Chris Standen is a Transport planning and modelling expert. He has prepared this submission in response to the EIS for the New M5. His submission will be published in four parts. Standen provides many important reasons for not supporting the project. Draw on his ideas to prepare you own submission
- The EIS does not comply with the Secretary Environmental Assessment Requirements (SEARS).
- There are major issues with the Traffic and Transport Assessment. There is insufficient information about the modelling inputs, assumptions and methodology for the forecasts to be independently verified. There is no sensitivity analysis of key assumptions.
- The social and environmental impacts described in the EIS are unacceptable and far outweigh any benefits of the project. Because of flaws in the modelling, the actual impacts are likely to be even greater than those forecast.
- The project does not meet the project objectives.
- Many of the project objectives, such as congestion relief, could be met through better management of demand on the existing road network, e.g., through reform of road pricing. The corridor already has an extensive and high capacity road network; there is just too much demand at present for it to operate effectively. Adding more capacity will not lessen this demand; it will only serve to increase it.
- A claimed benefit of the project is that daily traffic on the existing M5 East would reduce by 20-40 percent due to the new tolls. If it is acknowledged that tolls alone can be effective in meeting the main project objective (reducing congestion), then what is the rationale for adding more capacity
- The project makes little sense from a transport planning and policy perspective. The role of motorways is to allow traffic to circumvent densely populated areas. For radial transport into and out of urban centres, mass transit is more efficient and economical, and has less impact on the human population.
- The project is not in the public interest. It will be used by less than 1% of the NSW population each day. The rest of the population will pay dearly in terms of higher traffic impacts, poorer air quality, and state and federal taxes being diverted from public transport and other more worthy causes?
- The project has a high financial risk. The flaws and optimistic assumptions in the traffic modelling mean that toll revenue is likely to be significantly lower than forecast. AECOM has a history of providing over-optimistic traffic forecasts for toll roads, resulting in previous financial failures (e.g., Clem7).
- The average daily travel time in Sydney has been stable at about 80 minutes per person for decades, while the average trip distance has increased substantially (see graph below). In this time, billions have been spent on tollways. Travellers are spending more than ever on tolls, yet are not spending any less time travelling. The higher speed of tollways has simply encouraged people to move further from work, drive more, and make longer trips than before, for example, visiting shopping malls instead of local shops. It has made road more attractive than rail for freight.
- This predict and provide approach to transport planning has been a failure, and is being abandoned by advanced nations. In a city of 5 million people, we can never provide enough road capacity to enable everyone to live as far from work as they like, and drive wherever and whenever they like in free flowing traffic.
The rest of this submission is in four Section. This post covers only the first section which describes general issues with the EIS, the project and the broader WestConnex scheme (Section 1). The following sections will deals with non-compliances with the SEARs (Section 2), non-compliances with the project objectives (Section 3), and major issues with the Traffic and Transport Assessment (Section 4).
Section One – Project & Broader Westconnex scheme
1) The proposed New M5 and broader WestConnex scheme are not in the public interest.
- Any personal travel time savings generated by the project will not benefit the economy, and will be cancelled out in time by induced demand and induced sprawl.
- The New M5 will be used by less than one percent of the NSW population each day. The costs will be borne by the whole population.
- The project will cause immense social harm. It will destroy long-established communities. It will cause an increase in air pollution-related deaths and illnesses. The increase in air pollution will further inhibit lung and nervous system development in children.
- There are numerous ways of spending $16.8 billion that would deliver a much greater social and economic benefit, and would not cause so much destruction.
2) The EIS authors (AECOM) have not modelled or objectively assessed alternative policy scenarios that could meet the transport/accessibility needs of NSW’s growing population (individually or in combination), e.g.:
- Greater investment in mass/public transport;
- Demand management/road pricing reform
- Land use planning that places homes, employment and services closer together
3) It is no secret that the primary purpose of the WestConnex scheme is to increase the road freight accessibility of Port Botany and Sydney Airport, and that private passenger vehicles have been included in the scheme as a means of paying for it (through tolls). However, there are various policy alternatives for dealing with the growing freight task that have not been objectively assessed in the EIS, e.g.:
- Improve the capacity and reliability of rail freight.
