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Submission to WestConnex New M4/M5 EIS, project number SSI 16_7485
The Green House Gas (GHG) assessment for Stage 3 is based on the WestConnex Road Traffic Model version 2.3 (WRTM v2.3).This model which was developed by NSW Roads and Maritime Services has major flaws. The unreliable outputs of the model put into question the GHG assessment.
The assessment states that there will be a net increase in GHG emissions in 2023 under the ‘with project’ scenario, however under the 2023 ‘cumulative’ scenario, there will be a net decrease in emissions (page 22-15). However, as the ‘cumulative’ scenario includes the Sydney Gateway and Western Harbour Tunnel projects, which are neither planned let alone approved, the ‘with project’ scenario should be considered as a likely outcome – which would see an increase in emissions.
Both scenarios for 2033 show a reduction in emissions vs the ‘do minimum’ scenario. This is likely to rely on ‘free-flow’ conditions for the Project for most of the day. Should this not occur, the modelled outcomes could be significantly different.
Emissions were not modelled beyond 2033. This is a mistake, as the contractual life of the project is significantly longer, until 2060. The EIS states, on page 22-15 that ‘it is expected that savings in emissions from improved road performance would reduce over time as traffic volumes increase’. Therefore, the longer-term outcome of the project is likely to be an increase in GHG emissions
Targets for renewable energy and carbon offsets are not aligned with NSW government policy. (Table 22-8)
Targets for renewable energy and offsets are unclear.
No project should be allowed to proceed that so inadequately failed to respond to the global threat of climate change. All projects should be required to demonstrate how they will contribute to climate change