North East Link Project Joint Inquiry Advisory Committee · 15. As an example, the construction site offices may be erected on the construction compound, or the construction project

EXPERT REPORT

North East Link Project

Joint Inquiry Advisory Committee

12th of July 2019

Expert report prepared for Marcellin College

Instructions received from Rigby Cooke Lawyers

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Expert Report North East Link – Joint Advisory Committee

Table of Contents I. EXPERT ............................................................................................................................................................... 3

A. NAME, ADDRESS AND EXPERTISE ............................................................................................................................. 3 B. QUALIFICATIONS AND EXPERIENCE ........................................................................................................................... 3

Education ............................................................................................................................................................... 3 Experience ............................................................................................................................................................. 4

C. CONFLICT ............................................................................................................................................................ 6

II. INSTRUCTIONS ............................................................................................................................................ 7

A. GENERAL .......................................................................................................................................................... 7 B. DOCUMENTS INSTRUCTED TO CONSIDER .......................................................................................................... 7 C. ADDITIONAL MATERIALS USED IN FORMING OPINION .................................................................................................... 8

III. FINDINGS ....................................................................................................................................................... 9

A. INTRODUCTION ................................................................................................................................................. 9 B. PROPOSED CONSTRUCTION COMPOUND ......................................................................................................... 11

Size of the proposed compound ........................................................................................................................... 11 Possible uses of the proposed compound ............................................................................................................ 13 Duration of the proposed compound ................................................................................................................... 15

C. MARCELLIN SUBMISSIONS .............................................................................................................................. 16 Amenity ................................................................................................................................................................ 16 Ground Movement ............................................................................................................................................... 19

IV. DECLARATION ........................................................................................................................................... 21

V. APPENDIX A – LETTER OF INSTRUCTION ............................................................................................. 22

VI. APPENDIX B – EXTRACT FROM EES DOCUMENTATION ............................................................. 23

VII. APPENDIX C – MARCELLIN SUBMISSIONS ....................................................................................... 24

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I. EXPERT

A. Name, Address and Expertise 1. I am Clark C Briggs, of Suite 15, 574 Plummer St, Port Melbourne, 3207. I am a Civil Engineer

with expertise in the construction, planning, costing and management of civil infrastructure.

I am employed by CMC Group Int Pty Ltd as a consultant actively working in the civil and

building industry, specialising in project management, commercial management and

construction planning.

B. Qualifications and Experience

Education 2003 – 2006 Bachelor of Engineering (Civil), Major in Geotechnical Engineering with Honors

from Monash University, Victoria.

2009 – 2013 Masters in Business Administration with Honors from Newcastle University, NSW.

2014 – 2017 Masters of Construction Law from Melbourne Law School, The University of

Melbourne, Victoria.

2018 – 2020 Owners and Presidents Program (OPM 54), Harvard Business School, Boston, MA.

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Experience

2003 – 2011 CPB Contractors – Formally known as Leighton Contractors, part of the CIMIC

Group.

• Roles range from Civil Engineer to Senior Project Engineer working in heavy infrastructure

projects in the Mining and Civil industry.

• Mining projects included operations in coal, iron ore and quarrying sites in Queensland,

New South Wales and Western Australia.

• Civil Projects include road, rail, tunnel and building construction. All projects centred

around earthworks, cut to fill operations, heavy civil machines and granular pavement

construction.

2011 – 2013 – Robson Civil - NSW

• Project Management of a mining contract on a BHP Billiton Site. Plant included

100+ tonne excavators, crunching equipment, and 80t+ off highway haul trucks.

2013 – 2014 CPB Contractors – Formally known as Leighton Contractors, part of the CIMIC

Group.

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• Senior Project Engineer responsible for the construction of granular pavements,

including roads, carparks and service relocations.

2014 – 2019 CMC Group Int.

• Contract Roles with the following Major Civil Contracting Companies;

o John Holland Group -WA & Vic

o Lend Lease - NSW

o Fulton Hogan – Vic

o CPB Contracting Vic

o Halikos Group - NT

• Contact Roles with Government Departments

o Level Crossing Removal Authority – Victoria

o Department of Planning, Transport and Infrastructure – South Australia

o Transport for NSW - NSW

2. My expertise in the planning, managing and construction of civil infrastructure projects allows

me to comment with a high degree of authority on the topics contained in this report and

surrounding the hearing.

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C. Conflict 3. CMC Group Int as a business, nor Clark C Briggs as an individual either know or has ongoing

business with either entity in the project.

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II. INSTRUCTIONS

A. General 4. In a letter dated the 1st of July 2019, I received instructions from Rigby Cooke Lawyers.1 The

letter outlined some background to the project and instructions.

5. The instructions were as follows;2

B. Documents instructed to consider 6. In preparation of this report, I have been provided with and instructed to rely upon the

following documents, that were provided with the letter of instruction:

• An extract from the Environment Effects Statement [ESS] documentation,3

• A full and complete copy of the ESS,

1 The letter of instruction has been included in Appendix A, in its complete form. 2 Extract from the letter of instruction. 3 A copy is included in Appendix B.

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• Early Design Schematics and Artist Impressions September 2018,

• North East Link Melways Map October 2018,

• Submission dated 7 June 2019,4

• Terms of Reference,

• EES Transport Model Peer Review, and

• Overview of Social Impacts.

C. Additional materials used in forming opinion

7. No other material information was relied upon in forming the views expressed in this report.

4 As the submissions are a primary source of information to inform my opinion, a copy has been provided for ease in Appendix C.

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III. FINDINGS

A. Introduction In the first instance, I agree with the points put forward in the Marcellin Submissions. In

particular, the statement below provides a clear outline of whom shall bear the effects of the

project should the land as proposed be temporally occupied by the construction works.

8. Within this report, I will layout and provide my findings in line with how and when they were

presented in the Marcellin Submissions. Where appropriate, I will copy an extract of the

Marcellin Submissions and provide findings or comments in line with the instruction,

‘whether the size of the proposed compound on the Marcellin Land, and the need for the

project to occupy the school for such extended periods, is necessary and appropriate’.

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9. Firstly however, I will deal more generally with the question regarding the size of the

proposed compound, the duration of occupation and possible uses for the construction

compound as proposed and shown below.5

5 Specifically, Sheet 22 of 42 of the ‘North East Link Project - Horizontal plan: construction reference design’.

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B. Proposed Construction Compound

10. As per the image above, the proposed construction compound to the right-hand ride of the

tunnel entrance, will cut directly through at least two of the Marcellin sporting fields, this will

render them inoperable for the duration of the project.

