Action for Public Transport (N.S.W.) Inc.
|P O Box K606|
|Haymarket NSW 1240|
|16 October 2017|
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 of passengers and the wider community. We make this submission on the Environmental Impact Statement dated August 2017 for the WestConnex stage 3 M4-M5 link.
We note the following flaws in the EIS:
The EIS abrogates major design decisions, deferring them to later study, particularly the proposed Rozelle interchange. The missing details therefore cannot be taken into account in assessing the impact of building and operating the M4-M5 link. The legality of this incomplete EIS is questionable.
The EIS fails to consider relevant public transport alternatives. Part of the reason for this might be a deplorable NSW Cabinet policy - The Sydney Morning Herald of 15 June 2017 had an article by Peter Martin citing a directive not to consider public transport alternatives to the proposed F6 extension.
Other cities aren't making the same mistake. For instance Seattle is facing population growth of around 3% per year. Despite being much smaller than Sydney and therefore presumably able to rely on cars to a greater extent, Seattle has commenced a package called Sound Transit 3. According to an article in the Seattle Times of 27 April 2017:
With Sound Transit 3, voters authorized a 25-year, $54 billion package containing 62 new miles of light rail, stretching from Tacoma to Everett, as well as increased commuter rail and bus service.
By the time the system is complete, it will have 116 miles of light rail, more than five times the amount that is in service today between Angle Lake and the University of Washington.
The EIS fails to consider all relevant demand management alternatives. In particular, there is no discussion of road access pricing.
Road access pricing is receiving increased attention in the literature. For example, Professor David Hensher had an article in The Sydney Morning Herald on 11 March 2016 which said:
We need to begin a journey away from fixed charges, such as car registration, to use-based charges.Road access pricing is also receiving attention in Canberra. An article published in The Conversation dated 12 September 2016 by Marion Terrill and Owain Emslie states:
At the Institute of Transport and Logistics Studies we showed a while ago that for the Sydney metropolitan area, if you halved registration charges and introduced a 5¢ per kilometre peak period charge, then almost every driver would be better off financially (as would state Treasury, though the federal government would lose out on some fuel excise due to reduced distance travelled by cars).
It would result in a 6 per cent drop in peak traffic (similar to traffic drop during school holidays), which makes a huge difference to the performance of the road network. It also a way of ensuring that those who benefit for the time savings under the new reform also pay.
To convince people we are talking sense, take a simple example of typical peak period kilometres in Sydney per year (4000 kilometres out of the typical yearly average 12,500 kilometres for private cars). Halving registration charges should save on average $200 a year and 4000 kilometres with a peak charge at 5¢ per kilometre is $200 so it is cost neutral. We could reduce registration charges even more, as per the view of Infrastructure Australia, and then saving to motorists is greater than $200 (possibly as great as $500).
Road user charging is probably the best idea we have to reduce congestion and to enable better decisions on road investment. Average travel speeds in our cities are decreasing, and congestion is only likely to worsen as our population continues to grow.A very recent paper on the subject is "Stuck in traffic? Road congestion in Sydney and Melbourne" by Terrill available at https://grattan.edu.au/report/stuck-in-traffic/ which recommends inter alia:
Urban Infrastructure Minister Paul Fletcher recently gave an important speech, albeit largely unnoticed, in which he made the case for a universal road user charging scheme. Charging people to drive has previously been the dream of transport and economic policy wonks - serving politicians tend to see the idea as political poison.
Fletcher trod gently, cautioning his Sydney Institute audience that "there is a lot of work to do" and that any move in this direction would be "a ten to 15-year journey". It is still remarkable that a federal minister even took these first steps.
The NSW and Victorian governments should introduce congestion charging. People who want to drive on congested roads in the peak should pay a small charge to do so. The revenue should be returned to the community as discounts on car registration, and improvements to public transport. And as more toll roads are introduced, state governments should ensure they have the flexibility to adjust future tolls to manage traffic flows.
The EIS (Executive Summary, page v) justifies the project on grounds including the need to handle an extra five million trips per day. It is inconceivable that the whole WestConnex system could cope with anything like that number of trips. For comparison, the Sydney Harbour Bridge and Sydney Harbour Tunnel between them have 12 traffic lanes which handle about 300,000 3km trips per day. WestConnex, with a maximum of perhaps six lanes, has no chance of making a significant impact on five million trips, many of which will be well over 10km.
Another way of presenting the same issue, although measured on the whole of WestConnex rather than just the M4-M5 link, can be seen in an article by Chris Standen published in The Sydney Morning Herald on 17 August 2016:
Sydney already has a very high capacity road network by global standards - one which now handles about 110 million vehicle kilometres (VKT) a day, or 31.9 kilometres for every licensed driver.
Now the NSW government is spending $17 billion on the 33-kilometre WestConnex tollway, which will increase daily VKT by 0.5 percent, to 32.1 kilometres per licensed driver. Put another way, the Baird government is spending $7000 for every household in the state, and bulldozing homes, heritage areas, parks and trees, just so the average motorist can drive an additional 200 metres a day. And the road network will still be congested.
Expanding Sydney's transport system to cope with an extra five million trips per day would be very difficult but the most promising steps to take would include land-use changes to reduce the need for long trips and also expansion of public transport facilities. WestConnex works against both of those.
The fallacy in the Executive Summary is compounded in Chapter 8 - Traffic and Transport. According to section 8.1.1 (Strategic transport context, page 8-3), "WestConnex is also an enabler of integrated transport and land use planning, supporting the development of initiatives including The Bays Precinct and the Parramatta Road Corridor Urban Transformation Strategy". That's false. The whole WestConnex strategy shows no credible co-ordination of transport planning with land-use planning. WestConnex's capacity falls far short of what those two initiatives require. Shortcomings of Bays Precinct are well-known, if only because Google decided not to move its offices to Glebe Island, citing lack of public transport. And the Parramatta Road corridor UTS was cut back in 2015-2016 from 50,000 homes to 27,000 homes plus some employment area when it became obvious that transport would be inadequate despite WestConnex. Even if the WestConnex tunnels were dedicated to buses or other public transport, the route chosen does not fit public transport's needs because it avoids denser centres such as Burwood and the CBD. Rather than enabling these developments, WestConnex consumes resources which should instead go into the public transport that is clearly required; WestConnex therefore works against Bays Precinct and Parramatta Road Corridor UTS.
Figure 8-1, entitled "Sydney travel demand corridors" is misleading. Its age is evident by the absence of Western Sydney Airport and the old names "Southwest growth centre" and "Northwest growth centre". It might be intended to show demand for cars to travel which would limit its usefulness in planning transport for people.
We do not think that the EIS proposal can be justified.
We recommend that the EIS be rejected.