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| Action for Public Transport (N.S.W.) Inc. |
| P O Box K606 |
| Haymarket NSW 1240 |
| 16 August 2015 |
Action for Public Transport NSW is a transport consumer group, established in 1974. Our funds derive almost entirely from membership fees. Our members are users and beneficiaries of public transport.
Our key concerns are the systematic bias against public transport investment in current evaluation and assessment techniques, and the baffling policy decision of the Federal Government not to fund public transport.
Our submission is that a quantum leap in the availability and frequency of public transport is the key to accommodating increased population without damaging the quality of life of Australians, and degrading our environment.
Legitimate expectations and strategic aims
1. Australians expect their infrastructure networks to support a high quality, first world standard of living. They expect infrastructure to improve their quality of life in the future, notwithstanding significant population growth and major economic, social and environmental change.
3. Infrastructure exists to provide services …
We are pleased that IA has included in its base information a survey of what Australians expect infrastructure networks to deliver, and that it sees a need for greater community consultation on infrastructure decisions.
We note also your observation that all governments and most organisations are aiming to maintain and, if possible, improve Australians' “quality of life”. Your summary is that they are looking to pursue the following broad aspirations:
There is room for debate about whether continuing growth of the Australian economy is per se a “quality of life” aspiration; but we will assume for the moment that it is meant as some form of proxy for full employment, which clearly is central to quality of life and life prospects.
People do not usually travel for the sake of moving. They do so to access employment, education, goods, services, and social connections. None of these things should be conditional on a driver’s licence and a car, and yet this is the situation we have allowed to develop in many parts of Australia, even in parts of its biggest cities.
The focus of transport infrastructure and service planning needs to shift from mobility to access.
We think it is critically important that these legitimate expectations and strategic aims are kept in mind at all times in the development of a 15 year infrastructure plan. It is very easy to be misled by decision-making models that cannot cope with the important things that add up to quality of life: access to employment and education, social equity and inclusion, and a healthy environment.
Predictions and assumptions
6. Population growth will drive a significant rise in the demand for infrastructure services. On medium level projections, Australia’s population is projected to grow from 22.3 million in 2011 to 30.5 million in 2031 − an increase of 8.2 million or 36.5 per cent.
Furthermore, the audit refers to ABS medium level projections suggesting that:
Over the period to 2061, Australia’s population could grow to 41.5 million, with the combined capital cities' population growing to 30.5 million(p.22).
The prediction of rapid and significant population growth made throughout the audit needs careful consideration and explanation. We realise that IA is using ABS (and other) official forecasts, but it should be made clear that all such forecasts rest on assumptions, including assumptions about decisions yet to be taken.
In this case the assumption is that successive governments will decide to maintain this level and speed of growth regardless of whether a plausible plan for infrastructure provision emerges from IA's current deliberations, and regardless of environmental issues such as the one noted in audit finding number 41:
41. The projected decrease in rainfall (and the associated increasing exposure to severe drought) in the heavily populated southern parts of Australia presents significant challenges for the water sector.
Such an assumption is unfortunate and questionable. Governments in fact retain the flexibility to make different decisions, and may well do so if they conclude that the consequences of such rapid growth would be unmanageable and/or unaffordable. There needs to be a feedback loop; decisions on infrastructure and population growth should be integrated and iterative, and they need to acknowledge the looming threat of climate change.
Predict and provide approach
48. Demand for urban transport infrastructure is projected to increase significantly. The cost of congestion in our capital cities, estimated at $13.7 billion in 2011, is expected to increase to around $53.3 billion in 2031, or around 290 per cent, in the absence of additional capacity and/or demand management.
49. Demand for many key urban road and rail corridors is projected to significantly exceed current capacity by 2031.
51. The national land freight task is expected to grow by 80 per cent between 2011 and 2031, with a large component of this task expected to be handled by road freight vehicles.
52. Accommodating this growth will require a focus on policy reform to enable the wider use of higher productivity heavy vehicles (such as B-triples), and selected investment ….