11. Depending on the material that the boundary fence of the construction compound is

constructed from, there may be further detrimental impacts on the adjacent paying surfaces.

12. Commonly these type of fences are constructed from either cyclone wire chain mesh, or a

hard barrier, known as hoarding, constructed of wood or timber, commonly seen outside

construction sites in the Melbourne CBD, and may impact the safe usage of the adjacent

playing surfaces.

Size of the proposed compound

13. From the image, one can determine the proposed construction compound is of quite a

substantive size.6 This finding is in contrast to other comparable construction project’s

compounds in Melbourne and Sydney, where by the site compounds are significantly smaller

in size than the one proposed, given it is one of many the project will utilise.7

6 This has been completed by scaling of the drawing other objects to estimate the area proposed. This has then been cross referenced to the sporting field sizes as a check. 7 Melbourne Metro Tunnel, Sydney Light Rail Project, Westconnex and Sydney Metro as examples.

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14. An element in determining the size of a construction compound is where the project choose

to house their staff. This means where and in what configuration the site sheds or site offices

are placed.

15. As an example, the construction site offices may be erected on the construction compound,

or the construction project may hire, lease or purchase an existing office building close by

and use it as the site office. The latter decision would significantly reduce the required size of

land required in close proximity to the project.8

16. Further, the size of a construction compound is generally determined by its economics. For

instance, how cheaply and quickly the compound can be constructed. By way of example, a

more expensive construction compound, but one that would utilize a tenth of the area, would

be one that stacked site sheds vertically, rather than placing them horizontally.9 This is as a

result of the requirement for greater foundations to withstand the taller structure, in

comparison to when site sheds are placed on the natural ground surface and thus require

significantly less foundation work and design. This has a direct correlation to the cost of and

the required size of the construction compound.

8 Melbourne projects where the site team were housed in existing structures and hence the construction compound size was significantly reduced: City to Tullamarine Widening Project, LXRA [Grange Road, Bentleigh and others] and Melbourne Metro Head Office. 9 Examples of Melbourne Projects with vertical site sheds in use are: Melbourne Metro, CBD buildings along Flinders Street, LXRA projects [Caulfield to Dandenong, 9 crossings]. Melbourne Projects where larger horizontal site sheds are used are Western Distributer and LXRA projects [NEPA]

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17. During the planning phase of the project, and utilizing available controls, the Marcellin land

could remain unaffected, and its students unimpacted. This could occur by ensuring the

construction compound size is reduced or removed by utilizing the options available above,

and ensuring the construction compound is located on the other side of the freeway, or in

existing buildings.

18. Following the discussions above, the size of the proposed compound on the Marcellin Land

as depicted in the plan above is thus not necessary, and inappropriate given the impacts. At

this stage of the planning process, the construction compound could easily be moved to other

adjacent areas that would impose a lower, or insignificant level of impact on incumbent users.

Possible uses of the proposed compound

19. As an example, a list below has been created to outline the possible uses for construction

compounds, the below list is not exhaustive:10

1.1. Placement of either primary or satellite site sheds:

• Further to the above, these ‘sheds’ will house the projects engineering, surveying,

supervision, management and support staff. The site sheds will consist of a temporary

10 From the documents provided, it is unclear what the proposed construction site will exactly be used for.

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structure erected to act as an office. There will be absolution blocks, car parks, food

vendors, small and medium plant and tool storage and a substantial amount of

carparking made available.

1.2. Material storage, either from the site or to be utilized on the site:

• Materials to be used on the site could range from small concrete drains for

stormwater to larger items such as bridge beams,

• Materials that have come from the site would commonly be spoil material from the

tunneling operations,

• A washout facility would be located there for the hydro excavation truck to save on

EPA disposal fees by separating the solids from the liquids,

• Concrete liners for the tunneling operations, and

• Bitumen and hazardous materials.

1.3. Location for plant to enter site and be stored:

• In certain circumstances, some items of plant require inspection prior to entering

construction sites, as such these compounds can serve as a location to perform the

inspections on plant that has been bought to site, possibly from interstate or overseas.

• Makeshift maintenance facilities will be established to service and maintain the plant

and equipment,

• Refueling and diesel storage locations established, and

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• Plant and equipment wash facilities will be erected.

20. Given the circumtances of contaminated materials and hazardous substances being stored

within the construction compound, the need for the project to occupy the school’s land for

such extended periods is inappropriate and it should be relocated to a site or location that

would not impact the Marcellin students and the school.

21. Additionally, I do not believe the project needs to place its site offices on the land and could

easily relocate them to adjacent lands or established buildings, which would be more

appropriate and would eliminate any impact to the Marcellin School or its students.

Duration of the proposed compound

22. From the documents,11 it is noted the proposed construction compound will be used for an

estimated 7-year construction period.

23. From my experience, the period of occupation will be more than the proposed 7-year

construction period. This is as a result of many factors, however some examples of items

impacting the 7-year planned period would include:

• Site investigation works,

11 ESS.

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• Design works,

• Works to relocate existing infrastructure to allow construction works to

commence,

• The defect and post practical completion maintenance work that are essential to

a successful construction project, and

• The significant possibility of substantive project delays.

24. As such, my estimated duration that the proposed construction compound may impact the

students at Marcellin could range from 10 to 15 years.

25. This duration of impact could be eliminated or significantly reduced by ensuring the proposed

construction compound is located so as to not impact the operation of the Marcellin School.

26. I find the duration and severity of the impact imposed by the proposed construction

compound highly inappropriate, unnecessary and given it can be moved from the School

grounds, incongruous to consider.

C. Marcellin Submissions

Amenity

27. As detailed in the submissions, dust, noise and vibration are key concerns of Marcellin, and

an everyday event in construction actrivities. An extract below has been reproduced.

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28. Even when dust, vibrations and noise are actively managed and monitored by a construction

project, they will still exist in levels that will have a detrimental effect on the Marcellin lands,

it is the nature of heavy infrastructure construction.

29. The impact could be as simple as an item of plant moving across the proposed compound.12

29.1. This item of plant by law, is required to have audible devices to alert people within

the vicinity it is moving, this is for their safety. Flashing lights will be fitted and given its

sheer size and weight, the vibrations transferred through the land into the school will be

substantial.

