Action for Public Transport (N.S.W.) Inc.
|P O Box K606|
|Haymarket NSW 1240|
|29 January 2016|
Action for Public Transport (NSW) Inc. ("APTNSW") is a transport advocacy group active in Sydney since 1974. Our members are users of public transport services.
We make this submission because WestConnex carries an opportunity cost which is of great concern to our members. It is immensely costly, and growing more so as the scope of the project expands. Current estimates are in the order of $16 billion. This includes $1.8 billion of State money, $1.5 billion of Federal money, and an additional Federal loan of up to $2 billion1. Many public transport improvements that would genuinely reduce traffic congestion and support urban renewal are meanwhile stuck in a queue, forlornly waiting for funding.
The purpose of the EIS is to support an application by the RMS for approval to construct and operate a toll road between the existing M5 East Motorway east of King Georges Road and St Peters. The project would include an interchange at St Peters and connections to the existing road network.
The EIS does not provide a reasonable basis on which to approve the application. It rests on a series of fundamental misconceptions about transport, land use and cities. It fails to consider alternatives. It fails to deal sensibly with the impact of construction of the Badgerys Creek airport. Its reasoning runs counter to the Government's intention to remedy the imbalance in access to jobs for the residents of the growing western and south-western regions.
The WestConnex project will not achieve two out of three of its stated purposes: "reducing congestion, creating jobs and connecting communities". It will neither reduce congestion nor connect communities, and is likely to do quite the opposite. The construction jobs it would create would equally be created if the considerable funds involved were reallocated to more worthwhile projects.
The application to which the EIS relates should consequently be refused. The money should be reallocated to filling in missing links in the public transport system and disentangling the passenger rail network from the rail freight network. Doing so would achieve all the stated aims of the WestConnex project - unlike the project itself.
Misconception no.1: Increasing road space reduces congestion and travel times
Circular reasoning and self-fulfilling prophecies
The approach accepted in the EIS can be described as "predict and provide". The "predict and provide" approach is an exercise in circular reasoning and self-fulfilling prophecy.
It is based on projected population growth, from which growth in travel is assumed. Past patterns of mode share, adjusted for committed transport projects, (few of which are public transport projects) are then projected forward as "forecasts". This leads inexorably to the proposition that more road space should be constructed.
The New M5 EIS rests on the forecast (Vol.1A, p.4-12) that "72 per cent of journeys in 2031 will be made on the road network each weekday by vehicle, equal to an additional 4.3 million new trips compared to current traffic movements". This is a figure derived from the "predict and provide" approach, which is well past its use-by date.
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. However frenzied the expenditure on WestConnex, it will fail to reduce congestion and travel times.
The problem, as has been empirically established over many years2, is a persistent failure to acknowledge the reality of induced traffic. Traffic is not like water; it is a fundamental 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). Already, two lanes are being added to the M2 between Pennant Hills Rd and Windsor Rd, in an attempt to deal with the extra traffic which will be generated by NorthConnex.
It can be stated with a high degree of confidence that the "new" M5 will induce more traffic to occupy the extra road space it will create. The WestConnex New M5 Project Overview itself contains empirical evidence that this is what should be expected. It notes (p.9) that the "old" M5 East was congested within just six months of its opening in 2001, and now experiences the slowest typical travel speeds of any of Sydney's main motorways3.
In other words, it failed to achieve what it set out to do, which was to reduce congestion and travel times. This of course is the stated aim of WestConnex.
Doing the same thing over and over again in the expectation of a different outcome shows a deplorable lack of interest in evaluating the outcome of previous road projects. Stubborn attachment to an approach that empirically does not work can only lead to a monumental waste of public money.
The EIS for the M4 East concluded that the impact of constructing that section of WestConnex would be to worsen traffic congestion at the point at which it emerges on Parramatta Rd (at Wattle St).
That EIS then unconvincingly proposes to "mitigate" the problem by adding more "WestConnex" road projects to move the bottlenecks along, one at a time4.
