odour environmental risk assessment methodology for the evaluation of broiler farm impacts. Clean Air Society for Australia and New Zealand Conference, 7 – 11 September, 2013.

■ Cowan, I.M., Radford, A.L. and Grynberg, H., 2011. Use of Dispersion Models in the Assessment of Impacts from Spray Evaporation. Clean Air Society for Australia and New Zealand Conference, 31 July – 2 August 2011, Auckland, New Zealand

■ Radford, A.L., Cowan, I.M., 2011. 'Comparison of Near Field Impacts of Emergency Release Determined by Ausplume and Charm. Clean Air Society for Australia and New Zealand Conference, 31 July – 2 August 2011, Auckland, New Zealand

■ Corbet, L.C; Cowan, I.M; Stella, N. and Brooke. A.; 2009, The Integration of two regulatory dispersion models for a holistic approach to air quality assessment; Clean Air Society for Australia and

New Zealand Conference, 6th – 10th September 2009; Perth, Australia

■ Cowan, I.M.; 2007, Use of GIS as an air quality screening tool for planners and policy makers – Partnerships between local government and academia; International Union of Air Pollution Professionals World Congress, 10th-13th September 2007; Brisbane, Australia

■ Cowan, I.M.; 2004; The Development and Application of and Advanced Screening Model to Predict Air Quality Thesis (PhD). University of Surrey

Iain Cowan

www.erm.com 3

Key Projects Expert Witness Testimony ■ Maryvale W2E Facility – Provision of an expert

witness statement on the proposed Waste to Energy facility at Australian Paper’s facility at Maryvale. The assessment included dispersion modelling using the AERMOD and CALPUFF models for cumulative impacts from the Australian Paper facility and the proposed W2E facility. Case settled before proceeding to VCAT.

■ Foley – Expert witness at VCAT regarding the potential for odour generation from an expanded broiler farm impacting an individual dwelling

■ Lewis – Expert witness at VCAT regarding potential for odour generation impacting a local community from a proposed broiler farm in central north Victoria. Micrometeorological modelling of complex terrain was used to determine whether there non-standard meteorology occurs in the local area and whether the standard separation distance should apply and if not what would be an appropriate separation distance.

■ Maribrynong City Council – Expert witness statement to the independent inquiry and advisory committee on the West Gate Tunnel Project. Statement included the use of atmospheric dispersion modelling using the AERMOD dispersion model and emissions modelling using COPERT Australia.

■ Nuchev Pty Ltd – Expert at VCAT regarding the potential for odour and dust impact to surrounding land use as a result of a proposed goat dairy in central Victoria. Evidence was given as to the potential for odour impact, dust generation and transference to nearby sensitive receptors. Assessment of the impacts was undertaken based on odour flux hood monitoring at a goat farm and using the AERMOD dispersion model adopting the low wind speed option to capture worst case dispersion conditions.

■ Calleja Property Pty Ltd – Expert witness at VCAT regarding the potential for dust generation during land reprofiling on a former landfill. Evidence given as to the methods that would be needed to overcome issues in relation to dust generation. Preparation of witness testimony included the use

of dispersion modelling to assess potential impact from dust generating activities.

■ Regional Infrastructure Pty Ltd – Expert witness at Planning Panels Victoria hearing regarding the proposed development of a livestock exchange in Miners Rest, Western Victoria. Atmospheric dispersion modelling was completed using CALPUFF to demonstrate that the impact to the local community was at acceptable levels.

■ Barringhup Community Group – Expert witness at VCAT regarding the potential for odour generation from a proposed broiler farm cluster in Barringhup Victoria. This involved micro-meteorological modelling to determine the potential for gully flows which have been shown to result in significant impact from broiler farms in nearby locations.

■ Biomix Pty Ltd – Expert witness at VCAT regarding potential for odour generation from a proposed composting facility in northern Victoria.

■ Maddingley Brown Coal – Expert witness at VCAT regarding potential for odour generation from composting activities for permit amendment application.

■ Anonymous – Expert witness at VCAT regarding potential for odour generation impacting a local community from a proposed broiler farm in central north Victoria. Dispersion modelling incorporated micrometeorological modelling of complex terrain and odour dispersion in a river valley system.

■ Wodonga City Council – Expert witness at VCAT regarding the application for secondary consent for a drying and dewatering facility on a prescribed waste handling and composting facility.

■ Gadens Lawyers – Expert witness at Planning Panels Victoria regarding the requirement of a buffer for an existing egg laying farm within the urban growth boundary.

