gas import jetty and crib point to pakenham pipeline project · with traffix group pty ltd and...

Level 28, 459 Collins St Melbourne Victoria 3000

T: 03 9822 2888 [email protected]

Traffix Group Pty Ltd ABN: 32 100 481 570

traffixgroup.com.au

Gas Import Jetty and Crib Point to Pakenham Pipeline Project Inquiry and Advisory Committee

Date of Hearing: Commencing 12th October, 2020

Date of Statement: 24th September, 2020 Date of Inspections: 18th August, 2020

Prepared for: AGL Wholesale Gas Limited (AGL) and APA Transmission Pty Ltd (APA) Instructed by: Hall & Wilcox and Ashurst

STATEMENT TO THE INQUIRY AND ADVISORY COMMITTEE APPOINTED BY THE MINISTER FOR PLANNING FOR THE PROPOSED GAS IMPORT JETTY AND PIPLELINE BY CHARMAINE DUNSTAN, TRAFFIC ENGINEER

Expert Evidence Statement Gas Import Jetty and Crib Point to Pakenham Pipeline Project

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Document Control

Our Reference: G28776A-01A COPYRIGHT: The ideas and material contained in this document are the property of Traffix Group (Traffix Group Pty Ltd – ABN 32 100 481 570). Use or copying of this document in whole or in part without the written permission of Traffix Group constitutes an infringement of copyright.


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Executive Summary

1 This evidence statement provides an assessment of the potential traffic engineering impacts of the proposal to construct a Gas Import Jetty and Crib Point to Pakenham Gas Pipeline project. My assessment has been completed independently as instructed by Hall & Wilcox and Ashurst on behalf of APA and AGL, respectively.

2 My review has been primarily (but not exclusively) a peer review of the traffic engineering impacts of the proposal described in the Transport Impact Assessment prepared by AECOM, which forms Technical Report J of the Environmental Effects Statement. This technical report informs the EES and other approval documentation including the Pipeline Licence Application and the Planning Scheme Amendment.

3 The Transport Impact Assessment found there to be impacts associated with construction of project in relation to increased traffic volumes, road safety, road closures, impacts on pedestrians, cyclists and public transport. These impacts are most pronounced during construction when the workforce peaks.

4 I am of the view that the TIA fundamentally identifies the key impacts of the proposal. My review found that the transport impacts of the proposal are generally well characterised. However, the assumptions and analysis of the traffic impacts of the proposal in my view tend to be overly conservative. In some cases, in an effort to be conservative, the analysis appears to over-estimate what the traffic impacts of the proposal will be.

5 The traffic impacts of construction of the ‘fixed’ facilities at Crib Point and Pakenham are modest. The key traffic generator is the construction of the pipeline due to the number of workers and movement of heavy vehicles along the construction route. Any impacts on the road network will be temporary in most cases, as the 57km of pipeline will be constructed rapidly over a period of approximately 15 months, meaning the impact at any one location is generally limited in duration.

6 The key impacts or risks identified by the TIA

• The capacity of the road network to accommodate additional traffic during construction and operation

• Road closures in Hastings

• Road deterioration (during construction and operation)

• Dirt on roads

• Impacts on pedestrians and cyclists in Hastings

• Impacts on bus routes

• Road closes outside of Hastings

• The safety of Access Track intersections

• Railway level crossings


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• The transportation of Nitrogen

7 The TIA identifies a series of appropriate mitigating measures, including:

• A Traffic Management Plan (MM-TP01), including dust and debris management

• Level Crossings Audit (MM-TP02),

• Stakeholder consultation on transport changes (MM-TP03)

• Road Safety Audit (MM-TP04)

• Pavement Strength Survey (of Woolleys Road/The Esplanade) and pavement upgrade if needed following the survey (MM-TP05)

• Public Transport Disruption Management, which is a Sub-Plan of the Traffic Management Plan (MM-TP06)

• Nitrogen Transport Plan (MM-TP07)

8 I find these mitigating measures appropriate. However, I have recommended that the intersection of Frankston-Flinders Road/Denham Road be included in the list of locations reviewed in the Road Safety Audit process due to its high level of use during construction and its existing casualty crash history.

9 Once completed, the project will have minimal impact on the transport network. The number of workers and vehicle movements it will generate will be very low. At the operational stage, the key impact is the use of B-Double trucks to transport Nitrogen and deliveries of Odorant to the Crib Point Receiving Facility.

10 The number of deliveries will be low, with 6 deliveries per day expected (5 for nitrogen and 1 for odorant, with odorant only required once every two months). These trucks will be able to use already approved B-Double routes for the majority of their journey, with the exception of Woolleys Road (the last few kilometres of the trip). The TIA identifies appropriate mitigating measures, including a pavement strength survey of Woolleys Road and the need to seek appropriate permits for B—Doubles to use this road.

11 The mitigation measures identified in the TIA have been incorporated in Chapter 25 Environmental Management Framework of the EES. The mitigation measures identified in Chapter 25 of the EES are appropriate, subject to the inclusion of the requirement for a Road Safety Audit of Frankston-Flinders Road/Denham Road pre-construction.

12 The Pipeline License Application, including Chapter J, has appropriately incorporated the findings of the TIA, however it appears to have overlooked one Transport Risk, TP5 - Pedestrian and cycling access in Hastings. This appears to be an accidental omission.

13 The proposed Incorporated Document for the Mornington Peninsula Planning Scheme includes the following two requirements:

• The preparation of Environmental Management Plan (EMP) in relation to Traffic and Transport (with separate plans for construction and operation of the project).


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• Exemption from Planning Permit requirements to create or alter access to Road Zones, but this process is still required to be completed in consultation with the Roads Corporation.

I have no issues with either of these requirements.

14 Overall, I find that the EES documentation, subject to some minor changes, adequately describes the project, likely transport impacts and identifies appropriate mitigation measures.


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Table of Contents 1. Introduction ............................................................................................................................ 9

2. Statement of Witness ........................................................................................................... 10 2.1 Qualifications and Experience ......................................................................................................... 10 2.2 Project Team ................................................................................................................................... 10 2.3 Scope of Work ................................................................................................................................. 10 2.4 Key Tasks......................................................................................................................................... 11 2.4.1 Experiments .................................................................................................................................... 11 2.4.2 Reference Documents .................................................................................................................... 11

3. Proposal ............................................................................................................................... 13 3.1 The Gas Import Jetty and Receiving Facility ................................................................................... 15 3.2 The Pipeline ..................................................................................................................................... 17 3.3 Construction .................................................................................................................................... 20 3.4 Port of Hastings Upgrades .............................................................................................................. 22 3.5 Operation ......................................................................................................................................... 22 3.6 Decommissioning ............................................................................................................................ 22

4. Review of the EES Scope ...................................................................................................... 23 4.1 Minster’s Requirements ................................................................................................................... 23 4.2 Scoping Requirements .................................................................................................................... 23 4.3 Assessment of Specific Environmental Effects .............................................................................. 24

5. Review of the Transport Impact Assessment ........................................................................ 27 5.1 Existing Conditions Review ............................................................................................................. 27 5.2 Traffic Generating Activities ............................................................................................................ 31 5.2.1 Construction Phase ........................................................................................................................ 31 5.2.2 Operation Phase .............................................................................................................................. 35 5.3 Risk Assessment ............................................................................................................................. 36 5.3.1 Review of Risk Assessment Method .............................................................................................. 36 5.4 Review of the Risk Assessment ...................................................................................................... 39 5.4.1 Road Link Capacity Assessment - Risk TP1 .................................................................................. 39 5.4.2 Road closures in Hastings impacting local access - Risk TP2 ..................................................... 47 5.4.3 Road Deterioration - Risk TP3......................................................................................................... 50 5.4.4 Dirt from Construction on Roads - Risk TP4 .................................................................................. 52 5.4.5 Pedestrian and Cyclists access in Hastings – TP5 ....................................................................... 53 5.4.6 Public/School bus impacts – TP6.................................................................................................. 54 5.4.7 Road Closures outside of Hastings – TP7 ..................................................................................... 55 5.4.8 Access Tracks – TP8 ...................................................................................................................... 56 5.4.9 Railway Level Crossings – TP9 ...................................................................................................... 60


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5.5 Operation Phase Risks .................................................................................................................... 61 5.5.1 Road Deterioration due to Nitrogen Trucks – TP10 ...................................................................... 61 5.5.2 Safety and Amenity Impacts of B-Doubles through Hastings/Somerville – TP11 ...................... 64 5.5.3 Capacity of road network to accommodate workforce and heavy vehicle movements during operation – TP12 .......................................................................................................................................... 66

6. Review and Recommendations on the mitigation measures identified in the EES and Key Approval Documents ........................................................................................................................ 67 6.1 Mitigation Measures in the EES ....................................................................................................... 67 6.2 The Incorporated Document in the draft Planning Scheme Amendment ....................................... 73 6.3 The Pipeline Licence Application .................................................................................................... 71 6.4 EPA Works Approval Application – Gas Import Jetty FRSU ........................................................... 73 6.5 Recommendations .......................................................................................................................... 73

7. Consideration of Submissions .............................................................................................. 74

8. Conclusions ......................................................................................................................... 81

Appendix A Instructions .............................................................................................................. 83


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List of Figures Figure 1: Project Overview (Source: Figure 1-1 of the EES) ...................................................................... 14 Figure 2: Gas Import Jetty Works (Source: Figure 4-3 of the EES) ............................................................ 15 Figure 3: Crib Point Receiving Facility Proposed Layout (Source: Figure 4-12 of the EES) ..................... 16 Figure 4: Pakenham Delivery Facility Layout (Source: Figure 4-14 of the EES). ....................................... 18 Figure 5: A Mainline Valve Facility (Source: Figure 4-13 of the EES) ........................................................ 19 Figure 6: Construction ROW for the Pipeline (Figure 4-16 of the EES) ...................................................... 20 Figure 7: Key intersections analysed by TIA (red circles) .......................................................................... 46 Figure 8: LEFT - Potential truck routes for Nitrogen and Odorant Deliveries (Source: Figure 12 of the TIA), RIGHT – Gazetted B-Double routes (Source: VicRoads website - https://vicroadsmaps.maps.arcgis.com/apps/webappviewer) ................................................................ 62

List of Tables Table 1: indicate pipeline construction schedule (Table 4-12 of the EES) 20 Table 2: Construction Workforce and Operating Hours (Table 4-17 of the EES) 21 Table 3: Draft Evaluation Objectives (Table 1 of the Scoping Requirements for the Gas Import Jetty Pipeline Project Environmental Effects Statement, DWELP) 23 Table 4: Review of Evaluation Objectives 25 Table 5: Review of Existing Conditions Assessment within Technical Report J 28 Table 6: Summary of Traffic Generation by Construction Activity (adapted from Table 6-1 of Technical Report J and other sources) 32 Table 7: Traffic Generation during Typical operation (Source: Section 6-2 and Table 6-4 of Technical Report J) 35 Table 8: Likelihood of Risks 37 Table 9: Risk Assessment Ratings (Source: Table 4-1 of Technical Report J) 37 Table 10: Adopted Risk Assessment Matrix 38 Table 11: Revised Peak Hour V/C Assessment (VicRoads arterials highlighted in grey) 42 Table 12: List of Road Closures 48 Table 13: Sight distance review at Access Track locations 57 Table 14: Review of Mitigation Measures: 68 Table 15: Extract from Appendix J of the Pipeline Licence Application – Performance Standards 71 Table 16: Review of Key Issues identified by submissions 74

List of Appendices Appendix A Instructions


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1. Introduction 15 The proposal is to construct a natural gas import jetty facility at Crib Point and connect that

facility via a pipeline to Pakenham, at which point the gas will be distributed via the Victorian Transmission System (VTS).

16 On 8 October 2018, the Victorian Minister for Planning (Minister) determined that the Project will be assessed through a single Environmental Effects Statement (EES) under Environmental Effects Act 1978 (Vic) (the EE Act).

17 The Commonwealth Department of Agriculture Water and Environment (DAWE) has separately determined that each of the Gas Import Jetty Works (the AGL project) and the Pipeline Works (the APA project), are controlled actions under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act). These actions are to be assessed under the Bilateral Agreement between the Victorian and Commonwealth governments. Accordingly, the EES will address both the EE Act and the EPBC Act processes and requirements.

18 The Minster has appointed an Inquiry and Advisory Committee (IAC) to conduct the hearing regarding the EES.

19 I have been instructed by Hall & Wilcox and Ashurst, on behalf of AGL Wholesale Gas Limited (AGL) and APA Transmission Pty Ltd (APA) to provide expert evidence in relation to traffic issues related to the project. My instructions are to undertake a peer-review of the EES and supporting documentation, relevant to traffic engineering matters.

20 I have also considered relevant issues raised in submissions to the IAC.


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2. Statement of Witness

2.1 Qualifications and Experience

21 My name is Charmaine Chalmers Dunstan. I am a Director of Traffix Group Pty Ltd practicing from Level 28, 459 Collins Street, Melbourne.

22 My qualifications and membership of professional associations are as follows:

i. Bachelor of Civil Engineering (honours), Monash University, Clayton

ii. Masters of Traffic, Monash University

iii. Member, Engineers Australia (IEAUST)

iv. Fellow, Victorian Planning & Environmental Law Association

23 I have over 20 years’ experience as a Traffic Engineering and Transport Planning consultant with Traffix Group Pty Ltd and formerly Turnbull Fenner Pty Ltd. My experience also includes a number of local government appointments which involved acting in the role of Council’s Transport Co-Ordinator or Senior Traffic Engineer.

24 I have experience and expertise in traffic management, transportation planning, road safety planning and engineering, parking management and strategy development, and development impact assessment of a broad range of land-use developments within established metropolitan, regional and growth areas.

2.2 Project Team

25 Leigh Furness (Senior Associate) assisted with site inspections, review and analysis of the application material, transport engineering analysis and the preparation of this statement.

2.3 Scope of Work

26 This statement specifically reviews the transport engineering implications of the proposal to construct a Gas Import Jetty at Crib Point and a Gas Pipeline from Crib Point to Pakenham.

27 My specific instructions are to:

• provide analysis and opinion on the aspects of the Project relating to transport engineering matters;

• prepare an expert witness statement which addresses:

– the relevant evaluation objective in the Scoping Requirements and provides our opinion and analysis regarding Chapter 15 and associated Technical Report relevant to transport engineering matters;

– a review of the concerns raised in the public submissions that are relevant to transport engineering and our opinion on those matters;


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– provides any recommendations in relation to the mitigation measures proposed in the EES and outlined in Chapter 15 - Transport and the Key Approval Documents;

• review any public submissions filed with the IAC that are relevant to transport engineering matters;

• identify any further information relevant to the transport assessment;

• appear as an expert witness at the Hearing of the Project.

28 A copy of my instructions from Hall & Willcox/Ashurst is attached at Appendix A.

29 During my investigations, I have visited the site, reviewed the exhibition materials and background documents.

30 As part of my review, I have had regard to submissions. I have provided a response to key themes.

2.4 Key Tasks

31 The scope of my engagement has included the following tasks:

i. review of the site location and the surrounding transportation network,

ii. review and analysis of traffic data,

iii. review of historical road safety data,

iv. review of supporting documentation, and seeking additional clarification from the authors and AGL/APA where required,

v. review of Council and State policies and other relevant documents,

vi. review of the EES documentation, with particular reference to Chapter 15 Transport, and Technical Report J, Transport Impact Assessment which informs Chapter 15 of the EES and the proposed mitigating measures at Chapter 25,

vii. the Pipeline License Application, as it relates to traffic engineering matters,

viii. the proposed Planning Scheme Amendment,

ix. review of the potential traffic impacts of the proposal,

x. review of submissions, and

xi. preparation and giving of Expert Evidence in accordance with Planning Panels Victoria – Guide to Expert Evidence.

2.4.1 Experiments

32 I have visited the project area to observe the road network, relevant the pipeline route.

2.4.2 Reference Documents

The following key documents are relied upon in formulating this statement:

i. The EES, with particular reference to:


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– Chapters 1-5

– Chapter 15: Transport

– Technical Report J: Transport Impact Assessment completed by Aecom (date 04 June, 2020).

