Author: Alex Ivanov

Letter to Mr. Frydenberg re. train Stabling Facility in Seaford

Dear Mr Frydenberg

I write to you regarding the Proposed Train Stabling Facility in Seaford. This facility is 870 metres  to the Seaford Edithvale Wetlands which is listed in the Ramsar Convention. Birds migrate every year to these wetlands,to reproduce. It is well documented that these birds are drawn to Light ships and Stadiums, as they migrate at night. This facility will be lit all night, all 18 1/2 acres. The birds become confused and and use up vital energy stores and may never make it to the the wetlands, so very close by. As you know there are Threatened and critically endangered birds that fly to the wetlands and are protected by the China  Australia Migratory agreement (CAMBA)Japan Australia Migratory Bird Agreement ( JAMBA) and the Korea Australia Migratory Bird Agreement (ROKAMBA) Please find below studies about migratory bird paths and the affect light has on them and the migratory birds that fly to our wetlands.

An EES has not been done, therefore no assessment under the EPBC act has been generated. I ask you Mr. Frydenberg to call for an assessment under the EPBC act. These internationally listed birds must be protected. We must honour our agreements with Japan,China and Korea and take a cautionary approach with appropriate measures to preserve and enhance the environment of migratory birds. In particular, we should seek means to prevent damage to migratory birds and their environment. There is a viable alternative of an empty parcel of land in Baxter,not close to wetlands, residents or any businesses.

 

 

Kind regards

 

 

Supporting Information re the affect of light and migratory birds

“Birds have to use things to orient. One of the tools in their kit is celestial cues, so they can use the star maps like early navigators,” Susan Elbin, director of conservation and science at NYC Audubon, says. Believing they’re flying toward starlight or something similar, nocturnal migrants are drawn to the dazzling display, where they end up wasting crucial energy flying around and sounding off in distress.

Matt Watson, David Wilson, and Daniel Mennill of the University of Windsor recorded the flight calls of migrating birds passing overhead during the 2013 fall migration in southern Ontario, Canada, comparing sites with and without ground-level artificial lights. Analyzing 352 hours of recordings, including the calls of at least 15 bird species, they found that significantly more flight calls were recorded at lit sites than at dark sites. “By pointing microphones at the night sky, we can survey migratory birds based on the quiet sounds they produce in flight,” says Mennill. “This simple technique offers a special opportunity because we can resolve particular species of birds, or groups of species, using a fairly simple technology.”

“It was exciting to find that even low-level anthropogenic lights affect call detections from migrating birds,” adds Watson. Their findings have several possible explanations—ground-level lights could be disorienting birds, causing them to call more often and decrease their altitude as they attempt to straighten themselves out, or they could actually be attracting additional birds, as has already been documented with higher-elevation lights. In either case, artificial lights are causing migrating birds to waste energy, which could affect their chances of surviving their journey.

“Anthropogenic light has profound effects on wild animals. For migratory birds, we know that lights on top of skyscrapers, communication towers, and lighthouses disorient and attract birds,” says Mennill. “Our study reveals for the first time that even low-intensity lights on the ground influence the behavior of migratory birds overhead.”

Excessive or misdirected artificial light at night (ALAN) produces light pollution that influences several aspects of the biology and ecology of birds, including disruption of circadian rhythms and disorientation during flight. Many migrating birds traverse large expanses of land twice every year at night when ALAN illuminates the sky.

 

 

Supporting information re Seaford Edithvale Wetlands Listed birds under the Jamba, Camba and Rokamba

 

JAMBA

Cattle Egret

Rednecked Stint

Sharp tailed Sandpiper

Curlew Sandpiper

Black tailed godwit

Red necked Phalarope

White winged black tern

 

CAMBA

Cattle Egret

Great Egret

White bellied Sea Eagle

Black Tail Godwit

Wood Sandpiper

Latham’s Snipe

Red Knot

Red necked Stint

Sharp tailed Sandpiper

Curlew Sandpiper

Red necked Phalarope

White winged Tern

Caspian Tern

Common Tern

 

ROKAMBA

Latham’s snipe

Black Tailed Godwit

Common Greenshank

Wood Sandpiper

Red Knot

Red necked Stint

Pectoral Sandpiper

Sharp tailed Sandpiper

Curlew Sandpiper

Red necked Phalarope

Common tern

White winged black Tern

 

 

 

 

 

Option 2

Option 2

Rail bridge modified; 2.1% grade.