29.2. This scenario does not take into account the actual item of plant working or

constructing the project, just moving within the compound. When an item of plant, in

particular piling rigs, perform their intended tasks, the level of vibrations will be

substantially higher and with a high degree of certainty, disrupt the students from

learning in the class rooms.

12 Excavator, piling rig, drill rig, tunnel boring machinery, loader or other item of plant.

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30. The aforementioned impacts, even under severe conditions to limit, restrict or contain dust,

vibrations and noise, will have a detrimental impact to the Marcellin school and its students.

31. As such, the proposed construction compound in its location on the Marcellin land is

inappropriate for the longstanding use of the land and importance of amenity for the

students. Further, given the duration and exposure levels of noise, dust and vibrations

created by the compound, it is necessary to remove the school grounds from the projects

proposed construction compound.

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Ground Movement

32. As highlighted in the ESS, and noted in the submissions, the proposed construction compound

will have a substantial impact on the levels of the land following its use. The impact of the

weight, constant vibrations, loading and unloading, and compaction will render the soil and

fields below it unable to be used for their intended purpose, without significant remediation

works or full reconstruction.

33. This level of change will significantly impact the regolith layer of the sporting fields and will

damage the irrigation line under the service.13 The likelihood of the sporting field being

13 Regolith is the layer of broken and unconsolidated rock and soil material that forms the surface of the land and covers the bedrock nearly everywhere. An understanding of its properties and structure is very important in topics such as groundwater supply, soil conservation and construction efforts.

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handed back in a condition that they could be used in, without the need to undergo years of

repair work following the construction compound would be extremely low.

34. As such, I believe it is inappropriate for the proposed construction compound occupy the land

for both the planned durations, extended durations or reduced durations given the significant

impact the compound would have on the Marcellin land both in the short and long term.

35. The proposed construction compound could carve out the playing fields to preserve their use

and integrity without lengthy remediation works after the project is completed.

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IV. DECLARATION

36. In completing this report, 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.

Clark C Briggs

Director

CMC Group Int Pty Ltd

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V. APPENDIX A – LETTER OF INSTRUCTION

Level 11, 360 Elizabeth Street Melbourne Victoria 3000

GPO Box 4767 Melbourne Victoria 3001

T +61 3 9321 7888 F +61 3 9321 7900

www.rigbycooke.com.au

ABN 58 552 536 547 DX 191 Melbourne

Our ref: REA:20190693 Direct dial: 03 9321 7832 Your ref: Direct email: [email protected] Page: 1/10

Liability limited by a scheme approved under Professional Standards Legislation 20190693_3202910v1

1 July 2019 Clark Briggs CMC Group Suite 15, 574 Plummer Street PORT MELBOURNE VIC 3207 By Email: [email protected] Dear Clark, North East Link We act for Marcellin College (Marcellin) in relation to the proposed freeway connection between the M80 Ring Road and the Eastern Freeway (North East Link). A joint Inquiry and Advisory Committee (IAC) has been appointed to consider the Environment Effects Statement (EES), Works Approval Application (WAA), draft planning scheme amendments (Banyule, Boroondara, Manningham, Nillumbik, Whitehorse, Whittlesea and Yarra Planning Schemes) and public submissions in accordance with the Terms of Reference approved by the Minister for Planning on 11 April 2019. It is proposed to use parts of the Marcellin campus as a compound during construction of the North East Link (Marcelling Compound). Instructions We are instructed to request you to review our client’s submissions in relation to the Marcellin Compound and provide a preliminary opinion on whether the size of the proposed compound on the Marcellin Land, and the need for the project to occupy the school for such extended periods, is necessary and appropriate. Subject to your preliminary opinion, we will instruct you to prepare and present evidence at the Public Hearing. The Public Hearing is commencing on 25 July 2019 at The Veneto Club, 191 Bulleen Road, Bulleen. We have requested our submission be scheduled 19 or 20 August. Expert evidence must be circulated by 15 July 2019. Background EES

On 12 January 2018, North East Link Authority (NELA) provided the Minister for Planning with a project outline, and requested that the Minister declare the project to be 'public works' for the purposes of section 3(1) of the Environment Effects Act 1978.

mailto:[email protected]

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

Our ref: REA:20190693 Letter to: Clark Briggs Your ref: Page: 2/10

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On 2 February 2018, the Minister for Planning declared the North East Link Project as ‘public works’ requiring an Environment Effects Statement, including community consultation and an independent panel review to inform the Minister's Assessment and decision-making. North East Link Project (NELP) is managing the Project on behalf of the Victorian Government. Exhibition of Environment Effects Statement

The EES includes:

x A Summary Report: A short outline of key information in the EES;

x Main report chapters: Comprehensive summaries of the findings from each study area;

x Technical reports: Detailed information about the study methods

and the findings; and

x Map Book and Attachments (refer to folder titled Map Book): These include a Map Book with drawings of the design assessed for the EES and the Urban Design Strategy.

The EES also includes Draft Planning Scheme Amendment and a Works Approval Application for the construction of the tunnel ventilation system.

Please use the following links to the websites for: x EES Exhibition; and x the whole EES website.

Proposal In summary, the project includes:

x M80 Ring Road to Lower Plenty Road: From the M80 and Greensborough Bypass to the northern tunnel portal, this section will include above, below and at surface road sections, with new road interchanges at M80, Grimshaw Street and Lower Plenty Road.

x Tunnels: From the northern tunnel portal located just north of Lower Plenty Road to south of Manningham Road, twin tunnels would travel under residential areas, Banyule Flats and the Yarra River. Near each tunnel portal supporting tunnel infrastructure would be required, including ventilation structures and substations. This section would include a new interchange at Manningham Road.

https://northeastlink.vic.gov.au/__data/assets/pdf_file/0004/364072/NELP-EES-Summary-report.pdf

http://northeastlink.vic.gov.au/__data/assets/pdf_file/0020/364241/NELP-EES-Map-book-Key-Map-and-Horizontal-Alignment-Plans-Part-1.pdf;%20http:/northeastlink.vic.gov.au/__data/assets/pdf_file/0019/364240/NELP-EES-Map-book-Horizontal-Alignment-Plans-Part-2.pdf;%20http:/northeastlink.vic.gov.au/__data/assets/pdf_file/0006/364236/NELP-EES-Map-book-Vertical-Alignment-Plans-and-Indicative-Cross-Sections.pdf

http://northeastlink.vic.gov.au/__data/assets/pdf_file/0005/364091/NELP-EES-Attachment-V-Planning-scheme-amendment.pdf

http://northeastlink.vic.gov.au/__data/assets/pdf_file/0006/364245/NELP-EES-Attachment-VI-Works-approval.pdf

http://northeastlink.vic.gov.au/__data/assets/pdf_file/0006/364245/NELP-EES-Attachment-VI-Works-approval.pdf

https://engage.vic.gov.au/north-east-link-project

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


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x Bridge Street to Eastern Freeway: This section would include open cut and bored or mined tunnel with the southern tunnel portal located south of the Veneto Club. Further south, surface road and viaduct structures would connect to the Eastern Freeway via a new interchange.

x Eastern Freeway upgrades: From around Hoddle Street in the west to Springvale Road in the east, modifications to the Eastern Freeway would include widening to accommodate future traffic volumes, provision of new dedicated bus lanes for rapid bus services and associated works.