– Chapter 17: Land Use

– Chapter 25: Environment Management Framework.

ii. The Pipeline License Application.

iii. The proposed Incorporated Document for the Mornington Planning Scheme.

iv. Council Officer Reports by Mornington Peninsula Shire Council and Cardinia Shire Council.

v. Submissions.


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3. Proposal 33 The proposal is to create the delivery infrastructure required for the importation of natural gas

to Victoria by sea. The project consists of port facilities at Crib Point to allow for the unloading of LNG carriers and a pipeline to deliver the gas to the Victoria Transmission System (VTS) at Pakenham.

34 The project consists of two parts, the Gas Import Jetty Works and the Pipeline Works. AGL is undertaking the Gas Import Jetty Works and APA is undertaking the Pipeline Works.

35 The project area is described in the EES Attachment VII Map Book. My review is focuses on the alignment described in the Map Book and Technical Report J: Transport Impact Assessment (the TIA). This is the primary document relevant to my area of expertise as a traffic/transport engineer.

36 The Gas Import Jetty comprises the following components:

• The continuous mooring of a Floating Storage and Re-gasification Unit (FSRU) at Berth 2 of the existing Crib Point Jetty. The FSRU is a ship that stores Liquid Natural Gas (LNG) and it includes an onboard re-gasification unit to unload incoming LNG carriers and covert the LNG into natural gas before transmission to land.

• Jetty Infrastructure on the Crib Point Jetty, including Marine Loading arms and the require gas piping to transfer the gas from the FSRU to the landside Crib Point receiving facility.

• The Crib Point Receiving Facility located on land in close proximity to the Crib Point Jetty. This facility meters the gas, injects odorant and nitrogen into the gas before sending it into the pipeline.

37 The Pipeline Works consists of the following components:

• An underground bi-directional gas transmission pipeline approximately 57km in length extending from the Crib Point Receiving Facility to the Victorian Transmission System (VTS), east of Pakenham.

• A pigging facility at the Crib Point Receiving Facility. This allows for in-line inspections using a Pipeline Inspection Gauge (PIG).

• The Pakenham Delivery Facility adjacent to the Pakenham East rail depot to monitor and regulate the gas. This facility will be above ground.

• A below-ground End of Line Scraper Station located at the connection point of to the VTS, north of the Princes Highway in Pakenham.

• Two above-ground mainline valves (MLV1 and MLV2) located at different points along the pipeline (breaking the pipe into 3 parts) to enable isolation of part of the pipeline in the event of an emergency.

38 Figure 1 shows the locations of the key facilities described above and the route of the pipeline.

39 Construction and commissioning of the whole project is expected to take up to 27 months.


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40 The Gas Import Jetty Works are proposed to operate for 20 years, however this could be extended or shortened depending on supply and demand for gas.

41 The Pipeline Works has a design life of 60 years. It could be used for other purposes if the Gas Import Jetty were decommissioned.

Figure 1: Project Overview (Source: Figure 1-1 of the EES)


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3.1 The Gas Import Jetty and Receiving Facility

42 Figure 2 provides a layout of the Gas Import Jetty Works, the FSRU and the location of Crib Point Receiving Facility. Also shown is one of two Pipeline Works Laydown Areas required during construction of the pipeline. These facilities are located within the existing Port of Hastings and area is zoned as a Port Zone under the Planning Scheme.

Figure 2: Gas Import Jetty Works (Source: Figure 4-3 of the EES)


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43 Figure 3 illustrates the details of the proposed Receiving Facility at Crib Point. It includes accessways and loading areas for B-Double trucks delivering to the facility. This layout is not final and subject to detailed design, however illustrates the key facilities proposed.

Figure 3: Crib Point Receiving Facility Proposed Layout (Source: Figure 4-12 of the EES)


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44 The Receiving Facility has several critical functions:

• Metering of the gas arriving from the Jetty.

• Measuring of the gas composition on arrival.

• Odorant injection (as safety measure to give the otherwise odourless gas a smell).

• Nitrogen injection to dilute the gas, as required for distribution.

• Distribution to the pipeline.

45 Trucks will be required to deliver nitrogen and odorant to the facility on a regularly basis.

46 The supply of Nitrogen requires 900 truck deliveries per year from a facility in Dandenong (850) and Altona (50). B-Double trucks will transport the Nitrogen. Truck movements will be spread over the year. I understand that approximately 5 deliveries per day are expected (10 movements into and out of the facility), spread over the course of the day.

47 Odorant will be delivered approximately once every 2 months by trucks.

48 Accordingly, 12 B-Double truck movements (two-way) may occur at the Crib Point Receiving Facility.

49 The Receiving Facility is designed to be automated and may operate unmanned under normal operating conditions. There will be regular visits by technicians, maintenance workers, etc., and a combination of light and heavy vehicles will be used for these trips.

3.2 The Pipeline

50 The Pipeline works involve constructing a bi-directional gas transmission pipe for the transport of gas from the Crib Point Receiving Facility to the VTS at the Pakenham Delivery Facility. It comprises:

• The Pipeline itself will be approximately 57km long. A nominal 600mm diameter pipe will be used, with the top of the pipe buried 1.2m below ground level (to the top of the pipe).

• The Pakenham Delivery Facility at Pakenham, adjacent to the Pakenham East rail depot. The facility will provide filtration, metering, heating, pressure control and a vent stack. This facility will be automated and generally not be manned under normal operating conditions (see Figure 4 for a layout).

• Two mainline values (MLV) stations will be installed at intervals along the pipeline to allow isolation of sections of the pipeline in event of emergency (see Figure 5).

• A PIG launcher at the Crib Point Receiving Facility and the PIG receiver at the Pakenham Delivery Facility.

• The End of Line Scraper Station (EOLSS), an underground facility located at the connection of the pipeline to the VTS.


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Figure 4: Pakenham Delivery Facility Layout (Source: Figure 4-14 of the EES).


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Figure 5: A Mainline Valve Facility (Source: Figure 4-13 of the EES)

51 The pipeline would be located on land used for various purposes including rural residential living, road corridors, industry, conservation reserves and agricultural land. The detailed route of the pipeline is set out at Map Book VII.

52 I am instructed that the pipeline alignment has been designed to minimise impacts on sensitive land uses, and where possible, follows existing pipeline easements.

53 The pipeline heads north from the Receiving Facility and generally follows the Stony Point rail reserve through Hastings. Towards Pakenham, the pipeline crosses the Gippsland rail line before reaching the proposed Pakenham Delivery Facility adjacent to the Pakenham East rail depot. It then crosses the Princes Freeway and connects to the VTS.


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3.3 Construction

54 Construction and commissioning of the whole project is expected to take 18 to 27 months, subject to staging.

55 The landside facilities such as the Receiving Facility at Crib Point and Delivery Facility at Pakenham will largely be constructed within their site boundaries.

56 The pipeline will generally be constructed by laying a trench (cut and cover method). However, Horizontal Directional Drilling will be used for crossing major/sensitive water courses, major roads, railways, and some third-party assets. This process means drilling a pipe horizontally without breaking the surface above it.

57 The following table provides the indicative schedule of the pipeline construction. The key task of constructing the pipeline and reinstatement of the pipeline ROW are completed concurrently over approximately 15 months.

Table 1: indicate pipeline construction schedule (Table 4-12 of the EES)

58 To construct the pipeline requires a typically 30m wide construction right of way (ROW). The

operational easement is generally 15m wide. Figure 6 illustrates a general cross-section of the works area.

Figure 6: Construction ROW for the Pipeline (Figure 4-16 of the EES)


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59 Other areas will be required for temporary facilities to support construction including:

• Work areas for vehicle turnaround, workspaces around crossings, set up areas, laying out of pipe, stockpiling and other storage areas.

• Water supply tanks or dams for dust suppression and hydrostatic testing.

60 A total of 40 Access Tracks (AT) are required for access between the construction ROW and the public road network. These tracks will be temporary in nature, constructed of gravel and less than 10m wide.

61 Several construction laydown areas will be required for the store and organisation of construction materials and equipment. Laydown areas are proposed at the following locations:

• At Crib Point, opposite the proposed Receiving Facility.

• Denham Road, Hastings. This location will be the key laydown area for the majority of the pipe. It will also contain the project site offices.

• Adjacent to the Bluescope Steel Wharf, Bayview Road, Hastings. This area will be used for the temporary storage of pipe that is unloaded from a ship, before it is transferred to the Crib Point or Denham Road laydown aeras.

• Railway Road in Koo Wee Rup, adjacent to the Koo Wee Rup Bypass. This area may not be required.

62 Post-construction, the pipeline easement would be reinstated to open grassland.

63 The following table summarises the construction activity and required workforce to complete the project.1

Table 2: Construction Workforce and Operating Hours (Table 4-17 of the EES)

64 The task of constructing the pipeline requires the largest number of workers. The pipeline will

be constructed rapidly over a 21 month period, with the bulk of work completed within 15 months. As this construction activity is spread over the length of the route from several workfronts, the impacts of construction at any one location will be limited in time as the pipeline and workforce rapidly moves to the next location.

1 There are some minor inconsistencies between the number of construction workers listed and the TIA, with the TIA figures being slightly higher and are not significantly different.


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65 In discussions with APA, I have been instructed that workers on the pipeline complete 10-hour shifts, typically working 7am-5pm, with around 30min of mobilisation/demobilisation before the start and at the end of the day. Work hours may vary slightly due to daylight and project requirements.

3.4 Port of Hastings Upgrades

66 Whilst not strictly part of the project, the Port of Hastings Development Authority (PoHDA) will be undertaking upgrade works to the berthing facilities at the Crib Point Jetty and these may take place concurrently with this project. This proposal is described as requiring 120 workers and taking 27 months to complete by the TIA.

3.5 Operation

67 The FRSU will be operated and maintained by a crew of 30-35 people. Some may reside on the vessel and some may work in shifts.

68 The above-ground, land side facilities (the Receiving Facility, Delivery Facility, etc.) are designed to be automated and unmanned. Various support people, contractors, technicians, etc. will be required to maintain all landside facilities. These numbers will be low and workers will use a variety of light and heavy vehicles.

69 Daily operations of the pipeline will be managed by APA’s Control Room in Dandenong.

70 The key transport impact is the delivery of Nitrogen and odorant to the Crib Point Receiving Facility, with 6 trucks per day required to deliver these to the facility.

3.6 Decommissioning

71 The FSRU is proposed to operate for 20 years. This may be shortened or extended depending on the supply and demand for gas. When decommissioned, the FSRU will leave and the jetty infrastructure be decommissioned.

72 The pipeline has a design life of 60 years.


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4. Review of the EES Scope

4.1 Minster’s Requirements

74 The EES is required to consider the following issue in relation to transport engineering:

effects on socio-economic values, at local and regional scales, potentially generated by the project, including increased traffic movement and indirect effects of the project construction workforce on the capacity of local community infrastructure;

75 The scoping requirements of the EES set out the specific matters to be investigated by the EES.

4.2 Scoping Requirements

76 The Scoping Requirements for the Gas Import Jetty and Pipeline Project Environment Effects Statement (DWELP, January 2019) includes the following draft evaluation objectives:

Table 3: Draft Evaluation Objectives (Table 1 of the Scoping Requirements for the Gas Import Jetty Pipeline Project Environmental Effects Statement, DWELP)

77 The TIA identifies that two of these objectives are directly related to transport, namely:

• Energy efficiency, security, affordability and safety – To provide for safe and cost-effective augmentation of Victoria’s natural gas supply in the medium to longer term.

• Social, economic, amenity and land use – To minimise potential adverse social, economic, amenity and land use effects at local and regional scales.


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78 I have reviewed the draft evaluation objectives and I agree with the TIA that these two objectives are the most relevant to traffic/transport engineering.

4.3 Assessment of Specific Environmental Effects

79 The Assessment of Specific Environmental Effects of the Scoping Requirements sets out specific requirements for the assessment of specific environmental effects. The assessment has the following structure:

Key issues or risks that the project poses to the achievement of the draft evaluation objective. In addition to addressing the highlighted issues, the proponent should consider undertaking its own environmental risk assessment.

Priorities for characterising the existing environment to underpin predictive impact assessments having regard to the level of risk. Any risk assessment by the proponent could guide the necessary data gathering.

Design and mitigation measures that could substantially reduce and/or mitigate the risk of significant effects.

Assessment of likely effects through predictive studies or estimates of effects that are reasonably likely, as well as evaluation of their significance, having regard to their likelihood.

Approach to manage performance measures that are proposed to manage risks of effects, assuming that identified design and mitigation measures are applied, to achieve appropriate outcomes. This should inform the assessment of likely residual effects (assuming proposed measures are implemented) and consideration of environmental offsets where applicable.

80 The TIA has reviewed the specific environmental effects to be assessed and identifies the scoping requirements relevant to a Transport Impact Assessment.

81 Table 4 summarises the TIA’s detailed review of the specific environmental effects as they related to Transport.


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Table 4: Review of Evaluation Objectives

Draft Evaluation Objective

Key Issues Priorities for characterising the existing environment

Design and Mitigation Measures

Assessment of Likely Effects

Approach to Manage Performance

Energy efficiency, security, affordability and safety

• Workforce, nearby operations and public safety risks associated with the construction or operation of the project, including risks associated with or compounded by potential external threats (e.g. bushfire).

• Characterise the human environment near the project relative to safety buffer standards for surrounding current land uses and reasonably foreseeable land uses.

• Describe proposed measures to minimise risk and ensure safety for workforce, nearby operations and the public during construction and operation of the project.

• Assess the level of residual risk relative to standards applicable to the project, including the FSRU.

• Describe the monitoring program to form part of the EMF to identify any potential hazards in time for corrective action to be taken.

Social, economic, amenity and land use

• Potential for project works and operations to affect business (including farming and tourism) operations or other existing or approved facilities or land uses.

• Potential for temporary or permanent changes to use of or access to existing infrastructure in the project area and in its vicinity.

• Potential for impacts on reasonably foreseeable upgrades to public infrastructure.

• Identify existing and reasonably foreseeable land uses and businesses occupying land to be traversed by, adjacent to, or otherwise affected by impacts from the project.

• Identify options for mitigating impacts from project construction or operation on potentially affected businesses and community facilities including open space.

• Describe the likely extent and duration of temporary disruption to existing land uses arising from project construction.

• Describe potential impacts on public infrastructure including roads resulting from construction or operations activities.

• Assess potential safety hazards to the public arising from project construction and operation.

Location of Assessment corresponding to Evaluation objectives in the TIA

• Section 8.0 (Impact Assessment)

• Section 5.0 (Existing Conditions)

• Section 7.0 (Risk assessment)

• Section 8.0 (Impact assessment)

• Section 9.0 (Mitigation measures)

• Section 8.0 (Impact assessment)

• Section 9.0 (Mitigation measures)


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82 My review of this table and the Scoping Requirements identified two issues that have not been directly addressed under the Social, Economic Amenity and Land Use evaluation objective (emphasis added):

Design and Mitigation Measures

Identify potential and proposed design responses and/or other mitigation measures to avoid, reduce and/or manage any significant effects for sensitive receptors during project construction and operation arising from specified air pollution indicators, noise, vibration, traffic and lighting, in the context of applicable policy and standards and the anticipated increase in shipping traffic in Western Port resulting from the project.

Assessment of Likely Effects

Assess likely noise, vibration, traffic, lighting and visual impacts at sensitive receptors adjacent to the project during project construction and operation (both with and in the absence of the proposed mitigation measures), relative to standards.

83 A ‘sensitive receptor’ is not defined in the TIA. A sensitive receptor is described in the Scoping Requirements document as being dwellings, community centres, open spaces, etc. My reading of these objectives is that they relate primarily to amenity considerations.

84 Traffic engineers are not experts in amenity considerations. A traffic engineer’s role is to quantify potential impacts such as the volume, distribution and timing of traffic movements (including heavy vehicles), rather than necessarily judge or quantify whether these result in unacceptable amenity outcomes.

85 Notwithstanding that the TIA does not identify these amenity impacts specifically, it provides the necessary information for others to judge whether the project will have unacceptable amenity outcomes in so far as traffic movements are concerned, in particular at Section 8.0 (Impact Assessment).


