Action for Public Transport (N.S.W.) Inc.

Introduction

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 07 - Cost-benefit Analysis of Transport Regulatory Initiatives, released for public consultation in August 2019.

Comments

APTNSW has made a submission on ATAP's draft guidelines 06 and some of our comments in that submission are relevant to this document.

In addition, we would like ATAP to reconsider the approach taken to the assessment of proposed clearways. Clearways are still a "predict and provide" measure which assumes that "the problem" is an inadequate throughput of vehicles. They create serious problems for pedestrians, shoppers, and businesses. They reduce the amenity and walkability of local shopping districts, increase the need to travel, and shift mode choice towards car travel.

There may be a case for peak-hour clearways, but "all day" clearways are now becoming common e.g. on Victoria Rd Sydney. If CBA is to be used to assess clearway proposals, ATAP guidelines need to be broad enough to capture the full range of impacts of clearways.

To add insult to injury, the aggressive clearway program in Sydney has not operated as an alternative to roadbuilding. The RMS plunges ahead with a monumental interchange at Rozelle and a Western Harbour Tunnel that it acknowledges will induce more traffic than the interchange (and the Anzac Bridge) can handle. The "solution" proposed is - double down on the same failed strategy. APTNSW's submission on the proposal is at http://aptnsw.org.au/documents/the_crescent_overpass_submission.html.

Conclusion

APTNSW thanks ATAP for the opportunity to comment on this document.