58. Demand for airport infrastructure is projected to approximately double between 2011 and 2031.
59. Australia's 10 busiest airports handle more than 80 per cent of total passenger traffic. Over the next 15 years, additional capacity will be required in Sydney, Brisbane, Perth and Melbourne.
The central approach taken in the Audit can be described as “predict and provide”. This is exemplified in the statement on p. 14 that the transport modeling undertaken for the Audit is “intended to clearly show where transport demand is projected to grow in excess of supply”.
The “predict and provide” approach has serious flaws in the case of urban roads and we urge IA to undertake a serious reconsideration before it produces a 15-year plan built on this approach.
We are pleased to see the recognition in audit finding 48 of demand management as a possible alternative to additional capacity. All the road building undertaken in cities at enormous expense for more years than we care to count has failed to “solve” the problem of traffic congestion. Some might argue that population growth accounts for this, but that is only partly true. The fundamental problem, as many have pointed out, is a persistent failure to acknowledge the reality of induced traffic.
Traffic is not like water; it is a huge mistake to apply hydraulic principles to transport planning. The act of providing additional road space increases the demand it was aiming to accommodate, that is, it increases vehicle kilometres travelled (VKT), leading to endless demands for still more road space, at the expense of other uses, like homes, businesses and parks. This self-defeating and wasteful exercise has detrimental effects on the functioning of Australian cities and on their productivity.
Public transport services on the other hand are far less land hungry, and can accommodate additional travel needs without increasing VKT.
A second issue is the mode specificity inherent in findings 51, 52, 58 and 59. Increased freight movement is said to require communities and ordinary motorists to co-exist with B-triples. A projected rise in “air traffic” is said to require additional airport capacity. These findings contain an inbuilt assumption that the trips in question should be accommodated by that particular mode.
We suggest that it is dangerous and environmentally damaging to accommodate still heavier “road trains” and that the focus should be on actual trains. We agree with audit finding 54 which says:
Freight rail will need to play a growing role in the movement of goods between ports and inland freight terminals, and in the movement of containerised and general freight over longer distances.
We suggest that fast train services are a far better way to accommodate much of the additional “air traffic” forecast in audit finding 59, with positive consequences for regional centres along the route. Specifically, high-speed rail along the east coast of Australia can better meet much of the demand for air travel between Sydney, Canberra, Melbourne, and in due course Brisbane.
Increasing our reliance on fossil fuels and remaining dependent on imported oil is a questionable strategy for the future, as audit findings 40, 44, 45 and 68 acknowledge.
Project Evaluation
11. Infrastructure decision-making must place a high priority on productivity growth. This can only be achieved through efficient management of existing infrastructure, rigorous and disciplined evaluation of investment initiatives, and efficient delivery of new projects.
18. Improvements in long-term infrastructure planning, project appraisal and project selection (including the consistent use and transparent reporting of cost−benefit analyses) are necessary if Australians’ expectations are to be realised.
22. Post-completion reviews are not regularly undertaken for infrastructure projects, limiting the opportunities for governments and others to learn from mistakes and successes. This is to the detriment of current and future decision-making processes.
24. Environmental considerations should form a fundamental aspect of infrastructure project selection and planning processes.
35. Access to transport remains a critical social equity consideration, particularly for the outer suburbs of Australia’s cities and most parts of regional Australia. These areas generally have an undersupply of transport services (especially public transport) and of local employment options.
It would be difficult not to agree that improvements in long-term infrastructure planning, project appraisal and project selection are needed. Lobbying by vested interests is certainly not a good basis for infrastructure decisions; nor is pork-barreling. APT (NSW) is however becoming increasingly concerned about the level of faith placed in cost-benefit analysis. Tempting though it may be to seek a single ratio to sum up all the consequences of a government decision, the temptation needs to be resisted.
Cost-benefit analysis is sometimes misdescribed as “evidence-based”. It is however a technique based on inputs and assumptions. True evidence-based decisions focus on consequences. As findings 21 and 22 suggest, post-completion reviews are sorely lacking. One thing we do know is that expensive and destructive urban motorways built on the basis that they will reduce traffic congestion have done no such thing; yet Sydney has embarked on the Westconnex project expecting it to reduce congestion.