Marcellin College Marcellin College is located at 160 Bulleen Road, Bulleen (Land).

Access to Marcellin College is gained via two access points off Bulleen Road and one off Sandra Street. Bulleen Road has an entry and egress point running between Gartner Fields and Lyons Oval (Primary Access Point). An additional egress only point is provided to Bulleen Road to the south of Lyons Oval (Secondary Access Point). Sandra Street provides an entry and egress point, through the residential area however, buses and heavy vehicles cannot access the Marcellin Campus from this point. Bus access to the Marcellin Campus is provided only via the Primary Access Point. Marcellin is affected by the part of the project referred to as the “northern portal to southern portal”. At the northern portal of the tunnel, the road would transition into twin tunnels that connect to Lower Plenty Road via a new interchange before travelling under residential areas, Banyule Flats and the Yarra River to a new interchange at Manningham Road. The


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tunnel would then continue to the southern portal south of 191 Bulleen Rd, Bulleen (the Veneto Club). North East Link impacts on Marcellin Land The Marcellin Land is identified in the EES as being affected by the project. The ‘North East Link Project - Horizontal plan: construction reference design’ (extracted below Map book Horizontal Alignment Part 1) identifies the following (among other things):

x Parts of Gartner Fields and Lyons Oval within the ‘Project boundary’ and the

‘Indicative area of potential construction compound’; and

x The tunnel opening located immediately to the west of the Marcellin Land including proposed open cut or cut and cover works and the cut and cover tunnel.

http://northeastlink.vic.gov.au/__data/assets/pdf_file/0020/364241/NELP-EES-Map-book-Key-Map-and-Horizontal-Alignment-Plans-Part-1.pdf


20190693_3202910v1

Construction activities and compounds Construction works are estimated to extend over seven years, commencing in mid-2020. The tunnels would be constructed using three different construction methods to suit existing ground conditions and minimise above ground disturbance where possible:

x Cut and cover construction uses excavation equipment to dig a large trench in the ground in which the rectangular tunnel structure is constructed. This method would be used between Blamey Road and Lower Plenty Road, Bridge Street and Golden Way, and Rocklea Street and the southern portal.

x Bored tunnels use a tunnel boring machine (TBM) to excavate through soil and rock, with the tunnel lining being constructed as the excavation progresses.

x A short section of the twin tunnels (approximately 400 metres long) south of the Manningham Road interchange would be constructed using the mined tunnel method. Two excavation machines (road headers) would be used for this section, progressing at an average rate of 10 metres per week.

The proposed location of construction compounds are shown in figure 8-32 (extracted below Chapter 8 Project description) identifies the potential construction compound affecting the Marcellin Land as Site 17:

http://northeastlink.vic.gov.au/__data/assets/pdf_file/0004/364081/NELP-EES-Chapter-08-Project-description.pdf


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Submission

Marcellin lodged a submission on 7 June 2019 (Refer Tab 5). Public Hearing The Minister has appointed the following members to the IAC:

x Nick Wimbush (Chair)

x Dalia Cook (Deputy Chair)

x Peter Edwards

x Mandy Elliot

x Elizabeth Hui The Public Hearing is commencing on 25 July 2019 at The Veneto Club, 191 Bulleen Road, Bulleen. We have requested our submission be scheduled 19 or 20 August. If you have any questions please contact us. Yours faithfully

Rigby Cooke Lawyers


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Index of Documents Tab Document 1 Relevant pages of the EES documentation

Environment Effects Statement 2 Executive summary

Foreword

Abbreviations and glossary

Table of contents

Chapter 1 Introduction

Chapter 2 Project rationale

Chapter 3 Legislative framework

Chapter 4 EES assessment framework

Chapter 5 Communications and engagement Chapter 6 Project development

Chapter 7 Urban design

Chapter 8 Project description

Chapter 9 Traffic and transport

See also Revised Figures in Chapter 9 - Traffic and transport

Chapter 10 Air quality

Chapter 11 Surface noise and vibration

Chapter 12 Tunnel vibration

Chapter 13 Land use planning Chapter 14 Business

Chapter 15 Arboriculture Chapter 16 Landscape and visual Chapter 17 Social

Chapter 18 Human health Chapter 19 Historical heritage Chapter 19 Historical heritage


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Chapter 20 Aboriginal cultural heritage Chapter 21 Ground movement

Chapter 22 Groundwater

Chapter 23 Contamination and soil

Chapter 24 Surface water

Chapter 25 Ecology

Chapter 26 Greenhouse gas

Chapter 27 Environmental management framework

Chapter 28 Conclusion Attachments I Sustainability approach

II Urban design strategy

III Risk report

IV Community and stakeholder report

V Draft Planning Scheme Amendment

VI Works planning approval Map Book Horizontal Alignment Part 1

Horizontal Alignment Part 2

Vertical Alignment Plans and Indicative Cross Sections Technical Reports A Traffic and transport

B Air quality See also Revised Figures and Tables in Technical Report B - Air Quality C Surface noise and vibration Surface noise and vibration Appendices


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Surface noise and vibration E Part 1 Surface noise and vibration E Part 2 Surface noise and vibration Appendices F-I Surface noise and vibration Appendices J-K Surface noise and vibration Appendices L-M

D Tunnel vibration

E Land use planning Land use planning Appendix B Part 1 Land use planning Appendix B Part 2 Land use planning Appendix C Land use planning Appendix D Part 1 Land use planning Appendix D Part 2

F Business

G Arboriculture

Arboriculture Appendices A-B Arboriculture Appendices C Part 1 Arboriculture Appendices C Part 2 Arboriculture Appendices D