Showing the difference 0.1% grade makes to platform position and track elevation at platform.

 

Using 2.1% grade; McLeod joining Nepean from its’ current position and with the rail bridge modified.

Platform starts 84m past McLeod. This will be taken up with the station building(s) positioned at McLeod and ramp. The ramps for trenches at Springvale, McKinnon etc are over 100m long.

Rail elevation at the platform = -1673mm

The distance between the Patterson River (southern pier) and McLeod Road IS LONG ENOUGH to provide train clearance under the road and return to ground level before the Patterson River rail bridge (where boats access) at an incline that would allow trains to run safely.

Option 3

Rail bridge modified; 2.26% grade.  Still a full 0.1% less than currently on the Frankston line.

Showing platform position and track elevation at platform.

 

Platform starts 10m north of McLeod. Station building(s) can be positioned north of McLeod in the shopping centre area.

Rail elevation at the platform = -943mm

The distance between the Patterson River (southern pier) and McLeod Road IS LONG ENOUGH to provide train clearance under the road and return to ground level before the Patterson River rail bridge (where boats access) at an incline that would allow trains to run safely.

 

Option 4

Rail bridge modified; 2.3% grade.  Still a 0.06% less than currently on the Frankston line.

Using 403m distance, ie. Not continuing McLeod alignment to the edge of the trench.

 

Platform starts 10m north of McLeod. Station building(s) can be positioned north of McLeod in the shopping centre area.

Rail elevation at the platform = -938mm

The distance between the Patterson River (southern pier) and McLeod Road IS LONG ENOUGH to provide train clearance under the road and return to ground level before the Patterson River rail bridge (where boats access) at an incline that would allow trains to run safely.

The distance between the Patterson River and McLeod Road is not long enough

The distance between the Patterson River and McLeod Road is not long enough to provide train clearance under the road and return to ground level before the Patterson River rail bridge at an incline that would allow trains to run safely.

Understanding the above three arguments from LXRA are false the following are some options available:

Option 1

Rail bridge modified; 2.0% grade

Layout1

Platform starts 106m past McLeod. This will be taken up with the station building(s) positioned at McLeod and ramp. The ramps for trenches at Springvale, McKinnon etc are over 100m long.

 

Rail elevation at the platform = -2385mm

 

 

Using just 2.0% grade; McLeod joining Nepean from its’ current position and with the rail bridge modified.

The distance between the Patterson River (southern pier) and McLeod Road IS LONG ENOUGH to provide train clearance under the road and return to ground level before the Patterson River rail bridge (where boats access) at an incline that would allow trains to run safely.

 

Continue to Option 2.

 

A steeper incline would not meet metro and freight rail standards

LXRA are stating that 2.0% is the maximum incline for the Frankston line.

A relatively new rail section allowing for a trench solution at Ormond and McKinnon which appears to accommodate a storm drain is 2.36%. Obviously, this is a safe operation or it would not have been built by LXRA. Advice from LXRA representatives is that this was a special case and needed special safety considerations and, yes, special safety considerations could again be applied.

A steeper incline CAN meet metro and freight rail standards for safe operation.

Changes to the Patterson River rail bridge would NOT require a closure of the Frankston line for up to six months

A new road bridge connecting Station Street to Station Street over the Patterson River is planned.
This can be used as a temporary rail by-pass whilst any changes to the Patterson River rail bridge are completed.

Carrum temporary rail by-pass
Carrum temporary rail by-pass

Allowing for a safety fence 3m from the by-pass rail track access to properties either side of Patterson River remain unaffected.
This will require a stronger bridge for the train use but any additional height caused by deeper spans can be accommodated with the more lenient road design rules and/or service road use.
And this is working on a two-track by-pass where train schedules will not have to be altered.

But even with a single-track by-pass all trains can be accommodated.

