1. Part C: Commentary on Submissions & Expert Witnesses
Edithvale & Bonbeach Level Crossing Removals Environmental Effects Statement
NSRFL Reponse (No Sky Rail: Frankston Line) Community Association No: A C
Part C: Commentary on Submissions & Expert Witnesses
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission: Part A

2. Edithvale & Bonbeach EES Submission: Part A
Chapter Introduction
We have broken our presentation down into the Chapters shown below.
The topic of this Chapter is highlighted below.
Section
Title
Duration
Contents
Chapter A
Introduction
20 mins
Introduces NSRFL presentation on the EES on the Edithvale and Bonbeach Level Crossing Removals.
Chapter B
Methodology
NSRFL response to the EES statement, reviewing its Methodology and Approach.
Chapter C
Rebuttals
Reviews pro-Sky Rail submissions and other anti-Rail Under Road position taken by a small number of people
Chapter D
Community View
30 mins
Community views of a Rail Under Road solution.
This shows you want the community actually would like to see.
Chapter E
Summary
Brings together all sections of our presentation.
Links these to the EES panel hearings over the past two weeks.
Chapter F
Publicity Material
Appendix of supplementary and supporting material.
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission: Part A

3. EES Submissions: The numbers
We note that there are only a handful of submissions (7) that support elevated rail.
Most do not give valid reasons for opposing a trench, as we will show.
This is far outweighed by the 222 submissions supporting the Trenched solution proposed by the EES!
We note that 14 submissions were neutral, and another 5 were official submissions from government bodies.
Organisational
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission

4. Pro-Sky Rail Submissions: Why they are wrong!
Given our pivotal role in this community campaign, we have been asked by our members to address the few concerns raised by other residents supporting elevated rail.
This section shows how are actively addressing these concerns in our ongoing efforts to be a positive influence for Rail Under Road in the local community.
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission: Part A

5. EES Submission Responses
Key Concern
Response/Mitigation/Reference 1
Flooding or potential drop in ground water levels impacts on residential housing and remnant bushland
Visual impact of all that concrete is going to be appalling.
At Bonbeach our group (CBTS) has worked for a decade to improve the station precinct.
Groundwater level changes are not predicted to be an issue at Bonbeach, as groundwater flows parallel to Trench, not across it. Trench will have less impacts on residential housing amenity (as construction risks would be required to be managed in both options). Remnant vegetation would be removed in both options, however, we would likewise want to see greenery installed external to the trench
Agree that large amount of visible concrete (such as in elevated Rail) is not appealing. Again, we would want to see greenery installed external to the trench
The Friends of Bonbeach have done a fantastic job with plantings and tending and would like to see this continue at both the Bonbeach and Edithvale Stations.
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission

6. EES Submission Responses
Key Concern
Response/Mitigation/Reference 8
Worried about any potential wetlands impact.
States Anti-Sky Rail residents of being “selfish” and narrow minded.
Peer reviewed/Workshopped Risk Assessment to AS/NZ3100 Standard Stating Negligible/Minor Risk
No Skyrail: Frankston Line group membership encompasses a range of professional skillsets, (Design, Engineering, Project Management, Construction , Health and Social Services) are apolitical. Follow a written Code of Conduct, and encourage inclusive debate. All information published (via Facebook Group, Website and Leaflets) is checked/reviewed and clearly identifiable via Incorporation Number on all publications. We support Level Crossings being removed and represent nearly 3000 people 25
Worried about any potential wetlands impact
It would be fair to assume most (if not all) Stakeholders are. We highly value the Wetlands. However, as stated in the executive summary, there will be no impact to the Wetlands, backed by Peer reviewed and Workshopped Risk Assessment to AS/NZ3100 Standard Stating Negligible/Minor
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission

