For renewable energy projects in NSW, detail that is included in assessment reports will be directly reflect in the Development Consent (DC) by way of conditions and requirements. From a traffic and transport perspective there are key elements that will be included:
- Limitations on traffic movements, including heavy vehicles. These are typically by day and peak hour
- Limitations on heavy vehicles requiring escort, which will generally be a total across the construction, operation and decommissioning phases.
- Approved access routes (roads that project traffic must use for access). This can include limitations such as left and right turn restrictions (particularly at key State Road intersections).
- Road upgrade requirements, which generally include intersection requirements and access road upgrades as well as the need for dilapidation surveys.
We’ve seen projects where the way these aspects are managed during the EIS process creates issues post-approval, as follows.
Capped Traffic Volumes
The DC will apply a cap based on the highest traffic generation levels to and from the site from the submitted Traffic Impact Assessment (TIA). We have seen TIA reports where the levels are ‘averaged’ or, worse yet, based on high-level estimates from similar projects – but what they mean is that they are often underestimated. There is no doubt it is difficult to accurately project traffic generation early in a projects development – and there is some similarity between projects – but estimating too low generally means a lengthy Mod process after a construction contractor advises they cannot undertake the project with the traffic limits imposed by the DC (which are based on the TIA). Worse still, more accurate (and higher) traffic volumes may result in increased requirements for road upgrades, with cascading impacts should the works have impacts on biodiversity, visual impacts and the like.
OSOM Vehicles
In our experience, DPHI and relevant agencies will want to see a significant level of detail are around the Oversize/Overmass (OSOM) vehicles to site. In relation to the high-risk OSOM combinations, the expectation is that this would be a route assessment to confirm no external civil works on the route to site. Amber recommends including these assessments as part of the TIA to demonstrate the civil works that would be required to minimise the risk of a future Modification.
Access Routes
Department of Planning, Housing and Infrastructure (DPHI) and relevant agencies will impose restrictions on the travel route to site. Some TIAs will include very generic route(s) to/from site. We know that agencies use conditions to address their concerns post approval. This includes elements like left or right-turn bans, or controls that apply to different vehicle types. At worst, these controls can result in significant detours for access to/from the site which creates challenges for construction and management. We recently saw a project where left and right-turn bans resulted in a trip to site being lengthened by 35 kilometres and passing through a neighbouring town who understandably aren’t thrilled about the impact.
Road Upgrades
Like the access routes to site, agencies and authorities will use the conditions to impose their desired outcome for road upgrades, which doesn’t have to align with that outlined in the TIA. Often, we’ll see road upgrades included in conditions that go above and beyond that outlined in the TIA, generally things like the road sealing or increased road intersection upgrades. Sometimes, these changes can have unintended consequences on other aspects of a development.
Being Prepared is the Best Strategy.
Our approach to set up a project for success is to prepare a TIA that:
- Ensures traffic volumes used in the assessment best reflect the likely construction traffic generation levels. We have developed spreadsheets which we are happy to share to help estimate heavy vehicle traffic generation based on scale of material used. We will always benchmark provided traffic volumes against other projects and our experience, including up to the preparation of TMPs.
- Models the high-risk OSOM vehicle combinations to site early will identify any potential issues. We can include this as part of a TIA and have a growing suite of vehicles ana routes to use for the assessments.
- Undertakes early consultation with TfNSW and relevant local road authorities to ensure that the is agreement of the suitability of road upgrades and access routes. Amber takes a proactive approach with authorities to seek their feedback and address issues early, with an aim to have agreement on the road upgrades and routes in writing.
Undertaking the above means that the risk of Modifications and further projects changes with associated time and cost implications are addressed before approval rather than after.
