Review of Environmental Factors Addendum. Green Square Stormwater Drain Shea s Creek Channel Corridor Restoration

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1 Review of Environmental Factors Addendum Green Square Stormwater Drain Shea s Creek Channel Corridor Restoration November 2016

2 Sydney Water Corporation (2014). Commercial in Confidence. All rights reserved. No part of this document may be reproduced without the express permission of Sydney Water. 2

3 Table of Contents 1. Introduction Background information Proposal Purpose of this addendum to the 2014 REF Stakeholder and community consultation Legislation and planning context Environmental Planning and Assessment Act Other Legislation Local council approvals/liaison Alternatives and justification for the proposed change Proposal need Alternatives and their assessment Consideration of proposal against principles of Ecologically Sustainable Development Description of the proposed work and activities Scope of work Proposed activities Workforce and timeframe Changes to the scope of work Existing environment, potential impacts and measures Noise Waste management Heritage Aboriginal and non-aboriginal Traffic and access Social and visual Geology and soils Flora and fauna Air and energy Water and drainage Cumulative impact Environmental management Conclusion References Appendix A Clause 228 summary

4

5 1. Introduction 1.1 Background information The Green Square Stormwater Drain is a new stormwater drainage system currently being built in partnership by Sydney Water and the City of Sydney Council. It is a 2.4 kilometre drain that will, when completed, transfer stormwater from Epsom Park, through the Green Square Town Centre to Alexandra Canal. In accordance with the requirements of Part 5 of the Environmental Planning and Assessment Act 1979 (EP&A Act), a Review of Environmental Factors (2014 REF) for the Green Square Stormwater Drain was prepared in 2014 and determined by Sydney Water following consideration of submissions in a Decision Report completed in July The Green Square Stormwater Drain (GSSD) will help reduce flooding impacts within the Green Square Town Centre and on Joynton Avenue and Botany Road. It will also accommodate future stormwater drainage needs of the Green Square Town Centre. Between Maddox Street and Alexandra Canal, the new drain will be constructed next to the existing open channel leaving a corridor of land between the drain and the adjacent buildings. Restoration of this corridor is proposed to include fencing, lighting, plantings and a concrete pathway suitable for maintenance access and future use as a footpath and cycleway. The proposed path is a long term commitment and plan by both state and local governments. It is included in the following plans and strategies: 2001 Alexandra Canal Masterplan (by South Sydney Development Corporation, an agency of the NSW Department of Planning which included Sydney Water) 1997 South Sydney Council Development Control Plan Cycle Strategy and Action Plan Inner Sydney Regional Bike Network Sustainable Sydney 2030 Liveable Green Network as a main green corridor Employment Lands Urban Strategy Sydney Development Control Plan 2012 The section of path adjacent to the stormwater drain between Maddox Street and Alexandra Canal would connect to a path that will soon be constructed by the City of Sydney along the Canal. When complete, the path along the Alexandra Canal would provide important recreational and commuting links between the Cooks River and Sydney Airport in the south, with recreational destinations including Sydney Park, Perry Park and Centennial Park, and to the existing cycleway network into the city to the north. 5

6 1.2 Proposal This REF Addendum addresses the inclusion of a concrete path for a cycleway next to the stormwater drain from Maddox Street to Alexandra Canal. The 2014 REF did not include this pathway or specify the end use of the corridor of land between the new drain and the adjacent properties in this area. Section of the 2014 REF states that surface areas disturbed by construction activities would be re-instated to existing condition or as agreed with landowners. During detailed design and planning for construction the opportunity to improve the aesthetics of this corridor and enable future use as a cycleway was identified. This corridor of land is owned by Sydney Water and a cycleway in this location has been identified in City of Sydney s relevant plans and strategies. Incorporating this level of restoration into the stormwater drain project capitalises on the opportunity to improve the value of the corridor of land as a community asset, and avoids returning to the site to construct this in the foreseeable future. 1.3 Purpose of this addendum to the 2014 REF Sydney Water is a statutory state-owned corporation and is classified as a public authority under Section 4 of the Environmental Planning and Assessment Act 1979 (EP&A Act). Sydney Water is also the determining authority for the proposed work under Part 5 of the Act. Under section 111 of the EP&A Act, Sydney Water is responsible for assessing the impacts of its activities. This REF Addendum assesses the potential environmental impacts associated with the proposed restoration of the corridor of land between the stormwater drain and adjacent properties between Maddox Street and Alexandra canal. These potential impacts have been considered against the matters listed in clause 228 of the Environmental Planning and Assessment Regulation 2000 (EP&A Regulation) and are summarised in Appendix A of this REF. 1.4 Stakeholder and community consultation A Community and Stakeholder Engagement Plan (CSEP) has been implemented for the project to maintain relationships with and provide information to the community and key stakeholders. Stakeholders engaged during the planning of the project include government departments and agencies, businesses, residents, road users, utilities, The Metropolitan Local Aboriginal Land Council, developers and transport operators. Sydney Water have continued to liaise with these groups throughout construction. These stakeholders and the wider community are invited to comment on this REF Addendum. Information about the proposal and an invitation to comment on the REF Addendum will be made available via: community newsletter Sydney Water Talk (sydneywatertalk.com.au) - a Sydney Water website used to engage communities and encourage dialogue Issues raised during consultation Following the proposed community engagement activities listed in Section 1.4, any issues raised during consultation will be addressed. 6