7. EES Submission Responses
Key Concern
Response/Mitigation/Reference 31
Want rail over road, not big hole in the ground creating a useless area of unusable land
rail over road can put in further parking which will reduce the amount of people parking on my street
seems more cost effective for you to run rail over road all the way down from mordialloc rather then ‘roller coaster’ that everyone else wants.
Land is not useless area. At grade entry transitions from Station and local community
LXRA has confirmed no difference in parking (i.e no net loss), from both options
Cost differential between Rail Under and Elevated Rail has been confirmed by LXRA as marginal at a number of Community Consultation sessions 36
Prefers skyrail arrangement over a trench..that may be prone to flooding and that the Skyrail would NOT detract from the surroundings….and leave more room at ground level for other developments.
No evidence that trench will be prone to flooding
No great land use opportunities exist due to narrow width of existing rail corridor, and would be parking at both locations as the main land use
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission

8. EES Submission Responses
Key Concern
Response/Mitigation/Reference 94
Skyrail as it the best option for the community. Skyrail will provide Parking as it is a major issue in our community
trains can still run while it is being built
LXRA has confirmed no difference in parking (i.e. no net loss), from both options
Both options incur disruptions during construction campaigns
121
Our family actually see the benefits of a rail over road.
Concerned about plumbing/water flow issues with a rail under road for EDITHVALE.
The NO SKYRAIL group have frankly scared us with their campaigning into not defending our own opinion on the issue. We know many other families also intimidated by them.
Water flow issues are dealt with by the EES Report and Technical Reports
Everyone is welcome to their own opinion in the debate on these level Crossing Removals. NSRFL Group research and fact check all information prior to release. We welcome open discussions and have sought to engage with many groups and individuals over the last 2.5 years. We follow a Code of Conduct to engage with the Community in a positive and proactive manner
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission

9. EES Submission Responses
Key Concern
Response/Mitigation/Reference
213
The risk assessment in the GHD report appraised the likelihood of risk as too high and consequently as potentially catastrophic with potential impacts on the values of the wetlands, …. possibly jeopardizing the Ramsar listing.
The report is silent on any independent review of the groundwater modelling and the mitigation measures proposed.
Long term monitoring of the environmental factors … with a view to assessing any changed outcomes that may arise from this project is extremely important
We would also like to recommend that the monitoring of ground water is reported/assessed in a transparent and public manner so that the relevant people and groups are aware of these outcomes….that there will be careful monitoring of the trench option and contingency plans in place for unexpected issues
Pre-EES works. Since the GHD Feb 2017, a full EES has been performed, detailing no impact to the Wetlands, and also stating not impacting the Criteria for Edithvalve Wetlands to remain a RAMSAR listed Wetland
EPR’s are clearly listed for Groundwater (GW1 – GW4), Section in regards to meeting trench design, groundwater performance outcomes, management and monitoring plan and independent Peer review.
NSRFL agree this is as important, given the high value locally and internationally of Edithvale Wetlands
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission

10. EES Submission Responses
Key Concern
Response/Mitigation/Reference
242
The February 2017 GHD preliminary report estimated the mounding and drawdown from the trenches at 10cm. LXRA officers clearly had no idea whether or how this drop in groundwater levels will impact on the Coastal Banksia Woodland
We can accept a reasonable level of risk when the potential consequences are not severe, but when, as in this case, the potential outcome of something going wrong is catastrophic, in our view there is no room for error and we should not be accepting any level of risk.
We may well broaden our submission to cover other more specific issues, particularly if we are able to engage an expert witness. These are likely to include:…. the need to assess how the impact of the trench will interact with the existing threat of climate change and rising sea levels……risk of saltwater encroachment
GHD 2017 Report is preliminary and Pre EES findings, and therefore superseded. Refer EES sections:
Section Table 6.2. Wetland risk of mounding or threat Initial AND Residual Risk of NEGLIGIBLE
Section Table 6.4. Risk of Drawdown or threat Initial MINOR and Residual Risk of NEGLIGIBLE
The Groundwater modelling has taken into account the impacts of climate change and impact of saltwater intrusion (100 year model), Refer to EES sections 5.2 Methodology, and in particular subsections (numerical groundwater model development), (Wetland Hydrological Model) and (Risk and Impact Assessment)
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission

11. EES Submission Responses
Key Concern
Response/Mitigation/Reference
248
References the GHD Aecom Report February 2017 in relation to potential for significant adverse impact and loss of RAMSAR status for Edithvale Wetlands
GHD 2017 Report is preliminary and Pre EES findings, and therefore superseded. Refer EES sections:
Section Table 6.2. Wetland risk of mounding or threat Initial AND Residual Risk of NEGLIGIBLE
Section Table 6.4. Risk of Drawdown or threat Initial MINOR and Residual Risk of NEGLIGIBLE
The Groundwater modelling has taken into account the impacts of climate change and impact of saltwater intrusion (100 year model), Refer to EES sections 5.2 Methodology, and in particular subsections (numerical groundwater model development), (Wetland Hydrological Model) and (Risk and Impact Assessment)
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission

12. How the Experts viewed Rail Under Road
We have always maintained that Rail Under Road is entirely feasible on the Frankston Line
This section shows our support for the expert research undertaken by the LXRA to support this position
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission: Part A

13. KCC EES Expert Witnesses – summary
Subject/
Representation
Key Takeaway messages
Response/Mitigation/Reference
Dr_Andrei_Woinarski_Senversa
Hydrogeology Review, Senversa
None of the identified issues would prevent the construction of the level crossings at Edithvale or Bonbeach.
Uncertainty and limitations of the hydrogeological model and predictions be considered in monitoring and detailed design of mitigation measures.
Further detailed investigation of hydrogeological conditions, existing groundwater use and effectiveness of mitigations measures (are recommended.
Independent reviewer and independent EPA Environmental auditor appointed to ensure further assessment are carried through into the design and construction
NSRFL Agree that no identified issues would prevent the construction of proposed Rail Trench, in line with EES recommendations
NSRFL Agree in concept that any uncertainty should be assessed through design/construction noting that however the Risk Assessment concludes Negligible risks
NSRFL Agree that data continues to be gathered, and reviewed for effectiveness. This is prudent and in line with a Precautionary Approach
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission

14. KCC EES Expert Witnesses – Summary
Subject/
Representation
Key Takeaway messages
Response/Mitigation/Reference
Name
Jeff Yugovic
Ecologist Biosis - Foreshore vegetation
Provided the groundwater modelling for both Edithvale and Bonbeach foreshores is accurate, any material adverse impact on the foreshore vegetation appears unlikely.”
It would be sensible and appropriate to monitor the foreshore vegetation…..with agency responsibilities clearly defined in this process.”
NSRFL support this view along with ongoing monitoring
NSRFL support this view of ongoing monitoring to ensure baseline comparison and EPR’s demonstrated to be met
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission

15. KCC EES Expert Witnesses – Summary
Subject/
Representation
Key Takeaway messages
Response/Mitigation/Reference
Name
John Piper – Construction (Geotechnical, Contaminated Land and Soil Vapour Review)
None of the identified issues would prevent the construction of the level crossings at Edithvale or Bonbeach and can be all addressed during the detailed design.
Suggested that the horizontal drain proposal for Edithvale be further assessed for its practicality/ensure no unintended consequences.
Agrees with the EPA and LXRA proposal regarding an independent reviewer and independent EPA Environmental auditor
Ensure that the further assessment, identified mitigation and design issues are carried through into the design and through construction to ensure that the monitoring and any mitigation measures are implemented within a suitable time frame.
NSRFL Agree
NSRFL Agree as prudent
NSRFL Agree as prudent to ensure EPR’s are independently assessed and met
NSRFL Agree further assessment through Design and Construction, but also ongoing into Operation prudent to ensure EPR’s are independently assessed and met
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission

16. Edithvale & Bonbeach EES Submission: Part A
End of Chapter
No Sky Rail: Frankston Line
Edithvale & Bonbeach EES Submission: Part A