ORANGE Route for bypass goes against NSW environment rules and principles

This week Eurobodalla Councillors and members of the community attending the Public Forum session heard a presentation from Moruya resident, Yvonne Matthews

She advised the councillors of a submission that she had made to NSW Transport that read: "Thank you for the opportunity to respond to, and comment on your preferred corridor (the Orange one).

I make the following points based on the material found in your document titled Moruya Bypass Strategic Options Report.

My Primary Point. Based on the data you’ve provided in the aforementioned report, the selection of the Orange Corridor is a far inferior choice to the Yellow Corridor.

Argument Against the Orange Corridor.

1. Sustainability scored #1 in your report for the Orange Corridor. However, your detailed analysis of the impediments inherent in this route demonstrate that it is anything but sustainable and consequently should not score more than #4.

For the following reasons.

a. The corridor falls across an extremely vulnerable, highly valued environmental wetland (the Yellow Corridor does not). As stated, the route is within a NSW classified ‘Coastal Wetland’ (CM- SEPP) p20. Why put the road through a wetland land of significant environmental value when it can be avoided?

b. Moreover, the corridor also is in very close proximity to a NSW Govt declared Marine Park Reserve (Marine Estate Management Act 2014) p22. The chemicals and sediment from vehicles, the threat to the subterranean water table from vibration and leakages from construction imperil the viability of this natural environment. Placing the road through this area is incongruous with intention of the Act, which states to ‘provide the highest level of protection for habitats, animals, plants, and areas of cultural significance’. How can the proposed road passing through or very close to this wonderland of nature, hardly ‘the highest level of protection’.

c. Fisheries Management Act 1994. There are several areas mapped as key fish habitat within and near the investigation area, including Moruya River, Malabar Creek, and their tributaries p22. These habitats are also protected under the FM Act. And again, I’m left to wonder how you can possibly assign a score #1 for Sustainability, to the Orange Corridor?

d. The proposed corridor is also passing through known Acid Sulphate Soil. Your document states that the flood plain north of Moruya and east of the highway have a high probability of being ASS, which as you rightly affirm ‘………. can have a bearing on construction and the durability during the life of the asset’ p55. So why are you putting it there, in soil which could erode the concrete pillars of the bridge? How can you justify this risk, when the risk could be obviated easily by choosing the Yellow Corridor?

e. How can the ongoing maintenance costs of this route possibly be called sustainable? The document states (p 86) that ‘……….. acceptable methodology for stormwater discharge and treatment requirements from long bridges’ are needed or as you euphemistically phrased it on p58 . ‘Drainage requirements and water sensitive urban design would be considered in later design phases and the environmental assessment for the proposal’.

It seems to me that you know it’s the wrong choice, nevertheless you are intractably committed to a bad choice and will do whatever it takes, no expense spared to achieve public/official approval and justify your poor choice, with a list of desperate solutions, all of which could be avoided if reason and the data were followed, to their logical conclusion. The Yellow Corridor has none of these inherent impediments.

f. Construction risk. As mentioned in the document, construction on a flood plain is fraught with perils, if an adverse weather event occurs. And yet you contend that the choice is the right one. How can it be? The extra expense to protect against this risk and borne by the tax payers should not be the case. When a viable alternative is available, with no such risk.

Finally, I’m sure you are aware of the scientific, indisputable fact that one ton of concrete produces, one ton of Carbon Dioxide (CACO3 -à CAO +CO2 (g)). And yet you aver that the bridge structure is sustainable? Well, I’m at a loss to understand your position, which defies the science and, in an era, where world governments are at the point of hysteria over Climate Change. Sadly, the Orange Corridor will be a significant contributor to climate change since it’s made of many tons of concrete.

2. Resilience scored #1. I would dispute this score. A 5-6km concrete bridge structure across a flood plain, which has a high ASS content, could not be deemed resilient, by any rational person. The soil type (ASS) threatens the longevity of the asset, for which inordinate expense will be incurred in its manufacture and then in its maintenance.

Similarly, the location, placing it across a flood plain means on occasions the pillars will be submerged, which could cause structural damage to the asset, over time.

It’s spurious to argue as you do ………………… that having a bridge structure will keep the road open in flood peaks of AER X % etc p56, when the desired resilience could be achieved by moving it to a location that doesn’t flood. Achieving the desired resilience without the desperate measure required to achieve it. It’s like saying ‘I’ve found the solution to the problem that I’ve created’. Instead of choosing a route that doesn’t require desperate solutions.

Moreover, these potential hazards could be avoided by relocating the corridor to another position which is not subject to inundation. Such as the Yellow Corridor.

3. Liveability scored #1. Again, I’m confounded, how you can assign the highest rank; #1, to the Orange Corridor, in view of its assault on the rural/agricultural vistas of Moruya, which are quintessential to its history, heritage and desirability.

