Eds: This is a sample submission which focuses on social and economic impacts of Stage 3 WestCONnex. It is mostly based on a reading of Appendix P.
It’s written in the first person but you can easily change it for a group submission or use part of it for an information sheet.
- 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 our online submission. Remember you can make as many submissions as you like.
Submission to WestConnex New M4/M5 EIS, project number SSI 16_7485
One reason that I strongly OBJECT to this WestCONnex Stage 3 proposal is that I’m concerned about its social and economic negative impacts. The evidence shows that these would be devastating for the Inner West. These impacts would occur during construction and operation, across the Inner West and in Western Sydney, which would bear the brunt of tolls to pay for the project for decades. Although many impacts are acknowledged in the EIS, they are always glossed over or deferred for later consideration for mitigation or postponed to the ‘detailed design’ phase.
AECOM, the engineering consulting company that is responsible for the EIS appointed HillPDA to do the study. HillPDA was involved with AECOM in studying and promoting the UrbanGrowthNSW WestConnex Revitalisation Strategy for Parramatta Rd as far back as 2015. At this time, Hills PDA promoted the WestCONnex 33 tollway for its capacity to promote property development along Parramatta Rd. HillsPDA also has interests in property valuation and development. For these reasons, I don’t consider this company to be a suitable choice of a consultant to do a social and economic impact study. I believe that its commercial interests and support for WestCONnex are demonstrated in the apparent bias in its study. I ask that NSW Planning seek advice from consultants more qualified to do an independent qualitative and quantitive study of social and economic impacts.
A large number of risks and benefits are described in the EIS. The reliability of the analysis depends entirely on the accuracy of traffic and air quality studies. If either of these, turn out to be wrong ( I will also be submitting reasons why these are neither adequate or accurate), the social and economic risks and benefits referred to in the EIS will be way off the mark. This adds to my concerns about the choice of AECOM as a company to prepare the EIS Stage 3, especially given its inadequate EIS for Stages One and Two that failed to reveal the depth of impacts on communities or predict the difficulties residents would confront in seeking redress for complaints against contractors.
Another problem with the Social and Economic Impact study is that the findings about which of thousands of homes and social institutions will be most affected depends on the current route and design. WestConnex has made it clear that this the current plans are indicative only because the selected contractor will make the final decision at which point the public will have no formal opportunity for input at all.
Negative impact of WestCONnex M4/M5 across Inner West during 5 years of construction
The EIS does acknowledge many risks for the Inner West but in every case the study concludes that mitigation measures would be put in place post approval or that problems will be solved in the post approval “detailed design” phase. I am extremely concerned about this. The public will have no right of access to information or right of feedback post approval. Indeed because of the NSW government’s plan to privatise the construction and operation of WestCONnex, there will be no effective way of holding the consortium that wins the tender accountable for negative impacts. The potential consequences of this situation for residents’ future health, environment and safety is disturbing.
The EIS concludes overall that the impact on the Inner West LGA during construction would be negative. Given that there’ll be five years of construction , this is a serious matter. The study refers to this impact as ‘moderate’ but makes no attempt to quantify this negative impact either in terms of the costs to households or lost productivity. Nor is any attempt made to consider the cumulative impact of all the separate negative risks and how they would impact on the overall resilience and health of Inner West communities.
Construction fatigue glosses over real world experience with WestCONnex
One of the worst aspects of the Social and Economic Impact study is almost no reference is made to the actual experience with impacts of the construction during the initial work on the M4 East and the New M5. There is a reference to the concept of ‘construction fatigue’ which will apply to communities who have already endured years of construction impacts and would be expected to endure a further five years. There is barely any explanation of the experiences of those experiencing ‘construction fatigue’, other than to state that it makes people more sensitive to impacts. I find the term glib and frankly offensive as Haberfield resident Sharon Laura, who spends a lot of time assisting residents who are suffering as a result of construction, explained to City Hub in August,
Its offensive and inhumane to describe the impact as ‘construction fatigue. Right now in Haberfield there are people who are suicidal, who’ve been hospitalised, who are taking sleeping pills to deal with noise, health problems are being exacerbated, relationships are being destroyed
There is no reason why an impact study could not review the impacts of existing construction. The failure to do so simply reinforces the impression that the findings are a foregone conclusion.