- Increase rail/intermodal freight subsidies to match those of road freight.
- Divert container operations to other ports outside the city centre. It does not make sense to concentrate container operations in the city centre where road access is costly and has significant impacts on the surrounding residential areas. An expansion of the Port Kembla container terminal, which already has good road/rail access, would stimulate the Illawarra region’s economy.
- Freight demand management, e.g., incentivise shorter supply chains and local supply.
4) The new intermodal terminals at Moorebank and St Marys, along with the planned upgrades to the Port Botany rail freight rail line, will significantly increase the share of freight that can leave/enter Port Botany by rail. Against this background, spending $16.8 billion on marginal improvements to road freight access must be questioned. Is the proponent (RMS) aware of the new intermodal terminals?
5) The Traffic and Transport Assessment does not stand up to scrutiny. There is not enough information about the methodology, input data or assumptions for the forecasts to be independently verified. In particular the assumed toll price, on which the traffic forecasts heavily depend, has not been stated.
6) There is no sensitivity analysis in the Traffic and Transport Assessment. The effects of varying key assumptions (e.g., willingness to pay the tolls) have not been described. AECOM has a history of overestimating the willingness of motorists to pay for toll roads, resulting in overly-optimistic traffic forecasts and financial failures (e.g., Clem7).
7) There is no modelling/objective assessment of the travel time and accessibility impacts for non-motorised modes (walk and bicycle) in the Traffic and Transport Assessment
8) The issue of induced demand has not been adequately addressed in the Traffic and Transport Assessment.
9) Given the major flaws with the Traffic and Transport Assessment, there can be no confidence in the accuracy of the other impact analyses in the EIS that are dependent on the traffic forecasts, in particular:
- Air quality
- Noise and vibration
- Human health
- Greenhouse Gases
10) The role of motorways in a multimodal urban transport network is to allow traffic to circumvent populated urban areas, and to connect less densely populated areas (where mass transit is not justified). For radial transport into and out of employment/activity centres, mass transit (e.g., rail) is faster, more efficient, requires less space, and has fewer impacts on highly populated urban areas.
11) The EIS does not consider the cumulative costs and impacts of adding more urban motorways to those previously built through the heart of Sydney since the 1950s. Although the economic, social and environmental costs of each individual motorway (as reported in an EIS) may be considered by some stakeholders to be acceptable, the cumulative costs are considerable:
- Following decades of road expansion and consequential sprawl, Sydney now spends about 13% of its GDP on transport, while the average European or Asian city spends only between 5% and 8%.
- Serious human health impacts due to petrochemical vehicle emissions/smog, including:
- Lung cancer,
- Heart disease,
- Impaired lung and nervous system development in children living near motorways/exhaust stacks.
- Waterways contaminated with road runoff (heavy metals and carcinogens in brake and clutch dust, exhaust particulates, etc.).
- High traffic crash costs (deaths/traumatic injuries and material damage).
- Urban sprawl and increasing commuting distances.
- Social isolation for non-drivers living in car-dependent suburbs.
- Increasing numbers of people losing sleep due to traffic noise pollution.
- Impacts on visual amenity (pollution stacks, concrete interchanges, concrete flyovers).
- Extreme summer temperatures (urban heat island effect).
- Community destruction and severance
- Destruction of heritage areas/buildings.
- Irreversible biodiversity loss.
- Less incidental physical activity from walking and bicycling (including to/from public transport), resulting in higher rates of obesity, diabetes, cancer and heart disease.
- Increased chauffeuring burdens for parents and carers
- Less independence for children.
- High per-capita greenhouse gas emissions
Read Chris Standen Op Ed in the Sydney Morning Herald ( December 2015)