■ Innova Soil Technology – Expert witness at VCAT for proposed thermal soil remediation facility. Services included review of the application and opinion as to whether the application met the legislative requirements for meeting control of emissions to best practice and maximum extent achievable.

■ EPA – Expert witness at VCAT hearing for two proposed broiler farms adjacent to four existing

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broiler farms near to Nagambie, Victoria. Dispersion modelling using CALPUFF of odour from the existing and proposed broiler farms was undertaken to demonstrate existing and future impact with the proposed farms. Dispersion modelling of odour from the broiler farms was undertaken using the CALPUFF modelling system to take advantage of the lower thresholds for wind speed that can result in high odour impact. Modelling using five years of meteorology was undertaken to assess the impact from highly variable broiler growth cycles.

■ Brimbank City Council – Expert witness at VCAT for a proposed solid inert waste landfill adjacent to an existing concrete batching / crushing plant in north-east Melbourne. In preparation for the VCAT hearing. Three months of dust deposition monitoring were undertaken, and dispersion modelling using CALPUFF of the existing concrete crushing / batching plant and proposed development of a solid inert waste landfill.

■ Yarra Ranges Shire Council – Expert witness at VCAT hearing for compost odour impacting a local community. Flux hood measurements of odour emissions from compost piles were used with dispersion modelling using CALPUFF of odour from the compost facility to determine impact to the surrounding community.

■ Otway Shire Council – Expert witness at VCAT hearing for proposed broiler farm with potential to impact on local community. Review of dispersion modelling undertaken by the proponent and dispersion modelling to show impact using alternative modelling methodologies.

■ Grinders Coffee – Expert witness at VCAT hearing for proposed expansion of operation at a coffee roasting facility. Preparation of expert witness testimony included dispersion modelling of proposed emissions from the facility, and assessment of impacts on the surrounding community.

Transport ■ WestConnex North Sydney and Beaches Link –

Completed the emission estimation for the North Sydney and Beaches link project as a result of

updated PIARC factors which had the potential to alter the outcome of the assessment.

■ Anonymous – Independent third party review of air quality impact assessment from a major road tunnel infrastructure project in New South Wales as part of environmental due diligence review team.

■ Arcadis – Technical air quality expert to the IRAE on the WestGate Tunnel Project to provide comment on the development of the construction environment management plan and to ensure changes in design are in accordance with the planning permit and approvals.

■ Maribrynong City Council – Expert witness statement to the independent inquiry and advisory committee on the WestGate Tunnel Project. Statement included the use of atmospheric dispersion modelling using the AERMOD dispersion model and emissions modelling using COPERT Australia.

■ Singapore Cross Island Line – Internal technical peer review of baseline measurements and qualitative impact assessment for the construction of the proposed Cross Island Line in Singapore.

■ Brent Cross Shopping Centre – Assessment of traffic impacts on roads as a result of road realignment and construction of new roads for a shopping centre upgrade in north London. The assessment used the emission estimation model published by the UK Department of Transport together with ADMS-Roads to predict impacts at nearby sensitive receptors.

■ Goodman – Assessment of a traffic impacts on roads surrounding a proposed transport interchange depot (rail to road) in Slough, UK. The assessment UK emission factors for the vehicle fleet together with ADMS-Roads to assess the impacts of the increase in trucks to the air quality in the local environment.

■ Cikampek-Palimanan Toll Road – Assessment of a proposed toll road in Indonesia. Modelling included determination of diurnal emission rates followed by dispersion modelling using CALQ3HCR.

■ Hoddle Street Study – High level qualitative option review and detailed dispersion modelling of

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options for the redevelopment of Hoddle Street in Melbourne. Qualitative review of multiple options based on vehicle numbers / traffic mix and expected relative emissions from the options. Detailed modelling undertaken using AusRoads and AusVeh emission factors for anticipated traffic volumes for three potential route options.

■ Melbourne Airport Limited – Undertook complete modelling exercise of airport pollution sources including the aircraft, roads, parking facilities, jet engine testing and training fires to develop a concentration map of pollution using US FAA dispersion model EDMS. Modelling incorporated all aircraft movements from the terminals to the runway, take-off and landing and use of runway / taxiways varying with wind direction.

■ Bankstown Airport - Assessment of the impact on local air quality of moving the engine run-up bay from the current position to a new location at the north-eastern end of Bankstown airport. The assessment has used the regulatory dispersion model AUSPLUME to model concentrations of oxides of nitrogen (NOX), carbon monoxide (CO) and oxides of sulphur (SOX).