Construction impacts glossed over
Hundreds of impacts are identified but are never seriously evaluated against the claimed benefits of the project. These include:
Traffic disruption and congestion
Direct and indirect traffic disruption would be experienced on local and arterial roads in suburbs near construction sites. The impact of this would spread out across Ashfield, Haberfield, St Peters, Camperdown, Annandale, Lilyfield, Leichhardt, and Rozelle. This will lead to increased travel times over several years. This is treated as a temporary inconvenience. Those who experience daily traffic congestion know that five years is not experienced as ‘temporary’. There would also be lane and street closures and traffic diversions that would cause shorter term inconvenience.
The EIS concludes that traffic delays would affect freight and commercial vehicle transport efficiency, travel time and connections to and between neighbourhoods and employment areas. People could shop less at local businesses, which could cause them to close. Individuals would lose time and money. general access and connectivity to surrounding areas or employment centres. The overall impact would influence productivity of the whole Inner West local economy. ( I suggest that NSW Planning should pay a visit to Haberfield to discuss with the business owners how serious this can be. Hundreds of jobs have been lost in both Haberfield and St Peters.).
The EIS also acknowledges that delays in freight deliveries could add to costs that will be transferred to the community.
The EIS also finds that Increased traffic congestion during construction would increase emissions; that this is likely to impact on health and lead to lost work and education time and this disruption and disconnection would lead to a loss of sense and worth of community.
Loss of safety, especially near schools, child care and aged care
The EIS does accept that increases in traffic could reduce roadside safety, particularly in areas heavily used by pedestrian and cyclists, such as near schools, child care centres, aged care facilities and near public transport stops.
The EIS specifically mentions that a lot of extra traffic on Wolseley, Alt and Bland streets Haberfield could affect road safety for children at Haberfield Public School. There would also be risk to safety of those near Parramatta Rd in Camperdown, due to being near Bridge Road School and the Pyrmont Bridge Road tunnel site (C9).
The claim is made that the risks and costs of traffic congestion will be further considered during the detailed design phase. Once again how can residents be expected to trust this process, when an unknown contractor will be lodging a plan to which they will have no right of feedback. I note that no mention is made of instances in Haberfield where road closures did occur without proper notification, leaving visually impaired and other residents at risk. It would be more reassuring to at least recognise the failures and argue that lessons have been learned.
Years of increased congestion on City West Link and Parramatta Rd!
I am already aware of the congestion on the City West Link and Parramatta Rd and it is hard to believe that NSW Planning would actually make a decision to make this worse by adding 700 heavy vehicles a day ( one way), more than 200 of which would be during peak hour, for up to a five year period. The EIS does acknowledge that this will further reduce the already very poor level of service on these roads and will have a ‘moderate negative’ impacts on the social and economic environment of the Inner West. I consider that to be serious.
The EIS states that it would be expected that on Parramatta Road, north of Wattle Street, the eastbound mid-block level of service ( between traffic lights) is forecast to drop to LoS E ( second most congested level) in the PM peak hour . On City West Link, west of The Crescent at Rozelle, the westbound mid-block level of service is forecast to decrease to LoS F ( the worst level) in the AM peak hour.
It is expected that this extra traffic congestion on major roads could spin off onto local roads as drivers change routes to avoid congestion. This could impact on streets around Parramatta, Pyrmont Bridge, Victoria and City Links roads. Local streets in Rozelle are specifically mentioned. When you consider the relatively small area across which all this congestion is spread and the current state of congestion, the cumulative impact is a serious concern.
According to the EIS, the congestion could be so serious that it could cause people to shift to public transport. This could actually be a good thing except that public transport is already severely overcrowded. This merely highlights the stupidity of building more tollroads rather than investing billions more in public transport.