7 2. Legislation and planning context 2.1 Environmental Planning and Assessment Act 1979 The NSW Environmental Planning and Assessment Act 1979 (EP&A Act) and its associated regulations provide the framework for assessing environmental impacts and determining planning approvals for developments and activities in NSW. The EP&A Act also establishes State Environmental Planning Policies (SEPPs) and Local Environmental Plans (LEPs) which may include relevant provisions. Under the EP&A Act, Sydney Water is classified as a proponent and a determining authority (under Part 5 of the Act). A project can be assessed by a determining authority under Part 5 of the Act if it: may be carried out without development consent is not a prohibited development is carried out, or approved, by a determining authority. The restoration works do not require development consent under Part 4 of the EP&A Act, and are not classified as State Significant Infrastructure under Part 5.1. Therefore, the proposal has been assessed under Part 5 of the EP&A Act. This REF Addendum has been prepared to determine if the proposal is likely to have a significant impact on the environment. If a determining authority decides an activity is likely to significantly affect the environment, it must prepare an environmental impact statement (EIS). The proposed work is unlikely to have a significant impact on the environment or a threatened species, population or ecological community, and is not on land that is critical habitat. Therefore an EIS, or SIS, is not required. Clause 228 of the EP&A Regulation lists factors that must be taken into account when considering the likely impact of an activity on the environment. Appendix A includes a consideration of these factors for the proposal. 2.2 Other Legislation The statutory planning context of the project was considered in Chapter 2 of the 2014 REF. Statutory planning considerations for the proposal considered in this REF Addendum are summarised in Table Local council approvals/liaison City of Sydney is a member of the Alliance delivering these works and has been consulted extensively regarding the proposed restoration works. City of Sydney s identification of the corridor for future use as a cycleway and footpath is one of the main drivers for this proposal. 7

8 Table 2: Statutory planning consideration Legislation and policy State Environmental Planning Policy (Infrastructure) 2007 (ISEPP) State Environmental Planning Policy 33 Hazardous and Offensive Development (SEPP 33) Sydney Local Environment Plan 2012 and South Sydney Local Environment Plan 1998 Sydney Local Environment Plan (Green Square Town Centre) 2013 Sydney Local Environment Plan (Green Square Town Centre Stage 2) 2013 National Parks and Wildlife Act 1974 Threatened Species Conservation Act 1995 Contaminated Land Management Act 1997 Impact of proposed changes The proposed change does not alter the project s permissibility without consent. The work is permissible without consent under the ISEPP. It represents restoration work required as part of the Green Square Stormwater Drain Project. Also, development for the purposes of pedestrian and cyclist facilities is exempt development (under ISEPP clause 97) if it is carried out by, or on behalf of, a public authority in connection with a road or road infrastructure facilities. The proposed change does not alter the project to an extent that would cause SEPP 33 to be applicable. As outlined in relation to the ISEPP above, the proposal is permitted without consent. The proposal does not alter the role the stormwater drain will provide in supporting the existing land-use objective of the Green Square Town Centre. The proposal does not alter the role the stormwater drain will provide in supporting the existing land-use objective of the Green Square Town Centre. An Aboriginal heritage assessment for the project was conducted in the 2014 REF. The proposal is contained within the study area assessed in the 2014 REF. The potential for any threatened or endangered species impacts was assessed in the 2014 REF. The proposal falls within the site assessed in the 2014 REF. Environmental management measures for dealing with potential contamination at the site were assessed in the 2014 REF. The proposal falls within the site assessed in the 2014 REF. Heritage Act 1977 No additional impact on heritage items has been identified (see Section 5.3). Noxious Weeds Act 1993 Water Management Act 2000 and Water Act 1912 Protection of the Environment Operations Act 1997 Roads Act 1993 Waste Avoidance and Resource Recovery Act 2001 Environment Protection and Biodiversity Conservation Act 1999 (Commonwealth) National Greenhouse and Energy Reporting Act 2007 Environmental control measures to minimise the potential impacts of weeds were considered in the 2014 REF. The proposal falls within the site assessed in the 2014 REF. The project is currently operating under a number of groundwater access licenses issued under the Water Act. The existing licensing arrangements are applicable to the proposal. The project is not listed as a scheduled activity or development under this Act. The proposal does not alter this. The proposal would not alter traffic impacts and impacts to the roadway itself. The project is currently implementing the resource management hierarchy principles of avoid, recover and dispose. Section 5.2 provides further details on waste management for the proposal. An assessment of potential environmental constraints (conducted for the 2014 REF) indicates that the work associated with the proposed change would not likely have a significant impact on matters of NES as listed under this Act. This means that the project (including the proposed change) does not need to be referred to the Commonwealth Department of Environment and Energy. The proposal falls within the site assessed in the 2014 REF. It does not alter the potential impacts of matters of NES. Greenhouse gas emission and energy use related to construction of the proposed change will be reported by Sydney Water in accordance with this Act. 8