■ London Development Agency – Assessment of the impacts of traffic generation, construction and on site sources of the London Olympic Bid to the surrounding population. Modelling undertaken using ADMS-Roads.

■ Highways Agency – Design Manual for Roads and Bridges (DMRB) Impact assessment of the extension of the M6 to the Scottish border.

■ Welsh Development Agency – Guidance on Multi-Modal Assessment (GOMMS) Impact assessment for the construction of a bypass

■ Wiltshire County Council – Development of a specialised emissions inventory for modelling of transport emissions in a town with roads at high gradient. Modelling was undertaken using ADMS-Roads and used to assess options for reducing ground level concentrations by changing traffic flows on the road network.

■ Highways Agency – Secondment to the Highways Agency (major road regulator within England) to assist with the implementation and development of

policy with regard to the assessment of the impacts of road projects on local air quality.

■ Bristol NHS Trust – Impact assessment using ADMS-Roads of the redevelopment of two hospitals on local air quality incorporating the increase in vehicle numbers and the use of emissions control technologies for new generators.

Odour Assessments ■ Anonymous – Completion of comprehensive odour

measurement at an intensive animal farm in New South Wales and detailed atmospheric dispersion modelling to determine dominant source contribution to sensitive receptors with a view to minimising odour impact to surrounding land use.

■ Golden Plains Shire Council – Third Party review of an odour assessment for a proposed open green waste compost facility in central west Victoria

■ Evans Road Development – Audit support in determining potential odour impact from active municipal waste landfill to a proposed residential development.

■ SELX Pty Ltd – ERM completed an odour environmental risk assessment (OERA) for the proposed livestock exchange at Mortlake. The OERA comprised atmospheric dispersion modelling using AERMOD. The OERA was incorporated to the Works Approval Application and Planning Application for the development. ERM additionally provided representation to EPA regarding the approach to the modelling, ensuring a suitable outcome for the development.

■ Regional Infrastructure Pty Ltd – ERM completed an odour environmental risk assessment (OERA) for the proposed livestock exchange at Miners Rest. The OERA comprised atmospheric dispersion modelling using CALPUFF. The OERA was incorporated to the Works Approval Application for the development. ERM additionally provided representation to EPA regarding the approach to modelling and the modelling results ensuring a suitable outcome for the development.

■ Enviromix Pty Ltd – ERM completed an odour impact assessment for an organics recycling facility in eastern Victoria. The proposed facility is located adjacent to an existing broiler and dairy

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farm. Source apportionment of the source groups was used to understand the likely relevant contribution from the sources to overall odour impacts and thus determine the risk from an additional odour source.

■ EPA Victoria – Development of a guideline for undertaking a environmental odour risk assessment for proposed broiler farms.

■ Anonymous – Industrial odour assessment for a Halal Abattoir within Melbourne. Assessment required the generation of a site odour emissions inventory and modelling using Ausplume.

■ Mobil Oil Australia – Works Approval Application for Mobil Oil Australia for odour treatment system for delivery and storage of fuel oil. Dispersion modelling was completed using Ausplume.

■ Mobil Oil Australia – Numerous odour dispersion modelling studies using Ausplume for different grades of fuel oil delivered to terminal, to determine potential impact on surrounding community.

■ Norfolk Environment Waste Services – Odour assessment for landfill site. Odour emissions inventory for open and capped cells and landfill gas turbines. Modelled and assessed the impacts of odour using AERMOD.

Emissions Estimation ■ Qantas Airways Ltd –NPI reporting for Qantas

Airways for sites across Australia since 2009. Annual reviews product usage at all Qantas facilities across Australia to determine the reporting requirements. Emission estimation of NPI species to air, land, water and transfers are then reported to NPI on behalf of Qantas.

■ Shell Australia Pty –NPI reporting for Shell’s distribution and airport terminals for the 2008/2009 reporting year. Review of product usage at all Shell facilities across Australia to determine the reporting requirements. Emission estimation of NPI species to air, land, water and transfers are then reported to NPI on behalf of Shell.

■ Ford Motor Company of Australia –NPI reporting for Ford’s Geelong facility. Review of product usage to determine reporting requirements and estimates emission of NPI species to air, land,

water and transfers. The emission estimates are then reported to NPI on behalf of Ford.

■ South-East Water –NPI reporting for South-East Water. Reviews of processes at all of South-East Water’s treatment plants and estimates emissions to air, land and water for reporting to NPI.

