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| Action for Public Transport (N.S.W.) Inc. |
| P O Box K606 | |
| Haymarket NSW 1240 | |
| 25 September 2019 | |
Action for Public Transport (NSW) is a transport advocacy group, which has been active in Sydney since 1974. We promote the interests of beneficiaries of public transport; both passengers, and the wider community. We make the following submission on the draft document O6 - Alternative Options to Large Capital Investments, released for public consultation in August 2019.
APTNSW is pleased to see that ATAP is raising awareness of alternative options for managing urban road congestion, and that it includes public transport improvements among those options.
After more than 50 years of years of neglect and misguided priorities, the coverage of the public transport system is inadequate, and this needs to be rectified with significant capital investment in outer suburban areas and on regional services. There are however opportunities to improve the level of service offered to passengers on existing services that do not involve large capital investments. Many of these are identified in the draft document.
We note (from Table 15 on p.29) that prioritisation of high occupancy vehicles has shown a 21 per cent decrease in bus travel time in Sydney. We presume this is a reference to bus lanes and bus priority signals at intersections.
We have however in earlier submissions to ATAP pointed out that the CBA assessment method it champions is systematically biased against public transport proposals. The method as currently envisaged loads up the costs of public transport projects to such an extent that it will continue to seriously and unreasonably skew assessments against public transport improvements and produce worse outcomes for Australian cities and regions.
Draft ATAP Guideline O6 assumes and recommends the use of Guideline M1 to assess public transport enhancement proposals. The methodology set out in Guideline M1 (at p.75) involves including in cost benefit analyses of public transport proposals the following operating costs:
We note for example from p.81 of M1 that the construction cost of a single parking space is $15,000-$25,000 (at grade) or $30,000 -$40,000 (in a multi-deck car-park). Both bus lanes and carparks at stations are primarily demand management methods, aimed at relieving road congestion by encouraging transfers to public transport. It is unreasonable to add the costs of these measures to the cost of public transport projects.
Road projects are not burdened by the imposition of a profit margin for a hypothetical private operator in CBA assessments. The direct operating costs of private vehicles are not included in cost-benefit analyses. Nor are the "overhead" costs of keeping traffic moving safely included; traffic management, network control centres, police time, the cost of changing directional flow (crews and vehicles), RBT program, and court costs.
The inclusion of these costs in the case of public transport projects introduces an unjustified source of inbuilt bias to the assessment process. A particularly effective form of service level enhancement omission is increased frequencies, which greatly reduces waiting time and door-to-door travel time. "Turn up and go" frequencies as proposed in Future Sydney 2056 are a critical initiative, which would be seriously disadvantaged by the ATAP assessment methodology.
The need to clarify "relevant jurisdictional goals, transport system objectives and targets" is acknowledged on p.9 (3.1). This is absolutely correct, and it requires deep thinking.
We note that Section 2.4 is predisposed to the idea that "the problem" is urban road congestion. Is the free flow of traffic really the overriding aim of the transport system? APTNSW believes that it is past time for this destructive and impossible dream to be displaced.
A snapshot of the socially catastrophic outcomes of more than 50 years of underinvestment in public transport can be seen in the "effective job density" diagrams contained in the T2 guidelines. Although the diagrams do not show it, lack of access to jobs is directly correlated with higher welfare reliance and poorer health outcomes. Access to educational opportunity is similarly uneven, and lower rates of educational attainment are a significant cause of unemployment. We suggest that the aim of travel by any means is to gain access to goods, services, employment, education, and opportunities for social interaction. We urge ATAP to shift its focus from mobility to accessibility.
The logic of Table 6 p.19 seems to be that more platform seating/better toilets/less graffiti in some way compensates for slow service. These kinds of improvement are very welcome from a passenger perspective, but the theoretical argument seems to suggest that more comfortable conditions on platforms is an alternative to, say, straightening out of the rail line between Sydney and Newcastle to reduce journey times.
Assuming the aim is to increase patronage, APTNSW regards the argument as highly dubious. We would expect to see convincing empirical evidence to support it before it is embedded in ATAP guidelines and acted upon.
All public transport passengers are pedestrians at the beginning and end of their journeys, and some use bicycles to cover the "last mile" of their journey to and from their homes. APTNSW therefore has a strong interest in walking and cycling connections.
We note with some concern that in section 4.8 time is listed as a "disbenefit" of active travel, which will count against walking and cycling projects in cost-benefit analyses. These modes are usually slower, but they have significant health benefits and they are far less demanding of scarce and expensive urban space. APTNSW is concerned that the application of CBA to these projects will be misleading and produce perverse results.
APTNSW thanks ATAP for the opportunity to comment on this document. We hope that over time the assessment of transport proposals will become more sensitive to critical issues overlooked in conventional cost-benefit analysis, and less biased against public transport investment.