APT (NSW) understands that Westconnex was born of a desire to build a freight-only road from the Western Suburbs to Port Botany. That project could not, it seems, demonstrate a favourable cost-benefit ratio. The addition of commuter car traffic and a refocusing of the route on the established CBD managed to (barely) produce the coveted number. If it is indeed the case that the benefit-cost ratio improved as the project got worse for Sydney, there is a grotesque flaw in this methodology.
We suspect that finding number 18 may be hinting that IA is well aware of the limitations of cost-benefit analysis; we have previously noted that IA has tried to capture the benefits of agglomeration (co-location of mutually supportive activities in a central location)1 in cost-benefit analyses.
In essence it seems that cost-benefit analysis is prone to produce perverse results in the context of transport planning, because it cannot or will not account properly for social and environmental factors. For example, the cost-benefit analysis used by IPART to determine fares does not include consideration of benefits most people probably assume would be considered, such as the health impacts of creating car-dependent communities2.
Findings number 24 and 35 recognise that environmental and social impacts are relevant to infrastructure decisions, but they are largely ignored in cost-benefit analysis of transport projects.
Cost-benefit analysis also consciously ignores the question of who gets the benefits and who pays the costs. Most of the costs might fall on one group, and most of the benefits on another. Reverse the situation entirely, and the ratio will be unaffected. Yet the consequences of the decision are in reality very different.
The consequence is systematic bias against public transport in general and public transport in areas of greatest need in particular.
Transport planning is land use planning
16. Australia needs integrated infrastructure and land-use planning, across all levels of government. Progress has been slow in securing the efficiency and service delivery benefits of strategic decision making.
21. An improved framework is required to protect corridors for transport and other linear infrastructure. The failure to protect corridors can lead to significantly higher construction costs, making otherwise beneficial projects uneconomic.
50. Urban transport decisions need to complement land use decisions (especially about the supply and affordability of housing). Although some improvements have been made in this area, there remains a risk that community resistance to land use change and higher densities will undermine the economic, social and environmental benefits of investment in urban transport.
The call for integrated land use and transport planning has been made for many years, but APT (NSW) suggests that Jim Betts, CEO of Infrastructure NSW and former Secretary of the Department of Transport in Victoria, may be even closer to the mark. At an ADC Forum on Infrastructure in Sydney (March 2014) he reportedly said: “Transport planning is land use planning”.
The American suburban paradigm that took hold in the middle of the last century certainly matches that description. Litman notes that increased urban roadway capacity is likely to stimulate low-density, urban-fringe, automobile dependent development patterns, while other types of transport improvements usually result in more infill and clustered land use, and can increase travel options for non-drivers3.
The suburbs built from the 1950s right up to the present day have been car-dependent; they were planned that way from the outset. Well-resourced road agencies produced road plans, and these were then faithfully reproduced in the land use “plan”. If public transport was thought about at all, it was it seems assumed that services would materialise as the population grew. They didn’t, of course.
Inadequate attention to public transport contributes to high levels of unemployment in the West and South West of Sydney, significant health problems and a loss of productivity4. The timely construction of the Leppington rail line before residents move in to the new Leppington Precinct indicates a shift towards recognising public transport as essential infrastructure along with roads, water and sewerage. We hope this represents a new paradigm for urban development in Sydney5 and that IA recognises the wisdom of this approach in its forthcoming plan.
One of the key questions in integrating transport planning and land use planning is the idea of “containment”, namely that jobs can be moved to follow the population and that workers can and will take the job closest to their home. This would lead to lower VKTs and shorter commute times. That is not what happens in practice.
The better approach is to connect growing suburbs to clusters of higher order jobs, in locations that are highly accessible by public transport. The same is true of opportunities to attain the higher levels of skills and education required for the jobs of the future6. The completion of a rail link between Parramatta and Epping is for this reason urgently needed.