Industrial ■ BPFL – Impact assessment of acid deposition

resulting from emissions from a proposed ammonium nitrate plant on the Burrup Peninsula, WA. The study included consideration of atmospheric chemistry within CALPUFF, dry and wet deposition in addition to atmospheric formation of secondary particulate matter.

■ Holcim Cement – Impact assessment of emissions from a concrete batching plant in Margaret River, WA. Emissions estimation of particulate matter arising from material deliveries, movement and loading of concrete to the mixture trucks was undertaken and dispersion modelling completed using CALPUFF.

■ Orica Mining Services – Impact assessment of emissions from a proposed Ammonium Nitrate Emulsion plant near to Port Hedland, WA. Emission estimation was completed using manufacturer guarantees and dispersion modelling completed using CALPUFF.

■ Sun Metals Limited – Impact assessment of spray drift on surrounding land use from the use of spray evaporators within tailings ponds to reduce pond levels. Dispersion modelling was conducted using the CALPUFF modelling system on a sub-hourly basis using local ground level and upper air meteorological observations as a basis for dispersion modelling.

■ Holcim Cement – Impact assessment of emissions from a cement manufacture plant in New Zealand. Local terrain with a bluff adjacent to the stack meant that complex dispersion modelling using the CALPUFF modelling system was required. Local surface and upper air meteorological observations were used with terrain and land use to develop a CALPUFF compatible meteorological file that was able to account for the local geography.

■ CSL Limited – Generation of emissions inventory and completion of dispersion modelling using

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Ausplume in the assessment of formaldehyde release to atmosphere following the sterilisation of laboratories at two facilities.

LNG Facilities ■ ExxonMobil – ERM completed atmospheric

dispersion modelling for a proposed gas processing facility in Vietnam and three associated power stations. Dispersion modelling was completed using the CALPUFF dispersion model, with information from the model results used as input to the design process to ensure an IFC compliant design. Modelling incorporated the use of ABFlare to correctly assess emissions from flares and impacts to ground level concentrations.

■ Senex Pty Ltd – ERM completed screening dispersion modelling and a GHG assessment for a proposed gas development in the Surat basin. At the time of the assessment the exact location of the equipment was unknown, and dispersion modelling was used to understand the required exclusion zone to facilitate development of the field and central compression stations for this unconventional gas resource.

■ Origin Energy Pty Ltd – ERM has assisted Origin Energy over a number of years regarding emissions from two facilities in Victoria. ERM has undertaken atmospheric dispersion modelling using both AERMOD and CALPUFF for these facilities and estimated acute and chronic impacts to the surrounding land use for submission to EPA. ERM has also assisted Origin in determining the impact to surrounding land use from a flare blowdown event using ABFlare in combination with the AERMOD dispersion model.

■ REPSOL – ERM undertook an assessment of the potential for mercury impacts to the surrounding land use from the proposed development of a gas extraction, processing and gas to energy facility in PNG. ERM used CALPUFF together with ABFlare for intermittent flare use to determine the impact to the surrounding land use.

■ BLNG – Assessment of the potential for impact to surrounding sensitive receptors from flaring operations. Dispersion modelling was undertaken using CALPUFF adopting the ABFlare

methodology to ensure appropriate estimation of flare impacts to surrounding land use.

■ QGCLNG – Greenhouse gas assessment for the Surat North Gas Field Project for Scope 1 and 2 emissions were quantified for the project lifecycle in accordance with the NGERs technical guidelines and compared to State and national greenhouse gas inventories at peak emission production.

■ BSPL – Assessment of atmospheric emissions from Brunei Shell operations across Brunei. Operations were reviewed to determine likely emissions and using meteorological data define a monitoring regime to define baseline concentrations around BSPL.

■ ExxonMobil – Screening assessment of coastline impact from a proposed FLNG. Dispersion modelling used CALPUFF with a coarse grid at sea and fine resolution grids around the coastline to demonstrate potential for impact from NOx emissions.

■ Anonymous – Air Quality assessment as part of EIS for new LNG plant in Queensland. TAPM and CALMET used to generate local meteorological conditions with CALPUFF used for dispersion modelling.

■ PNG LNG – Air quality dispersion modelling using CALPUFF for two potential suppliers to the PNG LNG facility to the west of Port Moresby in Papua New Guinea. The assessment comprised sourcing local meteorology and land use information. Developing appropriate meteorological files for the site through the use of TAPM and CALMET, and dispersion modelling of all sources using CALPUFF.

■ BHP –Screening assessment of the proposed Macedon LNG facility in northern WA was undertaken to determine the potential impact from operation on surrounding facilities using Ausplume.