Sydney is a highly developed city. Wherever WestConnex emerges, it can only dump more traffic on roads that lack the capacity to take additional traffic. In this case, the bottleneck moves to St Peters, where it emerges as the spaghetti junction shown as Figure 5-8 in the EIS (Vol.1A).
Source: New M5 EIS Figure 5-8
Misconception no.2: The project will support higher densities and vibrant neighbourhoods
Urban motorways and urban density are antipathetic, not mutually supportive. The notion that building an inner city motorway will support population growth is at odds with the reality of how cities work.
WestConnex is underground in parts, but it remains land-hungry, and it will sever communities. This is inevitable, because it has to emerge somewhere. Rail tunnels are very different; people can reach the surface without dragging a vehicle with them. They can reach their destination without destroying it.
Flyovers and interchanges, portals, and ramps sterilise prime urban space that could otherwise be available for more productive land uses, like housing, employment, shops and cafes, recreational facilities and public transport facilities. They also reduce connectivity and sever communities.
Source: New M5 EIS Figure 5-10
The EIS implicitly recognises that ventilation stacks will also reduce opportunities for additional housing. It acknowledges (Vol.1A page x) that: "Future development of land (including re-zonings) in the vicinity of the ventilation facilities that may involve multi-storey buildings would need to consider the air dispersion performance of the New M5 facilities".
The implication is clear enough. It isn't healthy to live close to vehicle pollution; and so multi-storey dwellings should not be constructed near ventilation facilities.
The end result is that WestConnex is likely to reduce urban densities and blight neighbourhoods.
Failure to consider alternatives
The EIS purports to consider alternatives, but does not do so in any serious way. It never gets beyond generalities to consider specific public transport proposals, and whether they would do a better job of meeting the stated objectives of WestConnex.
For example, the deferred Hurstville to Strathfield rail link could reduce passenger vehicle travel on the M5 corridor. The light rail between Parramatta and Strathfield to which the government has recently committed should also do so. Similarly, a Badgerys Creek airport rail link can legitimately be seen as offering a possible alternative to WestConnex.
This kind of analysis should of course have been done by Transport for NSW at the outset, but it seems that the genesis of WestConnex lay somewhere else.
For a long time we have been told (wrongly) that Sydney could not have better public transport because its population was too small or not dense enough. We are now told to expect a major increase in population and density, but still the alternative of improving the public transport system is peremptorily dismissed in the EIS. This time, the argument (Vol.1A, p.4-12) is that:
Public transport is best suited to serving concentrated, high volume flows of people to and from established centres. It is less suited to serving ... [dispersed] cross-city or local trips.
It is more accurate to say that public transport or active transport are the only practical ways to serve concentrated, high volume flows of people to centres of activity. It is not accurate to say that public transport cannot serve cross-city or local trips (though many local trips would be better undertaken by some form of active transport for health reasons). This is a common misconception about public transport.
The EIS states (Vol.1A, p.4-12) that:
With about 60 per cent of employment dispersed across the Sydney Metropolitan area, public transport alone cannot viably serve most of these locations.
This statement is at such a high level of generality that it is grossly misleading. Except in the case of truly isolated employment locations, the proposition is wrong. The EIS errs in its use of average figures for the Greater Metropolitan Area, a huge area that contains many locations poorly served by public transport. It is hardly surprising that people are not using public transport that isn't there.
The secret to catering for diverse trip patterns is to increase the coverage of the public transport network, design it as a web of interconnecting routes, and run services at high frequencies5.
In any event the new M5 is not serving highly dispersed employment locations. The main employment areas served are Sydney CBD, and the airport to the city corridor. These are concentrated, centralised employment areas.
The modal split towards public transport for journeys to work ending in the CBD is exceptionally high, a feature essential to maintaining its function. The Sydney City Centre Access Strategy (NSW Government, 2013) recognises the fact that 80% of people commuting to the city centre in the peaks use public transport with a further 6% walking and cycling. Just 14% travel by car, a proportion that has reduced from 17% in 2001. North Sydney CBD also has a high modal split towards public transport.
