We've broken up our 200-page submission to the WestCONnex New M5 environmental impact statement (EIS) into sections to make it easier for you to work through them. This section contains our cover letter; others contain specific objections split by subject area.
Submission to EIS for project SSI 14_6788 WestConnex New M5
This document contains the formal submission made by WestCONnex Action Group Incorporated (WAG) to the WestConnex New M5 environmental impact statement (EIS).
WAG is a community group made up of residents from across western, inner and south-west Sydney. We are not affiliated with any political party.
WAG strongly objects to the New M5 project based on the information contained in this EIS, and to the WestConnex proposal as a whole. We ask the Minister for Planning to reject this proposal.
We have a huge number of objections to the project but also to the approach taken in the EIS itself. We agree with the City of Sydney that the inadequacy of the New M5 EIS is “so profound” that should not be used as a basis for a Ministerial determination to approve the project. The EIS as a whole should be rejected.
WestConnex as proposed is the wrong solution at the wrong time for Sydney. It is out of step with international best practice when it comes to transport policy and the creating liveable, economically viable cities in the 21st century.
Experience and research from independent experts here in Australia and overseas has shown that these kinds of toll road mega-projects are hugely expensive and do not ease congestion over the long term. If anything, such projects make congestion worse by increasing overall traffic volumes as the new road capacity quickly fills up. WAG has yet to hear of an independent transport expert who backs the project. Even the EISs produced for the various stages of WestConnex show it is not a long-term solution to Sydney's congestion problem.
In addition, WestConnex will divert billions of dollars of NSW and Federal taxpayer money into a tollway that only 1% of people in NSW will use. If its huge and rapidly escalating $16.8 billion cost was invested in more sustainable transport options instead - such as public transport improvements in western and south-west Sydney, better management of Sydney’s existing roads, and so on - it would not only be likely to reduce congestion and improve mobility in our capital. It would also free up much-needed public funds for improving roads, public transport, schools and hospitals in regional NSW. Spending it on a tollway that so few people will use is both wasteful and deeply unfair.
The strategic justification for the New M5 is weak and inconsistent with the NSW Government’s strategic planning and policy framework, despite its inclusion in the 2012 State Infrastructure Strategy and the Long Term Transport Master Plan. The project as proposed in this Environmental Impact Statement (EIS) does not deliver the broader objectives of WestConnex as stated in the Updated Strategic Business Case (November 2015).
There has been no compelling case made for why WestConnex should be built, and the project should not receive approval and not proceed. This EIS and the Updated Strategic Business Case for WestConnex are clear that the benefits accruing from Stage 2 do not outweigh the costs. Benefits are shown to come once the whole WestConnex project is built according to the Updated Strategic Business Case, and that no benefits exist until all three Stages are delivered (WestConnex Full Scheme: Economic Appraisal, KPMG, 19 November 2015). I am aware that even this has now expanded to include other tollways such as the Sydney Gateway, making it even more likely that this project will provide disbenefits to society if it proceeds as proposed in this EIS, i.e. as a standalone project. This is particularly concerning given there is a significant risk that Stage 3 will not be built.
This EIS is of a very low standard and fails to provide meaningful evaluation and assessment of the WestConnex New M5. Instead, the document reads like an advertisement for the New M5 and associated road works, rather than as a critical examination of the environmental impacts of the project. Parts of the proposed project are described only with subjective, conditional language such as "where feasible", while not providing any meaningful detail, and implying no requirement to meet objective standards. Some results are provided in context, whilst others are provided as numbers without a context, and yet others are essentially lists of things that have not yet been surveyed or planned. As such, we contend that the project has not had a meaningful EIS conducted or published.
The EIS lacks rigour and sound analysis, despite the huge volume of documentation. This lack of rigour and analysis is consistent across all chapters and appendices. The project objectives are biased towards a motorway solution, so that any proposed alternative falls short of the proposed solution. Similarly, the work undertaken in the EIS is highly compliance driven, and fails to take into account opportunities or strategic impacts, and the assessment of cumulative impacts is almost negligent.
WestConnex is presented as a ‘transformational’ infrastructure project, however, the EIS is not clear on what transformation it will achieve. There is no demonstration that WestConnex delivers transformation in terms of social or economic improvement, or better land use outcomes. To the contrary, WestConnex will deliver a piece of infrastructure that increases traffic on local roads, does not enable value capture or urban renewal, and is not consistent with the government’s land use priorities or the proposal in the 2012 State Infrastructure Strategy.
A larger question raised by the proposed New M5 project is what happens if capacity on this motorway is reached? The existing M5 East has proven that a new motorway can easily reach or exceed capacity within a 15 year timeframe. If that outcome is realised for the New M5, Sydney will be left with a transport legacy that cannot support the jobs growth in the west consistent with Government policy. Sydney needs to manage demand for existing road assets to maximise economically productive use and deliver sustainable transport as a real alternative to car travel. International cities such as Los Angeles are moving away from their dominant car-based culture to invest in public transport in order to build the sustainability and attractiveness of their city for residents, businesses and visitors alike.
The New M5 project has only been assessed to 2031, which does not take into account the 45 year concession period for the asset as stated in the WestConnex Updated Strategic Business Case. The assessment does not account for future events that may radically change travel demands or behaviours.
The EIS assumes that by 2031 the full WestConnex project will be complete. This includes the M4-M5 Link (Stage 3), which will have additional significant impacts on residents and businesses. Nowhere in the EIS are these impacts considered, nor information given to the public to fully consider or understand the implications of the whole WestConnex program.
The evidence provided by the EIS in support of the project is incomplete and unbalanced, selectively including and excluding impacts from subsequent planned stages of the WestConnex project. The analysis of strategic alternatives in the EIS is cursory and fails to demonstrate the New M5 extension is the best option to meet the needs of a growing Sydney population. The EIS also does not take into consideration the travel patterns of residents and businesses in western or south-western Sydney that the New M5 is intended to serve, nor the wider impacts on inner-Sydney communities affected by the WestConnex program.
The statement that the New M5 project is an integrated transport project is false and misleading. It is a motorway that does not provide for improved public transport connections and has not fully considered the active transport component in line with government policy. The government could have delivered a better outcome by focusing on ways to “improve access” that is modally agnostic and more consistent with government’s land use policies.
We recognise there is pressure on several NSW Departments, including Planning and the Environment, to approve this project, particularly as contracts have already been signed for the New M5 ahead of such approval being granted. We remind public servants of their obligation to the public and to the potential social, health and economic costs of spending $16.8 billion on WestConnex when it provides no solution to Sydney's transport needs.
In order to make this submission, WAG has consulted with and/or reviewed evidence provided by a wide range of experts, including transport planners, environmental organisations, scientists, transport economists, local councils, medical professionals, social workers, investigative journalists, and more. Combined with our own primary research and review of the EIS, this leads us to not only strongly object to the proposal as a whole, but to raise many specific objections in regards to many areas of this EIS.
As ordinary citizens, we have had to increase our knowledge of a range of new fields including transport, social planning and biodiversity studies. What really disturbs us is that we have encountered so much serious independent and academic opinion and research that runs counter assertions in the EIS, yet none of this is engaged with or reflected in the EIS. SImilarly we noted that in the Response to Submissions in the EIS, there was no engagement with critical analysis.
WAG asks that the Department rejects this proposal on the basis of this EIS. We expect a detailed response to each of the objections we have raised in this submission, and that you will publish this submission in accordance with the undertaking on your website.
Please send your acknowledgement of this submission and your response to our objections to us at:
WestCONnex Action Group
Address details followed here, but we've removed them from the website as it's also a home address.