9 3. Alternatives and justification for the proposed change 3.1 Proposal need The Green Square Town Centre is one of the City of Sydney s proposed key urban renewal precincts. Once fully developed, it will provide for future housing, retailing, public domain and community facilities. It is on a flood plain and experiences major flooding in wet weather at low points in the area. Urbanisation has dramatically altered the drainage within the Green Square catchment. The Green Square Stormwater Drain project will deliver a stormwater drainage system to reduce the risk of flooding in Green Square. City of Sydney and Sydney Water s objective for flood management in the GSTC is to: reduce the risk of flooding to the future community of GSTC from flooding in both Joynton Avenue and Botany Road; achieve zero or minimal ponding at Joynton Avenue in a 20 year Annual Recurrence Interval (ARI) flood event; significantly reduce ponding at both Joynton Avenue and Botany Road in a 100 year ARI event; and manage the flood risk at the Epsom Park Precinct and the Mid-block Precinct by capturing and transferring a 20 year ARI pipe flow from these future developments. Restoration and installation of a cycleway in the corridor next to the new drain between Maddox Street and Alexandra Canal is an ancillary activity and does not adversely impact the objectives of the stormwater system. It is consistent with one of Sydney Water s principal objectives as a Corporation (Sydney Water Act, 1994) 21 (1)(a)(iii) to exhibit a sense of social responsibility by having regard to the interests of the community in which it operates. 3.2 Alternatives and their assessment Alternatives were considered to the proposed restoration and installation of a cycleway, these included: return back to a grassed surface; soft landscaping; and concrete surfacing. The proposal was selected as the preferred option as it represents best option in terms of increasing the potential value of the corridor for the community. 9

10 3.3 Consideration of proposal against principles of Ecologically Sustainable Development The most common and broadest definition of Ecologically Sustainable Development (ESD) is development that improves the quality of life, both now and in the future, in a way that maintains the ecological processes on which life depends (Environment Australia, 1992). The proposal must be considered in accordance with the four principles of ESD as outlined in section 6(2) of the Protection of the Environment Administration Act 1991 and Schedule 2 of the EP&A Regulation. These principles are described below: The precautionary principle - if there are threats of serious or irreversible damage to the environment, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation. Inter-generational equity - the present generation should ensure that the health, diversity and productivity of the environment are maintained or enhanced for the benefit of future generations. Conservation of biological diversity and ecological integrity - these are fundamental considerations to the sustainability of development. Improved valuation, pricing and incentive mechanisms - that users pay for their products or services including their full life-cycle impacts and cost-effective market mechanisms to attribute externalities should be implemented. Sydney Water and City of Sydney have incorporated, and will continue to incorporate, the principles of ESD into all stages of the project, from conception to operation and development. We selected the preferred option, based on increasing the potential value of the corridor for the community, which is consistent with the principles of ESD: community amenity sustainability encourages alternative transport modes 10

