1.0 Objection to the failure of WestConnex, including the New M5, to achieve its stated core objectives

WAG objects to both the failure of WestConnex to meet its stated core objectives and the manner in which these objectives were formulated.

Adapted WestCONnex flyer

The stated objectives for WestConnex were contrived to fit the project after it had already been announced. In a democratic strategic planning process, objectives are set first based on the needs and desires of the community, and then alternative projects/policies are appraised against their ability to meet those objectives. 

The objectives have no associated targets by which their achievement can be ever be determined. Objectives/targets need to be specific, measurable, achievable, relevant and time-bound, and each of the project’s objectives fails on one or more of these measures.

Even though the objectives have been contrived to fit the project, the project still fails to meet them, as detailed below.

Core objective

Objective Met?

Support Sydney’s long-term economic growth through improved motorway access and connections linking Sydney’s international gateways and south-western Sydney and places of business across the city.

NO

The planned route for the WestConnex does not connect to Sydney Airport or Port Botany.

The EIS does not provide evidence that economic growth can be assisted by increased motor traffic to the CBD.

There are serious flaws in the proponent’s traffic modelling.

If WestConnex leads to more traffic congestion in the inner west, parts of south-west Sydney and routes into the CBD as most independent experts and even this EIS admits it will, the project will not improve access to businesses. Congestion and traffic will only worsen, not just on the New M5 and other parts of WestConnex, but on the surrounding road network. 

Should Badgery’s Creek airport be built, the emphasis on Sydney Airport is likely to be misplaced, as this hub is likely to act as a more appropriate international gateway for many air freight movements given its proximity to western Sydney freight facilities, as well as western Sydney residents. 

There are better ways of spending $16.8 billion that would deliver greater long-term economic growth, including:

·      improved road and rail access to Port Botany

·      improved public transport between Western Sydney and Sydney’s various CBDs

·      improving ring roads in Western Sydney

·      supporting and developing businesses in Western Sydney

There is already an extensive road and motorway network linking Sydney’s international gateways (Sydney Airport and Port Botany), Western Sydney and places of business across the city. The operation of this network could be improved significantly with demand management such as road pricing reform. There is no need for costly and destructive new motorways.

The most efficient and economic way to link large trip generators is with mass transit. A single motorway lane can transport only 2000 passengers per hour, under ideal conditions. A single railway line can transport 20,000 passengers per hour.

 

Relieve road congestion to improve the speed, reliability and safety of travel in the M5 Motorway corridor.

NO

The improvements in congestion claimed for the project arise from measures that can be separated from the rest of the project – namely the charging of tolls for using the M5 East and New M5.

Absent congestion charging, or similar, the laws of induced traffic means that increasing road capacity increases traffic volumes; it does not reduce congestion over the long term, if at all.

Charging for the M5 and New M5 without congestion charging on alternate routes will increase, not reduce, congestion on those routes.

Many intersections will remain at the lowest Level of Service (F) even if the project, including the New M5, is built.

The second sentence seems to assume rather than demonstrate that this objective is met by stating that diverse travel needs are ‘best met by road infrastructure.’

Claims by WestConnex that the project will improve speed and reliability depend on the reliability of its approach to traffic modelling, which experts argue are flawed. 

There is no evidence that increasing road capacity and building urban motorways can relieve road congestion in the long term, because the added capacity simply induces more demand.

As travel speeds increase, so do travel distances, i.e., increasing the speed of the road network encourages urban sprawl. Perversely, this sprawl has the effect of reducing the population’s accessibility to employment, education and services, and increasing transport costs, because people have to travel longer distances.

Road congestion is inevitable in any large city in the absence of adequate demand management. There can never be enough road capacity to satisfy the latent demand for driving, where everyone can live as far from work as they like, and drive whenever they like, to wherever they like in free flowing traffic. It is geometrically impossible.

Congestion on Sydney’s roads is the main thing keeping private vehicle travel demand in check. If this congestion is relieved temporarily by increasing the road supply, then demand will increase until limited by the resulting congestion. 

A better objective would be to give as many people as possible a more pleasant and faster alternative to sitting in traffic – particularly drivers of single-occupant vehicles who make up the vast majority of peak-hour traffic.

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 are effective in meeting the project objective (reducing congestion), then there is no rationale for adding more capacity.

More intersections in the study area will have an LOS of F with the project than without it in 2021.

 

Cater for the diverse travel demands along these corridors that are best met by road infrastructure

NO

The majority of traffic movements are fungible, and highly responsive to environmental changes including: provision of alternate modes of transport, (for e.g. public transport); provision of alternate traffic generators (for e.g. increased local employment opportunities); and cost and other signals (for e.g. congestion charging).

