Mordialloc Bypass presentation by Frank McGuire My name is Frank McGuire and I am one of 265 residents of the Wells Rd Chelsea Heights Lifestyle retirement village, where our homes are the closest homes affected by the proposed project. I request that the Committee recommend that mitigation is needed for the development of the project to balance project objectives with environmental outcomes in respect to PM2.5 air quality effects on residents at the Chelsea Heights Lifestyle retirement village. I request that such mitigation comprises-intensive vegetation screening designed for PM2.5 mitigation, between the Freeway and the retirement village. As background, there has been a significant change to the EES assessment of PM2.5 emissions standards arising from the EPA submission. I believe that should have changed the EES conclusions that impacts are predicted to be negligible. However, MRPV’s air quality expert and principle author of Appendix F, Dr Wallis, has said he has not changed his opinion (Para 9 of his report). It is therefore important to look at the basis and relevance of those EES conclusions. The EES Summary report states-With the application of standard controls, operational impacts on air quality are predicted to be negligible for particulate matter (PM10 and PM2.5) Chapter 13 Air Quality and greenhouse gas, states- PM (PM10 and PM2.5) are expected to have minor to negligible air quality impacts. Appendix F: Air quality impact assessment, states- Predicted operational ground level concentrations are expected to be minor for PM10 and PM2.5. It is clear that the EES conclusions regarding PM2.5 are based on the Appendix F conclusions. Further, the Appendix F conclusion is based on the Figure 9-14 graph, as shown here. This graph clearly shows that the predicted levels are minor compared to the criteria shown in red.
Transcript
Mordialloc Bypass presentation by Frank McGuire
My name is Frank McGuire and I am one of 265 residents of the Wells Rd Chelsea Heights Lifestyle retirement village, where our homes are the closest homes affected by the proposed project.
I request that the Committee recommend that mitigation is needed for the development of the project to balance project objectives with environmental outcomes in respect to PM2.5 air quality effects on residents at the Chelsea Heights Lifestyle retirement village.
I request that such mitigation comprises-intensive vegetation screening designed for PM2.5 mitigation, between the Freeway and the retirement village.
As background, there has been a significant change to the EES assessment of PM2.5 emissions standards arising from the EPA submission. I believe that should have changed the EES conclusions that impacts are predicted to be negligible. However, MRPV’s air quality expert and principle author of Appendix F, Dr Wallis, has said he has not changed his opinion (Para 9 of his report). It is therefore important to look at the basis and relevance of those EES conclusions.
The EES Summary report states-With the application of standard controls, operational impacts on air quality are predicted to be negligible for particulate matter (PM10 and PM2.5) Chapter 13 Air Quality and greenhouse gas, states-PM (PM10 and PM2.5) are expected to have minor to negligible air quality impacts.Appendix F: Air quality impact assessment, states-Predicted operational ground level concentrations are expected to be minor for PM10 and PM2.5.
It is clear that the EES conclusions regarding PM2.5 are based on the Appendix F conclusions. Further, the Appendix F conclusion is based on the Figure 9-14 graph, as shown here.
This graph clearly shows that the predicted levels are minor compared to the criteria shown in red.
However, below is the graph used to compare and below is the graph that should have levels after the EPA submission have been used after the EPA submission
This clearly shows that predicted levels are NOT negligible, or minor compared to the required criteria. As Dr Wallis stressed, “all of this information is in Appendix F of the EES, for anyone to use.”
The EES conclusion regarding PM2.5 emissions is based on an SEPP (AQM) legislated target that is for applications other than roads (see attached extracts from SEPP AQM). The Appendix F Report opinion (Page 8) by MRPV’s air quality expert Dr Wallis, that PM2.5 is expected to have minor to negligible air quality impacts, is based on that inappropriate target. His reluctance not to change that opinion (Para 9 of his Export report) is presenting a very misleading and prejudicial assumption that there is no reason to consider any need for mitigation. This is contrary to the evidence.
The subsequent assessment after EPA’s intervention, still omits comparison with the AAQ 2025 targets as recommended by the EPA.
In his verbal presentation, Dr Wallis said –“We do have a problem because the design objectives for PM 2.5 over the year is very low.” This acknowledges that a comparison of predicted PM2.5 levels, with the year 2025 objectives, shows only a marginal difference. Dr Wallis stated his view (Para 44) that the 2025 target was only applicable for population groups of 25,000. To the contrary, that SEPP (AAQ) clause 15, only relates to the number of performance monitoring stations needed.
The EPA’s submission (2.7.2) clearly states that their recommendation to use Schedule 2, of SEPP (AAQ) that includes 2025 objectives to compare and assess air pollution levels near roads, is in accordance with emerging scientific evidence and best practice.
I put it that the EPA recommendation, representing the people of Victoria in reducing harm from pollution, should take precedence over Dr Wallis’ s personal opinion to not use that target.
The EES Scoping objectives include 4.6, To protect the health and wellbeing of residents and local communities, and minimise effects on air quality, having regard to relevant limits, targets or standards. Those targets include SEPP (AAQ) as listed in 3.5 of the Scoping requirements. In not fully addressing those targets, the Scoping objectives are not being met.
I submit in support of my requests, that-a) The EES conclusion that impacts on air quality are predicted to be negligible for PM2.5, should
be disregarded, for the above reasons and b) The year 2025 SEPP (AAQ) objectives should be used to compare and assess air pollution at our
village, for the above reasonsc) There is a strong possibility of significant effect of PM2.5 air quality on residents at our village
and thence negative health risks.d) Mitigation measures are needed to minimise the negative health risks.
My evidence for the last two points is as follows-
1. PM2.5 Air Quality Risks
At his presentation, Dr Wallis stated that comparing PM2.5 projected levels with 2025 goals does not change the position that levels at receptor locations are still below the objective levels, but although much closer.