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5. Review of the Transport Impact Assessment 86 As prescribed in the Scoping Requirements, the TIA adopts a systematic risk-based

approached to understanding the project environment, the potential impacts of the Project and ways to avoid, minimise or manage and the impacts (or risk of impact) identified. The TIA adopts the following methodology:

1. Existing Conditions Assessment, including: a. A desktop study of the transport network. b. Site assessment of roads within the study area. c. Investigation of road safety data, public transport routes and heavy vehicle

routes and restrictions. d. Review of available traffic data for key road links. e. Review of policy and legislation.

2. A review Traffic Generating Activities a. Review of the workforce, plant and equipment required during the construction

phase the project. b. Review of the plant, supplies and workforce required to operate the project.

3. A detailed Risk Assessment 4. Assessment of Impacts for:

a. The construction phase b. The operational phase c. Residential and legacy impacts d. Possible cumulative impacts of PoHDA upgrade works to the berthing facilities

at the Crib Point Jetty, which may occur concurrently with the project. 5. Recommended Mitigation Measures

87 The review also included stakeholder engagement with VicRoads (now Department of Transport), Mornington Peninsula Shire, City of Casey and Cardinia Shire.

88 I am satisfied that the above methodology is appropriate.

5.1 Existing Conditions Review

89 A substantial body of work has been completed by Aecom assessing the existing conditions of the transport network in the vicinity of the project. This includes field inspections, sourcing of data from government databases and agencies, desktop reviews and discussions with key transport agencies and local councils.

90 The study area encompasses 57km of pipeline between Crib Point and Pakenham and from a traffic perspective, will potentially impact over 100 roads along the route. In completing this review, I have generally accepted the existing conditions assessment of the TIA as providing accurate information.

91 In this context, I have reviewed this material at a macro level to ensure all key factors have been considered and I have not sought to cross-check that every detail is correct at the micro level. For example, while the Technical Report considers key aspects of the road network (such as its physical configuration and how it is managed by road authorities), I have not


G28776A-01A 28

cross-checked pavement widths or speed zones of each road within the study area. This is unnecessary in my view.

92 Where a matter of detail is critical to the assessment of project impacts, a field inspection has been completed and the data verified. For example, sight distance measurements at each access track has been verified on-site.

93 Below provides a summary of my review of the existing conditions assessment contained in the TIA (Technical Report J).

Table 5: Review of Existing Conditions Assessment within Technical Report J

Area Section of TIA

Information provided

Review/Comment

Declared Road Network

5.1 Map of declared road network

Review of planned road upgrades

This information is necessary to consider and covered adequately.

Local Road 5.2

App. B

Detailed review of all local roads and classifications within study area


B-Double, Higher mass limits and oversize overmass vehicles

5.3 Detailed review of all restrictions on large vehicles in map form.


Existing Traffic Volumes

5.4 Traffic volume data on all roads within study area, with estimates provided where not available.

Seasonal variation in traffic volumes

It is necessary to consider the existing traffic volumes using various roads within the study area.

The project team had to contend with a lack of readily available traffic data. While data is readily available for the arterial roads, there is limited data available for local roads, as many of these roads carry negligible traffic volumes and are not the subject of routine data collection by Council. Data collection for every road is not strictly necessary in my opinion, given the scale and duration of likely impacts of the project.

Where data was available for any road, this information was adopted as the current traffic volume.

Where data was not available, the TIA adopted the approach of accepting upper limit of the ‘environmental’ or ‘target’ capacity for many of the urban local and rural


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Area Section of TIA


Review/Comment

local roads as being the current daily traffic volumes using these roads. This is highly conservative as many roads in the study are carrying negligible volumes.

In this context, there are two concepts regarding the capacity of roads to accommodate traffic:

• The traffic carrying capacity of a road is the theoretical amount of traffic a road link can carry on an hourly or daily basis. This is relevant for arterial roads.

• The environmental or target capacity of a road is a recognition that it is desirable for most local roads to carry less traffic than their theorical capacity. For a variety functional, amenity, safety and operational reasons, local roads are not expected to carry traffic at their higher theorical capacity.

Transport engineers and road management agencies (Councils and state agencies) classify lower order roads at various levels and generally include an environmental or target traffic volume for these roads.

In most cases, the actual traffic volume on any given local road is substantially less than its ‘target’ capacity. It is readily evident from a field inspection and other investigations that most of the local roads within the study area carry substantially less traffic than their ‘target’ capacity given the low density of land use abutting these roads.

An example of this can be seen at Woolleys Road, which connects directly into The Esplanade (see Table 8-1 of the TIA). The Esplanade was counted by Mornington Peninsula Shire Council as carrying approximately 400 vehicles per day. Woolleys Road leads directly into the Esplanade with minimal abutting traffic generating land uses. Based on its classification, the study adopts a daily traffic volume of 3,000 vehicles per day. In actuality Woolleys Road would carry a level of traffic much closer to 400 vehicles per day (the same as The Esplanade).

This presents a highly conservative assessment.

Crash Analysis

5.5 A review of all casualty crashes for the 5 year period between 2013-2017.

The TIA identifies all casualty crash locations. It provides further detail for fatal crash locations and crash locations with more than 5 casualty crashes over 5 years. The 5 year casualty crash threshold is typically used in road safety analysis to identify ‘Blackspots’. For local roads or rural arterials with lower traffic volumes (i.e. lower


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Area Section of TIA


Review/Comment

exposure), it may be appropriate to consider a lower threshold. This statement considers locations with 4 casualty crashes (responding to Mornington Peninsula Shire Council submission). This information was sourced from Aecom.

Bus Routes 5.6 Consideration of all public and school bus routes within the study area.

Public transport services are appropriate to consider and are covered adequately given the limited services in the area.

Pedestrians and Cyclists

5.7 Pedestrians and cyclists are identified as an issue within Hastings only.

Pedestrians and cyclists are not a strong consideration along the pipeline route (due to the rural nature of the area), except within Hastings.

Within Hastings, the use of the rail corridor (instead of Frankston-Flinders Road) significantly reduces the exposure of pedestrians and cyclists to the project workers area.

The TIA does not seek to quantify pedestrian or cyclist numbers as part of the existing conditions assessment. I am satisfied that this in reasonable in the context of the proposed route.

Level Crossings

5.8 Identifies all level crossings, the standard of the crossing and number of rail services

This aspect is necessary to consider and covered adequately.


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5.2 Traffic Generating Activities

94 There are two distinct phases of the project from a traffic impact perspective:

• Construction Phase – including the movement of the workforce, transportation of materials and construction equipment and direction construction impacts on transport infrastructure (road closures, etc.).

• Operational Phase – the movement of the everyday workforce, transportation of raw materials required for operation and movements of technicians/specialists performing maintenance of the project.

95 Each of these stages will generate different amounts of traffic and to different locations.

5.2.1 Construction Phase

96 The construction phase of the project will take 18-27 months to complete. The table below summarises the construction activity/location, the required workforce and expected truck movements. This table summarises information from Table 6-1 of Technical Report J, a detailed review of project assumptions, raw data information and calculations made available to me by Aecom and APA to assist in reviewing the predicted volumes.


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Table 6: Summary of Traffic Generation by Construction Activity (adapted from Table 6-1 of Technical Report J and other sources)

Construction activity (Time period)

Anticipated workforce (people) 1

Workforce daily traffic generation (two-way)2

Origin of Workers

Plant and equipment daily traffic generation (two-way)

Construction Times

Gas Import Jetty Works - Jetty infrastructure & Crib Point Receiving Facility (27 months)

90 180 light veh/day 90% Melbourne

10% local

42 heavy vehicle movements per day

Will vary from day to day depending on construction activity and schedule.

6am-6pm Mon-Fri

6am-3pm Sat

Crib Point Jetty Upgrade Works (by PoHDA) (27 months)

120 80 light veh/day balance of workforce to arrive by sea

Unknown at this stage of the project Unknown at this stage of the project

Crib Point to Pakenham Pipeline (21 months)

400 at peak

120 typically

50 at project office in Denham Road

800 light veh/day

240 light veh/day

100 light veh/day

50% Melbourne

50% local

101 heavy vehicle movements per day associated with movement of pipe from laydown areas to the pipeline ROW

6am-6pm, 7 days

Horizontal Drilling up to 24hr/7days

Pakenham Delivery Facility (18 months)

50 100 light veh/day 50% Melbourne

50% local

26 heavy vehicle movements per day 6am-6pm Mon-Fri

6am-3pm Sat

Total 580 1,260 169

Notes:

1. As estimated by AGL and APA. I understand that these numbers are conservative.

2. Assumes each worker drivers separately, to and from work each day (i.e. 2 movements per worker). Light vehicles are cars and utes. This assessment is conservative as at least a proportion of the workforce can be expected to carpool.


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97 Some key points within this table require further explanation:

• The table adopts an assumption that each worker generates two vehicle movements per day, comprising an arrival and departure movement. It conservatively assumes that no carpooling, or shuttle bus service is used, both of which may significantly reduce workforce traffic movements. For the purposes of this assessment, I find this assumption conservative and reasonable.

• It assumes that 400 workers are tasked with constructing the pipeline each day, which represents a maximum figure. I understand that the typical workforce is 120 workers per day.

• What is not immediately conveyed to the reader from this table is that the 400 (or 120) workers on the pipeline will be spread along the length of the pipeline during construction. The EES describes that the project will proceed on multiple fronts simultaneously, with up to 5 construction locations being active at any one time. For instance, two crews may be conducting horizontal drilling underneath a main road, while two more crews are working on the pipeline either side of it, each using different access tracks.

• The pipeline will be laid at an average rate of 800m per day over multiple fronts. This means that vehicle movements for workers and the delivery of pipe will be:

– Spread over a wide area and multiple access tracks.

– Move rapidly from one area to the next. The 57km of pipeline is scheduled to be laid over a 15-month period.

The consequences of this is that the TIA is highly conservative as it assumes that all pipeline workers are concentrated on each road, which is unlikely to be the case in practice. Furthermore, these impacts are relatively brief in duration as the project moves along the route quickly.

98 The EES highlights the short duration of construction impacts for the pipeline as follows (4-36, Project Description):

In rural areas, each stage of open-cut trenching pipeline construction would take between one and three days at a particular property to complete, with approximately one week between each stage. In urban areas, open- cut trenching amenity impacts for an individual receptor would likely last for up to 10 days, depending on weather and other conditions.

99 I have undertaken a review of the background information provided by APA to Aecom and the working spreadsheets prepared by Aecom to check the assumptions and figures described by Table 6. I generally find the assumptions and traffic distribution reasonable, with one key exception. The estimate of 101 two-way truck movements per day delivering pipe is too conservative in my opinion. APA estimates that a total of 772 two-way truck movements will be required to deliver pipe from the lay-down areas to the access tracks for the entire pipeline, which is to be constructed over the course of 15 months. From my review of the APA source material, the actual number of trucks delivering pipe to the Access Tracks is unlikely to be significant (average of less than 10 two-way truck movements per day).


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100 The table also does not reflect that at the start of the project, pipe will be transported from the Port of Hastings (Bluescope Western Port)2 and transported to laydown areas before transportation to the construction ROW commences. That is, this is not an on-going daily movement. Pipe will be delivered as follows:

• 28.5km will be shipped to Bluescope Steel at Hastings and transported to the Denham Road laydown area. Five trucks with extendable trailers will undertake 4 loads per day to transport the pipe. These movements are estimated to take 11 days.

• A second shipment of 28.5km will be shipped to Bluescope Steel at Hastings, with:

– 23.5km transported to the Denham Road layout down area.

– 5km transported to the Crib Point laydown area.

Five trucks with extendable trailers will undertake 4 loads per day to transport the pipe. These movements are estimated to take 12 days.

• 500m of heavy pipe will be shipped to the Port of Melbourne and then transported to lay down areas.

101 Accordingly, the transportation of pipe to laydown areas is expected to be completed in approximately 1 month, before construction commences.

2 57km of pipe will be shipped to Hastings and 500m of pipe will be shipped to the Port of Melbourne.


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5.2.2 Operation Phase

102 The table below sets out the typically daily traffic generation of the project expected during the operation phase, as detailed in the TIA.

Table 7: Traffic Generation during Typical operation (Source: Section 6-2 and Table 6-4 of Technical Report J)

Operational facility Anticipated Workforce

Workforce daily traffic generation1

Maintenance daily traffic generation

Heavy Vehicles

FSRU 36 72 0 0

Crib Point Receiving Facility

2 4 12 5 per day associated with Nitrogen deliveries2

Crib Point to Pakenham pipeline

2 4 0 0

Pakenham Delivery Facility

Unmanned 0 0 0

Total 40 80 12 6

Notes:

1. Each worker is assumed to generate two movements per day, one arriving and one leaving work. No car sharing or alternative transport modes are assumed, which is conservative.

2. Odorant will be delivered by truck approximately once every 2 months, which is not substantial in my view.

3. Any facility will require maintenance from time to time and this may generate additional truck and worker movements, with this not being a daily occurrence.

103 In my view, the daily traffic movements associated with workers during the operation phase are not significant. The overall level of traffic generation is modest once the project reaches the operational phase.

104 The regular deliveries of B-Double trucks to the Crib Point Receiving Facility have a greater potential for impact (due to the nature of trucks involved), however these movements are also modest in volume.


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5.3 Risk Assessment

105 The EES reviews the impacts of the project is a Risk Assessment, as described at Section 4.3 of the TIA.

106 Broadly, the risk assessment process involves the following tasks:

1. Establish the context of the risk assessment 2. Risk identification - Identify key risks/events 3. Risk analysis - Identify the likelihood of that risk/event occurring 4. Risk evaluation - Identify the severity of outcome if that risk/event occurs 5. Risk treatment - Identify mitigating measures to manage/reduce the risk

107 I have undertaken a thorough review of risks identified in the EES and the project in general to determine if any risks have been overlooked by the TIA.

108 While a risk assessment pathway is a subjective, the risk events identified should be broadly consistent across an assessment by independent parties.

109 The assessment of the likelihood and severity of each individual risk is more subjective, however, should not be substantially different. By example, one expert’s opinion may be that the likelihood of an individual risk is ‘rare’ while another opinion is that is ‘unlikely’. The difference is relatively small and unlikely to significantly affect the overall outcome of the assessment. In my assessment, I have not attempted to ‘split hairs’ between a risk level if my view is generally in accordance with the original EES assessment contained at Technical Report J.

110 The final part of the assessment is the identification of mitigating measure. My methodology was to review if the mitigation measures identified were appropriate and comment if additional measures should be included to further reduce the possible impacts of the project.

5.3.1 Review of Risk Assessment Method

111 Risks are defined by two features:

• The likelihood of the event occurring

• The magnitude of the potential consequences of an event

112 The TIA adopts the same levels of likelihood of risks as the all other parts of the EES, as per the table below.


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Table 8: Likelihood of Risks

Level Description

Rare The event may occur only in exceptional circumstances

Unlikely The event could occur but is not expected

Possible The event could occur

Likely The event will probably occur in most circumstances

Almost Certain The event is expected to occur in most circumstances or is planned to occur

113 The consequence rating of each event is adapted from the risk framework set out at Table 5-3 of the EES. Specifically, the TIA altered this table to reflect what transport impacts would be assessed as negligible, minor, moderate, major or severe.

114 On review of Table 4-1 of the TIA, I accept the qualitative descriptions adopted as being appropriate.

Table 9: Risk Assessment Ratings (Source: Table 4-1 of Technical Report J)

Level Qualitative description

Negligible Local, small-scale, easily reversible change in amenity for an area and the communities of interest can easily adapt or cope with change. No detectable change in a local transport operational setting. Negligible adverse impact on traffic conditions or road safety.

Minor Short-term (less than one year), recoverable change in amenity for an area and community has substantial capacity to adapt and cope with change. Short-term, reversible changes in a local transport operational setting. Detectable change in traffic conditions and increase risk of collisions by five per cent.

Moderate Medium-term (one to five years), recoverable change in amenity for an area and community has some capacity to adapt and cope with change. Long-term but limited changes to transport operational setting that are able to be managed. Detectable change in traffic conditions and increase risk of collisions by 10 per cent.

Major Long-term (five to 25 years), recoverable change in amenity for an area and community has limited capacity to adapt and cope with change. Long-term, significant changes resulting in risks to human health and/or the functioning of the transport network beyond the Project Area. Traffic congestion and delays exceed acceptable levels and increase risk of collisions by 20 per cent.


