( Ed: Dr Victor Storm is a psychiatrist who has spent much of his life living and working in the Inner West. He now lives in Haberfield, in the heart of a community where many are losing their homes or will be badly affect by the M4 East. People’s M4 EIS published his submission to the M4 East EIS. This project is still being assessed by the Department of Planning. Victor Storm objects to the whole WestCONnex. His submission to the M5 EIS took the form of a letter to the Secretary of the Department Carolyn McNally.) .
Ms C McNally
Department of Planning and Environment
re: WestConnex New M5 EIS, project number SSI 14_6788
I strongly object to this project and the entire WestConnex of which this is part, and ask that you reject this proposal on the basis of this environmental impact statement (EIS).
I object to the fact that the process and rationale for Westconnex has been constructed after the fact. This is the core problem. Someone had a thought bubble and managed to convince a number of others that building Westconnex was the solution to Sydney’s transport woes.
A new Federal government with a desire to be seen to be in action and state government wishing to be seen as open for business were caressed and conned by large engineering firms desperately seeking work as state sponsored finances shrank in Europe & Asia. A $10 Billion project has grown to $17 Billion & is yet to include costs for the links to the port & airport, so the prediction of $20 Billion price tag does not seem far-fetched. This demonstrates that the politics of the process jumped ahead of the planning logic.
I object to the fact that this project did not arise from answers to core questions such as:
What would be the best investment outcome to reduce Sydney’s traffic congestion?
How would you best invest $20 Billion of public funds to improve the productive life of Sydney’s citizens?
As a consequence of the failure to address these issues, we are left with a proposal based on flawed and faulty logic. The proponents engage in a circular argument, which is that the project is fundamentally the best solution and therefore any alternate ideas or proposals are inadequate because they do not result in what we already believe to be the best solution. However even in the current fragmented forms of the to date serial EISs for the M4x2 & M5; they all acknowledge that the core objectives will not be met & that significant traffic failure will occur across the road network.
Worldwide research and experience has demonstrated repeatedly and conclusively that these kinds of toll road mega-projects are very expensive and ineffective. WestConnex will induce more road traffic and increase air pollution for thousands of residents and workers. It will also expose NSW taxpayers to unacceptably high levels of financial risk. The EISs produced to date for the various stages of WestConnex all show that the proposal it is not a long-term solution to Sydney’s congestion problem.
I also strongly object to a number of specific aspects of this EIS, and I expect you to publish this submission and send me a written response to each of the objections I have outlined below.
I object to the fact the planning processes surrounding this project and WestConnex as a whole have been utterly distorted and corrupted. For example, key parts of the business case still remain hidden from public scrutiny, even though it is being funded by taxpayer money. Homes and businesses are being forcibly acquired, multi-million and/or billion-dollar contracts have been let, and construction works have occurred place before any planning approvals are granted for this project. The entire WestConnex, including this project, has been characterised by poor governance, and a complete lack of transparency and accountability. Community consultation has also taken place only after detailed plans have been drawn up, so the general public has little to no input on a project that will affect hundreds of thousands of people’s lives for many years to come.
I object that this project will cause immense social harm. It will destroy long-established communities. The manner in which the social and economic impact study dismisses these concerns from affected communities, demonstrates the analysis is weak and inadequate. There are numerous ways of spending $17 billion that would deliver a much greater social and economic benefit, and would not cause so much destruction. Such alternatives are barely mentioned in this EIS and have certainly not been analysed as required by the project SEARs.
I object because this project will directly cause an increase in air pollution. Consequently there will be increased air pollution related deaths and illnesses. The increase in air pollution will inhibit lung and nervous system development in children. The rhetoric within the EIS about improved air standards implies that the increased traffic and congestion will not cause local hot-spots. This demonstrates magical thinking. If there is increased road traffic & it has to exit the road system, it will exit into already congested streets. The fantasy of free flowing traffic is just that, fantasy. The reality is that the new proposal, if built, will become saturated and the current problems will only get worse. The proposal is no solution and must be rejected
I object that this project is diverting billions of dollars of NSW and Federal taxpayer money into a tollway that only 1% of people in NSW, most of whom are based in Sydney, will use. $16.8 billion invested across the state would go a very long way towards improving existing regional and city roads, public transport, schools and hospitals. Spending it on a tollway that so few people will use is both wasteful and deeply unfair.
