General Submissions

 

 

Eds: Here are sample submissions that focus on a range of issues relevant to Stage 3 WestCONnex. 

Most of these submissions are written in the first person but you can easily change it for a group submission or use part of it for an information sheet. You can also:

  • copy and paste whole or part of this submission for your own submission or share it with others
  • use it to trigger your own ideas
  • use some it and mix it with objections on other topics relevant to the EIS ( for example Air Quality).

When you have finished drafting a submission, here’s the link to ouronline submission. Remember you can make as many submissions as you like. 

Submission to WestConnex New M4/M5 EIS, project number SSI 16_7485

EIS should be rejected as it is ‘Indicative only’

The EIS is a strategy only document. It does not commit to any design and it therefore does not address any local impacts created by the proposed M4-M5 Link. Rather it prepares the pathway for sale of the Sydney Motorways Corporation to the private sector. If this privatisation goes ahead, the new owners and its contracting companies will be handed the handed responsibility for oversight and control of the final design, and cost and implementation of the M4-M5 Link. This is a frightening prospect for residents who have already experienced or observed others experiencing the terrible impacts of the Stages 1 and 2.

The EIS repeatedly states ‘the detail of the design and construction approach is indicative only based on a concept design and is subject to detailed design and construction planning to be undertaken by the successful contractors.’

For this reason alone, NSW Planning must not approve this project as it does not contain any certainty for residents as to what is proposed and therefore provides no proper basis on which the project can be approved. This entire process is a sham. If it is approved, no one will know to what extent concerns will be taken into account as the contractor can simply submit further changes. 

The contractor would not be  bound to take into account community feedback . Give that the contractor will be trying to deliver the project as quickly and cheaply as possible, it is unlikely that the additional measures proposed in the EIS  with respect to construction noise mitigation, for example, would not be adopted.

The EIS should not be approved on the basis that it does not provide a reliable basis on which to base the approval documents. It does not provide the community with a genuine opportunity to provide meaningful feedback in accordance with the legislative obligation of the Government to provide a consultation process because the designs are ‘indicative’ only and subject to change. Because of this the EIS is riddled with caveats and lacks clear obligations and requirements for project delivery. The additional effect of this uncertainty is that the community and other stakeholders, such as the Council, will be unable to undertake monitor compliance as the conditions are simply too broad and lack any substantial detail.

As has been seen with the M4 East and New M5, general conditions nearly always allow discretion and in practice are of little use to residents who have confronting horrific noise at night that damages health.  For example, normal work hours are generally meant to be applied but can be varied on application. As residents have found on the King Georges Interchange, M4 widening, M4 East and New M5 projects, contractors often do not bother to notify residents when they are breaching normal work hours. While this could seem a small thing, it can lead to sleepless nights and severe anxiety. 

Failure to meet stated strategic objectives

The Stage 3 EIS failed to provide evidence that WestConnex will meet its primary objectives of providing a direct motorway connection between Western Sydney and Sydney Airport and Port Botany.

Overlap in Construction Impacts

There are overlaps in the construction periods of the New M5 and M4 of up to one year. This will significantly worsen impacts for residents close to construction areas. No additional mitigation or any compensation is offered for residents for these periods.(Executive Summary xxvii).  It is unacceptable that residents should have these prolonged periods of exposure to more than one project. The EIS makes no attempt to seriously research the current impacts on residents, measure what the cumulative impacts would be or make suggestions that would mitigate the cumulative impact of these prolonged periods of construction noise exposure. 

Accountability handed to unknown private operator

I am completely opposed to privatisation being pursued by the NSW government. Stage 3 has not been approved. Other tollway projects, which are included as part of the justification for this project, do not even have a business case. NSW Planning approval is meant to be a way of safeguarding communities but once the project is sold, the government will no longer carry responsibility for the project. There has already been a huge problem with breaches of conditions on Stages 1 and 2. It is frightening for residents to imagine what it will be like if so much power over their lives is granted to a transnational consortium.

Lack of consideration of alternatives

Under the Secretary’s requirements, the EIS is supposed to provide an analysis of alternatives, including potential public transport alternatives.  ( SEARS 2 (e)). The EIS fails to meet this requirement. There is broad brush discussion about the need for the project without any detailed analysis of why other solutions including the one developed by the City of Sydney could not be pursued. Given the billions involved in this project, a detailed analysis of potential alternatives should be required.