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Level Qualitative description

Severe Long-term (five to 25 years), irreversible change in amenity for an area and community has limited capacity to adapt and cope with change. Irreversible, significant changes resulting in widespread risks to human health and/or the functioning of the transport network at a regional scale. Traffic congestion and delays severely restrict accessibility and increase in risk of collisions by 20 per cent or an increase in number of fatalities.

115 For completeness, I have included the adopted risk assessment matrix and risk rating.

Table 10: Adopted Risk Assessment Matrix

Consequence Rating

Negligible Minor Moderate Major Severe

Likelihood Rating

Rare Very Low Very Low Low Medium Medium

Unlikely Very Low Low Low Medium High

Possible Low Low Medium High High

Likely Low Medium Medium High Very High

Almost Certain

Low Medium High Very High Very High

116 For my review, I have worked within the defined risk framework set out above.


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5.4 Review of the Risk Assessment

117 Section 7.0 of the TIA identifies the project risks (see Table 7-1, starting page 50).

118 My approach to reviewing the risk assessment in the TIA has been to:

• Review each risk identified by the TIA.

• Peer review whether the impacts, assessment methodologies, risk weightings, overall risks and mitigation measures identified have been appropriately considered.

I have relied on the information provided in the TIA, information provided in the EES and associated map books and the projects online GIS platform, and information supplemented with my own investigations, where required to form an opinion.

• Considered with the TIA has overlooked any risks/impacts from the project.

5.4.1 Road Link Capacity Assessment - Risk TP1

119 Risk ID TP1 is the capacity of the road network to accommodate the workforce and heavy vehicle movements of the project during construction. The TIA evaluated the risks as set out in the following table.

Risk ID

Works area

Risk name Risk pathway Initial mitigation measure

Initial risk Additional mitigation measure

Residual risk

C L Risk C L Risk

Construction

TP1 Gas Import Jetty Works and Pipeline Works

Capacity of road network to accommodate workforce and heavy vehicle movements during construction

Additional traffic during construction may result in increased congestion exceeding level of service D, and ultimately compromising road safety within the vicinity of the Project Area

MM-TP01 Traffic Management Plan

Min

or

Unlik

ely

Low

No additional mitigation measures identified

Min

or

Unlik

ely

Low

Summary Response:

I agree with this assessment. Fundamentally, the level of traffic generated by the proposal during construction is modest, spread over a wide area and many trips will not occur in road network peak hours. Any impacts will also be of short duration as construction moves quickly along the route.

The proposed Traffic Management Plan is the appropriate response to manage this issue.


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120 In the detailed assessment, the TIA identifies two risks associated with the capacity of the road network to accommodate the level of traffic generated by construction (workers and heaving vehicles delivering equipment, and materials and supplies):

• Road Link Capacity (Section 8.1.2)

• Intersection Capacity (Section 8.1.3)

121 I agree that both these impacts are appropriate to consider.

122 Table 7 and Section 5.2.1 of my statement summarises the daily traffic generation to be:

• A peak of 1,260 light vehicle movements per day will be generated by workers. Typically, vehicle movements by workers will not exceed 700 light vehicle movements per day. These are inclusive of:

– 180 movements per day to/from Crib Point Receiving Facility.

– 240 movements per day by pipeline workers (or 800 movements at peak times resulting in the figure of 1,260).

– 100 movements per day to/from the Denham Road project office.

– 100 movements per day to/from the Pakenham Receiving Facility

– 80 movements per day associated with the Jetty Upgrade works by the Port of Hasting Authority.

• 68 heavy vehicle movements per day associated with the ‘fixed’ construction sites at Crib Point and Pakenham.

• A modest number of heavy vehicle movements per day (less than 10) for the transportation of pipe to the construction ROW (the pipeline). This differs from the 101 daily truck movements adopted by Aecom in the TIA.

123 The worker traffic generation assessment set out in the TIA is highly conservative as:

• It assumes the peak pipeline workforce of 400 people is active all the time, compared to a typical workforce of 120 people.

• All workers drive separately, without the benefit of car pooling or a shuttle service (from a common carpark or laydown area to work fronts).

124 I have reviewed Table 8-1 of the TIA which assesses the Average Annual Daily Traffic Volume of all road links impacted by construction traffic. I was also provided with the working spreadsheets used by Aecom to calculate the values in Table 8-1. This assessment adds the daily traffic generated by construction activities to the existing daily volumes. It was calculated using the following steps:

1. Existing AADT traffic volumes were sourced from traffic counts or assumed from a road’s classification as described previously.

2. Future traffic volumes were calculated by adding the estimated construction traffic (pipeline truck movements, pipeline staff, fixed facilities staff, plant/equipment and project office staff) to each road link as appropriate. Notably, 800 vehicle movements associated with pipeline workers were added to each road link, which is highly conservative.


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125 I find this assessment to be overly conservative for the following reasons:

• The assessment always assumes a maximum workforce of 400 pipeline workers, rather that the lesser, more typical figure of 120 workers at most times.

• All pipeline workers use each road listed in this table, rather than being spread over multiple roads/access tracks (due to multiple pipe work fronts).

• As set out above, the number of heavy vehicle movements associated with the delivery of pipe from laydown areas to access tracks has also been overestimated (101 truck movements per day estimated by Aecom, where the likely figure is less than 10 truck movements per day).

• Furthermore, the amount of traffic already using many of these roads is likely to have been overestimated, particularly for rural roads. This is due to the analysis using the environmental or target capacity of the road as an approximation for the current traffic volume (refer to my explanation in Table 5).

126 The assessment also does not convey the temporary and short duration of these impacts. These additional volumes are only generated on a short timescale, over a couple of weeks at most for almost all of the local roads as the pipeline construction rapidly moves along the route (an average of 800m per day).

127 Section 8.1.2 of the TIA reviews the capacity of the individual road links to accommodate the additional traffic based on a volume to capacity ratio (V/C) and a Level of Service assessment (LoS) based on this ratio. Table 8-3 sets out the existing V/C ratio of the road and the future V/C ratio of the road. These are calculated as follows:

1. The existing V/C ratio is calculated by taking the existing traffic volume, assuming 10% of the daily traffic occurs in the peak hour and adopts the capacity of the road link as 1,200 veh/h for two-lane roads or 2,400veh/h for four-lane roads. The assessment assumes all traffic travels in the same direction.

2. The anticipated V/C ratio is calculated by adding the daily construction traffic to the existing daily traffic and then assuming 10% of all daily movements occur in the peak hours (i.e. both existing and construction traffic).

Table 8-3 concludes that there is no road link with a capacity constraint.

128 I have taken an alternative approach to reviewing the material to test the assumptions of the TIA.

129 Firstly, I sought confirmation from APA as to whether the assumption that 10% of the construction traffic will occur in the peak hours is accurate. My understanding is that it is not. The advice is that:

• While the construction times listed in the EES typically state 6am-6pm on weekdays, APA advised that workers complete 10 hour shifts from approximately 7am-5pm, with a mobilisation/demobilisation period of up to 30 minutes at the start and end of the day. Work times may vary slightly due to factors such as daylight.

• APA indicated that it is reasonable to assume that all workers arrive in the one hour before 7am and leave in the one hour after 5pm.


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• Construction traffic associated with heavy vehicles (68 per day) and pipe transport (less than 10 per day) will be spread over the 10-hour workday, not concentrated in the road network peak hours and minimal heavy vehicle movements are likely at the peak times when workers are arriving/leaving the construction sites.

130 Accordingly, the amount of traffic generated by the works in the typical road network AM peak hour (approx. 8-9am) will be minimal, as workers are already on-site and the level of traffic generated by heavy vehicles will be modest.

131 During the PM peak hour (5-6pm), up to 520 movements per hour will be generated by workers on any one road link (noting the ‘fixed’ sites such as the Denham Road project office and the two receiving facilities are geographically far apart). Heavy vehicle movements are likely to be minimal.

132 Secondly, I have adopted the capacity of the road as being 1,200 vehicles per hour, per lane. A two-lane road (as most roads in the study area are) therefore have a capacity of 2,400 vehicles per hour.

133 I have revised Table 8-3 of the TIA based on the above assumptions in the following table.

Table 11: Revised Peak Hour V/C Assessment (VicRoads arterials highlighted in grey)

Impacted roads Municipality Anticipated V/C ratio - EES

Anticipated LOS

Anticipated V/C ratio – Traffix

Group Anticipated

LOS

Woolleys Road MPS 0.342 A 0.333 A

The Esplanade MPS 0.130 A 0.229 A

Seaglades Lane MPS 0.110 A 0.188 A

Stony Point Road MPS 0.358 B 0.348 B

Frankston Flinders Road MPS 0.753 D 0.544 C

Reid Parade MPS 0.342 A 0.304 A

High Street MPS 0.358 B 0.313 B

Cool Store Road MPS 0.108 A 0.188 A

Kanowna Street MPS 0.108 A 0.188 A

Graydens Road MPS 0.569 C 0.423 B

Hodgins Road MPS 0.317 A 0.292 A

Dandenong-Hastings Road MPS 0.648 C 0.495 B


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Anticipated LOS


Group Anticipated

LOS

Denham Road MPS 0.176 A 0.208 A

Whitneys Road MPS 0.126 A 0.195 A

McKirdys Road MPS 0.115 A 0.188 A

Pikes Road MPS 0.112 A 0.188 A

Tyabb Tooradin Road MPS 0.661 C 0.463 B

Bungower Road MPS 0.353 B 0.311 A

South Boundary Road East MPS 0.319 A 0.292 A

Western Port Highway MPS 0.473 B 0.292 A

Callanans Lane Casey 0.110 A 0.188 A

Vowell Drive Casey 0.110 A 0.188 A

Craigs Road Casey 0.317 A 0.292 A

Craigs Lane Casey 0.109 A 0.188 A

Baxter-Tooradin Road Casey 0.503 C 0.363 B

Healesville - Koo Wee Rup Road Casey 0.592 C 0.429 B

Koo Wee Rup Road Casey 0.455 B 0.360 B

Rossiter Road Casey 0.280 A 0.272 A

Fisheries Road Casey 0.317 A 0.292 A

South Gippsland Highway Casey 0.416 B 0.267 A

Adeneys Road Casey 0.319 A 0.292 A

Lynes Road Casey 0.110 A 0.188 A

Manks Road Casey 0.323 A 0.292 A

Muddy Gates Lane Casey 0.108 A 0.188 A


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Anticipated LOS


Group Anticipated

LOS

Tooradin Station Road Casey 0.319 A 0.292 A

Dalmore Road Cardinia 0.320 A 0.292 A

Ballarto Road Cardinia 0.157 A 0.202 A

Soldiers Road Cardinia 0.111 A 0.188 A

McGregors Road Cardinia 0.108 A 0.188 A

134 Fundamentally, while my calculations provide a more accurate reflection of the traffic conditions during construction, the material difference in outcome is minimal from the TIA. I am satisfied that the existing road network has capacity to accommodate the peak hour construction traffic with no road link performing worse than LoS C.

135 These traffic volume impacts are temporary in nature. The bulk of the traffic is generated by the pipeline workers under this assessment and the pipeline construction will proceed rapidly and be spread out along the route. The TIA states that multiple work fronts (sites) will operate simultaneously, multiple teams will be involved and up to 800m of pipe will be laid per day (at multiple sites). The bulk of the physical works to lay the 57km of pipe will be completed in 15 months3 (including mobilisation). As a result, any construction impacts will be of limited duration in any one location.

136 Section 8.1.3 (Intersection Capacity) reviews the capacity of key intersections to accommodate the level of traffic proposed. The TIA did not provide an adequate explanation of how the analysis of the 6 key intersections at Table 8-4 was conducted. I have sourced the original analysis (in spreadsheet form) from Aecom to interrogate the calculations.

137 I do not agree with the method that the V/C ratios were calculated, primarily because the capacity of the intersection was determined using the same rule that a rural road can accommodate 1,200veh/hr/lane. At an intersection, this capacity can be lower (particularly on a side road that must give way to major road traffic). The analysis also overestimates how much development traffic will use each intersection as it conservatively allocates all worker traffic to each intersection.

3 Table 4-11 of the EES lists the pipeline has taking 21 months to complete:

• 1 month for mobilization • 15 months for pipeline construction • 4 months for hydrostatic testing (which is concurrent with pipeline construction) • 12 months for reinstatement (which is concurrent with pipeline construction) • 1 moth for demobilization


G28776A-01A 45

138 Notwithstanding this, I am fundamentally satisfied that the peak hour impacts of the project are acceptable for the following reasons:

• The AM peak is not critical, as workers are expected to be on-site before 7am, with the road network peak hour not typically occurring until 8-9am. The PM peak hour will experience a greater potential impact.

• 400 workers on the pipeline is the ‘high’ estimate, the more normal figure is 120 workers. The assessment was too conservative in always assuming 400 workers using each road link.

• Workers will be spread over multiple fronts (multiple access tracks) and locations and rarely concentrated in one street/location. This is reflected in the analysis which conservatively allocates all workers to using key intersections.

• Any impact at any one location will be short. Construction along the pipeline will move rapidly, with any impacts at a particular location being limited to a number of days. Accordingly, any associated delays on the road network will also be limited in duration.

• The intersections analysed were around Hastings, as shown on the map below. The analysis assumes that all workers are using Frankston-Flinders Road, where in many cases, workers may live in Hastings or not travel from Melbourne daily, or not use this road. For instance, workers may use Coolart Road to avoid the Hastings/Somerville town centres. My expectation is that workers will disperse over the road network quickly and not be concentrated at individual intersections.


G28776A-01A 46

Figure 7: Key intersections analysed by TIA (red circles)

139 I am satisfied that further detailed traffic analysis of key intersections during peak hours is not necessary and the high-level assessment completed at this stage is adequate.


G28776A-01A 47

5.4.2 Road closures in Hastings impacting local access - Risk TP2

Risk ID

Works area

Risk name Risk pathway

Initial mitigation measure


Residual risk

C L Risk C L Risk

Construction

TP2 Pipeline Works

Road/lane closures in Hastings impacting business and local access

Road/lane closures in Hastings result in impacts on business operation and access.

MM-TP01 Traffic Management Plan MM-TP03 Stakeholder communication

Min

or

Alm

ost c

erta

in

Med

ium

Pipeline alignment change to Stony Point rail corridor as described in EES Technical Report N: Business impact assessment.

Neg

ligib

le

Alm

ost c

erta

in

Low

Summary Response:

I agree with this assessment. While road closures will be required on some local roads, the impact will be brief. All arterial roads are being drilled under, avoiding the need for road closures. All closures will be of short duration.

The proposed Traffic Management Plan and Stakeholder Communication requirement are the appropriate responses to manage these issues. The relocation of the pipeline from Frankston-Flinders Road to the Stoney Point line through Hastings has reduced the impact to the public road network.

140 The TIA lists 14 roads (See Table 8-7) that require a temporary closure for a maximum duration of 48 hours during construction. Some of these closures may impact property access temporarily or require management measures to maintain access. Access to no more than 12 properties is affected by road closures.

141 The Esplanade will require some traffic management as construction will necessitate this road to be temporarily reduced to one lane for two-way traffic. Given the low volume of traffic that uses The Esplanade (only 430 vehicles per day under existing conditions), this will not significantly impact the operation of this road.

142 There are 12 roads where an open cut construction method will require closure of the road as the cut is made across the road and the pipe is laid (See Table 6-3 of the TIA). In most cases, these roads are low volume, gravel roads.

143 All of the impacted roads are summarised in Table 12 below.


G28776A-01A 48

144 I note that the pipeline route was relocated from Frankston-Flinders Road to the Stony Point rail corridor through Hastings to reduce the number of properties/accesses impacted by the works.

145 Fundamentally, each closure is temporary and short duration. The Traffic Management Plans (MM-TP1) and Stakeholder Communication (MM-TP03) are appropriate to mitigate the risk. I agree that the overall impact is low. Table 12: List of Road Closures

Road Municipality Road classif-ication

Surface Closure for Pipelaying Notes

Constr-uction

Pipelaying across road

The Esplanade

Mornington Peninsula

Urban Collector

Sealed Y N

Kanowna Street


Urban Rural

Gravel Y Y Traverse the road longitudinally. Appears to be located under the road.