I object because if this project and other parts of WestConnex go ahead, the residents of western and south-west Sydney will be forced into even greater car dependency and paying large tolls to use this road. It is unacceptable that no attempt is made in this EIS to assess the impact alternatives such as increasing public transport capacity and connections within these areas combined with improved traffic management would have on reducing congestion and improving access to jobs for people in these suburbs.
I object that this project will provide no solution to traffic congestion, as the EIS shows that several intersections across the project route will remain at Level of Service F (i.e. the worst possible level, and the one that is indicative of system failure) after the project.
I object because the New M5, if built, will cause costly traffic chaos throughout the inner west and south-west Sydney. It is unacceptable that no traffic modelling was done beyond a very narrowly defined area – as little as two intersections past the end of the project. This blinkered view should be rejected.
I object because the roads around the St Peters interchange are already at an unacceptable Level of Service and are getting worse because of in-fill developments not accounted for in this EIS. This interchange has been positioned in what will be the most densely populated area in Australia. There is no evidence that this EIS has factored in this huge increase in density.
The EIS does however clearly demonstrate that traffic on roads around the St Peters Interchange will deteriorate as a result of WestConnex, as well as already heavily congested roads in Bexley, Rockdale, Brighton-Le-Sands and Kingsgrove. For example, according to the business case, Euston Road is supposed to handle 61,000 cars on 3 lanes each way. This is almost 10 times what it can handle on 2 lanes. There is no way it can handle 61,000 cars, however many lanes are added to it, because the streets around it are already at capacity. As another example, traffic on Stoney Creek Road was forecast to increase by 74%, with a total of 2280 big truck movements a day — three times more than now.
I also object that the EIS projects that the existing M5 and New M5 combined will take less traffic now than the Cross City Tunnel, which was a financial disaster. This is because the proponents know commuters will be unwilling to pay $6 each way to use either of these toll roads. The assumptions behind the EIS’s prediction that drivers will somehow decide to start paying this toll years after the toll road opens are not explained, and this has not been the experience with other recent toll road failures, including the aforementioned Cross City Tunnel. These contradictory sets of information demonstrate further that the proponents are not sure what will occur and that it is unclear how the proposed project can meet its objectives.
I strongly object to the fact that AECOM, which has a record of failed traffic modelling, has been paid $13 million of taxpayer money to complete this EIS even though it has been awarded other WestConnex contracts that depend on the project going ahead. This is a clear conflict of interest. The public cannot trust that this EIS properly and fully investigate the true economic, environmental and social impacts of this project, and indeed the poor quality of this document reflects this. The EIS is riddled with errors, basic omissions, superficial analyses, and opaque modelling, and should be rejected on this basis alone.
I object that Billions of dollars of construction contracts have been let for this project before this EIS was lodged. This casts huge doubts on the legitimacy of the community consultation process, and places unreasonable pressure on the Department of Planning and Environment to approve this project regardless of its flaws.
I object to the fact that thousands of residents and workers will be exposed to health impacts in all areas where demolition, earthworks, construction and removal activities would place. This includes communities in Arncliffe, Kingsgrove, Beverly Hills, St Peters and Alexandria. These health risks are rated as HIGH for all areas. Noise, Dust and general interference with daily patterns of life will all impact on peoples’ health and wellbeing. Mitigation is recommended, but no firm information is available about who might receive this and what it might be. Instead, decisions are put off until after approval – and in some cases the beginning of construction. This is completely indefensible and communities cannot be forced to accept this.
