Organisation:

Affected property:

669

Nicholas Aberle

Environment Victoria

NEL_EV_Submissi

Please see attached document. kind regards,

Attachment 1:

Comments:

Full Name:

No, but please email me thRequest to be heard?:

Submission Cover SheetNorth East Link Project EES IAC

Attachment 2:

Attachment 3:

06 June 2019

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

To the North East Link Project Inquiry and Advisory Committee,

Re: Environment Victoria submission on the Environmental Effects Statement and

Works Approval of the North East Link

Environment Victoria welcomes the opportunity to make a submission on the North East Link

Project.

Environment Victoria is an independent and not for profit organisation that has been

campaigning to look after Victoria’s environment since 1969. With more than 40-grassroots

member groups and 150,000 individual supporters, Environment Victoria is a growing

community of Victorians standing up for a safe climate, healthy rivers, and a sustainable future.

We are concerned that this project will destroy local habitats, impact the viability of threatened

species and reduce local biodiversity in the midst of a global biodiversity crisis. Further, the

project has the potential to increase Victoria’s greenhouse gas (GHG) emissions at a time when

urgent action is needed to substantially reduce them to prevent the worst consequences of

climate change.

Environment Victoria Opposes the North East Link (NEL) Project in its current form.

The current plans for the North East Link will cause unacceptable damage to the local

environment. It is particularly concerning to Environment Victoria that project proponents are

rarely required to analyse a wider range of alternatives beyond a ‘no-project scenario’. In this

case, relevant alternatives that should have been included as part of the scoping requirements

include: pricing schemes to reduce congestion, improved suburban public transport and

investment in ride-sharing or car-pooling as a way of reducing traffic volume and therefore

improving travel times. Each of these alternatives could solve existing problems at a fraction

of the cost and with much less, if any, environmental impact.

Furthermore, the project - despite its massive cost - could still fail to deliver its desired

outcomes due to the well-documented phenomenon of ‘induced demand’1, i.e. building new

highways will have the undesired effect of increasing the number of drivers and will ultimately

have a negligible effect on congestion levels. In this regard, there is evidence that demand-side

measures such as congestion pricing, increasing the cost of parking, tend to be more effective

than the construction of new highways, preventing environmental damage and saving large

amounts of public money.

1 Duranton, Gilles, and Matthew A. Turner. 2011. "The Fundamental Law of Road Congestion: Evidence

from US Cities." American Economic Review. Retrieved on 4 June 2019 from

If the state government chooses to proceed with the North East Link, we believe that the project

should be amended to reduce the environmental impacts of construction and operation.

North East Link’s submission does not properly address the impact of induced demand.

While the North East Link’s technical report on traffic and transport asserts that the effects of

induced demand were accounted for, the magnitude of the problem posed by the increase in

driving demand is most likely underestimated. The model estimates induced demand will

account for only 12% of traffic by 2036, which we consider to be optimistically low.

The expansion of highly congested roads inevitably generates considerable additional traffic2.

This phenomenon has been observed in the short-lived benefits of the Melbourne City Link

and the Western Ring Road.

Further, the forecast effects of the North East Link project on travel times and congestion are

assessed as of 2036, only 9 years after the NEL is expected to be finished. Several studies3 have

estimated an induced demand elasticity close to 1, i.e. a 10% of increase in road capacity will

translate into a 10% increase in traffic congestion in the long run, which is often assessed after

15 years.

The North East Link’s current design unnecessarily destroys local habitat.

The project in its current form will require the removal of 16,000 trees, destroy up to 52

hectares of native ecosystems and likely impact several state and federal listed species,

including flora species such as Matted Flax-lily, Clover Glycine, Arching Flax-lily, Studley

Park Gum, Grey-headed Flying-fox, Common Bent-wing Bat, Swift Parrot, Powerful Owl,

Australian Mudfish, Macquarie Perch and Murray Cod.

Further, the project in its current form will negatively impact surface and groundwater in the

project boundaries and downstream to an unclear extent. The Environment Effect Statement

submitted by the proponent lacks detail on the impact on surface and groundwater in the

Banyule Flats area, on intercepting groundwater and its plans for modification of open creeks

into covered drains.

NEL impact on Victoria’s commitments to net zero carbon emissions by 2050.

2 Marshall NL (2000) Evidence of induced demand in the Texas Transportation Institute's Urban Roadway

Congestion Study data set. 3 Duranton, G., & Turner, M. A. (2011). The Fundamental Law of Road Congestion: Evidence From US Cities.

American Economic Review, 101

Mark Hansen and Yranling Huang, "Road Supply and Traffic in California Urban Areas," Transportation

Research A, 31. 205-218. 1997.