H Landscape and visual

Landscape and visual Appendices A-B Landscape and visual Appendix C

I Social Social Appendices

J Human health

K Historical heritage Historical heritage appendices

L Aboriginal cultural heritage

M Ground movement

N Groundwater

O Contamination and soil

Contamination and soil Appendices


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P Surface water Part 1 Surface water Part 2 Surface water Appendices

Q Ecology

Ecology Figures Part 1 Ecology Figures Part 2 Ecology Appendices

R Greenhouse gas

3 Early Design Schematics and Artist Impressions September 2018

4 North East Link Melways Map October 2018

5 Submission dated 7 June 2019

6 Terms of Reference

7 Updated Information EES Transport Model Peer Review Overview of Social Impacts

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VI. APPENDIX B – EXTRACT FROM EES DOCUMENTATION

Summary report | 27

Construction activities and compounds

Construction works in this element would extend over four years, commencing in late 2021. Significant construction activities would occur around the site of the new northern interchange with North East Link and the Grimshaw Street interchange. Several construction compounds would be established adjacent to the new link to store materials and equipment, accommodate project workers and allow local access to construction work sites. The potential locations of construction compounds are shown in Chapter 8 Project Description.

Northern portal to southern portal

This project element runs through the municipalities of Banyule and Manningham, characterised by quiet residential streets and lively activity centres. The area surrounding North East Link includes the Heide Museum of Modern Art, Bulleen Industrial Precinct and the residential area of Bulleen. Towards the Eastern Freeway, the area features schools, recreational facilities and open space corridors such as Bulleen Park, Koonung Creek and the Yarra River and Estelle Street Linear Park. Bolin Bolin Billabong is part of a larger network of billabongs and swamps formed by the Yarra River and is of high significance to the Wurundjeri people.

Clark Briggs

Environment Effects Statement

28 | Summary report

Tunnel ventilation North East Link would incorporate a state-of-the-art tunnel ventilation system designed to ensure the health and safety of motorists using the tunnels, meet relevant air quality criteria inside and outside the tunnels, reduce energy consumption and minimise the visual impacts of the ventilation structures.

Project features

This element would extend in tunnel from the northern portal at Blamey Road to the southern portal south of the Veneto Club, Bulleen. Key project features would include:

• Six kilometres of twin three-lane tunnels with three trafficlanes in each direction

• Cross passages between the tunnels every 120 metres foroperations access and for evacuation in an emergency

• A tunnel management system to allow speed limits to bevaried and incidents to be managed safely and promptly

• Ancillary infrastructure to support the operation andmanagement of the tunnels, including additionalpower supply, tunnel ventilation system and watertreatment facilities

• Two ventilation structures each around 40 metres high –one located in the vicinity of the northern tunnel portal near Blamey Road (within SimpsonBarracks) and the other near the southern tunnel portal at Bulleen Oval (west of Bulleen Road)

• A motorway operations centre at the Manningham Road interchange to oversee North EastLink operations

• Interchanges at Lower Plenty Road and Manningham Road

• New or modified noise walls at the Lower Plenty Road interchange, the Manningham Roadinterchange and the southern portal to mitigate noise in residential areas and meet the project’snoise objectives

• Modifications to Bulleen Road to connect to the Manningham Road interchange, maintain accessto Manningham Road and connect to the Eastern Freeway

• New and improved walking and cycling paths, including a new shared use path alongBulleen Road

• Changes to waterways and drainage

• Protection and relocation of utilities, including the relocation of a wireless telecommunicationsbase station in Bulleen and the Melbourne Water Yarra East Main sewer along Bulleen Road.

The proposed tunnel alignment runs underneath the Yarra River, where the top of the tunnel would be at least 20 metres beneath the river. At its deepest point, in the vicinity of Sevenoaks Avenue in Heidelberg, the top of the tunnel would be approximately 40 metres underground. Along their entire length, the tunnels would be separated horizontally by approximately 15 metres.

Over-dimensional vehicles and some vehicles carrying placarded loads would not be allowed in the tunnels.

Summary report | 29

Figure 10 Northern portal to southern portal element


30 | Summary report

Construction activities and compounds

Construction works in this element would extend over seven years, commencing in mid-2020.

The tunnels would be constructed using three different construction methods to suit existing ground conditions and minimise above ground disturbance where possible:

•� Cut and cover construction uses excavation equipment to dig a large trench in the ground in which the rectangular tunnel structure is constructed. This method would be used between Blamey Road and Lower Plenty Road, Bridge Street and Golden Way, and Rocklea Street and the southern portal.

•� Bored tunnels use a tunnel boring machine (TBM) to excavate through soil and rock, with the tunnel lining being constructed as the excavation progresses. Two TBMs, each approximately 15.5 metres in diameter, would be used for three kilometres of the tunnels between Lower Plenty Road and Bridge Street. The TBMs would operate continuously, progressing at an estimated average rate of 60 metres per week.

•� A short section of the twin tunnels (approximately 400 metres long) south of the Manningham Road interchange would be constructed using the mined tunnel method. Two excavation machines (road headers) would be used for this section, progressing at an average rate of 10 metres per week.

A large construction compound would be required to launch and support the TBMs, provide laydown areas for construction materials and assist with spoil removal. Two options have been considered for this main site: a northern site at Lower Plenty Road (extending north to Blamey Road) and a southern site at Bridge Street (extending to Golden Way) – both are assessed in the EES. Some smaller compounds would also be established. The proposed locations of construction compounds are shown in Chapter 8 Project Description.

Clark Briggs

Clark Briggs

Clark Briggs

Summary report | 35

Transport

Construction

Construction of North East Link would impact the road network through changed road conditions, traffic flows and travel times. Construction activities have the potential to impact the transport network, including motor vehicles, public transport and pedestrians and cyclists. These activities would be managed carefully to minimise traffic and transport disruptions, as has been done successfully for recent major transport projects in Melbourne such as the CityLink Tulla Widening, Monash Freeway upgrades, the Metro Tunnel and the West Gate Tunnel.

To mitigate traffic impacts during construction, the EPRs would require the project contractors to:

•� Develop and implement Transport Management Plans (TMPs), informed by an appropriate level of transport modelling. The TMPs would include requirements for maintaining transport capacity in the peak periods and minimising impacts on local streets and community and commercial facilities. The plans would also identify potential construction traffic routes, establish the requirements for limiting construction haulage during the peak periods and outline measures to ensure connectivity and safety for all transport network users during construction.