To illustrate this, Dr Wallis presented a graph in his expert witness Report; although I note that that graph and all of his other PM10 and PM2.5 titled graphs in the Report, are actually for Carbon monoxide, and not for Particulate Matter.
In the actual PM2.5 graph from Appendix F, shown below, I have added in black, the year 2025 objectives of 7 ug/m3. This graph should have been used as a basis for assessment, as it includes the Schedule 2 objectives recommended by the EPA (2.2.7) to be used for that purpose.
Dr Wallis states (Para 93) that the SEPP(AAQ) objectives are considered to apply at the property boundary of residential buildings (including aged care and retirement villages). Appendix F, Table 7.2 shows a distance of 35m from the Freeway to our village. This PM2.5 graph, using the imposed 2025 objective, shows that the blue line predicted 2025 levels of PM2.5 is reached at the boundary of our village.
The blue line predicted levels shows a modelled drop off in the levels with distance from the road. However, as explained below, the emission levels away from the road could be higher than shown by the modelled blue line on the graph, and thence show higher potential health risk.
My submission provided evidence that international studies identified an exposure zone within a range of up to 300–500 m from a highway or a major road as the area most highly affected by traffic emissions. Dr Wallis states (Para 29) that the reduction will be down to 7% at 75m from the roadway, which is certainly not “highly affected”. Dr Wallis said (Paras 10 & 14) that he has read my submission and that it was impressively detailed and comprehensive. However, he has omitted to make any comment on why there is such a large difference between his modelling and the international studies quoted.
The Scoping requirements (3.2) include requirement for - appropriately detailed assessments of potential effects of the project …..together with an estimation of likelihood and degree of uncertainty and irreversibility associated with predictions.
I do not contend that Dr Wallis’s dispersion modelling is necessarily incorrect. However, having regard to the Scoping requirement and the information in my submission., it would have been more faithful to the objectives of the EES, for him to have advised of the uncertainties of the predicted decline in dispersion of PM2.5 and consequent possible effects on the assessment results.
The above graph certainly illustrates that a lesser than predicted decline in concentrations would show an increased impact on air quality on receptors at our village.In summary,
Dr Wallis’s predicted levels of PM2.5 are close enough to the 2025 objective as shown on the graph, to indicate an increased health risk to nearby residents
There is evidence that PM2.5 road traffic emissions can highly affect residents up to 500m from a highway, contrary to Dr Wallis’s predictions, and thence identifying possible higher increased health risk to nearby residents.
I believe therefore, that this is enough to show that it cannot be discounted, that by the year 2031 PM2.5 emissions at our village present a significant health risk.
I also wish to comment on a statement by Dr Wallis in his answer to a question from me at his presentation. His statement was relative to his evidence that the Freeway will be at an increased distance from my village. He said “they will have experienced higher concentrations in the past than whatever they will experience from the Mordialloc freeway”. I submit that this statement is highly presumptive, and is also misleading to the Committee, as it fails to recognise-
a) there will be an increase of 30,000 vehicles per day more than if the project is not built, on this section of road. That is a 60% increase above existing traffic levels.
b) there will be a consequent increase in congestion of southbound evening traffic, causing stop-start conditions. Dr Wallis’s verbal presentation said that stop-start conditions will cause emission increases of 20%, and
c) It assumes a significant reduction in dispersion with an increase of distance from the road. This is contrary to my evidence that PM2.5 does not exhibit the sharp distance-decay gradient evident for other air pollutants, and that emissions effects can continue for up to 500m or more from the roadway.
This information was all detailed in my submission.
2. Need for mitigation measuresThe above described information shows that year 2031 predicted PM2.5 emission levels could be close to or exceed the SEPP (AAQ) 2025 objectives at my village.
The EPA submission (3.1) statesThere is well established scientific evidence that traffic related air pollution, even at concentrations well below the current air quality standards, is associated with adverse health effect.It follows that any increase in PM2.5 emissions will lead to an increase in adverse health effect, and a level of emissions close to or exceeding the 2025 target is therefore a significant health effect.
Dr Wallis has also provided the following information that supports the need to mitigate the effects of air pollution on the residents of our village.Para 60-. A very small proportion of the population may be affected by adverse air quality, and of them, most are likely to be elderly and/or with severely compromised health.
Our village’s 265 residents are of average age of 73 years 8months (I am 82) and as such we are certainly elderly, and some have compromised health. The residents of our village, as sensitive receptors, are therefore most likely to be affected by adverse air quality as a result of the project. This can be a significant negative effect for sensitive receptors.
The Scoping requirements identify the need for mitigation measures to protect health of residents where the applicable standards identify any significant effects for sensitive receptors. It does not require that mitigation is only applicable when the standards are exceeded.
I note that EPR AQ1 states - Air quality (operation) The project must be designed and constructed to minimise air quality impacts during operation.
The EES projections are generally for the year 2031. However Appendix F (page 65) predicts that total emissions from vehicles on the Mordialloc Freeway in 2031 will be approximately the same as in 2021. It is therefore urgent that vegetation screening planting is a high priority now.
Finally, below are two photos of conditions at the rear of our village, that gives an indication that vegetation screening could be provided. Note that they also show how close the houses are to the road reserve.
That concludes my presentation. Thank you for this opportunity.
Following are two pages of the SEPP (AQM) as referenced in this presentation to show that-1Particles as PM2.5, refers to note 1 below that follows the table. 1 applies to point sources only. For area-based sources and roads, applicable criteria are specified in the relevant industry PEM. (There is no PEM (Protocol for Environmental Management) for roads)
20 s 240 21 December 2001 Victoria Government Gazette