While recognising that the extra traffic would have a ‘moderate negative’ impact across the Inner West, the authors of the study sidestep this by pointing out that it would be not much worse than it currently is ‘without the project’ but they never consider what other means might be used to reduce traffic congestion. This is a major flaw in the study. The study advises that advanced warning through clear messages may ameliorate the impacts but acknowledges that even with these, the traffic environment would deteriorate across the Inner West region.
Thousands of residents would be affected by construction noise. In some situations, for example, when pavements were to be torn up, this loud noise may only be for a few days or a week. Others will be forced to live next to demolition sites for more than three months or excavation sites and road works for up to five years.
Excessive noise impacts on the way people can use space, the ability to communicate and the way individuals undertake ordinary daily routines, such as gardening. It can cause stress and sleep disturbance, which in turn can cause health to deteriorate. For example, research shows that elderly people experiencing ongoing lack of sleep are more likely to develop dementia.
Noise impacts are particularly felt by people that work from home, shift workers, the elderly or households with young children that need quieter environments to work, rest and relax. Economic data shows that there is a higher proportion of health and social assistance workers who are often shift workers in the Inner West LGA than across the rest of Sydney.
1599 residences or thousands of residents would have noise levels in the evening sufficient to cause sleep disturbance. This is even allowing for acoustic sheds and noise walls.
I was concerned to read that 162 homes and hundreds of individual residents including young children, students and people at home during the day would be highly affected by construction noise. These homes are spread across all construction sites. The predicted levels are more than 75 decibels and high enough to produce damage over an eight hour period. Such noise levels are likely to severely impact on the health, capacity to work and quality of life of a proportion of the affected residents. NSW Planning should not give approval for this, especially given the difficulty residents near M4 East, M4 Widening and New M5 have experienced in achieving mitigation. A promise of some future plan to mitigate by a construction company yet to be nominated is not sufficient.
Some examples of areas that will be particularly affected include:
- Residents in 371 homes near the Darley Rd construction site would be affected by noise sufficient to cause sleep disturbance. The EIS promises negotiation over mitigation on a one by one basis. On other projects those with less bargaining power or social networks have been left more exposed. In any case, there is no certainty that additional measures would be taken or be effective. Experience on the New M5 has shown that residents who are affected badly by noise are being refused assistance on the basis that an unknown consultant does not consider them to be sufficiently affected. Night time noise is therefore another unacceptable impact of this project and reason why it should be opposed.
- Residents in more than 100 homes across Rozelle would be severely affected by construction noise for months or even years at a time. These would include young children, school students and people who spend time at home during the day. The predicted levels are more than 75 decibels and high enough to produce damage over an eight hour period. Such noise levels will severely impact on the health, capacity to work and quality of life of residents.
- Daytime noise at 177 properties across the project is predicted to be so bad during the years of construction that extra noise treatments will be required. There is however a caveat – the properties would change if the design changes. My understanding is that the design could change without affected residents being specifically notified or given the chance for feedback. This means that there is a possibility of hundreds of residents being severely impacted who are not even identified in this EIS.
- A number of educational institutions would experience excessive noise including Childcare Explore and Develop, 372 Norton Street, Lilyfield, Billy Kids Learning at 64 Charles St, Lilyfield, Rosebud Cottage Child Care Centre at 5 Quirk Street, Rozelle and Rozelle Public School at 663 Darling St, Rozelle. This could interfere with learning and ability to play outdoors.
NSW Planning should not give approval to a project that could cause such impacts. Promises of potential mitigation are not enough, especially when you consider the ongoing unacceptable noise in Haberfield during the M4East construction.
I do not accept the finding that there will be no noise exceedences during construction at Campbell Rd, St Peters. There has been terrible noise during the early construction of the New M5 which has extended to sections of Sydney Park. Why would this stop, especially given the construction is just as close to houses in Campbell Rd. Is it because the noise is already so bad that relatively, it will not be that much worse. If this is the case, it casts doubt on the whole noise study.