Sovereign Drive


Urban Local

Sealed Y Y Latitudinal cut across the road Minimal impact to end of street

Haddock Street


Urban Local

Gravel Y Y Latitudinal cut across the road Minimal impact to end of street

Whitneys Road


Rural local

Gravel Y Y Traverse the road longitudinally Appears to be located under the road.

Pikes Road Mornington Peninsula

Rural local

Gravel Y Y Latitudinal cut across the road

Bungower Road


Rural local*


South Boundary Road East


Rural local*

Gravel Y Y Latitudinal cut across the road Minimal impact to end of street

Callanans Lane


Rural local

Sealed Y Y Does not appear to cross the road based on AGIS review. Road is still required for construction access

Craigs Lane

Casey Rural local



G28776A-01A 49

Road Municipality Road classif-ication

Surface Closure for Pipelaying Notes

Constr-uction

Pipelaying across road

Low number of properties serviced by the road.

Bloomfield Lane

Cardinia Rural local

Gravel Y Y Traverses the road longitudinally in part, low number of properties

Hobson Road



Mcdonalds Drain Road



Oakview Lane


Sealed Y N Would appear that construction would require closure at some point.

Mount Ararat Road Sth


Gravel Y Y Traverse the road longitudinally Not identified in TIA

*Notes: Local rural roads in the section where the pipe crosses the road


G28776A-01A 50

5.4.3 Road Deterioration - Risk TP3

146 The risk assessment is summarised in the table below.

Risk ID

Works area




Residual risk

C L Risk C L Risk

Construction


Road deterioration

Public roads experience deterioration in the quality of the pavement due to the movement of heavy vehicles, machinery and plant.

MM-TP01 Traffic Management Plan MM-TP05 Pavement strength survey - Pavement rehabilitation, Road integrity surveillance, Regular meetings with road authorities

Min

or

Like

ly

Med

ium

Upgraded pavement for Woolleys Road and the Esplanade (subject to the pavement strength survey results)

Min

or

Unlik

ely

Low

Summary Response:

Some public roads may need repair following construction and it normal for a construction project to have to remediate the road. Woolleys Road/The Esplanade require a pavement strength upgrade due to its use as a B-Double route for Nitrogen deliveries post-construction.

147 The TIA identifies two issues regarding public road deterioration:

• Over-dimensional loads

• A road network infrastructure assessment that reviews:

– The existing road cross sections

– Anticipated traffic volumes

– Observations of pavement and infrastructure conditions

– Issues that may affect road safety, such as sight distance

Over Dimensional Loads

148 The majority of movements associated with over-dimensional loads would take place during construction. The on-going need for O-D loads would be minimal. These loads are expected to arrive from Melbourne.

149 Where the dimensions or mass of the vehicle/load combination are needed, a route audit would be carried out to assess route options, safety and clearance to potential obstructions


G28776A-01A 51

such as wires, structures, trees and rail crossing infrastructure. Accordingly, the alignment, cross section, pavement design and bridge design of these roads would require consideration of the anticipated width, length, height and mass of the over-dimensional loads. This is a ‘standard’ process for O-D loads.

150 Given that standard processes exist for the management of O-D loads, I am satisfied that this risk can be adequately addressed.

Road Network Infrastructure Assessment

151 The TIA undertook a comprehensive review of all roads in the study area, there condition and classification and safety issues.

152 At a high level, the assessment indicates that construction traffic and truck movements will largely use arterial roads or freeways for the majority of their movements. These routes are suitable for higher traffic volumes and truck movements. The use of the local road network will be limited to the last part of the trip from the arterial road network to the access track location.

153 I have reviewed Table 8-6 of the TIA and the conclusions is reaches regarding the roads listed. Two roads are listed as inappropriate for use in their current form:

• Whitneys Road, between Lumeah Road and Yaringa Road – due to narrow cross section

• Mt Ararat Road North – due to inadequate pavement condition.

154 I agree with this assessments based on my field observations. The TIA appropriately identifies some remedial works will be required (for Mt Ararat Road North) or bypassed for Whitneys Road.

Conclusion

155 I am satisfied that the TIA has identified the risks appropriately and that the management measures identified are appropriate. I agree that the overall risk is low.


G28776A-01A 52

5.4.4 Dirt from Construction on Roads - Risk TP4

156 Dust generation is a common potential impact of many infrastructure projects and can be generated by the transport of excavated material, movement of light and heavy vehicles on gravel roads and movement of equipment.

Risk ID

Works area




Residual risk

C L Risk C L Risk

Construction


Dirt on roads from construction vehicles

Plant and spoil trucks deposit construction debris on public roads leading to dust generation and perceived loss of amenity and public health and safety issues.

MM-TP01 Traffic Management Plan -including dust and debris management strategies MM-TP03 Stakeholder communication

Min

or

Alm

ost c

erta

in

Med

ium

MM-TP01 Traffic Management Plan -Monitor condition of roads. Dust suppression methods as described in EES Technical Report G: Air quality impact assessment (MM-AQ01 Dust suppression MM-AQ05 Covering vehicle loads)

Min

or

Poss

ible

Low

Summary Response:

Dust management is a common consideration on infrastructure projects and management of dust is a ‘normal’ construction activity requirement.

157 These are common issues with infrastructure projects, and I am satisfied that the EES has identified appropriate mitigating measures.

158 I do not see this impact as being particularly significant with appropriate management measures.


G28776A-01A 53

5.4.5 Pedestrian and Cyclists access in Hastings – TP5

159 Construction traffic has the potential to impact on the access and safety of pedestrians and cyclists.

Risk ID

Works area




Residual risk

C L Risk C L Risk

Construction


Pedestrian and cycling access in Hastings

Additional Project generated traffic and construction works impact pedestrians and cyclists resulting in a reduction in public safety and amenity Increased safety risk to school children in school zones, walking to/from school and school crossings in the impacted area.

MM-TP01 Traffic Management Plan - Pedestrian and cyclist connectivity MM-TP03 Stakeholder communication

Min

or

Like

ly

Med

ium

Pipeline alignment change to Stony Point rail corridor as described in EES Technical Report N: Business impact assessment.

Neg

ligib

le

Like

ly

Low

Summary Response:

The management of pedestrians/cyclists and other traffic around construction sites is a common occurrence. The relocation of the pipeline to the rail corridor will further reduce public exposure to the construction activity.

160 Fundamentally, large sections of this project occur in rural areas and on roads with minimal pedestrian/cyclist traffic.

161 The main potential for conflict arises from when the pipeline is constructed through the urban area of Hastings. I am satisfied that the relocation of the pipeline from Frankston-Flinders Road to the Stoney Point rail corridor (as per the EES) has significantly reduced the exposure of cyclists and pedestrians to the pipeline’s construction.

162 I agree that this impact is low.


G28776A-01A 54

5.4.6 Public/School bus impacts – TP6

163 Construction and construction traffic can impact on public transport/school bus operations.

Risk ID

Works area

Risk name

Risk pathway



Residual risk

C L Risk C L Risk

Construction


Public/ School bus impacts

Movement of pipes, plant and heavy machinery, as well as potential road closures and safety impacts on public transport and access for school buses.

MM-TP06 Public transport disruption sub-plan MM-TP03 Stakeholder communication – consultation with schools and PTV

Maj

or

Unlik

ely

Med

ium

MM-TP01 Traffic Management Plan -Avoid truck (pipeline and other activities) movements in Hastings between school hours (7:30-9:00am and 2:30 -4:00 pm) and avoid school zone areas, where possible. Driver induction to inform driver requirements from outcomes of the Public Transport disruption plan.

Maj

or

Rare

Med

ium

Summary Response:

In the context of the number of bus movements and relatively short duration of impacts in any one location, combined with the proposed management measures, I find the risks can be appropriately managed.

164 The following table sets out the public bus routes that operate on roads within the construction area.

Bus Route Service Roads impacted by pipeline directly

Route 782

Frankston-Flinders via Coolart Road and Hastings

Frankston-Flinders Road Hodgins Road High Street

Route 783

Frankston-Hastings via Coolart Road

Frankston-Flinders Road Hodgins Road

Route 795

Warneet - Cranbourne Fisheries Road South Gippsland Highway


G28776A-01A 55

165 In each case, the pipeline will be constructed under the road surface with no disturbance to traffic. Construction traffic or traffic management in the vicinity of work sites may cause some minor delay to general traffic, including bus services. These disruptions will be temporary, of short duration and be managed by a Traffic Management Plan (MM-TP01). As a matter of course, any TMP must consult with PTV if there are disruptions to bus services.

166 I am satisfied that this risk has been appropriately identified and can be satisfactorily managed.

5.4.7 Road Closures outside of Hastings – TP7

167 Road closures outside of Hastings may impact local vehicle access.

Risk ID

Works area




Residual risk

C L Risk C L Risk

Construction

TP7 Pipeline Works

Road/lane closures outside of Hastings due to Pipeline Works (along and across roads) impacting transport operations

Road/lane closures outside of Hastings due to Pipeline Works (along road due to narrow ROW and across roads due to open cut trenching) impacting access to properties.

MM-TP01 Traffic Management Plan MM- TP03 Stakeholder communication

Min

or

Alm

ost c

erta

in

Med

ium

MM-TP01 Traffic Management Plan - Construction activities to occur in off-peak periods when demands are low. Minimise the number and duration of road closures

Neg

ligib

le

Alm

ost c

erta

in

Low

Summary Response:

I agree that the risk is low due to the short-term nature of any impacts.

168 The TIA does not have a specific subsection providing a specific, detailed review of TP7 – the impacts of road closures or lane closures outside of Hastings.

169 At the detailed review of TP2, the TIA reviews the impacts of road closures both within and outside of the Hastings township (i.e. appears to cover TP7 as well).


G28776A-01A 56

170 I will not repeat by review of TP2 and detailed analysis of that here. I am fundamentally satisfied that the impacts of road closures in the rural areas is low due to:

• The rapidity of the works (most road closures are less than 48 hours).

• The rural roads impacted carry very little traffic.

171 I agree that the overall risk is low.

5.4.8 Access Tracks – TP8

172 The project requires the construction of 40 Access Tracks to connect the construction ROW to the public road network during construction.

Risk ID

Works area




Residual risk

C L Risk C L Risk

Construction

TP8 Pipeline Works

Access track / public road network intersection crash risks

Risk of crash at intersection of access track and public road due to non-complying sight lines, stopping distance and lack of lighting.

MM-TP04 Road Safety Audit MM-TP01 Traffic Management Plan

Maj

or

Poss

ible

Hig

h

MM-TP04 Road Safety Audit - minor relocation of non-compliant access tracks to achieve conforming sight distance requirements. Provide flag lighting during active access track use.

Maj

or

Rare

Med

ium

Summary Response:

This is a relevant concern that needs to be addressed as a number of access track locations are deficient in available sight distance. The mitigation measures identified are appropriate.

173 The TIA has reviewed the location of all 40 access tracks where the access the public road network with respect to available sight distances.


G28776A-01A 57

174 The TIA reviewed the Safe Intersection Sight Distances (SISD) available at intersections of Access Track with the public road network. The Austroads Guide to Road Design Part 4a (2017), SISD design requirements for cars are:

• 181 metres for 80km/h,

• 214 metres for 90km/h, and

• 248 metres for 100 km/h.

175 These values relate to cars only on a flat road. Adjustments are required for trucks and site specific grades where relevant.

176 In my view, the access tracks should also be assessed for SISD for trucks at the time of the Road Safety Audits of each access track, to be completed before construction commences. This is warranted in my view as the access tracks will experience heavy vehicle movements by trucks transport equipment and building materials. Trucks require longer SISD distances due to the nature of characteristics of trucks (slower braking and acceleration characteristics).

177 Notwithstanding this difference, the TIA identifies 11 access points where the Safe Intersection Sight Distance (SISD) is not met for cars4. Some of the sight distances are significantly below SISD requirements.

178 My office has completed a physical inspection of these locations to assess sight distance for each proposed Access Track, which is detailed in the table below. From this review, there appear to be some inconsistencies between the sight distances recorded in the TIA assessment and what is available in practice. Some of these differences may be due to vegetation changes (growth or pruning) which alter the road conditions (the site inspections by Aecom were completed over 18 months ago).

Table 13: Sight distance review at Access Track locations

Access Track

Location SISD Required

(cars)

SISD assessment

in TIA

Traffix review of SISD

Comments

AT2 Woolleys Rd 181m 80m W 150m W The sight distances recorded in the TIA appear to be overly conservative. It is possible that vegetation around these entrances has changed. In any event, the sight distances available remain below SISD.

AT3 Woolleys Rd 181m 40m W 120m W

AT4 Woolleys Rd 181m 60m E 120m E

AT5 Woolleys Rd 181m 80m W 90m E

70m W 60m E

Sight distance is significantly below SISD requirements.

4 Austroads Guide to Road Design, Part 4A


G28776A-01A 58

Access Track


(cars)

SISD assessment

in TIA


Comments

AT8 Frankston-Flinders Rd

181m Did not raise as an

issue.

Approx. 100m S Sight distance can easily be increased to over 300m with some minor tree pruning (tree removal not required).

AT10 Frankston-Flinders Rd

214m Not identified as

deficient

Limited at the ‘Stop Line’ to 150m N and

40m S

Vegetation near the stop line limits sight distance, however vehicles can move forward towards the traffic lanes to improve sight distance to acceptable levels (over 300m)

AT14 Whitneys Rd

N/A 100m E AT 14 does not appear to cross Whitneys Rd (connects two construction zones with no road

connection)

AT18 South Boundary Road East

N/A – private

road

50m +200m Some vegetation removal will be required to widen this access track. Once this is done, the sight distance should easily exceed 200m and acceptable for a low speed road.

AT26 Baxter-Tooradin Rd

248m 70m E 300m+ This AT was not able to be inspected due to the temporary closure of Baxter-Tooradin Road for roadworks. Based on an aerial photograph and street view, the sight distance available appears to be well in excess of 300m.

AT32 or AT33*

Koo Wee Rup Rd

214m 120m SE In excess of 300m

*There is an error in the report, there are two AT35 references to different roads. Both AT32 and AT33 have sight distances well in excess of 300m to the south-east.

AT34 Hall Road 248m Not identified as

deficient

120m W Tree pruning required to improve sight distance. Already deficient for existing driveway.


G28776A-01A 59

Access Track


(cars)

SISD assessment

in TIA


Comments

AT35 McDonalds Drain Rd

248m1 40m N 40m N Minor tree pruning may resolve this issue.

AT39 Oakview Lane

73m – 40km/h speed limit at railway

crossing

80m N due to vertical alignment

Agree Some additional traffic management may be warranted.

Notes: Gravel road where a 100km/h speed limit is unlikely to be possible in practice, despite it being the legal speed limit.

179 The TIA recommends that:

• A Road Safety Audit (RSA) is undertaken upon finalisation of the proposed routes and access tracks to ensure safe vehicle movements to the satisfaction of the responsible road management authority.

• Alternative track alignments be considered that meet SISD requirements.

• If alignments cannot be altered, that management measures such as signage or reduced speed limits be considered.

• Directing construction traffic to other access tracks.

180 In my view, the mitigation measures identified by the TIA are appropriate. A Road Safety Audit of each access track intersection before construction is the right assessment tool to ensure safe access at each location. Many of the sight distance issues at each location are related to vegetation in the road reserve, which simple pruning may resolve.

181 My first preference would be providing a physical solution (relocating the access tracks or tree pruning), instead of a management solution (signs or traffic management).


G28776A-01A 60

5.4.9 Railway Level Crossings – TP9

182 The pipeline route encounters level crossings at a number of locations.

Risk ID

Works area




Residual risk

C L Risk C L Risk

Construction

TP9 Pipeline Works

Crash with a train at a level crossing

Crash with a train at a level crossing due to increased traffic activity and new access tracks.

MM-TP01 Traffic Management Plan – route options analysis for construction vehicles Se

vere

Unlik

ely

Hig

h

MM-TP02 Level crossing audit - identify required measures to conform to safety standards

Seve

re

Rare

Med

ium

Summary Response:

There is one level crossing in the study area that is passively controlled, and this has been identified appropriately.