The airport area is sabotaged by the high station gate charge on the T2 Airport/Macarthur Line. The removal of the $2.60 "station access fee" for passengers using Mascot and Green Square stations reportedly saw patronage jump 70% in a year ("Ticket sales rocket on airport line as prices plunge" SMH June 9, 2011). We repeat, 70%.
Even allowing for the underlying increase in patronage (around 20% in the estimation of the Airport Link company) this is a stunning turnaround. Removing the (higher) station access fees on the airport line would do more to reduce congestion in the vicinity of Sydney Airport than expanding the M5.
Freight and delivery vehicles
The EIS (Vol.1A, p.4-13) suggests the M5 expansion project aims to move both people and freight, but considerable emphasis is placed on commercial deliveries and freight movement.
The EIS observes (Vol.1A, p.4-12) that almost 40 per cent of the users of the M5 East during business hours are on work related business (including deliveries and freight transport). The corollary is that more than 60 per cent are not.
There is scope to move more bulk freight by rail. This can be achieved by a number of measures mentioned in the EIS (p.4-14): the Moorebank intermodal; Enfield intermodal; Southern Sydney Freight Line; and the Western Sydney Freight line and terminal project, a new dedicated freight line connecting the Main West Railway Line and the Southern Sydney Freight Line to a new intermodal precinct at Eastern Creek. The EIS notes (Vol.1A, p.4-15) that:
The State infrastructure strategy anticipates that by 2036, about 4.3 million truck kilometres a year could be saved through the Western Sydney Freight Line and terminal precinct project.
The EIS also refers (Vol.1A, p.4-15) to the State Infrastructure Strategy's conclusion that to improve the reliability of rail freight in the Sydney greater metropolitan area requires 'unwinding' or improved separation of the passenger and freight rail use of the network.
The reality is that the lighter commercial vehicles that do need to be on the roads are being impeded by passenger traffic taking up space for want of a decent public transport alternative.
WestConnex offers no long-term relief for commercial users, because the growth in commuter traffic induced by road space increases will continue to crowd them out. If the history of the old M5 is any guide - and it is - 6 months after the "new" M5 opens they will be stuck in traffic again, and most of that traffic will consist of passenger vehicles. The EIS (p.4-12) says this:
The demand for passenger road travel is forecast to account for 73 per cent of total trip growth.
The EIS does not consider the alternative of a dedicated freight road, linking the M4 and M5 (in addition to the M7), which might avoid the problem of "crowding out". There is no reason such a link would need to go all the way in to St Peters.
It is our understanding that a dedicated freight link has been suggested in years gone by, but regular car traffic was added to improve the cost benefit ratio of the project. Since this makes the project both more destructive and less effective, this suggests a major flaw in the way cost benefit analysis is currently applied to transport projects.
Badgerys Creek airport
The existing Sydney Airport is a major land use that has been driving the case for the WestConnex project, or at least this component of it. It is now however evident that the construction of a new airport at Badgerys Creek is in fact imminent.
This will reshape travel patterns in Sydney, including and perhaps especially travel patterns associated with freight movement.
The impact of the Badgerys Creek airport is not appreciated in the EIS. It is suggested (p.4.16) that:
"The operation of the Western Sydney airport would be staged, ramping up over time, with initial operations only commencing in the mid-2020s (a minimum of five years after the anticipated completion of the New M5 project)"
The implication is that a mere five years after this project is completed, one of its major justifications will substantially disappear.
To soften this inconvenient truth, the EIS suggests that:
"Port Botany and Sydney Airport would still be key freight entry and exit points, with the new airport to complement the existing airport"
While this is obviously true of Port Botany, it is by no means clear at this point that Sydney Airport should or will remain a key freight entry and exit point once Badgerys Creek Airport is constructed.