In this submission I have only been able to cover some noise impacts. Ground and Airborne noise will also impact on residents and will bring with it health risks. That will be dealt with in the sample submission on NOISE.
The EIS acknowledges that if the current route were pursued, up to 229 buildings would be inside the minimum working distance of in the vicinity of works may be within the minimum working distance of vibration intensive equipment. These buildings house hundreds of residents. It is recognised that vibration could heighten ” levels of stress and anxiety during construction activities” caused by “uncertainty of duration for impacts and concern for their properties.” The authors observe that contractors would ‘make good’ damage but experience with cracking so far in Kingsgrove and Haberfield has shown that it is extremely difficult to get redress for cracking. Individual residents would be left to negotiate with powerful international construction companies and their sub-contractors. The difficulties that residents or other property owners could face is not even mentioned in Appendix P.
Visual impacts – loss of vegetation, community space and views
To quote from the EIS itself:
Trees contribute to the identity of a neighbourhood, provide protection from the elements and provide intermittent or consistent screening and privacy. As such, the clearing of established vegetation is likely to be of concern to the community, particularly those where the visual amenity and landscape character of the area or property is altered due to a reduction in landscape screening.
8000 trees have already been destroyed for WestCONnex. I am opposed to the destruction of even more trees in Foucart Street and Cecily Street, Rozelle and in Lilyfield. I don’t consider that open space near pollution stacks is compensation for the removal of trees and parks. I am appalled to think that SMC is considering removing even more trees and access to sunlight for Haberfield homes that would have already endured years of construction.
While the vegetation in the Rozelle Railyards cannot be directly enjoyed by the community, it has grown undisturbed over many years to provide a green softening and visual break in a massively congested stretch of road. If the project goes ahead, all these trees and bushes will be removed. Other mature trees will also be removed from Rozelle’s roads and streets.
Buruwan Park is well used by walkers and cyclists. It should not be removed from the community that has worked hard to develop cycle friendly pathways linking residents to Rozelle Bay.
By the time the M4/M5 would have happened, many residents will have their views replaced by ventilation stacks. This will include those using Easton Park and its well used playground. This park is surrounded by closely built up urban streets. It is not appropriate to excavate a huge construction site so close to a community park. After operation, residents would look directly across to an unfiltered pollution stack. In this context, I find it extraordinary that Easton Park would ever have been considered as a possible construction site. To say that it has been saved is an overstatement.
I have regularly visited the Haberfield and St Peters construction sites. Like many others I was shocked when I saw the scale of the devastation but even more shocked when I spoke to those who had experienced the impacts, particular on their health. Before Stages 1 and 2 began, many Sydney residents were unaware of the likely destruction. Having now seen it, many readily agree that this same destruction should not have happened, let alone be visited upon Annandale, Lilyfield and Rozelle or be continued for more years in Haberfield, Ashfield and St Peters.
Overall impacts during construction on many institutions
I am concerned about the risks of construction impacts including noise, lack of access, sleep disturbance, poor air quality on 9 schools and childcare centres. I am very concerned about Haberfield School which would not only be near construction for a further five years but whose students would be exposed to safety risks from additional traffic.
I am very concerned about the choice of Darley Rd as a site for construction. This is a known danger point in Sydney. Why would Sydney Motorway Corporation insist on pushing for this site against he wishes of the Inner West Council and independent experts?
Negative impacts of the project after completion
Social and Economic Impacts of the project after the opening of the M4M5 tunnel are only considered from the perspective of 2033. This means that there is no consideration of impacts from 2023 -2033. Given the number of unknown factors, the conclusions can be regarded as little more than speculative.