Centres policies (concentrating activity in well-serviced centres) are a classic example of integrated land use and transport planning, which APT NSW fully supports. As a productivity issue, jobs that can be accessed by public transport are a good way to address high rates of unemployment and disengagement from the workforce. Services to central points can be, and usually are, more frequent and direct. APT NSW has made a submission to a recent Senate Inquiry on this subject.7
APTNSW agrees that transport corridors need to be preserved and, we suggest a high priority is the route for a VFT service between Brisbane and Melbourne. As IA recognises, corridor reservation is worth doing even if it may be many years before construction starts.
It is no exaggeration to say that an airport at Badgery’s Creek would now be out of contention (due to houses etc. built on it) if the Federal government had not bought it the site in 1983. That decision is the only reason it is still possible, 30 years later, to build a second airport that was judged premature at the time, but probably necessary in the long term.
Audit finding 50 could be interpreted as a suggestion that in order to justify infrastructure provision, Australians will have to accept a wholesale shift to high-density living; this is turn could be taken as a reference to high-rise development. IA is right to expect a backlash against any such proposition.
Landcom's guide to density shows that there are many different ways to pursue increases in density, some more gentle than others.6
APT (NSW) notes that the typology of development in areas that have comparatively good public transport (like Sydney's eastern suburbs and north shore) is varied, and less land is devoted to asphalt. Blues Point tower is no better at supporting a decent public transport system than the terrace houses and variety of human scaled alternatives that surround it.
Balance between population centres
7. Almost three-quarters of this [population] growth (72.0 per cent) is projected to be in the four largest capitals – Sydney, Melbourne, Brisbane and Perth. In total, these four cities are projected to grow by 5.9 million people, or 46 per cent, to 18.6 million in 2031. This growth will impose additional demands on urban infrastructure already subject to high levels of demand.
8. The other capital cities – Adelaide, Canberra, Hobart and Darwin − are projected to grow in total by slightly more than 0.5 million people or 26.7 per cent. Given this, it is worth considering what steps could be taken to foster greater long-term growth in those cities, which may moderate the consequential infrastructure challenges in the larger cities.
We agree that this is an important issue for IA to consider. In the case of Canberra, we believe that fast train connections to Sydney and Melbourne would enable Canberra to play a bigger role. This would make use of existing infrastructure and reduce the pressure for outward expansion of Sydney.
Regional cities should be kept in mind as they also have established infrastructure and smaller populations (although we note IA’s concern about the prospect of droughts). Fast rail combined with the NBN makes it viable for businesses and residents to base themselves within actual and virtual reach of major centres, without placing pressure on those centres.
Bendigo is a good example of a regional city with an existing rail connection to Melbourne offering a real alternative. Newcastle could easily do the same if, instead of truncating its rail line, NSW recognised rail as a competitive advantage, straightened out the line and introduced fast and frequent services from Sydney.
Bad practices
46. Underinvestment in the maintenance of some parts of Australia’s infrastructure networks, notably in regional Australia, could reduce the ability of those networks to provide reasonable levels of service in the future.
APT NSW fully agrees that maintenance of assets needs to be recognised as a necessity. In the case of rail systems, the pattern of allowing both the physical assets and the frequency of service to dwindle until passengers desert the system has been wasteful and shortsighted.
The audit could be more explicit about bad practices with respect to assessing infrastructure proposals. There are two other particularly bad practices in infrastructure planning in recent years and we hope IA will be able to displace them.
Some States have entered into contracts for major road projects (East-West link in Melbourne; Westconnex in Sydney) before the completion of assessment processes. Several subsequent variations have been made to Westconnex without any semblance of justification. Despite the absence of a published business case for Sydney's Westconnex project, the Federal government has been in an unseemly rush to fund it.
This comes at an enormous cost if realisation subsequently dawns that it is not a good idea after all. Either the project is cancelled, attracting a compensation claim, or it is not, and good money is thrown after bad, instead of being spent on something more useful.
Another Sydney example is the Tibby Cotter “shared” bridge across Anzac Parade. The project was rushed through the assessment process and constructed at a cost of $38M. Safety issues, which should have been foreseen, emerged after construction; cycling is now forbidden on a bridge that was supposed to be a “shared” facility for cyclists and pedestrians.
