The NEL Tunnels Urban Design and Landscape Plan

Submission by Barry Watson

A new EES is now required to address Reference Design final detail and other matters described as follows.

PFAS/PFOS Contaminated Soil at Freeway Golf Course and Sports Ovals on Yarra Flood Plain

Attached is FOI Report “EPA Report 2021/559, Ref 9047694 Freeway Golf Course Balwyn Nth”. PFAS/ PFOS contaminated prescribed waste soil Category C excavated has now been dumped off site during relocation of services. EPA advise as follows:

  • EPA cannot explain why only 115 Lin m of trench was investigated by them for PFOS prescribed waste classification, when in fact, 200 Lin m of trench was excavated? The excavated amount nominated in the Report (115 Lin m) was 1000 m3 bulked. The 200 Lin m of trench amount may have been double that amount. The extra quantity of PFOS (1000 m3?), has not been classified by EPA but dumped somewhere and they don’t know where.
  • EPA advise that further investigation of groundwater contamination at this site is not proposed by them. PFAAS/ PFOS groundwater contamination from this site that may be occurring in the Yarra River and nearby wetlands but to what extent appears to be uncertain.

Flood Plain Impact Caused by NELP Portal and Interchange at Bulleen Rd / Eastern Freeway

The UDLP proposed Bulleen/ Eastern Freeway interchange and raised portal greenspace will impact floodwaters pattern. Recent floods in Queensland and NSW highlight the consequences of building on flood plains. The entire “Bulleen” area south or east of the Yarra river is a flood plain. Specific sites include the Freeway Golf Course, “The Colleges” (Marcellin, Trinity, Carey) sports ovals and Bulleen Sports Oval and the former Bulleen Drive In have been filled during the 60’s & 80’s with what appears to be contaminated soil.


The North East Link (NEL) EES has failed to adequately investigate the Road Traffic Noise Scoping Requirements impact. North East Link Project (NELP) is also “failing” the NEL project Scoping Requirements and Environmental Protection Requirements (EPR’s) and Australia’s best practice. These are described as follows:

  • The EES has not monitored existing road traffic noise near over passes and ramps on the Eastern Freeway. NELP are refusing to include road overpasses like Middleborough Rd etc.
  • NEL Scoping Requirements calls for night-time road traffic noise attenuation to be 40 dB at facade. The Planning Minister Mr Wynne has approved 55 dB(A) free field. NELP have changed this to 58 dB(A). NSW has 50 dB(A) night-time. The Planning Minister Mr Wynne has completely ignored the NELP Scoping Requirements placing residents health at risk.
  • Much of the EES existing road noise monitoring has been done above the wind limit of 3 m/sec and has been adopted at 63% of data from the EPA Viewbank weather station.
  • Existing vertical sound reflective concrete walls must be replaced by Swiss curved acoustic walls (attached). Centre median acoustic walls are essential to preserve liveability and sleep.
  • Downwind road traffic noise impacts caused by the opposite side vertical sound reflective concrete walls on the Eastern Freeway have been ignored by NELP.
  • Acoustic treatment of tunnels portals is required.
  • Best practice Swiss acoustic noise walls must be adopted in lieu of concrete walls that deflect noise back at houses on the opposite side. Median walls will also be required.


I attach Barry’s Graph which shows PM2.5 breaches of State Environmental Protection Policy (SEPP). The actual background monitored data used in the graph was obtained under FOI and is real time NELP data. The graph represents one month of a year and needs to be replicated for 12 months, Our EPA should have done this in the EES. Incredibly, no SEPP AQM compliance study was done in the EES by EPA. A SEPP AQM study was called for by Dr Iain Cowan at the Panel Hearing. The Panel ignored this and so did The Planning Minister Mr Wynne. Pollution from vehicles kills more people than car accidents in Australia. Diesel fuel is the biggest problem and electric cars will not solve the problem caused by diesel trucks on surface freeways. Table 85 (attached) from the EES shows a more than double increase in PM2.5 on the Eastern Freeway with a functional NELP in 2026/ 2036 caused by vehicles.

Unfiltered tunnel vent stacks are proposed. Zero emissions cannot be achieved whilst emitting pollutants via chimney stacks. Cleaner technology will not eliminate fine particles from rubber tyre and brake dust. Diesel fuel trucks will be a polluter for at least the next 10+ years. Hybrid vehicles will always contribute to pollution gasses.

Table 85 from the EES shows PM2.5 will increase to 136% of “base” in 2026, with a strong correlation to Nitrogen Dioxide from vehicles. Clearly vehicles are the problem and SEPP (AAQ) will be breached.

The EPA must determine SEPP (AQM) compliance or non-compliance when 1700 deaths (conservative) per year in Australia are caused by vehicles pollution.