Stuck in traffic? Road congestion in Sydney and Melbourne. Grattan Institute Report No. 2017-10, October

2017. Retrieved on June 7, 2019 from https://grattan.edu.au/wp-content/uploads/2017/10/892-Road-

congestion.pdf

Victoria’s Climate Change Act 2017 commits the state to transitioning to net zero emissions

by the year 2050. Victoria has similarly signed on to the Paris Pledge Agreement, committing

to doing our part to hold global warming to well below two degrees. To do this, our GHG

emissions must be drastically reduced over the next decade. The recently released independent

expert report, headed by Greg Combet and advising on emissions targets for 2025 and 2030,

indicates that the transport sector will need to deliver significant abatement before 2030.4

In stark contrast to the urgent need to reduce emissions, the proponent concedes that

construction of NEL will lead to an increase in Victoria’s annual greenhouse gas (GHG)

emissions by 0.25 per cent per annum over 7 years.

We are particularly concerned by the claims that NEL would reduce GHG emissions due to

heavy vehicles using NEL instead of local roads. This claim of a freeway delivering emissions

reductions contradicts existing literature on the phenomenon known as the ‘fundamental law

of road congestion’ and studies on the long-term elasticity of induced demand - that is, as the

NEL inevitably becomes increasingly congested, the supposed GHG benefits from more fuel-

efficient use of heavy vehicles will be lost.

We urge the Inquiry and Advisory Committee (IAC) to require supplementary documentation

from the proponent to properly assess the claims that NEL will delivery emissions reductions

despite the overwhelming evidence on the long-term effect of freeways on traffic congestion

and GHG emissions.

Further, if the NEL is to proceed, with its estimated price-tag of $16 billion, we call on the state

government to commit to developing:

● wide-scale car-pooling schemes, which would simultaneously reduce traffic volumes

at peak times, save commuters money, and reduce greenhouse gas emissions from the

transport sector, and

● more far-reaching incentives to the adoption of fuel efficient cars.

Environmental Effects Statement and Works Approval Process

The weaknesses in the methodology used to assess the impact of the project on traffic

congestion and therefore on GHG emissions should be properly addressed by the proponent,

especially in light of Victoria’s commitment to reach net-zero GHG emissions by 2050 and

soon-to-be announced emissions targets for 2030.

If, despite the methodological issues and the likely negative impacts of the projects on local

environments and biodiversity, the Victorian government decides to pursue NEL we urge the

Inquiry and Advisory Committee to require the proponent to adopt the following mitigation

measures:

4 https://www.climatechange.vic.gov.au/reducing-emissions/interim-targets

- Extend the tunnel portion of the project to just north of the Hurstbridge Rail line as

proposed by the Banyule City Council under their northern Option A2 tunnel extension,

developed by the international tunnelling consultancy firm BabEng.

- Removal of the Lower Plenty road interchange.

- Additional tree planting within the corridor rather than the virtual ‘no net loss’ proposal

of 30,000 replacement for 26,000 lost and offsets outside the area. Re-vegetation of

understory and ground cover species be undertaken. These plants should be in addition

to the 30,000 trees already proposed.

- Retention of Banyule Creek and Koonung Creek as open, unlined waterways.

- Development of a plan capable of ensuring protection of Banyule Flats habitat from

overflow from water treatment facility north of Lower Plenty Road, and water

drawdown.

- Protection and enhancement of the quality of water entering the Banyule Creek,

Koonung Creek and the Yarra.

- Re-development of the works area south of the Manningham interchange (current

industrial estate and drive-in site) as open public green space to compensate for the

overall loss of conservation, passive and active space within the north-south corridor of

the NEL.

- Identification of the habitat trees, used by Swift Parrots, at Macleod Railway Station as

a ‘no-go zone’.

Conclusion

Building large and expensive new freeways is routinely put forward as a solution to traffic

problems, but the traffic problems inevitably persist, and this outcome is compounded by

significant local environmental damage and a locking-in of future greenhouse gas emissions by

encouraging greater use of private vehicles.

In future, before any plans for new freeways are put forward, either by government or

infrastructure companies, Environment Victoria would like to see an alternative approach to

transport planning. Our preference would be for government to lead a genuine, concerted and

well-funded effort, in collaboration with stakeholders, to develop transport plans that focus on

reducing the number of cars and trucks that need to use our roads in the first place, rather than

assuming that demand will only increase.

We would be happy to provide any further information if required.

Regards,

Dr Nicholas Aberle

Campaigns Manager

Environment Victoria

9341 8112 / 0402 512 121