183 The TIA identifies that all railway level crossings within the project area are provided with boom gates, audible warning devices and flashing lights, except for a crossing at Access Track No. 8 leading off Frankston-Flinders Road between Reid Street and Lady Nelson Parkway.

184 The TIA (section 8.1.11) recommends a Traffic Management Plan and Level Crossing Audit to review the safety measures required at this level crossing. I am satisfied that this is the appropriate response to manage construction impacts.


G28776A-01A 61

5.5 Operation Phase Risks

185 This section reviews the impacts of the project during its operational phase.

5.5.1 Road Deterioration due to Nitrogen Trucks – TP10

186 The project will require regular deliveries of Nitrogen to the Crib Point receiving facility and these have the potential to deteriorate the road surface as large trucks cause many times more pavement damage that car-sized vehicles.

Risk ID

Works area




Residual risk

C L Risk C L Risk

Operation

TP10* Gas Import Jetty Works

Road deterioration due to nitrogen trucks

Roads experience pavement deterioration due to the movement of nitrogen trucks (up to 900/year for 20 years) especially along Woolleys Road and the Esplanade (not B-Double approved)

MM-TP07 Nitrogen transport plan MM-TP05 Pavement strength survey

Mod

erat

e

Like

ly

Med

ium

MM-TP03 Stakeholder communication – Regular meetings with Mornington Peninsula Shire to agree and confirm pavement upgrades of impacted local roads around Crib Point. Upgrade pavement of impacted local roads, subject to the pavement strength survey results

Mod

erat

e

Unlik

ely

Low

* Note: The Traffic Management Plan – Nitrogen Transport Plan in conjunction with pavement strength survey would verify that the final designated truck access route can be supported by the roads upon which it travels.

Summary Response:

For most of the route, B-Double trucks are using arterial roads/freeways and already approved B-Double routes. The TIA correctly identifies that the last 3km of the trip along Woolleys Road/The Esplanade will require approval by regulator authorities and some mitigating works such as pavement upgrades may be necessary. These measure are appropriate.


G28776A-01A 62

187 The operational phase of the project will require Nitrogen and Odorant to be delivered to the Crib Point Receiving facility. This involves:

• 900 B-Double trucks per year of Nitrogen – spread over the year, with approximately 5 deliveries per day.

• 6 trucks per year of Odorant – averaging 1 every 2 months

188 This volume of truck traffic is not high, particularly in the context of the heavy vehicle volumes already using key arterial roads leading into the Hastings area as a result of the Port of Hastings and other industrial land uses.

189 The TIA identifies 3 routes that may be used by trucks to make deliveries:

• The direct route between from the Mornington Peninsula Freeway, Frankston-Flinders Road to Stony Point Road, Woolleys Road and The Esplanade.

• Mornington Peninsula Freeway to Coolart Road (C785) then back to Frankston-Flinders Road after bypassing Somerville, Tyabb and Hastings.

• Western Port Highway (C780) then bypassing Hastings using Coolart Road.

190 These routes are shown in the figure below.

Figure 8: LEFT - Potential truck routes for Nitrogen and Odorant Deliveries (Source: Figure 12 of the TIA), RIGHT – Gazetted B-Double routes (Source: VicRoads website - https://vicroadsmaps.maps.arcgis.com/apps/webappviewer)

191 Each routes uses the arterial road network and is an already approved B-Double route (except for the last 3km to Crib Point along Woolleys Road/The Esplanade, see below). When inspecting these arterial roads, it is readily apparent that their design standard allows for B-Double access.

192 I understand from the consultation process that VicRoads supported a route the avoids the town centre of Hastings. While Frankston-Flinders Road travels through Hastings, it is evident that this road is specifically designed for truck access, already carries a large number of

https://vicroadsmaps.maps.arcgis.com/apps/webappviewer/index.html?id=636d0f14807e4b13a3414b8d48a56c0f


G28776A-01A 63

trucks, directly services a large number of industrial uses and effectively bypasses the town centre of Hastings.

193 In my view, any of the three routes identified are a practical possibility for B-Double access to the Crib Point receiving facility.

194 The Risk Assessment identifies that B-Double trucks may impact the road surface, particularly of the last 3km of the journey on Woolleys Road and the Esplanade that are not gazetted B-Double routes. They will require permits for access.

195 Larger trucks and especially B-Doubles significantly impact the road surface. A single B-Double causes more damage to road surfaces than 10,000-100,0000 cars (depending on weight).

196 The TIA correctly identifies the risk of road deterioration as a project impact and identifies mitigation measures including assessments of road strength and that possible upgrades may be required. I am satisfied that this risk has been addressed.


G28776A-01A 64

5.5.2 Safety and Amenity Impacts of B-Doubles through Hastings/Somerville – TP11

197 B-Doubles travelling in built-up areas can impact safety and amenity within townships.

Risk ID

Works area




Residual risk

C L Risk C L Risk

Operation

TP11 Gas Import Jetty Works

Amenity, safety and traffic operation impacts through Hastings and Somerville due to transport of nitrogen B-Double trucks

Transport of nitrogen in B-Doubles (up to 900/year for 20 years) through Frankston Flinders Road increase the crash risk with road users (vehicles, buses, pedestrians and cyclists), impacting amenity and traffic operations in Hastings and Somerville town centre

MM-TP07 Nitrogen transport plan

Maj

or

Poss

ible

Hig

h

MM-TP07 Nitrogen transport plan Using alternative roads to bypass Hastings and Somerville town centre

Maj

or

Rare

Med

ium

Summary Response:

The TIA outlines two alternative B-Double routes that avoid the Somerville and Hastings townships and these options should be explored further.

198 The most direct route from the Mornington Peninsula Freeway to the Crib Point receiving facility via Frankston-Flinders Road travels through Somerville, Tyabb and Hastings. The TIA identifies that there are safety, amenity and operational impacts of B-Double truck travelling through urban areas, even though Frankston-Flinders Road is a gazetted B-Double route. These are:

• Amenity/social impacts of truck movements within Hastings and Somerville.

• A safety risk for general traffic. Specifically, the review identified that Frankston-Flinders Road has a higher number of intersection blackspots (intersections with 5 or more casualty crashes in the last 5 years).


G28776A-01A 65

• A risk to road link and intersection capacity – which is minor in the context of 12 truck movements per day (5 nitrogen and 1 odorant truck travelling to and departing Crib Point).

• A safety risk to buses.

• Safety impacts to pedestrians and cyclists.

199 The TIA recommends that the Nitrogen Transport Plan use alternative routes to bypass the Hastings and Somerville town centres, as described in the previous section. This strategy minimises the exposure – the number of truck movements impacting on busier areas of town centres.

200 I am satisfied that this analysis is appropriate and agree with the recommendation that regular deliveries should avoid the town centres of Hastings and Sommerville, if possible.


G28776A-01A 66

5.5.3 Capacity of road network to accommodate workforce and heavy vehicle movements during operation – TP12

201 During operation, the workforce and deliveries of supplies will impact the road network.

Risk ID

Works area




Residual risk

C L Risk C L Risk

Operation


Capacity of road network to accommodate workforce and heavy vehicle movements during operation

Additional traffic during operation may result in increased congestion exceeding level of service D, and ultimately compromising road safety within the vicinity of the Project Area.

No initial mitigation measures

Min

or

Unlik

ely

Low

No additional mitigation measures identified

Min

or

Unlik

ely

Low

202 Table 7 of my statement sets out the daily traffic generation of the project during the operation phase associated with the workforce. A maximum of 80 vehicle movements per day by regular workers is not significant and, in my view, does not warrant detailed analysis.

203 Other movements associated with inspections or technical maintenance at various facilities will not be an everyday occurrence and again these movements are not significant in my view.

204 My review of TP 10 and TP11 assesses the impacts of B-Double movements, which I find are minimal and appropriate manage the impacts of these movements.

205 The TIA does investigate the Road Link and Intersection capacities for key roads along the road in detail. It agrees with my view that the traffic generated by the operation phase of the project is minimal.

206 In my view, the impact of workforce and heavy vehicle movements is negligible (resulting in an overall rating of Very Low).


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6. Review and Recommendations on the mitigation measures identified in the EES and Key Approval Documents

6.1 Mitigation Measures in the EES

207 The following table reviews the transport mitigation measures described in the EES. In particular, I have taken the Table of mitigation measures identified at Chapter 25 of the EES (page 25-54) and provided my responses to each of the mitigation measures proposed.


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Table 14: Review of Mitigation Measures:

MM ID

Mitigation Measure Works Area

Statutory Implementation

Timing Associated Risk ID

Response

MM-TP01

Traffic Management Plan (TMP) A Traffic Management Plan (TMP) will be prepared and implemented for construction by an appointed contractor for approval by the relevant local government authorities and VicRoads. The TMP will include specific measures for discrete components or stages of the works having the potential to impact on roads, shared use paths, bicycle paths, footpaths or public transport infrastructure. The TMP will include a number of sub-plans including:

• Public Transport Disruption Management sub-plan

• Pedestrian and cyclist connectivity

Gas Import Jetty Works and Pipeline Works

Pipeline License

Incorporated Document

Construction TP1, TP2, TP3, TP4, TP5, TP6, TP7, TP8, TP9, B1

This mitigation measure is appropriate and a ‘standard’ feature of any significant construction project.

MM-TP02

Level Crossing Audit An audit of the existing level crossing with passive control adjacent to Frankston-Flinders Road will be carried out prior to construction by a suitably qualified person to investigate if the current condition is suitable for construction use.

Pipeline Works

Pipeline Licence

Design and Construction

TP9 One access track crosses a rail line at a location with minimal existing control and it is appropriate that the safety of this crossing is re-assessed.

MM-TP03

Stakeholder and consultation on transport changes Prior to commencement of works and any temporary road closures, stakeholder consultation will be carried out and advanced notice given to affected residents, businesses or industries. This includes measures such as letter notification to inform residents and businesses of upcoming works and road closures. Stakeholder engagement and communications strategies will be established in the TMP and the Stakeholder Engagement Management Strategy to be prepared for the Project. Stakeholders may include local councils, road authorities, business operators and residents among others.

Gas Import Jetty Works and Pipeline

Works Area

Pipeline Licence


Construction and Operation

TP2, TP4, TP5, TP6, TP7, TP10

This mitigation measure is appropriate and necessary for the project


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MM ID




Response

During operation, regular meetings will occur with Mornington Peninsula Shire and an agreement will be reached with the Council to confirm pavement upgrades of impacted local roads around Crib Point, subject to the pavement strength survey results.

MM-TP04

Road Safety Audit Intersections will be designed and constructed to provide safe vehicle movements to the satisfaction of the responsible road management authority. A Road Safety Audit will be undertaken upon finalisation of the proposed routes and access tracks to confirm mitigation measures. This will consider investigating existing warning signage, lighting, turning movement lane provision and sight clearance and access track alignment modifications to improve safe intersection sight distance (SISD) for those that are non-conforming. This includes management measures such as advanced warning signage and flag lighting. In order to provide a safe route for the operation stage, signage improvements and speed reduction measures will be considered at Hunts Road to minimise the likelihood of collision with other vehicles at the black spot identified at the intersection between Hunts Road and the Coolart Road. The Road Safety Audit will be undertaken in consultation with local councils.


Pipeline Licence Consent under the Marine and Coastal Act 2018


Construction and Operation

TP8 This measure is appropriate and necessary. The current TIA identifies some deficiencies, particularly with respect to intersection sight distances at access tracks, which are best addressed just before construction commences.

The RSA should be expanded to include a review of the Frankston-Flinders Road/Denham Road roundabout as this intersection will be used for a longer period of time for construction purposes (due to the Denham Road stockpile and project offices) and has a history of casualty crashes (4 over 5 years).

MM-TP05

Pavement strength survey A pavement strength survey will be undertaken for Woolleys Road and the Esplanade prior to construction to determine suitability to accommodate projected heavy vehicles for construction and operation phases. The survey’s results will determine potential location

Gas Import Jetty Works and

Pipeline Licence


Design, Construction and Operation

TP3, TP10 This mitigation measure is appropriate.

There is a difference between the pavement strength survey and upgrade of Woolleys Road/The Esplanade due to the use of this route by B-Doubles on a regular


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MM ID




Response

where road upgrade may be required. Key gravel roads within the study area will be assessed separately and will be subject to specific maintenance checks. These roads will be named within the Traffic Management Plan once the Project details have been confirmed. Pavement will be restored to existing condition or better after construction.

Pipeline Works

basis, and various other roads that may be damaged in some way during construction and which would have to be remediated by the project.

MM-TP06

Public Transport Disruption Management sub-plan Prior to commencement of works affecting public transport services, a plan to minimise disruption to public transport services resulting from Project construction activities will be developed and implemented. The plan will be developed in consultation with relevant authorities such as Public Transport Victoria and the Department of Transport and will be included as a sub-plan to the TMP.


Pipeline Licence


Construction TP6 This is a ‘standard’ management measure to ensure the project has minimal impact on public transport operations and is appropriate.

This mitigation measure should also include the management of impacts on school buses.

MM-TP07

Nitrogen Transport Plan A Nitrogen Transport plan will be developed. This plan will include identifying the preferred route(s), management measures at key intersections and permit requirements for access to roads that are not approved B-Double routes. Alternative roads to bypass Hastings and Somerville town centres will be used where possible.

Gas Import Jetty


Pipeline Licence

Operation TP10, TP 11

This is the most significant on-going transport impact of the project during the operation phase and this plan is appropriate to address the potential impacts.

I support a route choice that avoids the urban centres of Hastings and Somerville.


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6.2 The Pipeline Licence Application Mitigating Measures

208 The Pipelines Act is the primary Act governing the construction and operation of pipelines in Victoria. The Pipelines Act covers ‘high transmission’ pipelines for the conveyance of gas, oil and other substances.

209 The Pipeline Works require a Pipeline Licence under the Pipelines Act for construction and operation. The Pipelines Act does not apply to a pipeline which is wholly within a port. Given the Gas Import Jetty Works are located entirely within declared Port of Hastings land, these works cannot be licensed under the Pipelines Act.

210 Attachment 2 of the Application is the Construction Environment Management Plan. The Environment Management Plan (EMP):

• identifies the risks to the environment arising from the pipeline operation;

• specifies what the licensee will do to eliminate or minimise those risks, including rehabilitation of the land; and

• sets out any matter prescribed by the Pipelines Regulations 2017 (the Pipelines Regulations).

211 The Environment Management Plan accurately reflects the risks and actions described in the TIA, except that it has omitted Risk TP5 - Pedestrian and cycling access in Hastings. This appears to be an oversight, as every other risk is accurately translated. This should be included in the EMP.

212 Appendix J of the Pipeline Licence Application includes a set of performance standards that address the environmental impacts and risks and legal requirements for the Project. The standards cover design, management and mitigation measures. Monitoring and contingency plans are also detailed.

213 Table 9-F of Appendix J details the performances standards of all construction activities associated with the pipeline. The standards relevant to traffic engineering matters are listed in the table below.

214 I am satisfied that these objectives accurately reflect the risks identified by the EES and Technical Report J.

Table 15: Extract from Appendix J of the Pipeline Licence Application – Performance Standards

Ref Environmental Controls Project Phase

Site access and property management

A8 A Traffic Management Plan (TMP), approved by the relevant local government authorities and VicRoads, will be in place prior to the commencement of construction. The TMP will include the following: - stakeholder and communications arrangements - Public transport disruption management - Level crossing audit requirements for the level crossing adjacent to Frankston-Flinders Road

Pre-construction


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Ref Environmental Controls Project Phase

- Road safety audit requirements - Pavement strength survey and condition assessment requirements

A9 Restricted vehicle movements After arrival at the Project site, all construction vehicles and plant will remain within the construction footprint or on public roads and designated access tracks, unless undertaking survey or property management activities with prior agreement of the land owner.

Construction

A10 Vehicles and plant will be checked daily to ensure that combustible materials such as grass and debris do not build up in areas where ignition may occur. Construction

A11 Vehicle and pedestrian access Where vehicle and pedestrian access are altered during construction, vehicle and pedestrian access will be replaced, in accordance with relevant road design standards and in consultation with landholders and any other relevant third parties.