11 4. Description of the proposed work and activities 4.1 Scope of work The proposed scope of work provides for restoration of the corridor adjacent to the new stormwater drain between Maddox Street and Alexandra Canal. This corridor is currently a grassed slope that is fenced to prevent access. Restoration of the area between the new drain and the adjacent properties would include a installing a concrete pathway, fencing, lighting and soft landscaping within the approximately 4 metre wide corridor. The pathway would provide for maintenance access to the drain and would be suitable for future use as a footpath and cycleway. 4.2 Proposed activities The restoration works occur as an integrated part of the construction of the drain through the corridor and as such would include: installation of traffic and environmental controls; relocation of services; minor excavation; preparation of subgrade and installation of concrete slab; stockpiling and other ancillary activities; landscaping and planting; and installation of lighting and fencing. The path would be supported by the drain s piling wall and capping beam. Soft landscaping would consist of vegetation chosen by City of Sydney and installed within garden beds along the corridor. 4.3 Workforce and timeframe These works would be conducted as part of the overall GSSD project being delivered by the DG Alliance. The overall workforce of the Alliance consists of up to 100 workers, varying depending on current construction activities. Activities associated with the restoration in the area would take 3 months to complete with the works to be completed by April Changes to the scope of work If the scope of work or construction methods described in this document change significantly, supplementary environmental impact assessment must be prepared for the amended components in accordance with Sydney Water s Environmental Impact Assessment and Approval Pathway Procedure (SWEMS0019). 11

12 Subject Area proposed cycleway Figure 1 Green Square Stormwater Drain Project and Proposed Cycleway 12

13 5. Existing environment, potential impacts and measures The construction location or footprint of the proposal is within the project area as assessed in the 2014 REF. The following sections consider any impacts additional to those assessed in the 2014 REF. 5.1 Noise The subject corridor is located within a highly developed area. Day-time noise is characterised by traffic noise and noise from surrounding industrial and commercial sites. The construction noise and vibration impact assessment conducted for the original REF monitored ambient noise at 18 Huntley Street, identifying the following background noise levels (RBLs) for the nearest residential catchment area: 56 db(a), day-time; 46 db(a), evening; and 36 db(a), night-time. The corresponding noise management levels (NMLs) in accordance with the Interim Construction Noise Guideline (DECC 2009) (ICNG) are: 66 db(a), day-time (L Aeq ); 51 db(a), evening(l Aeq ); and 41 db(a), night-time (L Aeq ). The day-time highly noise affected level is 75dB(A) (L Aeq ). NMLs (external noise levels for commercial and industrial premises) are 70 and 75 db(a) (L Aeq ) respectively. Impacts and environmental measures The noise and vibration assessment conducted for the 2014 REF identified no residential receivers in the vicinity of the subject area where NMLs would be exceeded during construction either at day or night-time. It did however identify a number of adjacent industrial and commercial properties where NMLs would likely be exceeded during the day. The proposed restoration works are likely to have less noise and vibration impacts compared to the construction of the stormwater drain at this location, and those anticipated in the 2014 REF. The necessary construction activities are consistent with those proposed in the 2014 REF. Similarly, vibration levels would be consistent. The noise and vibration mitigation measures identified in the REF would be implemented and are considered sufficient to mitigate the noise and vibration impacts associated with these works. Noise and vibration from the proposed restoration works would not have a significant impact. 5.2 Waste management The proposed restoration works would generate additional waste in comparison to restoration involving vegetation (turfing) only. 13

