The Freeway Option Review currently on display makes no provision for a new EES. This raises serious issues about the Government’s procedures for carrying out major projects and about its ability to develop long-term transport planning strategies.
 

The 1987 EES is grossly out of date

The ALP made an election commitment that, in government, it would require all Cabinet Submissions to include an environmental impact statement.1 The previous EES, released in 1987, has little relevance in 2000, and cannot be used to justify proceeding with the project.

The groups involved with this Submission believe that the Government would be acting illegally and irresponsibly to proceed with the extension knowing that this 1987 EES is deeply flawed. In particular:

 · The 1987 study was based on a 4-lane arterial road. Whilst a 6-lane freeway was foreshadowed, all impacts were assessed on the basis of a 4-lane road;

 · Traffic volumes (45,000 to 55,000 vpd) used are irrelevant since current figures two years after the opening of the Koonung extension are already double these figures;

 · Impacts of the extension on traffic at either ends of the road (Punt Road and Ringwood) were not fully examined;

 · Public transport alternatives were not fully examined;

 · KMFA argued at the time that the air quality study was faulty. Subsequent studies and memoranda have supported the validity of our work;

 · The 1987 EES made virtually no mention of the possible health impacts of air pollution caused by the road. Since then a large and often damning volume of information has surfaced on the adverse effects of vehicle emmissions;

 · World and local standards for acceptable levels of noise and noise abatement are in a state of change. The 1987 EES could not have taken these changes into account;

 · Understandings about the effect of road run-off on the local creeks, the Yarra River and Port Phillip Bay were not available when the 1987 EES was carried out;

 · A road through the Mullum Mullum creek valley contravenes the recommendations of both the Gibson and Russell reports (see p. 1).

There has been no formal justification for building the road

In its submission to the Gibson Panel in 1990, VicRoads concluded that: “The Panel should consider whether the 1989 Planning Scheme reservation [between Nunawading and Ringwood] should be retained for the longer term, with any decision on an actual scheme to be the subject of a future investigation ” (our emphasis). Such an investigation, this implied, would involve further public consultation and external assessment. (The Gibson Panel had recommended the abandonment of the freeway reservation within the Mullum Mullum Creek valley and proposed that the land be transferred to the Department of Conservation and Environment.)

Despite this, a VicRoads’ internal report, Review of the Eastern Freeway: Springvale Road to Ringwood, dated March 1995, was accepted by the former Kennett Government as sufficient justification for extending the freeway. The review “confirmed the need to extend the freeway ... to avoid intolerable traffic congestion on existing roads and degradation of the suburban environment”.2

KMFA submits that a new EES must be carried out by genuinely independent consultants.

For example, on what grounds VicRoads have assessed traffic levels on existing roads as “intolerable”? If the situation is indeed intolerable, why have alternative traffic management solutions not been considered, both in the short and long terms?

Specifically, the Gibson Panel recommended that “the following works should be constructed and come into operation not later than completion of the Eastern Arterial Extension to Springvale Road... :

 Rec 14.1:
 Grade separation of the Maroondah Highway/Springavle Road intersection by lowering the Maroondah Highway and the railway line under Springvale Road.

 Rec 14.2 :
 Grade separation of the Maroondah Highway/Mitcham Road intersection.

 Rec 14.3 :
 Addition of extra traffic lanes to the Maroondah Highway at the intersections of Rooks Road, Deep Creek Road and Heatherdale Road.”3 

Why were these recommendations ignored, particularly 14.1 prior to construction of the Koonung section, allowing the “intolerable” (north-south traffic) situation to develop which is now being used to justify building the (east-west) extension?

A new EES must also produce evidence to show that a “No-Build Option” will result in unacceptable “degradation” of the eastern suburbs, as defined by independent criteria.

For a new EES VicRoads must explain:

1) its rationale for proceeding with the extension without proceeding simultaneously with the Scoresby Freeway when:

 it wrote in 1990 that “Any extension of the Eastern Arterial should be in the context of responding to circumferential rather than radial traffic demands; by terminating the Arterial Road at Springvale Road with any future extension to Ringwood being dependent on prior construction of the Scoresby Route to the south of Ringwood ” (our emphasis).4 (In 1999 plans for the Scoresby Transport Corridor were deferred indefinitely by the Bracks Government.)

2) how it will respond to its own concerns about air quality in the valley:

 [We have] “identified a significant air quality problem if vehicle numbers were permitted to escalate between Springvale Road and Ringwood ... On these grounds alone the project should be restricted to four lanes with provision to go to six no earlier than about 2010 unless air quality monitoring indicates otherwise”;5

3) why it continues to use its own traffic modelling figures to justify building the road when it knows these are faulty:

 “The EES [1987] envisaged approximately 40,000 vpd whereas now, volumes in excess of 90,000 vpd are being mooted.” (memo cited).
 

The new design options constitute a new major project

The new design options currently under consideration differ greatly from those assessed in 1987. As such, the proposed extension must be treated as a new major project, which requires a new EES.

The internal memo already quoted stated that a new EES could be expected: “Other than an option which utilises the existing [planning scheme] reservation route ... in all probability it will be required that a new EES be prepared”.

The Government must act on VicRoads’ own understanding that a new EES is required.
 

The extension will generate additional road projects

The further extension of the Eastern Freeway to Ringwood will place immediate, focused and increased traffic pressure on both ends of the freeway. The Punt Road / Alexandra Parade exits and the Ringwood area will experience increased congestion.

The Government has announced that it will “undertake a separate detailed traffic study to identify and assess satisfactory ways to connect the Eastern Freeway to the existing road network south of the Ringwood Bypass”.6

Such a study has already been carried out by consultants PPK Environment and Infrastructure Pty Ltd on behalf of Maroondah City Council in October 1998.7

They recommend that a further $37.9 million of roadworks be carried out in Maroondah by 2011 to accommodate the traffic flowing from the Ringwood Bypass and Eastern Freeway. These projects include:

(by VicRoads)

 · widening of Ringwood Bypass Stage 1 to six lanes (by VicRoads);
 · widening of Mt Dandenong Road between Maroondah Highway and Dublin Road to six lanes;
 · widening of Mt Dandenong Road between Carcoola Road and Wicklow Avenue to six lanes;
 ·  duplication of Canterbury Road between Bayswater Road and Dorset Road;
 · traffic management of Canterbury Road between Dorset Road and Colchester Road (VicRoads
    proposes widening to six lanes);
 · widening of Canterbury Road between Colchester and Liverpool Road to six lanes;

(by Maroondah Council)

 · traffic management of Ringwood Street between Maroondah Highway and Loughnan Road;
 · duplication to four lanes of Loughnan Road between Eastern Freeway and Ringwood Street;
 · widening of Eastfield Road between Mt Dandenong Road and Bayswater Road to four lanes; and
 · duplication to four lanes of Hull Road between Dorset Road and Allendale Road.

Note: Further work was recommended to alleviate the extra pressure that would be placed on the local traffic scene if the Scoresby Freeway was built!

No such study exists which examines the additional road projects that will be required to cope with the extra traffic at Punt Road and Alexandra Parades. However in September 1999 the Coalition called for private sector interest to build a billion-dolllar tunnel under Carlton to link the Tullamarine and Eastern Freeways.