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Action for Public Transport (N.S.W.) Inc.

P O Box K606
Haymarket NSW 1240
1 March 2021


Director, Transport Assessments
Planning and Assessment
Department of Planning, Industry and Environment
Locked Bag 5022
Parramatta NSW 2124
Submitted via website

Submission on SSI-8862

Beaches Link and Gore Hill Freeway Connection EIS

Who we are

Action for Public Transport (NSW) ("APTNSW") is a transport advocacy group active in Sydney since 1974. We promote the interests of beneficiaries of public transport - passengers and the wider community alike.

Key points

Given the lack of success of previous motorways to reduce congestion and improve travel times, it is not sensible to expect a different result in the case of Beaches Link.

In any event, the proposal is at odds with the State's integrated transport and land use plans and with its intention to transition to net zero emissions by 2050.

Many public transport improvements in both urban and regional areas are canvassed in Future Transport 2056, and in other strategic documents, but cannot progress unless funding is made available. They should have priority over a motorway to the Northern Beaches of Sydney.

Discussion

A 2014 NSW Audit Office report1 notes (p.15) that the Westconnex project began with the NSW Government asking Infrastructure NSW (established mid-2011) to provide advice on "Sydney's next motorway priority" as part of its work in developing the State Infrastructure Strategy (SIS). Exactly when and how this request was made is not indicated in the report. Nor is it clear why the request was made, presuming as it does the need for a motorway at all.

The reason may be the one alluded to in a March 2012 report by the National Infrastructure Co-Coordinator2, which stated (p.29) "There have been suggestions that Transurban may present an unsolicited proposal to the NSW Government to develop several motorway links".

The opaque "unsolicited proposals" process that delivered the Westconnex proposal then produced the "Western Harbour Tunnel and Beaches Link".

The proposals have now leapt straight from a "scoping" paper in 2017 to EISs in 2018 and 2020. At no point have the proposals been the subject of a proper process of strategic justification.

We note tolling facilities are to be built in, indicating sale to a toll operator. It is easy to see why a tollway connecting a high-income area to the established CBD and the airport would be an attractive proposition for a tollway operator. How and why the proposition would get this far without proper, open assessment is a mystery worthy of investigation. It would obviate a huge number of long car trips.

The EIS presents the proposal as consistent with the strategic transport plans simply because it is "referenced". APTNSW regards this as a misrepresentation. The list of committed road initiatives on p.77 of the Greater Sydney Services and Infrastructure Plan includes the Western Harbour Tunnel and Beaches Link (subject to Final Business Case) (emphasis added). No "business case" has been produced.

The highest priority identified in integrated transport and land use planning is clearly (and correctly) improving public transport. The Greater Sydney Services and Infrastructure proposes "a coordinated approach to land use, transport and infrastructure" (p.46) and states:

As part of this integrated approach, we will deliver services and infrastructure that enable 30-minute access by public transport (emphasis added):
The Strategy proposes to achieve this by:
... investment in mass transit, improving service frequencies, better prioritising public transport around centres (see Figure 22) and improving walking and cycling connections to public transport.
The government is planning and delivering public transport but most projects are uncommitted and unfunded; motorways are referenced through clenched teeth and "subject to a business case" which has never been published.

The business case for this project should be prepared to the standard that the size of the project would dictate. Four or five pages will not suffice. The case should discuss, inter alia,

It is worth noting that taxes on petrol can't be relied upon as an efficient way of controlling car traffic. A declining proportion of vehicles burn petrol.

Note the unique situation of the Warringah peninsula which can only be reached by using one of just three roads. Installing tolling facilities on Spit Bridge, Roseville Bridge and Mona Vale Rd could easily solve peak hour road congestion in the region at trivial cost.

Also note the unused capacity on the Sydney Metro line which is currently being constructed between Chatswood and Central. There is an obvious opportunity to reduce the need for car travel across Roseville Bridge by building a Warringah Metro. It would branch off at Chatswood, cross Middle Harbour and service trip generators such as Northern Beaches Hospital and Warringah Mall. About 17km of underground track would take it to Collaroy Plateau. While it would cost more to construct than Beaches Link, its effects on the peninsula would be far more beneficial than a motorway would.

For the reasons set out above, the Beaches Link tollway presented in the EIS should be rejected. Alternative plans should be developed which align with government policies to reduce greenhouse emissions and which support a wider view of public transport networks. web counter


Footnotes


1 NSW Auditor-General's Report to Parliament WestConnex: Assurance to the Government
2 National Infrastructure Coordinator March 2012 Report to Minister for Infrastructure on Private Financing Options for Upgrades in Sydney's M5 and F3-M2 Corridors