No logic to the overlay and GHD contamination report

AFTER studying all the relevant documents relating to the Environmental Audit Overlay for over a month now, I find it a total waste of time and money to conduct Preliminary Risk Site Assessments using the 2016 GHD contamination report.

The normal procedure for a development would be, based on the findings of the contamination report, a Preliminary Risk Site Assessment would be conducted, which is usually a desk top study, drawing on the GHD contamination report, aerial photos and any other local knowledge they can obtain to identify areas of contamination.

The information from the Preliminary Risk Site Assessment would be used to ascertain whether an Environmental Audit is required.

I would think that prior to any earth works commencing the development would be surveyed and areas of potential contamination mapped out and dealt with accordingly.

In the case of most of the land that the EAO has been placed on, these logical steps have not taken place. No assessments were done, earth was dug up for roads and services, blocks levelled and cut, topsoil stock pilled and moved around, possibly moved to other estates rendering a lot of the information in the GHD report useless.

Also, the Wonthaggi North East Precinct Structure plan is the guiding document for the development. Looking at section 3.4 Biodiversity, threatened species and 3.6 Integrated water management and utilities, both have requirements and guidelines that could not have been met without first addressing the issue of potential contamination at the very start of the development.

This logical approach is, however, taking place with the development of 135 blocks at McGibboneys Road Wonthaggi, the most eastern section of the Environmental Overlay. The Preliminary Risk Site Assessment was started on January 23, 2023 and completed on April 12, 2023. The Preliminary Risk Site Assessment has advised that an Environmental Audit be done. It states, Reason for Audit, Planning System Requirement. These documents can be viewed on the EPA website, Environmental Audit and Preliminary Risk Site Assessment Register.

So why was this approach not taken with the rest of the land affected by the Environmental Audit Overlay?

Viewing these documents highlights just how ludicrous and expensive it is to be conducting these assessments on every single titled block rather than one on the whole development, there is definitely an economy of scale at play here.

We have spoken to at least a dozen companies that do Preliminary Risk Site Assessments and Environmental Audits and all are bewildered by what has happened here in Wonthaggi.

Let us hope that logic can produce a satisfactory outcome for all concerned.

Darren Martin, Inverloch