Action for Public Transport (N.S.W.) Inc.
| ||P O Box K606
| ||Haymarket NSW 1240
| ||1 September 2017
Environmental Impact Assessments
for State Significant projects
Action for Public Transport (NSW) is a transport advocacy group active in Sydney since 1974. We promote the interests of beneficiaries of public transport; both passengers, and the wider community. We make this submission on the review opened under project numbers 8452 8454 8455 8456 8457 8458 8459 8461 and 8462.
APTNSW is concerned that some projects are being approved that would not be if environmental assessment were done optimally. For road projects, the adverse effects of generated traffic are often ignored and/or denied in the EA process.
Transport planning as practised in New South Wales has some fundamental flaws which prevent the best results being achieved.
One obvious problem is that transport planners have no incentive to recommend minor improvements to existing works, even if they are better value. Another problem is lack of a common aim between the separate ministries involved - transport, roads and planning. The whole transport planning system is based on contrary policies, one of which is to develop public transport around Sydney (which tends to increase densities) and another is to build a network of motorways which tends to create a dispersed pattern of development. A third problem is that the myth that more road space reduces congestion persists, even though Sydney's roads have been suffering worsening congestion for fifty years despite dramatic increases in road space.
The environmental impact assessment process, which is only a late stage of the planning for important projects, was introduced under the Wran government. It was heralded as a world first. It was intended to minimise any environmental damage that large projects might cause; it was probably not intended to be the only brake on such projects. Very few projects have been stopped at the EIS stage. Unfortunately, several factors have reduced the power of the EIA process to limit environmental damage:
For a closer look at just one project whose assessment exhibits many of the issues listed above, the New M5 segment of Westconnex, see http://aptnsw.org.au/documents/new_m5_eis.html.
- The rise of the unsolicited proposal. Governments seem reluctant to look a gift horse in the mouth. Yet such gifts might be packaged with undesirable features which should outweigh any value of the gift. An obvious example is the tollroad network which is imposing significant costs on government for additional roadwork in response to the extra traffic. We refer to the Alexandria - Moore Park Connectivity Upgrade, which is obviously prompted by Westconnex traffic. See our submission at http://aptnsw.org.au/documents/a2mp_submission.html.
- The large amounts of money which tenderers spend on preparing their bids to construct projects. Governments are reluctant to reconsider projects that have received significant investment from any source, even when an EIS shows that is clearly called for. This bias seems likely to skew the determination in favour of, for example, the Western Harbour Tunnel and Beaches Link projects.
- Withholding of pertinent details as "commercial in confidence" or "cabinet in confidence", meaning that the public is unable to use those details in raising environmental issues. There have been many recent examples where the detailed business case for a project was not released, yet the public was supposed to accept reassurance that benefits outweighed costs.
- Skilled marketing of projects, boosted by a common but childish belief that large or expensive projects must necessarily have great benefits. This theory is easily debunked by one example - the Albert (Tibby) Cotter footbridge, which cost more than $25 million to construct and is ugly and devoid of useful benefits. Unfortunately, the belief persists.
- Ignoring induced traffic. The private consortia which back expansion of Sydney's tollway roads rely on a growth in traffic levels in response to the extra capacity provided. They are never disappointed for long. However, the reduction in traffic congestion which the EIS calculates as a benefit of the project assumes that traffic growth is independent of the project. Consultants who want to recognise induced traffic simply don't get the job of writing the traffic and transport sections of the EIS.
- Deliberate failure to consider alternatives to a project. Even though Schedule 2 to the EP&A Regulations requires feasible alternatives to be assessed, that requirement can readily be bypassed by crafting project objectives so tight that alternatives are artificially eliminated. Meanwhile, the Sydney Morning Herald of 15 June 2017 cited a cabinet directive not to consider public transport alternatives to the [F6] motorway including a rail option that would cut the time taken to travel from Wollongong to Central by train from 90 minutes to little more than one hour.
- Dismissive treatment of inconvenient issues raised in EIS submissions. Large quantities of dissenting submissions are simply ignored. For example, the M4-East round of Westconnex submissions included over four thousand objections. Yet the project was commenced as planned. Another example is the CBD&S-E light rail project. About 40 submissions asserted that the system would not have enough capacity to meet peak-hour demand. That was based on 48-metre trams. The review of submissions simply replied that capacity would be adequate. Even though the vehicles were subsequently lengthened to 67 metres, it is now accepted that the vehicles will have over 4 standing passengers per square metre of floor space in peak hour. The recently-reported surge in patronage on the inner west light rail service shows how popular light rail is with passengers. The problem should have been ameliorated then by designing extra capacity into the system, e.g. a line to Green Square, Redfern station and perhaps Darlington. Other possible northern termini exist that would increase light rail capacity.
- Ignoring the close link between transport planning and land-use planning. Even though this link has been recognised for decades, we still see developments approved without adequate transport. An obvious example is The Bays, whose deficiencies famously came to public attention when Google cited lack of public transport as a reason for not relocating there. Other examples can be found along Parramatta Road and at Erskineville, where the Ashmore estate will double the local population with no increase in public transport capacity.
- Special legislation enabling particular projects to bypass the EP&A Act's assessment process. An early example is section 10 of the Sydney Harbour Tunnel (Private Joint Venture) Act 1987.
The environmental impact assessment process is not doing its job. Substantial changes should be made to it, not only to force the recognition of all impacts whether convenient or not, but also to ensure that an EIS is not simply about attempts at mitigation. The EIS should provide an opportunity to ensure that a bad project does not proceed. In particular, submission reviews should be done fairly. After the review, the determination process should not be a mere formality. All parties should recognise that state significant projects around Sydney aren't just building a road or a school; they are building an important city.
- Ensure that induced traffic is recognised in EISs.
- Ensure that alternatives are genuinely considered.
- Let it be known that EISs can and will stop bad projects, including unsolicited proposals, regardless of any investment they might then have received.
- Even after EIS submissions are reviewed by the proponent, hold the determining authority responsible for the quality of the EIS, for the proper review of submissions and for ensuring that all matters raised in submissions are dealt with.