■ BOC –Air quality impact assessment of a proposed LNG facility in northern Tasmania as part of an effect statement. TAPM was used with locally measured meteorological data to generate inputs to Ausplume and Ausroads. Assessments of emissions from industry were undertaken using

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Ausplume, whilst emissions from vehicles using the local road network were modelled using AusRoads. The combination of results from Ausplume and AusRoads, for a small local network, enabled the provision of a cumulative impact assessment for sources with changed emissions.

■ Anonymous – An initial screening assessment for a proposed domestic gas facility in northern WA was undertaken to determine the potential impact from operation on surrounding facilities using Ausplume.

Offshore Gas Facilities ■ Brunei Shell Pty Ltd – Atmospheric Dispersion

modelling was undertaken using the CALPUFF dispersion modelling to determine the contribution from platform operations to ambient concentrations on the shoreline.

Emergency Release Modelling ■ Orica – Emergency release assessment of

emissions from the nitric acid stack and consideration of potential of impact on other site buildings through the use of near field dispersion modelling at an ammonium nitrate plant.

■ Anonymous – Emergency release modelling of CO2 storage facility to determine potential impact from the puncture of CO2 tanks on surrounding housing, roads, stock, fauna and flora.

■ Gasnet Pty Ltd – Emergency release modelling of natural gas from a gas compression station on a second by second basis to define the development of the plume area over the period of the release and classify the extent of the hazardous area.

■ Australian Pipeline Association – Emergency release modelling of natural gas at a gas compression station from within a building. The study was used to determine the time taken for gas to exit the building during an accidental release, and to determine whether concentrations would be elevated in locations where sensors had been placed as part of the emergency shut-down mechanism.

Ambient Monitoring ■ Calleja Properties Pty Ltd – Expert witness

testimony on the impacts of dust from the regrading of a landfill cap to accommodation future

use. Assessment incorporated the design and recommendation of a monitoring system to prevent impact to nearby sensitive receptors.

■ Anonymous – Baseline monitoring plan development and implementation for the redevelopment of a large tourist attraction in Singapore. Project involved consideration of siting for monitoring during baseline measurement, analysis of results and development of an environmental management plan for construction.

■ Brunei Shell Company Pty Ltd – Design and implementation of ambient monitoring of particulate and volatile organic compound concentrations during a routine flaring event at a nearby school. ERM selected the monitoring equipment and undertook monitoring throughout the flaring event to determine impact at a sensitive use location nominated by community.

■ Singapore Cross Island Line – Baseline monitoring plan development and implementation to inform Environmental Management Plan for tunnel shaft construction within a national park.

■ Sell & Parker – Air quality assessment as part of an EIS which included atmospheric dispersion modelling and design of a boundary monitoring plan with trigger levels to prevent impact to the surrounding land use.

■ Orica Mining Services – Development of an ambient monitoring plan for use during construction to ensure ambient concentrations of dust generation were in acceptable limits. Work included sourcing and specification of monitoring equipment and discussion / sign-off from the regulator.

■ Singapore North-South Expressway - Internal technical peer review for baseline measurements and qualitative impact assessment for the Singapore North South Expressway.

Power Generation ■ Energy Australia – Independent review as part of

environmental due diligence on the emission concentrations from two gas fired power stations in Victoria and the potential for constraint of operation as a result of environment protection licence limits.

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■ Java 1 – Assessment of a proposed power station in Indonesia adjacent to the coastline. Modelling was completed using the CALPUFF dispersion model to account for the proximity of the coastline and the potential for coastal fumigation.

■ Newcrest Mining Ltd –ERM undertook atmospheric dispersion modelling using CALPUFF to determine the potential impact to the surrounding land use from a change in fuel oil source with a higher sulphur content. The modelling incorporated emissions from three power plant generation areas within the production facility at Lihir.

■ AGL Limited – Assessment of proposed peak loading gas fired power station in the west of Victoria. Advanced dispersion modelling used the CALPUFF modelling system, and has incorporated observed ground level and upper air observed meteorological conditions. The assessment has considered start-up conditions on a sub-hourly basis and base load operations on an hourly basis, in addition to taking account of a further proposed base load power station by another operator in the vicinity. Following submission of the Works Approval Application to EPA, a presentation of the potential impacts was made to the Victorian Planning Panel.

■ SCB PTES – Assessment of a proposed expansion to a based load and peak load power generation facility in Sulawesi Selatan.

■ AGL Limited– Assessment of proposed change in operating hours from peak loading to base load capacity for a gas fired power station in northern Melbourne using Ausplume.