•� Undertake independent road safety audits after each stage of detailed design and post-construction.

•� Monitor transport impacts during construction and provide real-time traffic information to travellers during the construction period. Where monitoring identifies adverse impacts, appropriate mitigation measures would be implemented.

•� Convene a Transport Management Liaison Group with representatives from the Victorian Government, VicRoads, local councils, emergency services and other relevant agencies to exchange information and discuss issues associated with the TMPs.

During construction, additional traffic would be generated by workers accessing construction sites and trucks delivering materials and equipment and transporting spoil. The highest number of daily truck trips during the project’s construction period is estimated to be between 3,500 and 3,700. The TMPs would outline requirements for spoil to be transported along designated haulage routes that give trucks efficient access to the freeway and arterial road network, minimising the impact on local traffic and local roads wherever possible.

Road closures and diversions would be required to enable construction of North East Link. The TMPs would outline measures to minimise the impact to transport users and surrounding areas, while allowing sufficient space for safe construction works. Construction would be scheduled in stages so that multiple roads are not closed at the same time and lane closures would only be permitted outside of peak periods. Longer term lane closures are anticipated at several locations, including the Greensborough Bypass between Grimshaw Street and Watsonia Road, Grimshaw Street, Manningham Road, Bridge Street and Doncaster Road. Detours, diversions and other measures would be implemented through the TMPs to reduce impacts at these locations.

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Protecting the tunnels from flooding The North East Link tunnels have been designed to take into account local flooding conditions. The northern portal is within the floodplain of Banyule Creek and the southern portal is within the floodplain of the Yarra River. The Banyule Creek catchment is relatively small and immediate to the northern portal. Accordingly, the northern tunnel entrances have been designed to cope with a probable maximum flood event (estimated by applying the worst conceivable rainfall event to the catchment in conditions that are conducive to generating floods). For the southern portal, located within the Yarra River floodplain, there would be a warning time of several days for large flooding events. Consequently, the southern tunnel entrances would use a combination of active and passive measures (such as flood gates and floodwalls) to manage the potential for flooding. Emergency plans would be prepared for large flood events, including warning systems and evacuation procedures.

The EPRs would require these activities (and all works on waterways) to be undertaken to the satisfaction of Melbourne Water or the relevant drainage authority. Any waterway modifications would be required to mitigate changes to water flows and minimise the potential for erosion and sediment plumes. Appropriate measures would be taken to maintain the bank stability of waterways to the satisfaction of Melbourne Water or the relevant drainage authority.

Post-construction, the project contractors would be required to maximise the visual and aesthetic amenity and environmental conditions of these waterways having regard to the relevant strategies, policies and plans for the waterway and in consultation with Melbourne Water or the relevant drainage authority.

The EPRs would require the project to maintain existing storage and available water supply for the irrigation of sporting fields. The area currently used for a private dam within the Trinity Grammar

School Sporting Complex would be required to build the southern extent of the tunnels. The dam would be modified during construction and suitable water supply reinstated post-construction. An alternative stormwater supply would be provided during construction to irrigate the Trinity Grammar Sporting Complex and Marcellin College ovals.

Upstream waterway modifications would be considered to minimise impacts on the Trinity Grammar wetland and a suitable water supply would be maintained for the Bolin Bolin Integrated Water Management Project if local drainage needs to be rerouted temporarily for construction of the tunnels.

There are many locations where the project would interface with an existing floodplain. At these locations, the obstruction of existing flow paths by construction works and temporary and permanent project structures would have the potential to change the existing flood extent and increase flood levels. Project works and structures must not increase overall flood risk or modify the flow regime of waterways without the consent of Melbourne Water or any other relevant drainage authority.

Flood risk would be assessed by modelling of the design of works and structures to demonstrate that the project meets flood level, flow and velocity requirements. The CEMP and OEMP would include measures to maintain existing flow paths, drainage lines and floodplain storage during construction and operation. With the application of the EPRs, the EES impact assessment determined that there could be a localised minor increase in flood water levels.

Overall, the risks to water quality, water supply and flooding have been assessed to be low to medium. Additional design refinements during the detailed design phase would further minimise surface water impacts.

Clark Briggs


56 | Summary report

Planted trees

The project area contains high numbers of planted trees, particularly within the existing road zones of the M80 Ring Road and the Eastern Freeway. Tree canopy makes a vital contribution to the wellbeing and liveability of urban neighbourhoods by absorbing heat retained by roads and buildings, supporting cleaner air and water, insulating against noise pollution and providing local habitat. Recognising these benefits, councils across Melbourne − including those within the North East Link project boundary − have adopted strategies and plans to maintain the integrity of the urban tree canopy and extend the ‘urban forest’. While the scale, location and extent of North East Link means that the removal of planted trees is unavoidable, the project has been designed to minimise tree removals and would be required to protect as many trees as possible and to replace and increase tree canopy cover.

Approximately 15,800 planted trees would need to be removed to construct North East Link, as summarised in Table 4. As shown in the table, almost three quarters of these trees (73 per cent) would be within areas reserved for future road uses.

There is the potential for an additional 10,100 trees to be affected, as summarised in Table 5. Potentially impacted trees include those located within the project boundary but not within the actual footprint of the reference project. More than half (57 per cent) of these potential tree removals would be within the existing road zone.

Table 4 Planted trees planned for removal

Element Total trees planned for removal Trees within the road zone (% of total)

M80 Ring road to northern portal 7,882 7,077 (90%)

Northern portal to southern portal 905 95 (10%)

Eastern Freeway 7,027 4,287 (61%)

Total 15,814 11,459 (72%)

Table 5 Trees potentially impacted

Element Trees potentially impacted Trees within the road zone (% of total)

M80 Ring road to northern portal 2,108 1,099 (52%)

Northern portal to southern portal 318 86 (27%)

Eastern Freeway 7,707 4,677 (61%)

Total 10,133 5,862 (58%)

Page 24 of 24


VII. APPENDIX C – MARCELLIN SUBMISSIONS

Level 11, 360 Elizabeth Street Melbourne Victoria 3000

GPO Box 4767 Melbourne Victoria 3001

T +61 3 9321 7888 F +61 3 9321 7900

www.rigbycooke.com.au

ABN 58 552 536 547 DX 191 Melbourne

Our ref: REA: 20190693 Direct dial: 03 9321 7832 Your ref: Direct email: [email protected] Page: 1/9