Catering more adequately for travel demands that are not ‘best met by road infrastructure’ also has the advantage of releasing road capacity for road users with no alternatives (within the limitations imposed by induced traffic) and potentially at a lower overall cost that proper process would have seen explored as an alternative to this project. 

There is already more than sufficient capacity along these corridors to cater for all the essential vehicle travel, particularly if alternative strategies such as demand management and public transport investment are implemented.

 

Enhance the productivity of commercial and freight generating land uses strategically located near transport infrastructure

NO

The planned route for the WestConnex does not connect to Sydney Airport or Port Botany.

This is a reference to faster travel times that should enhance the productivity and attractiveness for businesses along the WestConnex route. It also relies on traffic modelling predictions being accurate. Modelling has failed for some past projects leading to business failure. It’s also not clear exactly what this is referring to and in the absence of a transparent business case, it’s not possible to evaluate the ‘enhanced productivity’ of land uses.

This objective could be more easily and more economically achieved by improving the operation of the existing road network with demand management, e.g., road pricing reform. 

It has to be questioned whether a highly populated inner city area is the optimal location for some commercial and freight generating land uses. Could some of it be moved to less populated areas, where the transport costs and externalities are lower? There is evidence this is already happening in places like Moorebank; this would render this objective, and much of the justification for WestConnex, moot.

 

Fit within the financial capacity of the State and Federal Governments, in partnership with the private sector

NO

The EIS does not include the business case. Until the full business case is released - i.e. one in which critical information such as the cost and toll revenue figures have not been redacted - and been independently verified, it cannot be assumed that the project fits within the financial capacity of the State and Federal Governments. It has already been made clear that the private sector will not be funding this project unless and until the toll road becomes profitable precisely because of concerns about its viability.

Billions of dollars of public money are being paid to private companies, and the public not the private sector carry the risk on this project. Such a one-sided relationship can hardly be described as a “partnership”. Currently we do know that the WestConnex will absorb billions of Federal and State funds – not to mention toll revenues from motorists – that could be spent on alternative projects with better and more sustainable returns.

There is a high risk of toll revenue from the project not meeting forecasts, resulting in financial losses for the government at state and federal level – which of course, are losses that be borne by NSW and Australian taxpayers.

The cost of the overall WestConnex project is currently blowing out at the rate of over $2 billion a year. It came with a price tag of $10 billion at its inception in 2012; it is now a muti-tollway project that comes with a $16.8 billion cost. At this rate the final cost would be double that by the time stages 1-3 of WestConnex are due for completion in 2023.

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).

 

 

Optimise user-pays contributions to support funding in a way that is affordable and equitable

NO

The proposed cost model will not be affordable for many residents, particularly when high parking and vehicle running costs are added to the equation. The tolls are likely to be even less affordable for residents from western and south-west Sydney, where the mean income is below that of residents in the inner city.

Numerous studies have shown that irrespective of income, drivers are extremely sensitive to tolls. This has been ably demonstrated by the financial failure of the last four toll roads built in Australia, including Sydney’s Lane Cove Tunnel and Cross City Tunnel.

More than 99% of the NSW population will not use the project each day, but they will still have to pay for it through general taxation. 

Many of the potential users will be from low-income households who cannot afford to live near employment centres or railway stations. They will have to pay high tolls while higher-income households have access to cheaper roads and public transport. This is hardly equitable.

 

Provide for integration with other WestConnex projects and the proposed Southern extension, while not significantly impacting on the surrounding environment in the interim period

NO

The project proposes significant environmental damage both during the construction period for the New M5 and the future operation of this tunnel if it is built.

The EIS acknowledges there are significant impacts in relation to noise, loss of housing, destruction of heritage, and destruction of or serious threats to endangered flora and fauna.

Already on the M4 widening, there are issues with asbestos waste that was not properly assessed in that project’s EIS, while at Beverly Hills noise walls have been stripped away from the M5 and will stay down for months longer than originally predicted by the King Georges Road Interchange upgrade EIS. It is difficult to believe such construction issues will not eventuate with the New M5 if it proceeds. 

There is a high risk that future stages of the WestConnex scheme will never go ahead, due to the likely financial failure of the preceding stages.

The proponents are also increasingly relying on other unplanned and unfunded tollways, particularly the Sydney Gateway and southern extension, in order to make its traffic model work. There is also a high risk of these projects not proceeding.

 

Manage tunnel ventilation emissions to ensure local air quality meets NSW Environment Protection Authority (EPA) standards

NO

The emissions from the exhaust stacks and tunnel portals will not be filtered.

Local air quality near the project is already poor, with air toxin levels regularly exceeding standards. Even when they do not exceed standards, they still cause health problems. There is no safe level of air pollution.