Granted the livability criterion 1 – 4 (p81) are all important, nonetheless criteria 1,2&4 are met by all of the options on the short list, with exception of the Purple Corridor, which leaves us with……

Criterion 3: Minimise impacts to landscape character and visual amenity, as measured by a qualitative assessment of impact on landscape character value. P81

Thus criterion 3 is the only distinguishing criterion. An ugly bridge reaching 5 metres high, made of concrete and spanning the full length of Mullenderee Flat is a grotesque scar on the rural character of Moruya, and not

‘…..…a moderate impact in terms of landscape and visual effect…’ p81

As you indicate it’s a qualitative assessment, or beauty is in the eye of the beholder. If it were moved to the Yellow Corridor, it would not be beheld (out of view) and thereby genuinely meet all the criteria.

Case for the Yellow Corridor

1. Sustainability: Admittedly this option would have a high impact on the terrestrial ecology since it traverses bushland. Notwithstanding it out performs on all other corridors with reference to

1. Aquatic ecology, there’s no coastal wetlands to cross other than the Moruya River and a small portion of land just south of it.

2. Minimize impact to land owners and farm owners (unlike the Orange option which imperils prime agricultural land, and ruining livelihoods).

3. Minimises Aboriginal and non-Aboriginal heritage

You state that the Yellow option will cause a higher level of impact on Aboriginal heritage, non-Aboriginal heritage due to the bushland terrain on the north side of the river (p 83). Perhaps this may be so with reference to Aboriginal heritage, but the Yellow option affords less impact on non-Aboriginal heritage by virtue of its passage through bushland, because it’s not ruining the landscape of the northern entrance to Moruya, which the Orange option is culpable of. Nor does it have any impact on the operation of the sea-plane.

4. Maximises integration with existing and future land use planning.

Furthermore, unlike the Orange Corridor, there is no need for the ongoing use of and expense of energy, to maintain the filtration plants required to cross the flood plain. Nor are waterways and marine life and habit under constant assault, from the same. And what’s more, the trees lost in the construction of the road can be replaced (are renewable), while a ravaged wetland cannot. Do you intended to provide carbon credits to offset the large amount of CO2 this option will produce?

While the construction of the Yellow route may pose some challenges, nonetheless these challenges are not without an antecedent. Last time I looked, the Berry Bypass seemed to require a massive amount of cut and fill. NSW Transport had no trouble moving a mountain there, surely, they can do the same here?

2. Resilience: Both the Yellow and Orange Corridors scored #1 for resilience. The determination of the superior route is contingent on the weighting given to flooding vs bushfires. Be that as it may, it could be argued that during bushfires the existing highway is a viable backup, allowing travel to continue unabated, if a bushfire were to close the Yellow Corridor.

However, the expense of maintaining the Yellow route pales, before the ongoing high maintenance costs of the Orange route.

3. Liveability: I contest the ranking of #4 that you’ve assigned to the Yellow option. The document states, it scored poorly against amenity due to its distance from the town and poor connectivity to the industrial areas in North Moruya. p 81

Granted that the connectivity to North Moruya industrial area is less than the other options. Notwithstanding it could be argued that this is a minor consideration, for the traffic which enters and leaves the industrial area is primarily trucks from Sydney, which would not be using the bypass, wherever it was located. Since they travel no further south than Moruya.

Furthermore, since you are not building access into the bypass from North Head Drive nor South Head Road (maybe), the bypass in its proposed form offers no amenity to locals. Locals will be using the existing routes for the daily travel and not the bypass.

Moreover, your statement on p81 Its performance against landscape and visual was poor due to the cuts and fills required.

This is an extremely subjective statement, it could be legitimately argued that since we’re accustomed to cut and fill on all highways throughout Australia, that the cut and fill along the Yellow Corridor is no different. While on the other hand, a monstrous bridge 5 metres high and 5-6 km long running across a stunning rural landscape is visually confronting in its context, dare I say ‘sacrilege’.

4. Financial Cost – I am amazed that a comparative cost of construction was not even considered to be a criterion. The estimated comparative costs of the corridor options were not considered at this workshop. P77

With respect they should have been. For you are meant to be the stewards of hard-earned taxpayer dollars. This is a serious omission. And we the public have the right to see the cost comparison on these options, before the Orange Corridor is imposed on us.

Summary

My purpose was to draw your attention to the dubious analysis of the data that you’ve presented, as a case for the Orange Corridor. When in fact the data says the contrary.

The Orange Corridor is a poor choice, due to the singular fault of being located across a flood plain. This corridor threatens the habitat of fauna, the purity of our waterways, the Marine Park and productive farm land. Will be costly to maintain and produce tons of CO2 for its construction. And yet you deem it Sustainable.

It is affront to the scenic beauty of Moruya, and will cost an inordinate amount of money to build. And yet you claim it supports Liveability.

It’s placed on ASS, and subject to inundation. And yet you assert its Resilience.

Surely the data says otherwise? It’s not too late to select the optimum choice, Choose the Yellow Corridor. A choice with none of these liabilities.

Thank you for your time and attention.

Yours Sincerely

Victor Matthews B.A, BCS, & B.Optom and Yvonne Matthews