Post- construction

Air, Noise & Vibration Management

E1 Speed limit within the site boundary including access tracks restricted to a maximum of 40kph. Construction

E2 Activities will be managed onsite to ensure dust is not a hazard. Management/control measures proportionate to the level of risk must be put in place to minimise risk of generation. Control measures used may include:

• Water carts used on unsealed work areas;

• crushed rock placed on existing permanent unsealed access tracks where agreed with relevant stakeholders

• Water spray units used on soil stockpiles and during the loaded and unloaded of dust generating materials .i.e. soil/sand/fill and aggregates; and

• Vehicle loads covered when carrying dust (or litter) generating material.

Dust suppression activities are to be undertaken as directed by the APA Construction Manager, who will take the following factors into consideration:

• Weather patterns; hot, dry, windy forecasts;

• Ground cover .i.e. exposed surfaces;

• Type and moisture content of soil present; and

• Type of activities being conducted, such as vehicle movement, vegetation clearing and excavation.

Construction


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6.3 The Incorporated Document in the draft Planning Scheme Amendment

215 The Incorporated Document largely exempts the project from planning permit requirements.

216 In relation to traffic engineering requirements, the Incorporated Document specifies:

• The preparation of Environmental Management Plan (EMP) in relation to Traffic and Transport (with separate plans for construction and operation of the project).

• Exemption from Planning Permit requirements to create or alter access to Road Zones, but this process is still required to be completed in consultation with the Roads Corporation.

217 I have no issue with either of these requirements.

6.4 EPA Works Approval Application – Gas Import Jetty FRSU

218 This document is not relevant to my area of expertise.

6.5 Recommendations

219 Overall, I am satisfied that:

• The mitigation measures identified in Chapter 25 of the EES are appropriate, with the inclusion of the requirement for a Road Safety Audit of Frankston-Flinders Road/Denham Road pre-construction.

• The incorporated document includes appropriate traffic engineering requirements.

• The Pipeline Licence Application is acceptable, subject to the Environment Management Plan incorporating the transport risk, TP5 - Pedestrian and cycling access in Hastings.

• The EPA Works Application for the Gas Import Jetty is not relevant to traffic engineering matters.


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7. Consideration of Submissions 220 A proportion of the submissions raise transport engineering issues with the project. The

majority of submissions do not raise issues with the land-side transport impacts of the proposal.

221 In the table below, I have reviewed and responded to key submissions made by the Local Councils (which do raise various transport issues) and the other state government agencies relevant to transport engineering matters.

Table 16: Review of Key Issues identified by submissions

Sub. No. Issue Response

Agency/Group Submissions

1357

Department of Transport

No significant traffic engineering issues raised.

The DoT did not raise any significant traffic engineering issues with the proposal. It supports the pipeline route.

It has requested some additional conditions in regard to construction and design detail that are not relevant to my area of expertise.

1461

Major Roads Projects Victoria

No significant traffic engineering issues raised.

MRPV did not raise any significant issues with the project, subject to the including of some conditions in relation to construction detail that is not relevant to my area of expertise.

2276

Mornington Peninsula Shire Submission

12.1.1. The traffic volume data appears to have been ‘estimated’ with no verification by actual count data at critical locations which either have a high accident history or are expected to carry the majority of the construction traffic;

The traffic data for many of the non-arterial roads was estimated using its environmental or target capacity. This method is very likely to over-estimate the amount of traffic using these roads. Some cases, by a significant amount.

I am satisfied that this approach is acceptable in the context of the extent of the study area as the assessment is highly conservative. My review of the analysis and my own investigations does not lead me to believe that construction traffic impacts are significant.

The traffic impacts of the proposal during construction as substantially mitigated by the fact any impacts are temporary in nature as the project works area moves along the pipeline route.


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12.1.2. The lack of detail about the anticipated distribution of traffic to and from the Project site;

This is a function of this type of project. The key point about the construction of the pipeline is that it is not taking place in one location of over months or years, it will take place over a short time period (a matter of days) before it moves onto the next site. Accordingly, undertaking a traffic distribution analysis for each ‘stage’ or week of the project is not realistic task and not required in the context of the short duration of any local impacts.

12.1.3. The use of or reliance on daily traffic movements as a metric of construction related traffic. Given the nature of construction related movements, Council considers the analysis should have focussed on the AM and PM peak hours;

The TIA includes both daily and peak hour movements.

I am satisfied that the AM peak hour is not critical, as workers arrive on-site before the road network peak hour. There will be more movements in the PM peak hour as workers leaving the site(s) coincide with the road network peak hour. However, fundamentally I am satisfied that detailed analysis of individual locations is not required for this stage:

• The AM peak is not critical, as workers are expected to be on-site before 7am, with the road network peak hour not typically occurring until 8-9am. The PM peak hour will experience a greater potential impact.

• 400 workers on the pipeline is the ‘high’ estimate, the more normal figure is 120 workers. The assessment was too conservative in always assuming 400 workers using each road link.

• Workers will be spread over multiple fronts (multiple access tracks) and locations and rarely concentrated in one street/location. This is reflected in the analysis which conservatively allocates all workers to using key intersections.

• Any impact at any one location will be short. Construction along the pipeline will move rapidly, with any impacts at a particular location being limited to a number of days. Accordingly, any associated delays on the road network will also be limited in duration.

• The intersections analysed were around Hastings, as shown on the map below. The

12.1.4. The limited peak hour analysis of 6 Frankston-Flinders Road intersections is insufficient to assess the likely impact on those intersections;

12.1.5. Peak hour analysis should also have been completed for other significant intersections within the study area, especially those with an identified accident history that are likely to experience significant additional traffic movements in the peak hours;


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analysis assumes that all workers are using Frankston-Flinders Road, where in many cases, workers may live in Hastings or not travel from Melbourne daily, or not use this road. For instance, workers may use Coolart Road to avoid the Hastings/Somerville town centres. My expectation is that workers will disperse over the road network quickly and not be concentrated at individual intersections.

12.1.6. The review of accidents in the TIA does not provide a particularly meaningful analysis of accidents within proximity of the Project so as to enable an assessment of the likelihood of further accidents as a result of increased traffic associated with the Project and potential mitigation measures to reduce the risk of such accidents;

The review provides total casualty crash numbers by location.

It identifies key intersections for assessment in the subsequent project stages. This is appropriate.

12.1.7. The review of accidents omits discussion or study of intersections proximate to the Project where there have been 4 or more accidents including the Denham Road/Frankston Flinders roundabout which is proposed to be used for stockpiling and other activities during the construction phase of the Project;

When considering locations with 4 casualty crashes over 5 years, there are only two intersection locations along the pipeline route that are likely to experience any reasonable level of construction traffic, namely:

1. Frankston Flinders Road/Denham Road roundabout.

2. Manks Road/Tooradin Station Road

Healesville-Koo Wee Rup Road has a further two locations with 4 casualty crashes, however this road will be duplicated in the near future (and substantially change).

In my view, the Frankston Flinders Road/Denham Road roundabout should also be subject ot a Road Safety Audit. This intersection will be used for a longer period than others due to the role that Denham Road plays in providing access to the pipe stockpiles and project offices. An RSA of this location should be included as a mitigation measure.


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12.1.8. The limited consideration or discussion of how the movement of pipes along the local road network will be managed during construction;

I agree that the TIA did not include detailed information on pipe transportation. My investigations of the other EES documentation and enquires with APA lead me to conclude that the number of truck movements associated with pipe transportation from stockpiles to Access Tracks will be limited to handful per day (less than 10 truck movements).

12.1.9. The review of access track locations includes an assessment of sight distance, with 7 access track locations on the Mornington Peninsula identified as having inadequate or unspecified sight distance. The minimum shortfall is identified as 90m. Due to the inability to move the access track entry within the 30m nominated work area, Council is concerned that the nominated traffic safety mitigation measures will not be sufficient to ensure movements in and out of some of these access tracks can be managed safely and appropriately;

The proposed mitigation measures include a pre-construction Road Safety Audit of the Access Tracks. This is an appropriate mitigation measure.

There is a wide variety of migration options to address the access track sight distance issues, including relocation, vegetation pruning and traffic management measures (temporary speed reductions).

I am satisfied that these issues can be appropriately managed.

12.1.10. No swept path analysis has been provided to confirm that the larger trucks required can enter and exit the site satisfactorily and whether the entire road will be required to do so;

This is not a significant issue, it is a design detail issue that can be dealt with at the time of the pre-construction Road Safety Audit.

12.1.11. The absence of any proposed mitigation measure such as a road safety audit to ensure the safe crossing of a passively controlled level crossing, west of Frankston-Flinders Road between Marine Parade and Denham Road, proposed to be used for construction purposes;

MM-TP02 specifically proposes a Road Safety Audit at this location.


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12.1.12. The EES does not identify whether upgrade of the level crossing on Frankston-Flinders Road (between Reid Parade and Lady Nelson Parkway) is necessary to accommodate the Project.

The EES identifies that this level crossing will require management, but it does not require a permanent upgrade.

This level crossing services a driveway-level access road. It provides non-public vehicle access to Warringine Park and as such does not require a permanent safety upgrade.

12.1.13. The absence of consideration of school bus routes in mitigation measure MM-TP06: Public Transport Disruption Management sub-plan;

I agree.

This mitigation measure should include consideration of school bus routes.

12.1.14. The lack of detail regarding the Nitrogen Transport Plan to enable Council to consider land use planning issues and the need for any road upgrades along the proposed route.

The EES identifies 3 possible routes for B-Doubles to access the Crib Point Receiving Facility, all of which use existing arterial roads and approved B-Double freight routes, except for the last 3km of the route.

The EES identifies mitigation measures to address the last 3km of the route.

Finally, a volume of 5 B-Double trucks per day to Crib Point is not high and does not in my view prejudice road network upgrades or planning in the area.

12.1.15. The absence of any meaningful assessment of whether the Project will preclude the future duplication and electrification of the Stony Point Railway to Hastings and associated necessary upgrades to Hastings Railway Station.

This is outside my area of expertise to examine. My area of expertise does not include planning significant rail projects.

It is noteworthy that neither VicTrack or the Department of Transport raised issues around the pipeline negatively impacting the rail corridor.

2805

Cardinia Shire Council

There are numerous of inaccuracies in the Traffic Impact Assessment reports, particularly with regard to traffic volumes and full consideration has not been made to recent and future development particularly in Pakenham East.

The submission is non-specific about the inaccuracies of the TIA. The traffic volumes for many roads were estimated (most likely significantly over-estimated for many local roads), not surveyed directly. This is acceptable in my view in light of the extent of the project and nature of the construction activities.


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A Traffic Management Strategy and accompanying Traffic Management Plan should be prepared by a suitably qualified traffic consultant, using accurate up-to-date traffic information, in consultation with the Cardinia Shire’s traffic engineers.

Traffic management plans will need to be prepared throughout this project as a matter of normal process. These would require approval by Cardinia Shire.

Landowner Submissions

1685 Traffic management will cause delays while leaving home and to/from work.

The submission relates to a property near Reid Parade. This road will not be closed for construction (the pipe will be bored under the road). I would not expect appropriate traffic management to cause unreasonable delays.

Broad issues

Traffic volume impacts The impacts of the construction traffic are reviewed extensively by the TIA. Fundamentally, the construction traffic impacts are of short duration in most locations and are acceptable.

The traffic impacts of the project during the operational phase are not significant in my view.

Heavy vehicle traffic on local roads

Post construction, heavy vehicle movements will largely be limited already approved B-Double truck routes on arterial roads. This is an acceptable outcome. The only exception is the last 3km along Woolleys Road/The Esplanade.

Mitigation measure MM-TP07 (Nitrogen Plan) and MM-TP05 (Pavement strength survey) both directly address the issue of Woolleys Road/The Esplanade.

Safety of cyclists on rural roads with trucks

The majority of truck trips will be made along arterial roads through rural areas. Most of which are already approved for B-Double traffic.

The volume of cyclists on local rural roads is unlikely to be significant.


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Sludge removal by trucks from Crib Point

I am not able to respond to this submission as the EES contains no information in this regard.

Road safety impacts The TIA reviews casualty crash history of the area. The TIA also recommends appropriate mitigating measures to address key intersections and Road Safety Audits at key locations, including at new access tracks.

I am satisfied that issues regarding road safety are considered in detail by the TIA.

Ability to upgrade the Stoney Point line

I understand that the pipeline route using the rail reserve has been approved by the relevant state agencies. It is not within the scope of my engagement or specific expertise to assess this issue. I reasonably assume that the relevant agencies have considered this issue.


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8. Conclusions 222 This statement provides a peer review of the potential transport engineering impacts for the

proposal to Gas Import Jetty and Crib Point to Pakenham Pipeline Project. My opinions are set out as follows:

a) Technical Report J: Transport Impact Assessment of the EES is the primary traffic study completed for assessing the transport impacts of the proposal.

b) The TIA identifies the key impacts of the proposal, including impacts during construction and in the operational phase.

c) The construction phase of the project will have a greater impact on the transport network compared to the operation phase. This is due to the movement of a higher number of workers associated with construction and the movement of heavy vehicles. During the operational phase, the workforce is significantly lower.

d) The TIA errs on the side of conservatism when assessing the transport impacts of the proposal and as such represents an overly conservative assessment of traffic impacts of the proposal on the nearby road network. In particular:

i. Where data is unavailable, it assumes that each road carries a volume of traffic equivalent to its environmental or target capacity, when most roads are likely to carry far less traffic in practice.

ii. The maximum number of workers are assumed to be on-site at all times and that all pipeline workers use every road link impacted, instead of being spread along the route.

iii. The number of heavy vehicle movements associated with the transport of pipe is significantly over-estimated.

e) The risks or impacts identified by the TIA are applicable. My two key observations are:

i. The intersections between the Access Tracks and the public road network will need to be reviewed in detail before construction commences for sight distance and appropriate mitigating measures applied.

ii. The Frankston-Flinders Road/Denham Road intersection should be included in the list of locations reviewed by a Road Safety Audit due to the importance of this intersection for project vehicle movements and its existing casualty crash history (4 casualty crashes over 5 years).

f) The mitigation measures identified in the TIA are appropriate. Each measure is commonly implemented for construction projects of all scales, such as the requirement for a comprehensive Traffic Management Plan.

g) The mitigation measures identified in Chapter 25 of the EES are appropriate, with the inclusion of the requirement for a Road Safety Audit of Frankston-Flinders Road/Denham Road pre-construction.

h) The Incorporated Document includes appropriate traffic engineering requirements.


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i) The Pipeline Licence Application is generally acceptable, but the Environment Management Plan needs to incorporate the transport risk, TP5 - Pedestrian and cycling access in Hastings.

j) The EPA Works Application for the Gas Import Jetty is not relevant to traffic engineering matters.

223 I have made all inquiries that I believe are desirable and appropriate and there are no matters of significance which I regard as relevant which, to the best of my knowledge, have been withheld from the Panel.

CHARMAINE CHALMERS DUNSTAN

B.E. (Civil) Hons., Masters of Traffic, M.IEAust., F.V.P.E.L.A

G28776A-01A

Appendix A ppendix

Appendix A Instructions

UNDER THE ENVIRONMENT EFFECTS ACT 1978 (VIC)

PLANNING & ENVIRONMENT ACT 1987 (VIC) PIPELINES ACT 2005 (VIC)

ENVIRONMENT PROTECTION ACT 1970 (VIC) ENVIRONMENT PROTECTION AND BIODIVERSITY CONSERVATION ACT 1999

(CTH)

GAS IMPORT JETTY AND PIPELINE PROJECT INQUIRY AND ADVISORY COMMITTEE

AGL Wholesale Gas Limited and APA

Transmission Pty Ltd

Brief to Charmaine Dunstan

Traffix

Ashurst Level 26

181 William St MELBOURNE VIC 3000

T +61 3 9679 3000 F +61 3 9679 3111

RWJ SCO 1000 000 480

Hall & Wilcox Level 11, Rialto South Tower 525 Collins St MELBOURNE VIC 3000 T +61 9603 3555 F +61 9670 9632

Privileged and Confidential 24 September 2020 Page 2

Gas Import Jetty and Pipeline Project

660435961.12

INSTRUCTIONS TO EXPERT WITNESS PRIVILEGED AND CONFIDENTIAL

Charmaine Dunstan - Traffic

1. INSTRUCTIONS

We refer to our email of 30 March 2020 and now wish to engage you on behalf of AGL Wholesale Gas Limited (AGL) and APA Transmission Pty Ltd (APA) as an independent expert to prepare an expert witness statement which sets out your opinion and analysis in relation to the traffic and parking impacts of the Gas Import Jetty and Pipeline Project (the Project). Ashurst act on behalf of AGL and Hall & Wilcox act on behalf of APA.