Total by-pass length <500
Metro train length 150
Total to travel 650

Use a temporary by-pass speed restriction to suit track transitions:

Transit use time in by-pass
At 40km/hr ~ time 59 secs
At 50km/hr 47 secs
At 60km/hr 39 secs
Add acceleration 10 – 15 secs

Red figures indicate new schedule
All changes within 2 minutes

A minimum of 3 minutes between
entry to by-pass end

All trains serviced ~ No bussing reqd.

Morning peak

Bonbeach By-pass   Carrum
0600 0601
0606
10 11
20 21
22/24
29 30
33
43/42
44 45
47/48
50 51
55
59
0702 0703
0709
12 13
16
 20/19
21 22
24/25
28
31 32
35
 39
43
 43/45 44/46
49
53
53/55 54/56
59
0804 05
0810
16 17
21
26 27
 33
37 38
43
 46 47
 53
54/55 55/56

Evening peak

Bonbeach By-pass Carrum
1702
1704 1705
12
14 15
 22
25 26
 30
35 36
39 40
44
49 50
53
59 1800
1803
1805 1806
10 11
13/14
21 22
23/25
25/27 26/28
32/31 33/32
33/35
36/37 37/38
44/43 45/44
 45/47
 48/49 49/50
 54
54/56 55/57
1906 1907
10
10/12 11/13
16 17
20 21
24
 26 27
 37 38
39/41
 47 48
54
 57 58

Changes to the Patterson River rail bridge DO NOT require a closure of the Frankston line for up to six months.

Carrum: Lowering the Patterson River rail bridge would NOT impact boat access.

Carrum Boats only use the two mid spans.
Carrum: Boats only use the two mid spans.
The southern span can be lowered without impacting on boat access.
The southern span can be lowered without impacting on boat access.

This effectively increases the distance from the Patterson River to McLeod Road.
Additionally, the vertical gradient transition from level to – 2% (or more) can be achieved over the
mid spans of the bridge improving the effectiveness of lowering the southern span and not impacting on boat clearance.

Rail under road in Carrum

Carrum Station Options for a Trench

LXRA say:
A rail under road design is not possible in Carrum due to:
1. The distance between the Patterson River and McLeod Road is not long enough to provide train clearance under the road and return to ground level before the Patterson River rail bridge at an incline that would allow trains to run safely.
2. A steeper incline would not meet metro and freight rail standards for safe operation.
3. Changes to the Patterson River rail bridge would require a closure of the Frankston line for up to six months, which is not feasible for commuters or freight operators.
4. Lowering the Patterson River rail bridge would impact boat access.
5. Moving the McLeod Road connection further south would increase congestion, reduce traffic flow and move the station 350 metres south away from shops and services.

We will look at each of these points but not in the order given above.

See full responce in PDF document – March 2017 summary of options.

Lowering the Patterson River rail bridge would impact boat access.

Changes to the Patterson River rail bridge would require a closure of the Frankston line for up to six months, which is not feasible for commuters or freight operators.

Letter to the Commissioner Lang

Dear Commissioner Lang

You may not be aware that the State Government of Victoria has not done an Environmental Protection and Biodiversity Conservation study (EPBC) in regards to the Elevated Rail project over Seaford Road in Seaford.  As this planned project is 700 metres from Ramsar Wetlands, which is specifically mentioned in the EPBC act the Victorian Government is required by law to do this. I reiterate it has not been done and Australia risks breaking Migratory Bird Agreements with China, Japan and the Republic of Korea(CAMBA,JAMBA and ROKAMBA. )Please be aware tenders are out, two contractors have been shortlisted and contracts WILL be signed before the end of the year. Works to begin early next year. I realise you are a busy man and it is a busy time of year but time is of an essence and is fast running out. I respectfully ask you as the Commissioner for Threatened Species to call for an EPBC with expedience. Please find below some information about the bird life in these wetlands.

Over 100 different species of birds can regularly be seen at Edithvale-Seaford Wetlands. Seventeen species of migratory birds from the northern hemisphere visit the Edithvale-Seaford Wetlands.  Most of them are protected by international treaties. All of these species could be threatened by elevated rail.