14 The majority of this waste would be concrete and steel and would be suitable for recycling. The waste mitigation measures identified in the 2014 REF would appropriately manage this waste. The construction team would ensure that all material suitable for recycling would be sent to a suitable facility. Increased waste volumes from the proposed works would therefore not have a significant impact. 5.3 Heritage Aboriginal and non-aboriginal The 2014 REF did not identify any Aboriginal sites within the corridor of land between the existing stormwater drain and the adjacent buildings. Similarly, it did not identify any significant non- Aboriginal sites within this area. The site is not identified as an area of non-aboriginal heritage sensitivity. The existing stormwater drain itself is not listed, however, Alexandra Canal is listed on the State Heritage Register. The project has a Section 57(2) exemption under the Heritage Act, 1997 for works impacting the canal in place. There is also a Section 139(4) Exemption in place covering the entire GSSD project. The proposed restoration would not have any adverse heritage impacts and the proposal would not impact heritage items. The restoration works would not impact Alexandra Canal itself and the remaining works are covered by a Section 139(4) Exemption. No additional mitigation measures are required for these works. 5.4 Traffic and access A partial road closure is currently in place for Huntley Street and traffic control would continue to be required for the proposed works. Extensive traffic assessment and modelling was undertaken in the 2014 REF which found that there was adequate capacity within the local road network to accommodate partial and complete road closures during the construction of the GSSD. As the construction location or footprint has not been altered, traffic impacts are not likely to be any greater than those identified and mitigated in the 2014 REF. Pedestrians and cyclists During the partial closure of Huntley Street, pedestrians would be limited to one side of Huntley Street. As Huntley Street is not a dedicated cycleway or a cycle friendly route, cyclists would be subject to the same traffic control as vehicles. Mitigation strategy The partial road closure of Huntley Street would require traffic controls to be implemented for the duration of the restoration works. Provision would be made to accommodate continued vehicle access to properties along Huntley Street that do not have alternative access. Traffic control plans would be prepared to manage the proposed works and would be subject to relevant authority approval. The plans would adopt the recommendations in the revised traffic assessment and requirements from Council and Roads and Maritime Services (RMS). Works requiring road closures would be subject to prior approval for road occupancy licences and speed zone authorisations. As discussed in Section 1.4 consultation actions are being undertaken to provide advanced notice of upcoming works to the community and to provide guidance to drivers, pedestrians and cyclists in the vicinity of the worksites and on access routes. During construction, ongoing consultation with the community would be undertaken to ensure that timely information regarding the works is provided. 14

15 5.5 Social and visual Social and visual impacts would be positive. The existing area is currently unsightly and unused (refer to Figure 2). When complete the visual amenity of the area would be significantly improved (refer to Figures 3 and 4) and the corridor would be accessible for the community, which would benefit local businesses. Visual impacts during construction would be temporary and mitigated through community notification, effective housekeeping at the construction site, timely repairs of any damage and quick and effective restoration of the site once works are completed. 5.6 Geology and soils The existing area is currently a highly disturbed and developed environment. The corridor is highly modified, and would be further modified by the GSSD works which have been assessed and mitigated within the 2014 REF and CEMP for the project. As the restoration of the corridor is within the existing construction footprint, no additional impacts are expected. As such, no further assessment or mitigation measures are required. 5.7 Flora and fauna As previously noted, the corridor is highly disturbed and does not provide high value habitat for any flora or fauna. The 2014 REF assessed the impact of the works on flora and fauna and it was found that there would be no significant impact. The proposed landscaping would reduce weed infestations in the corridor and provide improved habitat for transient fauna. 5.8 Air and energy Minor, short term impacts to local air quality were identified in the 2014 REF. The impacts, as assessed in the 2014 REF, are anticipated to be the same as the proposal does not alter the construction location or footprint. The air quality and energy mitigation measures in the existing CEMP would be implemented for the restoration works. 5.9 Water and drainage The proposal is within the existing construction footprint, in the Shea s Creek stormwater catchment. The drainage impacts of the project were assessed to have positive outcomes in the 2014 REF by providing improved drainage and reduce the risk of flooding in Green Square. The impact assessment in the 2014 REF is valid for this proposal as it is within the existing construction footprint, and the controls to manage water quality impacts that were identified. Noadditional impacts are anticipated Cumulative impact The Green Square development is a large urban renewal project that is progressively changing the character and land use of Green Square. While there is significant construction works within the area east of Bourke Road, there is little construction activity near the corridor adjacent to the proposed path location between Maddox Street and the head of Alexandra Canal. Construction works associated with the pathway would not represent any significant additional impacts over the normal construction activities for the stormwater drain. The future long-term positive impacts (both of the new shared path and the stormwater project as a whole) are considered to outweigh the temporary cumulative impacts that may occur during the construction period. 15

16 Figure 2 Existing corridor Figure 3 Indicative restoration proposed (Note: details may change during finalisation of design) 16

17 Figure 4 Indicative restoration proposed (Note: details may change during finalisation of design) 17

18 6. Environmental management The proposed works would be conducted in accordance with the current Construction Environmental Management Plan (CEMP) for the Green Square Stormwater Drain Project. No mitigation measures in addition to those already in place for the overall GSSD project were identified. Project-wide mitigation measures would be implemented as required by the CEMP and an Environmental Work Method Statement covering the construction works within the corridor would be developed and implemented. Landscape plans for the proposed works have been produced and would be finalised prior to works commencing. 18