Long lasting inequitable impacts ignored in EIS

The project will increase intergenerational equity by failing to provide public transport alternatives, embedding car dependency in areas of Sydney that are not adequately served with public transport and discriminating against those who cannot afford to pay tolls. People will be forced to choose between spending an increasing proportion of income on tolls or travelling on slower congested routes.

The EIS acknowledges that the project would have a legacy of traffic congestions which means that whole communities would not only have  had their quality of life severely impacted by construction for up to eight years,  but those same communities will be left with the health impacts of traffic congestion.

Business case does not justify moving to this EIS

SGS Economics and Planning was commissioned by the City of Sydney to undertake an analysis of the  Updated Business Case,  which  the NSW government reluctantly released in late 2015.  SGS found that

  • the Business case found a Benefit Cost Ratio (BCR) as 1.71 when it should have been  1.64.
  • the construction costs appear too conservative – if these were to increase, the BCR would reduce accordingly. (This is particularly relevant to Stage 3 because the construction costs of the Rozelle Interchange would be huge because of the design and technical challenges of building overlapping tunnels underground. Also the Sydney Gateway was originally part of the project but has now been moved out of WestConnex.)
  • modelling for post-2031 conditions was not undertaken, however benefits were assumed to continue until 2052.
  • the Business Case did not reflect global approaches to congestion management, such as transit investment and demand management.
  • the Business Case suggested WestConnex would help renew Parramatta Road by reducing traffic on it, despite the modelling showing that many parts of it would carry more traffic, not less.
  • travel time savings were a key component of the positive BCR. A significant number of these supposed benefits that were supposed to arise from travel time savings were within the margin of error of modelling, or were so small that motorists might not notice them (and therefore would not value them).

In fact as a result of considering these and other factors, SGS consulting found that the actual BCR of the project could be less than 1:1, with NSW taxpayers exposed to the risk that the project may not succeed.

Read the full SGS Consulting Report or other reports on the SGS critique of the WestConnex business case can be found here and  here

Costs not taken into account mean benefits are overstated

The EIS relies on the WestConnex business case. This means that many of the errors in the business case are repeated in the EIS.  In assessing the social and economic impacts, the EIS for Stage 3 fails to account of many of the costs including:

  • cost the reductions in public transport, especially the loss of fare revenue.
  • loss of heritage to the whole community (not just property owners)
  • road widening that is made necessary by traffic congestion exacerbated by WestConnex

The People/s EIS considers that the NSW government is currently falsely holding the costs of WestConnex to $16.8 billion while it moves towards privatisation. The total costs are likely to be closer to the City of Sydney’s estimate of $45 billion. It is very likely that the true BCR of WestConnex would be less than 1:1. It is not acceptable for NSW Planning to exclude this important point from its assessment because these cost benefit assumptions are clearly built into the EIS including the Social and Economic Impacts study. 

Independent assessment is needed

The NSW government wants to turn the approval of the  EIS into a foregone conclusion. The People’s EIS asks NSW Planning staff to approach the issues as planning professionals and not be bulldozed by NSW politicians.  Despite the Critical Infrastructure provisions that rule out legal appeals and hearings, there is no legal impediment to this assessment process being a genuine one.

The NSW Planning department must not ignore City of Sydney and independent experts but should investigate their views thoroughly during the assessment process.

Lack of tranparency

Public consultation cannot be meaningful when so much is hidden from the public and so much is uncertain.

Land Use changes no adequately modelled.

No analysis of how inadequate land use forecasts for Stages One and Two impact on the cumulative impacts of the project. The EIS notes that the project design and land use forecasts have changed significantly since the Stage 1 and Stage 2 EIS. However the cumulative analysis does not quantify the expected change on those roads. The EIS only notes significant increases in traffic volumes.

Preferred Infrastructure Report must be published

The People’s M4/M5 EIS understands that the Sydney Motorway Corporation is already preparing a report with its preferred construction options.  This must be published and the public allowed  a genuine opportunity to provide feedback on this report.

 

 

 

 

 

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