I object to the proposal that tunnelling activities would need to be conducted 24 hours per day, seven days a week – including associated activities such as spoil handling and haulage – is not tolerable and unacceptable. These activities would also cause vibration and damage to homes. In some cases, tunnels and tunnelling would take place less than 20m below people’s homes. This is not acceptable, particularly given the collapse of buildings that took place during the Lane Cove Tunnel’s construction, and the legal action residents above Brisbane’s Airport Link are now being forced to take after experiencing property damage.
I object that the air quality study shows that some communities will be exposed to increased doses of dangerous pollution, especially those living close to surface roads and unfiltered ventilation stacks. I am particularly concerned about residents on hills and in high buildings in Kingsgrove, St Peters, Arncliffe and Alexandria, who are likely to be subjected to high levels of these pollutants.
Scientific experts agree there is no safe level of fine particle pollution. Rather than aiming to shift dangerous pollution from area to another, the government should be finding cleaner transport solutions that do not leave residents living beside polluted roads or unfiltered pollution stacks – no matter where they live.
The analysis of alternatives to WestConnex provided by AECOM in this EIS provides no solid evidence for the conclusions drawn. A combination of demand management of traffic and new public transport projects, especially for western Sydney, along with alternatives for goods transport from the ports, should have been explored. These are just some of many potential alternatives that could have provided more effective, sustainable and cost-effective ways of easing congestion that AECOM has failed to adequately analyse.
I object because the noise assessment demonstrates that hundreds of homes will experience noise above acceptable levels. The real impact is likely to be far worse than the results provided in this EIS, because noise monitoring was only done for one location at Beverly Hills and one in St Peters, where only 30% of results could be included. Such limited evidence provides the community with no confidence in the conclusions reached in this EIS. Independent experts have also reported that some of the tables are inaccurate in the noise report and are therefore not reliable.
I object that the proposal results in significant environmental damage. Community parks, an endangered Green and Golden Bell Frog colony, critically endangered Cooks River Castlereagh Ironbark Forest and trees along the M5 East would be destroyed for these projects if it proceeds. Some of these, such as the endangered flora and fauna, were species that the RMS was legally obliged to maintain and protect as part of construction for the M5 East. Others, such as the M5 Linear Park and trees lining the noise walls, are spaces the local community has built up over many years after their community was carved up the M5 East. It is not acceptable for the proponents to simply sweep aside earlier requirements and undertakings for this toll road. These proposals must be rejected, for if not it would be both undemocratic and a grave violation of the government’s environmental and legal responsibilities.
I object to the fact that the project’s proponents have misled the public about its plan to take 14,000 square metres of Sydney Park. For months it said it would only take 8,000 square metres, leaving it until the EIS was lodged to inform the Council that it planned to forcibly acquire the rest. This will diminish the enjoyment of the park in many ways. Peaceful paths, exercise equipment, children’s play areas and sporting grounds, and more will all be adjacent to a major highway. This is completely unacceptable.
I strongly object to compulsory acquisition of so many homes and businesses and the arrogant way the impact of this on communities is dismissed in the EIS. I also object to the process by which these acquisitions are taking place, which the NSW Government was told three years ago was deeply unfair to people whose properties were being forcibly acquired. It is clear from the number of home and business owners who have had their properties seriously undervalued by the RMS that such changes were not implemented, and in fact the government appears to have become systematically aggressive and unfair in its approach to forcibly taking properties for this project and other parts of the WestConnex. Valuable heritage buildings in St Peters will also be destroyed and/or left marooned and surrounded by tollway and congested roads.
I object that that here are no clear plans of where millions of cubic metres of mined spoil will be deposited in communities in western Sydney. None of these communities have been given information or consulted about these impacts. This is unacceptable.
I therefore respectfully ask that you reject this proposal, publish my name and submission in accordance with the undertaking on your website, and provide a written response to each of the objections I have raised.
January 27 2016