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 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.


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