Long term negative impacts on St Peters
At 8-4 in Appendix P, the following passage occurs:
St Peters interchange and surrounds are forecast to experience increased congestion and delays during the PM peak. The forecast in traffic growth for the St Peters interchange and surrounds is expected to cause delays and increase congestion for users. Negative socio-economic impacts associated with delays and congestion include reduced safety, health impacts, reduced amenity and community cohesion. The associated socio-economic impacts at St Peters would be medium-long term and would have the capacity to affect a large number of people and businesses across the Greater Sydney Region. Variances from the existing baseline environment would be large and socio-economic impacts would be possible. Therefore, the significance of effect is considered to be moderate negative.
So in 2033 after the investment of a minimum of $17 billion plus all the extra billions for other projects that are assumed to have been completed in this EIS, we learn that traffic congestion at St Peters, Haberfield and Rozelle will remain a costly problem in health, economic and social terms, not just locally but across the Sydney region.
The only answer offered is yet another traffic study or ‘Road Network Performance Review’ to be carried out by RMS in consultation with Councils and other measures to deal with congestion. So while drivers on the WestCONnex would be paying tolls to pay to the tollways company for the M4M5, the tax payer would still be paying to construct more roads near the portals. NSW Planning officers must surely ask themselves whether it is not time to pull the plug on this disastrous regime of road planning in NSW.
Concerns of residents not accurately reported
Table 6.1 in Appendix P ( Social and Economic impact) summarises concerns identified through the community feedback process. This is not an accurate report of the concerns of residents provided at community feedback sessions. This table fails to convey the depth of concern and opposition of thousands of residents to the whole project. It fails to mention the strength of concern about the Darley Rd site or the concerns of residents in Haberfield and St Peters about more years of construction. It mentions concerns about heritage in Glebe but fails to mention concerns about heritage in Newtown. I can only assume that this is because there was almost no consultation in Newtown and a complete failure to notify residences on the Eastern Side of King Street and St Peters. ( I will deal with this further in my submission on the Community Feedback Report).
When considered as a whole, the EIS Social and Economic study identifies hundreds of risks to the community. These impacts include dust, noise, the negative impacts of hundreds of trucks a day through neighbourhoods, loss of views, loss of heritage, loss of properties and businesses, loss of recreation space, stress, loss of sleep and health problems. Some residents will experience impacts for several weeks, some for four or more years and some permanently. The EIS authors never attempt to seriously evaluate what the total cumulative impact of this devastation will be on the community. It also never considers whether in the light of the scale of the impact it would be better not to go ahead.
Of course, I do understand that infrastructure development is likely to have some negative impacts. However given the congestion that will remain at the end of the project, the burden of tolls on communities in Western Sydney and elsewhere and foregone opportunities for other public infrastructure, I do not accept that these negative impacts on hundreds of thousands of people in my community are justified.
The study also deals with the impact of tolls. I don’t think the EIS accurately reflects evidence of the impact of tolls on less advantaged communities, although it does acknowledge it as a problem. It makes no attempt to consider the long term impacts on the cost of living for drivers of decades of escalating tolls. I will deal with this topic in an another submission.
Having dealt with the negative impacts, the EIS Social and Economic Impact study then predictably turns to the positive impacts of the project. These are measured from the standpoint of the 2033 traffic analysis – the intervening decade from completion in 2023 to 2033 is completely missing and the Strategic Business Case which is also out of date. There is no acknowledged that this Business case has been severely criticised by independent experts. It has now been revealed that the $17b budget does not include any of the road works will be made necessary by the WestConnex, all of which will be borne by the taxpayer and which will continue from now until post 2033.
The overall finding that the benefits outweigh all the negatives is reliant on traffic and air quality studies and are based on completion of the the Western Harbour Tunnel, the Beaches Link, the so-called F6 ( that would involve the destruction of hundreds of more homes and parkland). These projects are neither planned, let alone approved. I cannot imagine how Planning professionals would consider it appropriate to approve a project carrying such negative impacts on hundreds of thousands of residents on the basis of such speculative and uncertain evidence. I ask you to reject the project.
Eds note: The People’s M4/M5 EIS attended an EIS public session at Leichhardt on September 3rd and were told by SMC staff there that Hill PDA will not be attending any EIS sessions to answer questions.