19 7. Conclusion Sydney Water and City of Sydney have developed the Green Square Stormwater Drain project to achieve the following objectives: reduce the flood risk to the future community of Green Square Town Centre from flooding at both Joynton Avenue and Botany Road; achieve zero or minimal ponding at Joynton Avenue in a 20 year ARI flood event; significantly reduce ponding at both Joynton Avenue and Botany Road in a 100 year ARI event; and manage the flood risk at the Epsom Park Precinct and the Mid-block Precinct by capturing and transferring a 20 year ARI pipe flow from these future developments. This REF Addendum has assessed potential impacts associated with the additional proposed works to restore the corridor adjacent to the new stormwater drain between Maddox Street and Alexandra Canal. Restoration of the corridor would include fencing, plantings, lighting and a concrete pathway suitable for maintenance access and future use as a cycleway and footpath. There would be construction impacts from the proposal, however they would not exceed those identified in the original REF. Given the nature, scale and extent of impacts, the proposed restoration would not result in the overall project having a significant impact on the environment. The overall project will result in positive long-term effects. Accordingly, an environmental impact statement under part 5.1 of the EP&A Act is not required. 19

20 8. References Sydney Water (2014) Review of Environmental Factors Green Square Stormwater Drain. Sydney Water (2014) Decision Report Green Square Stormwater Drain. Sydney Water (2016) Review of Environmental Factors Addendum Green Square Stormwater Drain Huntley Street Crossing.

21 Appendix A Clause 228 summary In the context of clause 228 of the Environmental Planning and Assessment Regulation 2000, consideration of the likely impact on the environment of the proposed work is summarised below. Clause 228 factor Any environmental impact on a community A transformation of a locality Any environmental impact on the ecosystem of the locality Any reduction of the aesthetic, recreational, scientific or other environmental quality or value of the locality REF finding Impacts associated with construction may include noise, dust and traffic. These impacts may temporarily affect the local community. We would minimise environmental impacts on the community by implementing the mitigation measures identified in the 2014 REF. Where stakeholder consultation identifies additional measures, these would be implemented where practical. The restoration works would improve the aesthetics and future recreational value of the land. The subject area is a highly disturbed urban area characterised by commercial and industrial development. The restoration works are unlikely to have a significant environmental impact. The restoration works would improve the potential recreational quality of the location while not adversely impacting it s scientific or environmental quality Any effect upon a locality, place or building having aesthetic, anthropological, archaeological, architectural, cultural, historical, scientific or social significance or any other special value for present or future generations Any impact on the habitat of any protected fauna (within the meaning of Section 98 of the National Parks and Wildlife Act 1974) The proposed restoration works will not affect identified areas of archaeological potential. It will not affect any locality, place or building having aesthetic, anthropological, archaeological, architectural, cultural, historical, scientific or social significance or other special value for present or future generations. The proposed site restoration is unlikely to impact on protected species or their habitat. Any endangering of any species of animal or plant or other form of life, whether living on land, in water or in the air Any long-term effects on the environment Any degradation of the quality of the environment Any risk to the safety of the environment Any reduction in the range of beneficial uses of the environment The restoration works would not endanger any species of animal, plant or other life form, whether living on land, in water or in the air. The project would result in positive long-term effects in the locality by improving the aesthetics of the corridor and increasing the recreational value of the locality To prevent any degradation of the environment, mitigation measures are an integral part of the project. The project s CEMP incorporates safeguards to minimise any site-specific environmental impacts of the project. The mitigation measures in the project s CEMP serve to minimise risk to the safety of the environment. The range of beneficial uses of the environment in the project area will not be significantly affected by the construction of the project. The long-term use of the pathway would improve recreational value and visual amenity, this providing improved beneficial uses.

22 Clause 228 factor Any pollution of the environment Any environmental problems associated with the disposal of waste Any increased demands on resources (natural or otherwise) that are, or are likely to become, in short supply Any cumulative environmental effect with other existing or likely future activities Any impact on coastal processes and coastal hazards, including those under projected climate change conditions REF finding There is potential for temporary impacts to the environment during construction including noise, and dust. There would be no environmental problems associated with waste disposal. We would classify waste materials in accordance with NSW DECCW (2009) Waste Classification Guidelines prior to reuse or disposal. The restoration works would not increase the demands on resources that are, or are likely to become in short supply. There are likely to be some cumulative construction impacts associated with the project given the scale of development occurring around the project at the same time. We would implement the mitigation measures to minimise cumulative impacts from the project. The restoration works would not impact on coastal processes or hazards, including on projected climate change conditions. Completion of the overall project will reduce the frequency of flooding in the locality during high rainfall events.

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