Liability limited by a scheme approved under Professional Standards Legislation 20190693_3174757v1

7 June 2019 Joint Inquiry and Advisory Committee North East Link c/o Planning Panels Victoria 1 Spring Street MELBOURNE VIC 3000 By online submission Dear Sir/Madam Submission to Joint Inquiry Advisory Committee North East Link Marcellin College - 160 Bulleen Road, Bulleen We act on behalf of Marcellin College (Marcellin), the owner1 and occupier of land at 160 Bulleen Road, Bulleen (Marcellin Campus). This is our client’s submission on the Environmental Effects Statement (EES) and Planning Scheme Amendment GC98. Marcellin generally supports the North East Link Project (Project) and recognises the community benefit of improved road infrastructure. However, Marcellin does not support the proposed temporary occupation of any part of the Marcellin Campus during construction of the Project or permanent occupation (via compulsory acquisition) post construction. It does not appear, from the exhibited documents, that permanent occupation is proposed, however, Marcellin seeks written confirmation that permanent occupation is not required. Temporary occupation of Marcellin Campus (including changes to the access/egress to Bulleen Road) would have significant detrimental impacts on the operation of the Marcellin Campus and the wellbeing of the 1430 students. Given the significant impacts (as detailed below), the proposed compound must be located on a more suitable site. Background Marcellin is a secondary college for boys and has occupied the site since 1963. The Marcellin Campus comprises 14 hectares and consists of multiple learning areas (located towards the rear of the site) and three key sporting facilities (Bray Oval, Lyons Oval and Gartner Fields) located along the Bulleen Road frontage. The sporting facilities are utilised daily by Marcellin students as part of the schools’ health and physical education program and after hours/weekends by community groups including Old Collegians, St Clements Primary School and others. Access to the Marcellin Campus is via Bulleen Road and Sandra Street.

1 By association with the Trustees of the Marist Brothers.

Our ref: REA: 20190693 Letter to: Joint Inquiry and Advisory Committee

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A campus map is provided below at Figure 1.

Figure 1 - Campus Map

Bulleen Road has one entry and egress point running between Gartner Fields and Lyons Oval (Primary Access Point). An additional egress only point is provided to Bulleen Road to the south of Lyons Oval (Secondary Access Point). Sandra Street is a residential street and provides an alternative entry and egress point, however, buses and heavy vehicles cannot access the Marcellin Campus from this point. Bus access/egress is via the Primary Access Point. Marcellin proposes to undertake major redevelopment works in the next 18 months with access for heavy vehicles required during this period. Project impact on Marcellin Campus Marcellin Campus is identified in the Environmental Effects Statement (EES) as being affected by the Project. Specifically, Sheet 22 of 42 of the ‘North East Link Project - Horizontal plan: construction reference design’ (extracted below) identifies the following (among other things):

• Parts of Gartner Fields and Lyons Oval on the Marcellin Campus sit within the ‘Project boundary’ and the ‘Indicative area of potential construction compound’; and

• The opening of the tunnel is located immediately to the east of the Marcellin Campus including proposed open cut or cut and cover works and the cut and cover tunnel.

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Sheet 22 of 42 of the ‘North East Link Project - Horizontal plan: operation reference design’ identifies the following (among other things):

• Bulleen Road as a ‘Proposed surface road’, extending from a ‘Proposed elevated ramp or structure’ to the south of the Marcellin Campus;

• An upgraded Primary Access Point with a slip lane entry and egress onto Bulleen Road (Upgraded Primary Access Point);

• The closure of the Secondary Access Point to Bulleen Road with a new connection around Lyons Oval to the Upgraded Primary Access Point;

• A ‘Proposed Sewer’ traversing Gartner Fields and Lyons Oval; and • A ‘Proposed ventilation structure’ to the west of the Upgraded Primary Access Point.


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Appendix E (Community infrastructure facilities) to Chapter 17 of the EES identifies the impact rate for the function of the facility and on users as minor-moderate. Appendix E provides the following summary on the impact on the Marcellin Campus:

Marcellin College is located to the east of works on Bulleen Road. Its most western sporting field and a portion of the next field would be occupied by a temporary laydown area. Consequently, the school and associated users would temporarily lose access to these facilities at this location, including a number of community groups. The facility would likely experience a change in the noise environment, which has the potential to impact on users and managers. Temporary and intermittent increase in noticeable levels of noise could disturb conversation, impact people’s capacity to participate in work and learning activities, and outdoor play and learning activities. The EPRs outlined in Technical report C – Surface noise and vibration would manage noise changes at community facilities to be within acceptable noise limits during most times. At times, there could be temporary and intermittent disruption due to increased noise levels but noise changes would be unlikely to impact on the functionality of the community infrastructure facility.

Details of the significant detrimental impacts of temporary occupation on the operation of the Marcellin Campus and the wellbeing of students is detailed below.


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Temporary occupation Marcellin has engaged regularly with North East Link Authority (NELA) over the past two years. NELA has stated that the Project does not necessitate the permanent acquisition of any of the Marcellin Campus. Marcellin seeks an undertaking that no permanent acquisition of any part of the Marcellin Campus will occur. Table 9.4 ‘Land acquisition and temporary occupation of open spaces and recreational areas and facilities’ in Technical Report I - Social of the EES identifies that 20% of Marcellin College will be occupied during construction and 1% during operation. Temporary occupation of significant parts of Gartner Fields and Lyons Oval (Temporary Occupation) will have a detrimental impact on sports and recreational uses on the Marcellin Campus both for the school and community groups. At least two, possibly three, of the sports grounds will be unavailable for use during Temporary Occupation. The suggestion by NELA that alternative off site facilities will be made available for the period of Temporary Occupation is unacceptable, will be disruptive to the class timetable and expensive with buses being required to transport students to and from the offsite facilities. The sports grounds are used 7 days per week, both during the day and into the evenings. Specifically, the loss of facilities arising from the Temporary Occupation will impact on:

• School health and physical education programs; • Inter School sports (including AFL football, soccer, rugby, cricket); • Old Collegians sports (AFL football, soccer and cricket); and • Community groups (who use the facilities from time to time) such as:

Marcellin Eagles Basketball Club; A number of Catholic Primary Schools for various sporting carnivals/competitions; “Shegles” Womens Football teams; Local Parishes for family days etc; and Other community groups on request.

