(Ed: The New M5 is being assessed under State Significant provisions of the NSW Environment, Planning and Assessment Act. Under this law, the Department prepares the Secretary’s Environmental Assessment Requirements (SEARs). You can read a full copy of the SEARS here.
This is the second part of Transport planning and modelling specialist Chris Standen’s four part submission. In this part, Standen analyses the SEARS and finds the EIS does not meet a number of requirements. It’s worth noting that some local Councils and other experts agreed with Standen that the M4 EIS requirements were not met by the Westconnex EIS. The failure to meet requirements should be a serious matter that if allowed to pass without examination undermines the entire assessment process. No decision has been made on the M4 East project yet.
( If you have missed the first part of his submission, read it here.)
The submission has been presented by the People’s M5 EIS is a format that suits wordpress. The full submission will be uploaded later on the People’s M4 EIS. You can use this and other submissions on the People’s M5 EIS to develop your own response.
The SEARS provide for an analysis of feasible alternatives to the carrying out of the proposal and proposal justification, including:
- an analysis of alternatives/options considered, having regard to the proposal objectives (including an assessment of the environmental costs and benefits of the proposal relative to alternatives and the consequences of not carrying out the proposal), and whether or not the proposal is in the public interest,
- justification for the preferred proposal taking into consideration the objects of the Environmental Planning and Assessment Act 1979,
- details of the alternative ventilation options considered during the tunnel design to meet the air quality criteria for the proposal,
- details of the short-listed route and tunnel options from the tender process and the criteria that was considered in the selection of the preferred route and tunnel design, and staging of the proposal and the broader WestConnex scheme, and in particular access to Sydney Airport and Port Botany and improved freight efficiencies.
Standen’s finding: FAIL
Comment: The EIS does not include cost-benefit analysis, modelling, or any other objective analysis of feasible alternatives. Only cursory descriptions are provided.
No alternative staging strategies are described or objectively assessed.
Cumulative aspects and proposal’s relationship to rest of Westconnex works
Details of the proposal’s relationship to and consistency with the broader WestConnex, and an assessment of the cumulative impacts taking into consideration the WestConnex program of works.
Standen’s finding : FAIL
Comment: Cumulative construction impacts for the New M5 and other WestConnex projects have not been modelled/reported. Only a cursory description of cumulative impacts is provided.
The assessment of operational cumulative impacts does not include past/existing developments, in particular existing arterial roads and motorways. Although the economic, social and environmental costs of the proposed New M5 on its own may be considered by some stakeholders to be acceptable, the cumulative costs of this and previous/existing/planned motorway developments 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%.1
- Serious human health impacts due to petrochemical vehicle emissions/smog, including:
- Lung cancer,
- Heart disease,
- Impaired lung development 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.
- Noise pollution from traffic and its impacts on sleep.
- Impacts on visual amenity (pollution stacks, concrete interchanges, concrete flyovers).
- Extreme summer temperatures (urban heat island effect).
- Community destruction and severance.
- Destruction of heritage.
- Irreversible Biodiversity loss.
- Less incidental physical activity from walking and cycling (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.
Meeting objectives of the entire Westconnex
Standen : FAIL
Comment: finds that the project FAILS to meet the Westconnex objectives. This will be covered in Part 3 of this submission.
Impact of New M5 on traffic and transport after start of operation
Requirement: An assessment and modelling of operational traffic and transport impacts on the local and regional road network (in consultation with affected councils), and the Sydney motorway network, including the consideration of planning proposals, major urban renewal and development, the potential cumulative impacts of Stage 3 – M4 South (Haberfield to St Peters), and the impacts of potential shifts of traffic movements to alternative routes outside the proposal area (including as a result of tolls).
Standen Finding : FAIL
Comment :The assessment of operational traffic and transport impacts is limited to a small study area around the project site. However, there will be significant traffic and transport impacts outside the study area, and indeed throughout the whole Sydney metropolitan area.
The assessment of operational traffic and transport impacts ignores delays at new on-ramps and off-ramps.
The EIS does not include any objective assessment or modelling of impacts on pedestrians and bicycles using the local and regional road network.
Pedestrian and bicycle movements have not been included in the strategic model (WRTM) nor the intersection models (LinSig). There is no forecast of the impacts on walking and bicycling travel times and accessibility.
As such the EIS does not provide a complete “assessment and modelling of operational traffic and transport impacts”, it provides only an objective assessment of motor vehicle and public transport impacts within a small part of the area affected.
Requirement: Induced traffic and operational implications for public transport (particularly with respect to strategic bus corridors and bus routes) and future public transport opportunities.
Standen Finding : FAIL
Comment: Induced demand has not been adequately accounted for because:
- The model ignores the induced demand caused by long-term transport decisions of individuals and firms, including:
- Residential location choice – the project will encourage more people to move further from work (sprawl), thereby increasing average travel distances/demand.
- Work location choice – the project will encourage more people to work further from home, thereby increasing average travel distances/demand.
- Car ownership choice – the project will encourage more car ownership and use.
- Firm location choice – the project will encourage firms to locate in locations further away from their labour supply/customers/suppliers than they otherwise would, thereby increasing travel distances/demand.
2. To my knowledge, there has been no long-term evaluation/verification of the methodology used to forecast induced demand (New Zealand Transport Agency Economic Evaluation Manual (EEM)). Induced demand by its nature materialises over several years, as people gradually move home/work location etc. Without a long-term evaluation/verification of the methodology, there can be no confidence in the induced demand forecast produced.
Cyclists and Pedestrians
Requirement: Impacts on cyclists and pedestrian access and safety and consideration of opportunities to integrate cycleway and pedestrian elements with surrounding networks.
Standen : FAIL
Comment: The EIS does not include any objective assessment or modelling of impacts on pedestrians and bicycles using the local and regional road network.
Pedestrian and bicycle movements have not been included in the strategic transport model (WRTM) nor the intersection models (LinSig). There is no forecast of the impacts on walking and bicycling travel times and accessibility.
Requirement: An assessment of construction and operational activities that have the potential to impact on in-tunnel, local and regional air quality. The air quality impact assessment must provide an assessment of the risk associated with potential discharges of fugitive and point source emissions on sensitive receivers.
Comment: An accurate assessment of air quality impacts is dependent on an accurate assessment of traffic and transport impacts. Because the traffic and transport impacts have not been correctly modelled, the air quality impact assessment is worthless.
Human Health Impacts
An assessment of human health impacts.
Comment: An accurate assessment of human health is dependent on an accurate assessment of traffic and transport impacts. Because the traffic and transport impacts have not been correctly modelled, the human health impact assessment is worthless.
Requirement: An assessment of the noise impacts of the proposal during operation, consistent with the Road Noise Policy (EPA, 2011) and NSW Industrial Noise Policy (EPA, 2000).
|An accurate assessment of noise impacts is dependent on an accurate assessment of traffic and transport impacts. Because the traffic and transport impacts have not been correctly modelled, the noise impact assessment is worthless.|
Note: You will find out more about why Chris Standen does not believe the traffic and transport analysis is reliable if you read the other parts of his submission
Here’s a piece Standen published in the SMH last year.