■ Origin Energy – Impact assessment of a proposed change in fuel use and construction of a new turbine at a facility in northern Queensland using the Ausplume dispersion model. The assessment incorporated the generation of a meteorological dataset, dispersion modelling and assessment and the use of a regulatory airshed model for the local city.

■ Origin Energy – Determination of minimum stack height for the redevelopment of a gas fired power station in central Queensland. The assessment incorporated the development of a meteorological

dataset and the modelling of emissions from a variety of stack heights, taking in to account building downwash to finalise the redevelopment design.

Contaminated Land Management ■ Viva – Evaluation of VOC and odorous emissions

from contaminated land during excavation and treatment through windrow volatilisation for a former storage facility in NSW. Sampling was undertaken via collection of soil samples and delivery to a laboratory for odour and volatile analysis through flux hood samples. Dispersion modelling was undertaken using CALPUFF. The results of the assessment were used to define the remediation action plan in terms of the area of land that could be excavated.

■ Roche – Evaluation of VOC and odorous emissions from contaminated land during remediation activites to evaluate the need for capture within a marquee and treatment options. Monitoring undertaken through collection of samples and delivery to a laboratory for odour and volatile analysis through flux hood samples. Dispersion modelling for proposed remedial action plan using CALPUFF.

■ Jemena – Evaluation of emissions from contaminated sediments during remediation activities to evaluate potential for odour impacts during remediation activities. Project included measurement of odorous emissions from the contaminated sediments using flux measurements and dispersion modelling using CALPUFF.

■ Anonymous – Evaluation of emissions from land contaminated with TCE during renewal of a concrete slab within an industrial facility. Assessment of impact undertaken using dispersion modelling to determine impact on surrounding sensitive receptors.

■ Exxon Mobil – Evaluation of emissions from an air stripper and thermal oxidiser for the remediation of contaminated ground water in Melbourne. Evaluation included the use of Ausplume to demonstrate potential for impacts to surrounding land use.

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■ Shell – Evaluation of emissions from a mobile thermal oxidiser used to treat contaminated ground water in rural New South Wales.

■ Anonymous – Evaluation of emissions from contaminated land during remediation activities for the construction of a new hardware store. Assessment included fluxhood monitoring of emissions from the contaminated soil, dispersion modelling and recommendation for minimisation of impact during remediation.

Mining / Quarries ■ Hanson Pty Ltd – ERM completed atmospheric

dispersion modelling as part of environmental approvals for a quarry expansion in NSW. In addition to the expansion of the quarry area, the tonnage of the project was proposed to increase as well as the introduction of an asphalt plant and concrete batching plant. Through the use of the dispersion modelling, ERM worked effectively with the proponent to ensure a compliant development through the use of effective mitigation measures.

■ BHP Ltd – ERM completed a review of results from LiDAR monitoring undertaken in Port Hedland to understand the relationship between LiDAR results and ambient air quality monitoring.

■ Newcrest Mining Ltd – Dispersion modelling of projected emissions resulting in a proposed change of fuel for the electricity power stations at one of Newcrest’s mines. Dispersion modelling was undertaken using the CALPUFF dispersion model.

■ Newcrest Mining Ltd – ERM undertook atmospheric dispersion modelling of odour emissions from the xanthate floatation plant to determine impact to the surrounding community. The atmospheric dispersion modelling, using CALPUFF, assisted in identifying the float plant as the likely cause of odour complaints and use of a variance in pH reduced the odour generation.

■ Volcanic Construction – Atmospheric dispersion modelling study for the expansion of a quarry in northern New South Wales to provide material for the Pacific Highway duplication. Dispersion modelling was undertaken using CALPUFF taking account of dust emissions from handling, vehicle movement, crushing and windblown emissions.

Time varying emissions were used to represent realistic emissions from operation of the facility.

■ Hanson Construction Materials – Dispersion modelling study for the expansion of a quarry in northern New South Wales. Dispersion modelling was conducted using CALPUFF, and taking account of dust emissions from handling, vehicle movement, crushing and windblown emissions. Time varying emissions were used to represent realistic emissions from operation of the facility.

■ MMG Pty Ltd – ERM developed emission estimation spreadsheets for the Kinsevre and the Las Bambas mines. The emission estimation spreadsheets were developed to assist with corporate reporting and used emission estimation techniques taken from the NPI and NGERs for emissions of general chemicals and also GHGs. The spreadsheets incorporate macros that facilitate the estimation of emissions from general site data which is input on a weekly basis.