We note that a construction compound is proposed on the western side of Bulleen Road, to the south of the Veneto Club. A larger construction compound in this location would be more appropriate than the current proposal. The compound would impact the sport and recreation facility for Carey Grammar, however, as this site comprises sporting facilities only, the impact would be significantly less than the current proposal. It is unclear from the exhibited documents how the construction compound is to be used. It is possible that the compound could be used for:

• Construction (including bitumen) of a temporary diversion of Bulleen Road; and • The storage of spoil or other potentially contaminated waste.

The potential ramifications (short and long term) of such uses on a school site are a serious concern for Marcellin.


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Access The Marcellin Campus requires unrestricted car and bus access from Bulleen Road at all times (including weekends). Approximately 75% of students arrive and depart the Marcellin Campus via bus to Heidelberg Station and other local destinations. The bus movements are estimated at 24 per day. Buses are unable to access the Marcellin Campus from Sandra Street, therefore, it is critical that continuity of access to and egress from the Primary Access Point is maintained. Marcellin submits that:

• during construction works to Bulleen Road unrestricted access/egress to the Primary Access Point must be maintained;

• temporary traffic lights must be installed at the Bulleen Road and Primary Access

Point; and

• Bulleen Road must not be diverted onto the Temporary Occupation area.

Visual impact A 40 metre ventilation stack (Stack) is proposed in close proximity to the Marcellin Campus entrance. The Stack, at this scale, must be designed and located to reduce the visual impact by measures such as:

• locating the Stack to the west of the tunnel entry; and • the use of appropriate materials to ensure it is sensitive to the existing surrounds.

Emissions from the Stack Marcellin has serious concerns about the potential impacts on the health and wellbeing of its students and staff. Potential emissions from the Stack as identified in Table 66 of ‘Technical Report B - Air Quality’ shows the location of the predicted maximum within the Marcellin Campus for option 5. Marcellin seek assurances that emissions from the Stack will not adversely impact the air quality in and around the Marcellin Campus. Amenity Other potential amenity/environmental impacts on the Marcellin Campus arising from the Project include noise, dust emissions and ground movement both during construction and post completion. Marcellin’s key concerns are:

• Noise - the impact of noise on students’ concentration levels during class is a major concern during the construction period and post construction. NELA should


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install noise barriers and double glazing to affected windows to mitigate any impacts.

• Dust emission - the EES recognises the potential for dust from the construction of the Project. Marcellin seeks assurances that the Marcellin Campus will not be adversely impacted from dust emissions and would like to be consulted on any Dust and Air Quality Management and Monitoring Plan prepared for the implementation of the Project.

• Ground movement - ‘Chapter 21 - Ground movement’ states:

The assessment considered the potential for ground movement associated with these works to cause settlement, depressions, ponding of water and damage to the playing fields (risks GM17, GM18).

It is estimated that approximately five and ten millimetres of settlement could occur at the eastern boundary of the playing fields. This degree of settlement is classified as negligible and would not impact the function of the playing fields. The buildings on the property are set well back from Bulleen Road and would not experience ground movement.

Marcellin has spent a lot of time and money maintaining the sporting facilities to the standard required for completion level. Settlement of the playing fields of 5 to 10 millimetres is unacceptable. Measures must be implemented to ensure that the facilities are not impacted by the Project.

Marcellin must be consulted during the preparation of any Ground Movement Plan prepared for the implementation of the Project. Loss of mature trees The Bulleen Road frontage of the Marcellin Campus comprises large mature trees, some of which were planted for approximately 50 years (depicted in the below Google image). It is unclear from the EES material whether all or some of the trees are proposed to be removed to facilitate the Project. The removal of large, significant trees should be avoided.

Source: Google street view


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Assurances and management during construction Marcellin require certainty around the timing of works adjacent to the Marcellin Campus including:

• Commencement dates; • The estimated duration of works; • Rectification works required; and • Completion dates.

These details are integral to ensuring Marcellin can properly manage impacts to the Marcellin Campus. Physical impacts on Marcellin Campus frontage Marcellin has a duty of care to maintain safe access to the Marcellin Campus. Marcellin is concerned about potential damage to key infrastructure during the Project including:

a. Structural integrity of the Front Fence; b. Trees; c. Main entrance – structure & signage; d. Irrigation; e. Sylvester Drive exit; f. Crema Drive entrance/exit; g. Water pumping station; h. Fire Services (external); and i. Fire Pumping station and Storage tanks.

All of this key infrastructure is located in compliance with safety regulations. Marcellin require details of the potential impacts (if any) of the infrastructure and where impacts are proposed, the mitigation measures. Deterred enrolments Marcellin is concerned that prospective students may be deterred by the Project construction. Marcellin would like an undertaking that NELA will compensate Marcellin for any loss arising directly or indirectly from Project impacts on student enrolments. Water Marcellin holds a licence to pump water from the Yarra River into a dam located to the north of the Marcellin Campus and utilised by both Marcellin and Trinity College for the purpose of irrigation. Access to this water is critical for maintaining the sporting facilities and the landscaping throughout the Marcellin Campus.


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If access to irrigation water is jeopardised by the Project, Marcellin will need to access water from the reticulated supply at significant cost. Marcellin submits that it should be reimbursed for any costs for using the reticulated water supply including establishment costs and usage costs both during construction and operation. Relocation of sewer The relocation of the Yarra East main sewer (Sewer) is proposed through the Marcellin Campus either in sub-surface strata or Easement. Marcellin submits that:

• any works undertaken to relocate the Sewer should not interrupt essential services to the Marcellin Campus both during school hours and during afterhours activities;

• any sub-surface or surface works to relocate the Sewer should not cause damage to the Marcellin Campus. NELA must make good any damage caused;

• any works relating to the relocation of the Sewer should not impede continuity of access to the Marcellin Campus; and

• Marcellin must be compensated for any grant of an easement required to relocate the Sewer.

Continuing Consultation

At this time, the Project design is uncertain and may be subject to change throughout the EES process and during construction. Marcellin must be consulted prior to any changes to the Project design which affect the Marcellin Campus. In conclusion, Temporary occupation of Marcellin Campus (including changes to the access/egress to Bulleen Road) would have significant detrimental impacts on the operation of the Marcellin Campus and the wellbeing of the students. Given the significant impacts the proposed compound must be located to a more suitable site. Our client reserves the right to make any further submission. If you have any questions, please contact Rhodie Anderson on 03 9321 7832.

Yours faithfully

Rigby Cooke Lawyers