Source: Infrastructure NSW, State Infrastructure Strategy Update 2014 (adapted from TfNSW Long-Term Transport Master Plan 2012)
The EIS (p.3-15) notes that both Growing Sydney and the Transport Master Plan identify the need to prioritise development of centres such as Parramatta, Penrith and Liverpool to bring jobs closer to homes and areas of increasing population. And yet it endorses a massive injection of funds in the opposite policy direction, saying (Vol.1A, p.4-17):
However, housing is more affordable in Western Sydney and there is a great demand for additional jobs in the east in areas that are part of or support Port Botany, Sydney Airport and the surrounding industrial areas, resulting in a disparity in employment opportunities close to people's homes.
WestConnex does nothing to alleviate this disparity; it serves only to cement it in place.
As the EIS records (4.2.4 p. 4-17), the State infrastructure Strategy notes that investment in Sydney's strategic road network can be sustainable if complemented by strategies to manage congestion and environmental impacts and should be undertaken in tandem with investment in public transport. We take that as "if and only if".
The problem is of course that choices have to be made, because funds are not unlimited. WestConnex is soaking up funds, but it has yet to demonstrate that it can deliver any lasting public benefit.
It is pleasing to see investment in Sydney's public transport network after more than 50 years of neglect. APT NSW recognises and welcomes the initiatives that are underway and those recently completed. There are however many worthwhile initiatives that cannot proceed until funding is available.
For example, the government was forced to choose between four potential light rail connections serving Parramatta; the money spent on WestConnex would easily fund all of them, and more. The list of worthwhile projects is a long one: rail to Badgerys Creek; straightening out the rail line to Newcastle to dramatically improve travel times; perhaps the resuscitation of the "Metro West" proposal.
This of course is a selection in no particular order, not an exhaustive list. Projects that untangle freight rail from passenger rail, such as those referred to in the EIS, also deserve higher priority than does WestConnex.
Interestingly, the fact that public transport provision moderates growth in demand for travel on the road network is implicitly recognised by Infrastructure NSW, as noted in the EIS (p.4-12):
Even though the use of public transport is expected to grow with the implementation of key public transport initiatives most growth in transport demand over the next 20 years will be met by roads.
The recent necessity to increase services on the light rail line between Dulwich Hill and the city bears this out empirically.
Public transport is the real congestion buster. It also supports higher densities, because it uses land so much more efficiently.
How did we get here?
A 2014 NSW Audit Office report6 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-Coordinator7, which canvassed prospects for "high value vehicle" roads and stated (p.29) that "There have been suggestions that Transurban may present an unsolicited proposal to the NSW Government to develop several motorway links".
It would be reasonable for a government facing unsolicited transport proposals to have in place a strategic framework against which such proposals could be assessed. The question actually asked was however bound to elicit something else entirely.
We now have a pointless project prematurely endorsed and announced; and funded ahead of other projects not answering the description 'motorway'. Contracts have been let before the project was properly assessed and indeed before it was properly planned. The project is being redesigned month by month as it becomes blindingly obvious that it will cause traffic congestion wherever it attempts to rejoin the existing road system.
WestConnex has become a juggernaut careering across Sydney, trying to mitigate the harm it is causing by doing more of it.
The WestConnex project will not achieve two of its three stated purposes. It will neither reduce congestion nor connect communities, and is likely to do quite the opposite. It will employ construction and engineering firms and construction workers, as claimed, but so would more worthwhile projects such as filling missing links in the rail system, and untangling freight rail and passenger rail.
APT NSW suspects that many Government members know this. Transport planners certainly do. But we are witnessing WestConnex inertia - a body is in motion that will continue in motion unless acted on by an equal and opposite force.
The government should not succumb to the "sunk-cost fallacy"8. The WestConnex project (including this component) should be dropped, in favour of initiatives genuinely capable of reducing congestion over the long-term. It is better to drop a bad idea, even if some may think you don't know what you're doing, than to proceed in the face of empirical evidence that it won't work, and remove any doubt about it.