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