The project will result in poorer local air quality. The air quality modelling in the EIS is worthless because it is based on flawed traffic modelling.

 

Maintain regional air quality

NO

Regional air quality in Sydney is already poor, with air toxin levels regularly exceeding standards. Even when they do not exceed standards, they still cause health problems. There is no safe level of air pollution.

The project will result in poorer regional air quality. The air quality modelling in the EIS is unreliable because it is based on flawed traffic modelling.

 

Manage in-tunnel air quality to stringent air quality standards

NO

The in-tunnel air quality will be poorer than that for surface roads. People using the tunnels on a regular basis will have a higher risk of lung cancer, asthma, heart disease and other diseases. The health of children being driven through the tunnels is a particular concern.

 

Minimise energy use during construction and operation

Roads are one of most energy-intensive ways of moving people and freight. Road construction is also energy-intensive.

The project will encourage longer travel distances (sprawl), which will result in increased transport energy use.

The project will encourage travellers to switch from energy-efficient public transport to energy-inefficient private vehicles.

Transport energy use could be better minimised by:

  • Providing for energy-efficient transport modes (public transport, walking, bicycling).

  • Land use planning that places homes closer to employment and other destinations.

Manage noise impacts in accordance with the NSW Road Noise Policy and realise opportunities to reduce or mitigate noise

Traffic volumes on surface roads will increase, resulting in increased noise pollution.

The noise assessment shows that hundreds of homes will experience noise above acceptable levels. In fact 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.

The noise monitoring performed in this EIS has been too limited to properly assess the massive noise that will be generated by construction and operation of this project, and the impact it will have on the hundreds of thousands of Sydney residents who would be exposed to and affected by it. It is likely that these impacts will be severe for many residents.

Provide for improvement of social and visual amenity

The project will reduce social and visual amenity.

  • The concrete interchanges and pollution stacks will be visually obtrusive.

  • The increased traffic volumes on surface roads will result in lower amenity (more noise pollution, more fear and intimation, increased crash risk etc.).

  • The increase in petrochemical exhaust emissions from the tunnel portals, pollution stacks and surface roads will result in increased smog and reduced visibility and air quality.

Minimise impacts on natural systems including biodiversity

NO

The project proposes significant environmental and cultural damage, rather than enhancement or protection.

The project proposes the destruction of endangered and critically endangered flora and fauna, the protection of which was a condition of approval for the current M5. For the proponent to insist that these should now be destroyed because this motorway was a failure renders such environmental protections meaningless, and the process a farce.

The proponents’ claim that WestConnex will reduce emissions (which could be held as minimising the impact on the environment) does not hold up. No credible authority in the world today would suggest that building freeways is the solution to cutting national greenhouse emissions. 

The overall increase in VKT and increased traffic volumes on surface streets will result in poorer air quality and more noise pollution.

The project will directly cause irreversible biodiversity loss, and indirectly through increased greenhouse gas emissions that will contribute to climate change and damage natural systems. 

The project will result in increased VKT, and therefore more contaminants (brake and clutch dust, hydrocarbon particulates etc.) being deposited on roadways and washed into waterways. 

The project is not a sustainable development either economically or environmentally.

 

Minimise impact on Aboriginal and non-Aboriginal cultural heritage

NO

A number of heritage buildings will be destroyed if this project proceeds. Others will be left marooned, surrounded by construction compounds and then traffic.

Protect surface and groundwater sources and water quality including management of contaminated areas

NO

The project will result in increased VKT, and therefore more contaminants (brake and clutch dust, hydrocarbon particulates etc.) being deposited on roadways and washed into waterways.

Reduce susceptibility to, and minimise impacts of, flooding

NO

The project will contribute to climate change through increased greenhouse gas emissions. This will increase the risk of flooding and other extreme weather events, not just in Sydney, but worldwide.

A number of roads in St Peters within the project footprint are already subject to heavy flooding. Adding even more surface roads and removing green space to do so will only worsen this.

Integrate sustainability considerations throughout the design, construction and operation of the project, including consideration of the Infrastructure Sustainability Council of Australia (ISCA) Sustainability Rating tool scorecard

NO

The project is not a sustainable development.

  • Not economically sustainable. The costs far outweigh the productivity benefits.

  • Not socially sustainable. It will destroy and sever communities, and result in poorer public health, more car dependency, more transport inequity, and more social isolation.

  • Not environmentally sustainable. It will result in higher greenhouse gas emissions and irreversible biodiversity loss. 

Conclusion 

WAG formally and strongly objects to the WestConnex project, including the New M5, on the basis that it will not even meet its contrived core objectives, and we ask that the Minister for Planning reject the WestConnex New M5 project.

 


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