Ashurst and Hall & Wilcox would like to jointly engage you as an independent expert for the purposes of the public hearing in this matter on the terms and conditions set out in this brief.

2. BACKGROUND

2.1 Overview

On 8 October 2018, the Victorian Minister for Planning (Minister) determined that the Project will be assessed through a single Environmental Effects Statement (EES) under Environmental Effects Act 1978 (Vic) (the EE Act).

The Commonwealth Department of Environment and Energy (DEE) has separately determined that each of the Gas Import Jetty Works (the AGL project) and the Pipeline Works (the APA project), are controlled actions under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act). These actions are to be assessed under the Bilateral Agreement between the Victorian and Commonwealth governments. Accordingly, the EES will address both the EE Act and the EPBC Act processes and requirements.

The Minister's "Reasons for Decision" and the Scoping Requirements for the EES are contained at Tabs 1 and 2. The DEE's determination that the Gas Import Jetty Works and the Pipeline Works are controlled actions are contained in Tabs 3 and 4 to this brief.

2.2 Key approval documents

The EES will be jointly exhibited together with the following approvals documentation:

(a) a Pipeline Licence Application under the Pipelines Act 2005 (Pipelines Act) for the Pipeline Works;

(b) a Works Approval Application under the Environment Protection Act 1970 (EP Act) for the Floating Storage and Regasification Unit (FSRU) component of the Gas Import Jetty Works; and

(c) a Planning Scheme Amendment (PSA) to the Mornington Peninsula Planning Scheme (C272), which will apply a Specific Controls Overlay and Incorporated Document to facilitate the use and development of land at Crib Point with the Gas Import Jetty Works. The PSA will also extend the Port Zone further around the jetty, and rezone some anomalous areas to Port Zone.

Together the Pipeline Licence Application, Works Approval Application and PSA make up the Key Approvals Documents.



660435961.12

2.3 The public hearing process

The proposed EES Schedule includes:

(a) a public exhibition period: 2 July – 26 August 2020; and

(b) a directions hearing on 17 September 2020

(c) a public hearing (the Hearing): from 12 October 2020 for six to eight weeks as required.

Public comments on the EES and the Key Approvals Documents will be invited during the public exhibition period. The Minister will appoint an Inquiry and Advisory Committee (IAC) to conduct the Hearing. Terms of Reference for the IAC are provided at Tab 5.

Once appointed, the IAC will review the EES, the Key Approval Documents and public submissions and then convene the Hearing. The IAC will report to the Minister, and the Minister will make his assessment of the EES and make recommendations about the Key Approvals Documents to the relevant statutory decision makers.

Chris Townshend QC, Barnaby Chessell and Alex Guild of Counsel have been jointly briefed to appear for both AGL and APA at the Hearing.

We understand the IAC is likely to require witness conclaves following the filing of evidence and prior to the commencement of the hearing. Please ensure your availability during this time (ie from 28 September to 9 October 2020).

3. ENGAGEMENT

3.1 Summary engagement

You are instructed jointly by Ashurst and Hall & Wilcox on behalf of AGL and APA respectively. We will work cooperatively and common interest privilege will apply to your engagement.

We request that you please:

(a) provide your analysis and opinion on the aspects of the Project relating to traffic and parking. For your assistance section 5 of this brief identifies chapters and information which you may consider relevant for your statement;

(b) prepare an expert witness statement which addresses the matters set out in section 3.3 below;

(c) review any public submissions filed with the IAC during the public exhibition period which raise issues relevant to your witness statement1;

(d) identify any further information relevant to your assessment, which you require to complete your expert witness statement;

(e) appear as an expert witness at the Hearing of the Project (which may be held by digital medium depending upon the restrictions in place at the time);

(f) if required to do so by the IAC, attend a conclave with other experts in your field of expertise who are giving evidence in the Hearing; and

(g) if you consider necessary, attend a site visit of the areas relevant to your witness statement in advance of the Hearing.

1 Public Submissions will be provided electronically in due course.



660435961.12

3.2 Confirmation of engagement

In order to confirm your engagement, could you please:

(a) provide us with a fee estimate for the preparation of your expert witness statement and appearance at the Hearing; and

(b) provide us with a list of any general restrictions on your availability in October-November 2020

3.3 Preparing your expert witness statement

Could we please ask that your witness statement:

(a) considers the relevant evaluation objective in the Scoping Requirements and provides your opinion and analysis regarding the Chapter and Technical Report relevant to your area of expertise. For your assistance section 5 of this brief identifies chapters and information which you may consider relevant for your statement;

(a) includes a section summarising the concerns raised in the public submissions that are relevant to your area of expertise and your opinion in response to those concerns;

(b) provides any recommendations you may have in relation to the mitigation measures proposed in the EES and outlined in Chapter 25 - Environmental Management Framework and the Key Approval Documents;

(c) is generally in accordance with the suggested structure provided in Annexure A of this brief, subject to any changes that in your opinion are necessary for your particular area of expertise;

(d) addresses all of the matters required in the Expert Evidence Guide (Guide) used for Planning Panel hearings (which is included in Tab 6 to this brief).

4. THE PROJECT

The Project consists of two key sets of works:

(a) the Pipeline Works which are to be developed by APA; and

(b) the Gas Import Jetty Works which are to be developed by AGL.

4.2 The Pipeline Works

The Pipeline Works include:

(a) an underground gas pipeline approximately 57 kilometres long linking the Crib Point Receiving Facility at Crib Point and the VTS east of Pakenham (noting that various options were considered for the route and minor deviations may continue to arise due to negotiations with affected landowners along the route);

(b) a pigging facility at the Crib Point Receiving Facility to enable in-line inspections of the pipeline with a pipeline inspection gauge (pig);

(c) an above-ground Pakenham Delivery Facility adjacent to the Pakenham East rail depot to monitor and regulate gas;

(d) a below-ground End of Line Scraper Station (EOLSS) located at the connection point to the VTS, north of the Princes Highway in Pakenham; and



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(e) two above-ground mainline valves (MLV1 and MLV2) located at different points along the pipeline alignment to enable isolation of the pipeline in an emergency.

4.3 The Gas Import Jetty Works

The Gas Import Jetty Works include:

(a) continuous mooring of an FSRU at Berth 2 of the existing Crib Point Jetty to store LNG and regasify LNG into natural gas using the onboard regasification unit;

(b) jetty infrastructure on the Crib Point Jetty including marine loading arms (MLAs) that would connect to the FSRU and gas piping, to transfer the gas from the FSRU to the Crib Point Receiving Facility;

(c) Crib Point Receiving Facility, including gas metering, odorant injection and nitrogen injection (if required to meet the standard gas quality specifications) – the Crib Point Receiving Facility would be located on land adjacent to the Crib Point Jetty.

4.4 The FSRU

An FSRU is a ship that can store liquified natural gas (LNG) and which is also fitted with an onboard regasification unit that can return stored LNG into a gaseous state and then supply it into the gas network. The gas would be used as a fuel by domestic, commercial and industrial customers.

The FSRU would be capable of storing approximately 170,000 cubic metres (m3) of LNG and regasifying it using the onboard regasification unit as required to meet gas demand. Following regasification, the gas would be transferred from the FSRU to the Crib Point Receiving Facility via MLAs that would connect to gas piping mounted on the jetty. The FSRU would receive LNG from ships known as LNG carriers.

For a general introduction to the Project, you may wish to review Chapters 1-5 of the EES. Further details about the Project can be found in Chapter 5-Project Description.

4.5 Navigating the EES

This EES was prepared in accordance with the scoping requirements for this EES issued by the Victorian Minister for Planning in February 2019 and the Ministerial guidelines for assessment of environmental effects under the EE Act.

The EES addresses the potential impacts on the environment and informs an Environmental Management Framework for the Project. 17 specialist technical studies were undertaken, and the findings of these studies are presented in the technical reports attached to this EES.

The structure of EES is shown below. It is available for download at this link (https://www.gasimportprojectvictoria.com.au/environment-effects-statement#view-the-ees).

https://www.gasimportprojectvictoria.com.au/environment-effects-statement#view-the-ees





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Outline of EES

Summary Report

EES Main Report

Volume 1:

Chapter 1. Introduction

Chapter 2. Project rationale

Chapter 3. Project development

Chapter 4. Project description

Chapter 5. Key approvals and assessment framework

Volume 2:

Chapter 6. Marine biodiversity

Chapter 7. Terrestrial and freshwater biodiversity

Chapter 8. Surface water

Chapter 9. Groundwater

Chapter 10. Contamination and acid sulfate soils

Chapter 11. Greenhouse gas

Chapter 12. Air quality

Chapter 13. Noise and vibration

Chapter 14. Landscape and visual

Chapter 15. Transport

Chapter 16. Safety, hazard and risk

Chapter 17. Land use

Chapter 18. Social

Chapter 19. Business

Chapter 20. Agriculture

Chapter 21. Aboriginal cultural heritage

Chapter 22. Historic heritage

Volume 3:

Chapter 23. Climate change risk

Chapter 24. Sustainability

Chapter 25. Environmental Management Framework

Chapter 26. Stakeholder Engagement

Chapter 27. Conclusion

Technical Reports

A. Marine biodiversity

B. Terrestrial and freshwater biodiversity

C. Surface water

D. Groundwater

E. Contamination and acid sulfate soils

F. Greenhouse gas

G. Air quality

H. Noise and vibration

I. Landscape and visual

J. Transport

K. Safety, hazard and risk

L. Land use

M. Social

N. Business

O. Agriculture

P. Aboriginal cultural heritage

Q. Historic heritage

Attachments

I. Matters of National Environmental V. Community engagement reports



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Outline of EES

Significance

II. Legislation and policy report

III. Environmental risk report

IV Climate change risk report

VI. Draft planning scheme and amendment

VII. Map book

5. TRANSPORT IMPACTS

Chapter 15 is entitled "Transport" and addresses the traffic and transport impacts of the Project. The EES also contains Technical Report J which also addresses transport issues. A copy of these documents are available on the Crib Point Jetty Gas Works website and the Engage Victoria website for the Project. We can also provide you with hard copies of these documents if required.

The following documents are also likely to be relevant to your witness statement:

(a) Volume 1 - Chapters 1-5 which provide an overview of the project and the rationale;

(b) EES Chapters -

(i) Chapter 17. Land use

(c) Technical Reports -

(i) L. Land use

APA has developed an interactive mapping tool that may assist your understanding of the pipeline route, including zone and overlay controls, mapped protected species, waterways etc. We will arrange for you to be given access to this mapping tool.

6. COMMUNICATION AND CONFIDENTIALITY

Your instructing solicitors for your engagement are Sophie Osborn, Ashurst, and Meg Lee, Hall & Wilcox. Meg Lee is your primary contact for the Project.

In order to ensure that legal professional privilege is retained in relation to your work products, we request that you comply with the following communication and information management protocol during the course of this engagement:

(a) Written communications (including email) should be addressed to your primary contact.

(b) Written communications (including email) with AGL personnel in relation to this retainer should be addressed to Robert Jamieson, Sophie Osborn or Anna Seddon of Ashurst but may be copied to the relevant person at AGL who is involved in actioning the substance of the communications.

(a) Written communications (including email) with APA personnel in relation to this retainer should be addressed to Natalie Bannister or Meg Lee of Hall & Wilcox but may be copied to the relevant person at APA who is involved in actioning the substance of the communications.

(c) To the extent that you communicate with AGL, APA, Ashurst or Hall & Wilcox by telephone, please keep any notes of these conversations in a folder marked "Confidential and Subject to Common Interest Privilege – for Ashurst and Hall & Wilcox".




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(d) This brief, any other materials, printed email, working notes or other documents relating to this retainer should also be maintained in a file clearly marked with the words: "Confidential and Subject to Common Interest Privilege – for Ashurst and Hall & Wilcox".

7. FEE PROPOSAL AND INVOICING

As set out above, we request that you provide Hall & Wilcox with a fee proposal that outlines any applicable rates and disbursements required for you to prepare your report and appear as a witness.

You should liaise directly with your primary contact in relation to the scope of work and terms of this engagement.

Invoices in relation to your services should be:

(a) charged to Hall & Wilcox;

(b) clearly demonstrate all services undertaken; and

(c) forwarded to Meg Lee of Hall & Wilcox and we will then include your fees as a disbursement on our monthly invoices to APA.

8. CONFLICTS OF INTEREST

As an independent expert, it is important that you are free from any possible conflict of interest in providing your advice which could preclude you from providing your opinion in an objective and independent manner.

Please notify us as soon as possible if you become aware of any connection you have with any other party which would preclude you from providing your opinion in an objective and independent manner.

9. ADMINISTRATIVE MATTERS

We would be grateful if you could confirm agreement to the terms of this brief, and provide your fee proposal by way of reply email.

If you have any questions, please contact Sophie Osborn on (03) 9679 3881, Meg Lee on (03) 9603 3312 or Anna Seddon on (03) 9679 3041.

Ashurst and

Hall & Wilcox

13 July 2020

ANNEXURE A

Structure for Witness Statement

1. INTRODUCTION

(a) name and address;

(b) qualifications, experience and area of expertise; [Ashurst/H&W suggestion: This may be included as an annexure if it is long].

(c) details of any other significant contributors to the statement (if there are any), and their expertise;

(d) details and qualifications of any person who carried out any tests or experiments upon which the expert has relied in preparing the statement.

2. INSTRUCTIONS AND INFORMATION RELIED UPON

(a) all instructions that define the scope of the statement (original and supplementary and whether in writing or verbal).

[Ashurst/H&W suggestion: Reference Memo of Instructions]

3. FACTS, MATTERS AND ASSUMPTIONS

(a) the facts, matters and assumptions on which the expert relies in preparing the statements;

(b) reference to documents and materials the expert has used in preparing the statement.

4. SUMMARY OF KEY ISSUES, OPINIONS AND RECOMMENDATION

5. CONSIDERATION OF CHAPTER AND EXHIBITED TECHNICAL REPORT

Consider the draft evaluation objective in the Scoping Requirements and provide your opinion and analysis on the relevant chapter and technical report in the EES.

6. REVIEW OF SUBMISSIONS

[Ashurst/H&W suggested approach]:

(a) If >5 submissions, your witness statement can respond to consistent themes/concerns raised by submitters rather than by responding to specific submitters

(b) If <= 5 submissions, your witness statement should respond to specific submitters (can cross refer to responses made to other submissions if required).

7. REVIEW AND RECOMMENDATIONS ON THE MITIGATION MEASURES IDENTIFIED IN THE EES AND THE KEY APPROVAL DOCUMENTS

As relevant to your area of expertise:

(a) review the mitigation measures recommended in the EES relevant to your area of expertise (these are discussed in the Chapter relevant to your expertise and are also identified in Chapter 25- Environmental Management Framework);

(b) review the Incorporated Document in the draft Planning Scheme Amendment;

(c) review the Pipeline Licence Application;



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(d) review the Works Approval Application; and

(e) provide any recommendations you have regarding the proposed mitigation measures or the Key Approval Documents.

[Drafting Note: Consider whether all of these approval documents are relevant or not to the particular expert and adapt as required]

8. DECLARATION

(As per Expert Witness guide, provided as Tab 6 of this engagement brief).



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ANNEXURE B

Index of Documents

Tab Document Date

1. EES Reasons for Decision 8 October 2018

2. EES Scoping Requirements January 2019

3. EPBC Act Controlled Action Decision – AGL 28 November 2018

4. EPBC Act Controlled Action Decision - APA 28 November 2018

5. Terms of Reference for the IAC 1 June 2020

6. Expert Evidence Guide for Planning Panel hearings April 2019

http://melcvs01v/Reports_BI/Pages/Report.aspx?ItemPath=%2fExpert%2fProfessional+Reports%2fCSR001+-+Contribution+Scorecard_v19.3.1&ExecId=qnyorw55ppks0w2bd345am55&PingId=j03d53fka1tk5355qrfodp55

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