The Edithvale–Seaford Wetlands  are a unique habitat for a diverse range of waterbirds with seventy-five native waterbird species being recorded at the Ramsar site between 1989–2007.

Of particular note, the Seaford Ramsar site regularly supports more than 1 per cent of the East Asian-Australasian Flyway population of sharp-tailed sandpiper, a waterbird species of international importance listed under both JAMBA and CAMBA. The East Asian-Australasian Flyway extends southwards from Alaska and Russia’s far-east, through East Asia and South-East Asia, to Australia and New Zealand. The wetlands provide suitable habitat for the sharp-tailed sandpiper as they prefer shallow, freshwater, ephemeral wetlands. Large numbers gather at the Ramsar site as the wetlands dry out.

The ability of the wetlands to regularly support more than 1 per cent of the flyway population of sharp-tailed sandpipers enabled the site to satisfy Ramsar Criterion Six at the time of listingThe Edithvale–Seaford Ramsar site also provides suitable habitat for the regularly recorded Australasian bittern, a waterbird species of international significance. The Australasian bittern is listed as endangered by the International Union for Conservation of Nature and Natural Resources. The south-east Australian population of Australasian bitterns, supported by Edithvale–Seaford Wetlands, is one of four remaining in the world.

All of these listed bird species could be negatively impacted by elevated rail as we have diesel trains that run along the Frankston Line. Each train is pulled by two diesel trains approximately 30 trucks long. In each truck there are two steel coils weighing approximately 30 tonnes each. Our concern is that as the rail is elevated the carcinogenic fumes will drift across to the wetlands with only a slight breeze. Do I know this for sure? No I don’t as no EES has been done. Does the Level Crossing Removal Authority (LXRA) know that it is safe? No they don’t as an EES has not been done.

The Seaford Wetlands as been as the main point of contention against a rail under Rd Solution. Research into the Seaford Wetlands shows it to now be a largely artificial Wetland that has current engineering controls in place to maintain the levels of the various cells through-out the varying seasons as required. These engineering controls regulate the water coming in and going out to waste from the Seaford Wetlands. Given the fact that the Seaford Wetlands are now known to be actively managed in regards to its hydrology & the engineering solution has been proved to be 36% of the original assumptions by the LXRA you would have to question the original recommendations.

The Kananook Creek has constantly been used as another point of argument by the Government and the LXRA quoting it to be at a believed 10% of its natural flow. The Kananook Creek now has current engineering controls to help maintain the flow however the main system which lives close to the mouth of the entrance to the Kananook Creek is known to be in disrepair and has been this way since the nineties greatly influencing this problem, Simple repairs or replacements of these controls would no doubt be beneficial and help increase the flow.

A rail under solution has been drawn in 3D cad from detailed feature surveying data to calculate the length of the required solution, this information negates the LXRA claimed 1 kilometre long concrete bath-tub to an approx 380 meter long cutting. Due to current topology in Seaford it creates a rail under solution reduced in length by 64% when compared to Edithvale seriously reducing any potential impacts that may or may not happen. In short the length of the required engineering solution has been reduced to 36% of its original quoted length which in turn no doubt reduces the chances of any possible impact by a significant amount.

The LXRA announced the Skyrail decision before any detailed investigation had been performed into an engineering solution for a rail under rd scenario at Seaford Rd as quoted in the Aecom/LXRA report

As revealed recently via FOI. The LXRA were instructed by the State Government to not consult with the public. Throughout the entire engagement process LXRA staff have refused to respond to or engage  in any productive conversation since the beginning of the project, various reports and section drawings have never been released or shared with the public, no real consultation has ever occurred.

A strong case has been built against the proposed design and needs to be seriously considered.

I look forward to your reply with anticipation

 

Letter to Dr. Gillian Sparkes

Dr. Gillian Sparkes

Victorian Commissioner for Environmental Sustainability

Level 16,  570 Bourke St.

Melbourne Vic. 3000

E: info.ces@ces.vic.gov.au

 

(Date …………………………….)