The Commonwealth, meanwhile, will fund roads but refuses point blank to fund public transport. The rationale given for this absence of balance at the Federal level has been that if the Federal level funds roads, that leaves more money for States to devote to “their” area of responsibility, public transport. In reality, State governments have an incentive to favour the projects for which they can get Federal assistance - road projects. Such a stance therefore imports systematic bias into transport decision-making at both levels of government.
It is possible that this stance is in reality a “captain’s pick” based on a position firmly and unreasonably held by the Prime Minister (2009)8:
“Mostly, there just aren't enough people wanting to go from a particular place to a particular destination at a particular time to justify any vehicle larger than a car”.
If this were correct, we wouldn't have traffic jams.
Funding and affordability
38. Dealing equitably with the affordability of infrastructure services is an important consideration, as a matter of social policy. Unless affordability concerns are addressed, the necessary shift to greater application of user charging will struggle to gain community and political support.
In some cases, such as actual damage to infrastructure, user charging is clearly appropriate. In the case of public transport however affordability is a very real issue and we are glad IA recognises this. Apart from being a social policy issue, user charges (that is, fares) can deter public transport patronage more than may be recognised. We note that estimates of the implied elasticity of demand for public transport (that is, how responsive people are to fare changes) proved wildly wrong in the case of the Airport Rail Link9.
It was reportedly expected (using conventional analyses) that removal of the $2.60 “station access fee” for passengers using Mascot and Green Square would increase patronage by around 15-17%. Instead, these stations reportedly saw patronage jump 70% in a year in response to cheaper fares (“Ticket sales rocket on airport line as prices plunge” SMH June 9, 2011).
Even allowing for the underlying increase in patronage (around 20% in the estimation of the Airport Link company) this is a stunning turnaround. It is now perfectly clear that high fares (due to station access fees) artificially, and savagely, suppressed patronage on the airport line. The consequence is underutilisation of a piece of public transport infrastructure.
It has been suggested by the Reserve Bank Governor Glenn Stevens, among others, that there is merit in the traditional approach that built most of the infrastructure current generations enjoy – government borrowings, paid off over time. The drawbacks of all other possibilities have become clearer with experience. At a time of low interest rates, this may turn out to be the best strategy for many key infrastructure projects10.
Public consultation
APT (NSW) is concerned that many infrastructure decisions have been made after rushed, inadequate or ignored public consultation. We draw Infrastructure Australia's attention to the need for proper public involvement. See, for example, Arnstein's discussion.11
Conclusion
APT (NSW) is grateful for the opportunity to make this submission and we would welcome the opportunity to participate in the public consultation which IA has indicated it wishes to undertake.
1 Action for Public Transport (NSW) submission to IPART Review of External Benefits of Public Transport 2014 http://www.aptnsw.org.au/documents/ipart_ext_benefits.html - discussion of question 14
2 Action for Public Transport (NSW) submission to IPART Review of External Benefits of Public Transport 2014 http://www.aptnsw.org.au/documents/ipart_ext_benefits.html - discussion of question 1
3 Litman T. 2009, Evaluating Public Transit Benefits and Costs: Best Practices Guidebook, Victoria Transport Policy Institute (Canada) http://www.vtpi.org/tranben.pdf
4 http://www.aptnsw.org.au/documents/role_of_P_T.html
5 http://www.aptnsw.org.au/documents/leppingtonDCP.html
6 See Better Public Transport. Better Productivity. PwC report for TTF November 2014 http://www.ttf.org.au/DisplayFile.aspx?FileID=2475
7 Senate Standing Committee on Rural and Regional Affairs and Transport, inquiry into the role of public transport in delivering productivity outcomes January 2014 http://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Rural_and_Regional_Affairs_and_Transport/Public_transport/Report
8 Tony Abbott (2009) Battlelines, p.173
9 Action for Public Transport (NSW) submission to IPART Review of External Benefits of Public Transport 2014 http://www.aptnsw.org.au/documents/ipart_ext_benefits.html - discussion of question 3
10 http://www.borrowandbuild.com.au/
11 Arnstein S R (1969), A Ladder of Citizen Participation - http://lithgow-schmidt.dk/sherry-arnstein/ladder-of-citizen-participation.html