■ Weda Bay Nickel – Dispersion modelling study as part of ESIA to determine impact from mining and process plant activities. Dispersion modelling considered multiple scenarios for variation throughout the mining schedule and included deposition of metals associated with particulate matter within the ore on the surrounding land area.

■ Rio Tinto –Review of potential climate and meteorological impacts determined by the UK Meteorological office as a result of the proposed mine adjacent to the Simandou Ridge in Guinea, West Africa.

■ Cedar Point –Assessment of impact from dust for a proposed quarry in New South Wales. Dispersion modelling used the CALPUFF modelling system and required development of a meteorological model for the local area followed by emission estimation and dispersion modelling.

■ Xstrata Zinc – Internal technical peer review and guidance for an impact assessment for a five million tonne per annum zinc-lead and silver deposit.

■ Lihir Gold Limited – Comprehensive impact assessment as part of an EIA for expansion of the mine processing area. The project included emissions inventory generation and modelling for

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power generation, process plant, unmade road dust generation, tailpipe emissions. Complex dispersion modelling was undertaken using the CALPUFF modelling system to account for steep terrain surrounding the site on three sides and the ocean on the fourth side.

■ Bendigo Mining Limited – Revised operational procedures required the modelling of particulate and hydrogen cyanide emissions using Ausplume from operations at a proposed mine for comparison with the approved program.

■ BHPB – Dispersion modelling of dust generation for a proposed mine expansion in Queensland. Dispersion modelling included development of a meteorological model for the local area, emissions estimation for a number of sources and dispersion modelling using CALPUFF.


APPENDIX B INSTRUCTIONS

[7849160: 24393254_1]

Interstate offices Canberra Sydney Affiliated offices around the world through the Advoc network - www.advoc.com

Email Letter

From Date Terry Montebello 26 June 2019 Direct Email 03 9258 3606 [email protected]

To Organisation Email Iain Cowan ERM [email protected]

Our Ref TGM:7849160 North East Link Inquiry and Advisory Committee Hearing Dear Mr Cowan We continue to act for Banyule City Council (Banyule), City of Boroondara (Boroondara) and City of Whitehorse (Whitehorse) (collectively, the Councils) in relation to the Joint Inquiry and Advisory Committee (IAC) for the North East Link (Project). We are instructed to engage you to provide expert evidence in the area of air quality. The IAC has been appointed:

▪ to hold an inquiry into the environmental effects of the Project under section 9(1) of the Environmental Effects Act 1978; and

▪ to review the draft planning scheme amendment prepared to facilitate the Project under section 151 of the Planning and Environment Act 1987.

Further details regarding the role of the IAC is set out in paragraphs 1 and 2 of the Terms of Reference. The biography for each committee member of the IAC is available here. The IAC will hold a public hearing commencing on 25 July 2019. Scope of Instructions

You are instructed to:

1. review the Ministerial Guidelines for assessment of environmental effects under the Environmental Effects Act 1978 (2006);

2. review the exhibited North East Link Environment Effects Statement (EES) documents, relevant to your area of expertise;

3. review:

(a) the Councils submission on the EES, dated 7 June 2019;

Lawyers Collins Square, Tower Two Level 25, 727 Collins Street Melbourne VIC 3008 Australia

Telephone 61 3 9258 3555 Facsimile 61 3 9258 3666

[email protected] www.maddocks.com.au

DX 259 Melbourne

https://s3.ap-southeast-2.amazonaws.com/hdp.au.prod.app.vic-engage.files/3115/5496/2888/Signed_ToR_for_NEL_IAC_S8NS16AD19041115320.pdf

https://s3.ap-southeast-2.amazonaws.com/hdp.au.prod.app.vic-engage.files/2715/5770/0330/North_East_Link_IAC_Biographies.pdf

https://www.planning.vic.gov.au/__data/assets/pdf_file/0026/95237/DSE097_EES_FA.pdf


https://northeastlink.vic.gov.au/environment/environment-effects-statement-ees/environment-effects-statement-documentation

https://s3.ap-southeast-2.amazonaws.com/hdp.au.prod.app.vic-engage.files/9915/6074/7490/Submission_716_Banyule_City_Council_Boroondara_City_Council_and_Whitehorse_City_Council.pdf

[7849160: 24393254_1] page 2

(b) the IAC report on Preliminary Matters and Further Information Request; and

(c) any other submissions or documents we subsequently refer to you;

4. prepare an expert witness report that contains your opinion on the following matters, as relevant to your area of expertise:

(a) does the EES adequately document and assess the nature and extent of the environmental effects of the Project? In addressing this question please explain where you are satisfied with the content of the EES and why, and if not, what if any deficiencies exist in the documentation and/or assessment of the nature and extent of environmental impacts contained in the EES;

(b) can the Project as described in the EES achieve a level of environmental performance which is consistent with relevant legislation, documented and endorsed policy or acknowledged best practice?