Dear Dr. Sparkes

I write seeking an Environmental Effects Statement (EES) or consideration of The Environment Protection and Biodiversity Conservation (EPBC) Act Relating to the removal of Seaford Road Railway Crossing, in Seaford Victoria.

As I’m sure you are aware the Environmental Protection and Biological Diversity Act (EPBC) must be invoked with any large infrastructure project, it has not been invoked, and thus no Environmental Effects Study (EES) has been triggered. The Ramsar Wetlands are specifically noted in the EPBC act.  By not doing an EES (whether the rail goes under or over the road) Australia is breaking international Migratory Bird Agreements with China, Japan and the Republic of Korea.

For your information 17 species of migratory birds from the Northern Hemisphere visit the Edithvale/Seaford  Ramsar Wetlands. These wetlands regularly support more than 1 percent of the East Asian Flyaway population of the Sharp-tailed Sandpiper, a waterbird species which is listed as a species of international importance under the Jamba and Camba agreements. The Australasian Bittern is listed as endangered by the International Union for Conservation of Nature and Natural Resources. The South-East Australian population of Australian Bitterns, supported by these wetlands, is one of four remaining in the world.

Air quality will be reduced due to greenhouse gas emissions from the increase in fuel of the freight trains going up, then down on the Frankston Line. Each freight train has two engines to pull it, each train has approximately 30 trucks and in each truck there are two coils of steel weighing approximately 30 tonnes each. We believe a rail under road design which will not use as much fuel.

It should be noted that the elevated rail will be 700 metres from the Ramsar Wetlands and is directly next to sporting grounds. It should be recognised that the pollution from the carcinogenic fumes will become airborne and drift over to the wetlands and sporting fields.

Social Structure and Networks. Antisocial behaviour and graffiti on the pylons under the elevated rail. These pylons will need to be close together to bear the weight of the freight trains therefore there will be no meaningful recreational space as put forward by LXRA: instead it will be a railway bridge to blight our community. In a predominantly low rise housing area the elevated rail is out of character and will be a visual eyesore for many, many years to come.

Amenity.  Substantial overshadowing of properties near or along the rail corridor robbing us of a basic amenity — sunlight. Lack of sunlight is a known cause for depression and lack of the feeling of well being.

Social vulnerability and different effects on a part of the community. This includes security risk in streets along the rail corridor due to increased accessibility to the rear of properties. Over 97 % of the community are against any elevated rail option.

I ask you Dr. Sparkes how does this not trigger an EES? I ask for your support to call for an EES and please note time is of an essence so any action taken will need to be expedient.

Regards

(Sign your name ……………………………….)

 

Frydenberg – Conservation study at Seaford crossing

Dear Mr Frydenberg
You may not be aware that the State Government of Victoria has not done an Environmental Protection and Biodiversity Conservation study (EPBC) in regards to the Elevated Rail project over Seaford Road in Seaford. As this planned project is 700 metres from Ramsar Wetlands, which is specifically mentioned in the EPBC act the Victorian Government is required by law to do this. I reiterate it has not been done. Please be aware tenders are out, two contractors have been shortlisted and contracts WILL be signed before the end of the year. Works to begin early next year. I realise you are a busy man but time is of an essence and is fast running out. I respectfully ask you as the Federal Minister for the Environment and Energy to call for an EPBC with expedience. Please find below some information about the bird life in these wetlands.

Seventeen species of migratory birds from the northern hemisphere visit the Ramsar Wetlands in Seaford. Most of them are protected by international treaties.Today they are recognized as precious community assets.Of particular note, the Edithvale–Seaford Ramsar site regularly supports more than 1 percent of the East Asian-Australasian Flyway population of sharp-tailed sandpiper, a waterbird species of international importance listed under both JAMBA and CAMBA. The Edithvale–Seaford Ramsar site also provides suitable habitat for the regularly recorded Australasian bittern, a waterbird species of international significance. The Australasian bittern is listed as endangered by the International Union for Conservation of Nature and Natural Resources. The south-east Australian population of Australasian bitterns, supported by Edithvale–Seaford Wetlands, is one of four remaining in the world.

Kind regards …………