(c) if the Project, as described in the EES cannot achieve a level of environmental performance which is consistent with relevant legislation, documented and endorsed policy or acknowledged best practice, are there any recommendations that you would make as to specific measures which you consider necessary and/or appropriate to prevent, mitigate and/or offset adverse environmental effects? If so, please explain your reasoning in detail. To the extent that it is within your expertise to comment upon the feasibility of any of your recommendations, please state whether or not any recommendations are feasible, explaining your reasoning.

(d) how does the Project as described in the EES respond to the principles and objectives of “ecologically sustainable development” as defined in the Ministerial Guidelines for assessment of environmental effects under the Environmental Effects Act 1978 (2006);1

(e) are there any recommendations that you would make as to specific measures which you consider necessary and/or appropriate to improve the response of the Project to the principles and objectives of “ecologically sustainable development”? If so, please explain your reasoning in detail. To the extent that it is within your expertise to comment upon the feasibility of any of your recommendations, please state whether or not any recommendations are feasible, explaining your reasoning; and

(f) to the extent that the content of the draft planning scheme amendment, works approval application or environmental performance requirements (EPRs) lies within your expertise, do you have any recommendations for changes that should be made to the draft planning scheme amendment, works approval or planning approval and/or EPRs in order to improve the environmental outcome of the Project.

5. in due course, review and comment on other parties’ expert evidence in relation to your area of expertise.

6. participate in any expert conclave requested by the IAC; and

7. present your evidence at the IAC Hearing. You should anticipate preparing a short (no more than 30 minutes) presentation to facilitate the delivery of your evidence. The presentation is to be drawn from your expert witness report and may respond to other expert reports (as relevant).

Please ensure you are familiar with the requirements of the Planning Panels Guide to expert evidence (DOCX, 81.8 KB), April 2019 and ensure that your evidence is prepared in accordance with the requirements set out in the Guide. 1 At page 5.

https://s3.ap-southeast-2.amazonaws.com/hdp.au.prod.app.vic-engage.files/4515/6107/1277/5._Preliminary_Matters_and_Further_Information_Request.pdf



https://www.planning.vic.gov.au/__data/assets/word_doc/0026/98162/G2-Guide-to-Expert-Evidence-Apr-2019.DOCX

https://www.planning.vic.gov.au/__data/assets/word_doc/0026/98162/G2-Guide-to-Expert-Evidence-Apr-2019.DOCX

[7849160: 24393254_1] page 3

Relevant documents The exhibited EES documents can be accessed at: https://northeastlink.vic.gov.au/environment/environment-effects-statement-ees/environment-effects-statement-documentation. Please also consider any relevant “information updates” contained on the NELP website: https://northeastlink.vic.gov.au/environment/environment-effects-statement-ees/information-updates Please let us know if you require any of these documents in hard copy. We also consider the background information contained in our letter requesting your fee proposal dated 18 April 2019.

Key Dates

We are currently waiting on written directions from the IAC to confirm the key dates for the hearing. We will provide these to you when they come to hand. In the meantime, please note the following anticipated key dates:

▪ Your expert witness statement will need to be circulated by 10:00am on Monday 15 July. We kindly ask that you provide us with a copy of the report no later than 5:00pm on Tuesday 9 July.

▪ A conclave of specified fields of experts is likely to be scheduled to occur on the week of 15 July. We will confirm this as soon as possible;

▪ Presentation of the proponent’s case is scheduled to commence on Thursday 25 July; and

▪ Presentation of the Councils’ case is likely to be scheduled to commence in mid-August. We will confirm this as soon as possible.

Key Contacts

Council’s representative for this engagement will be Terry Montebello, Partner, Maddocks [email protected] and Phone: 03 9258 3698.

Terry is being assisted by Sophie Jacobs, Senior Associate, Maddocks Phone: 03 9258 3546 Email: [email protected]

Please contact Sophie Jacobs on 03 9258 3546 if you have any queries or wish to discuss any aspect of these instructions with us. Yours faithfully Terry Montebello Partner



https://northeastlink.vic.gov.au/environment/environment-effects-statement-ees/information-updates




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Documents

North East Link Air Quality Assessment Review