This is an introduction to a sample submission. 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
- share it with others
- use it to trigger your own ideas
- use some of it and mix it with objections on other topics relevant to the EIS ( for example Social and Economic Impact).
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
I object to the project known as Stage 3 of WestConnex, to link the newly widened and extended M4 and the duplicated new M5 between Haberfield and St Peters. The following discussion of the EIS case outlines my objections and reasons for demanding that this project be rejected by Planning.
1.Stage 3 of WestConnex is supposed to benefit the commuters and businesses of Western Sydney by improving the flow of traffic on the road system but the one element which could help drivers from the west, a direct route to Sydney Airport or Port Botany, is not part of the WestConnex project.
2. It will charge distance-based tolls which will fall heavily on people of Western Sydney who on average have lower household incomes while not delivering any obvious improvement to western Sydney traffic congestion.
3.The EIS fails to provide a convincing case for needing an eastern link between the new M4 and new M5 instead of upgrading the A3 connector. Most of the benefits the EIS ascribes to the stage 3 will only be realised in further stages – the western harbour tunnel or the Sydney gateway.
4. WestConnex, and stage 3, in particular, have huge opportunity costs because the funds which could otherwise have been spent by government on extending or improving public transport in western Sydney are dedicated to this massive road project and its ancillary surface road works.
While we are told repeatedly that WestConnex will benefit the people of Western Sydney, the reality is that drivers from western Sydney will generate ever increasing revenue to investors in the operators of roads that do not serve their needs.
Project Need and Alternatives
The original purpose of the WestConnex project was to improve and extend the M4 motorway and to connect the M5 to Port Botany and to Sydney Airport. Improving the road system for trucking freight was supposed to be the principal purpose. None of the three stages goes to Port Botany or to the airport.
The proposed link between the two motorways duplicates the A3, a national road which would be improved by an upgrade but does not appear to need duplication many kilometers further east. The eastern link between the M4 and M5 doesn’t offer any obvious benefits to drivers in or from western Sydney.
Neither the new M5 (needed for the large trucks which cannot use the existing M5) nor the stage 3 tunnels go to Port Botany. For that there is a separate project proposal, the Sydney Gateway, for an additional tollway to move freight from the port to distribution centres further inland or directly to final destination (see Section 4.1.4 EIS Project development and alternatives). So it is misleading to claim improvement in freight movement as a benefit of this project. Instead the link to the M5 interchange at St Peters and the new M5 – if they fulfill expectations of numbers of vehicles using them – will deliver 1000s of vehicles into the roads to the airport which are already at capacity.
The discussion of the strategic need (chapter 3) states a number of outcomes from Stage 3 but nearly all of them depend on other road projects not part of WestConnex (eg, the Sydney Gateway or the western harbour tunnel).
Alternatively the EIS asserts time savings and benefits unsupported by evidence. The need for a link between Haberfield and St Peters is not substantiated. Achieving reductions of volumes of traffic on Parramatta Rd, King Georges Road or the existing M5 are asserted but the model which predicts these effects is not provided for scrutiny or independent assessment. The model’s margin for error is not stated. The rest of the benefits all depend on the asserted traffic reductions generating improved travel times and better bus services or freight movement etc. So far the experience of the growth of traffic on Parramatta Rd in response to the re-imposition of tolls on the widened section of the M4 gives us leave to doubt these touted benefits.
The EIS is supposed to discuss alternatives to building the proponent’s referred option but it is limited and the alternatives are not given the detailed scrutiny which enables the public to assess them on the same basis as the tunnel project. For example upgrading the A3 as an alternative to the M4-M5 link is not discussed, modeled or costed although the section admits that the intersection of King Georges Road rebuilt as part of the new M5 project is expected to improve capacity.
Upgrading and extending the passenger train service alternative for Western Sydney – which is the preferred alternative of commuters travelling to the CBD from Western Sydney – is dismissed with:
“A scoping study to better understand the need, timing and service options for rail investment to support western Sydney and the Western Sydney Airport” [is underway] p.4.18.
but no estimate of cost offered. The improvement of the public heavy rail train services by upgrading of tracks and the signalling system is not canvassed at all. Only the (private) Sydney metro and light rail extensions are identified with high capital costs or none cited. Since these are all private developments it is not clear why their capital costs are relevant. The impact of these new services on passenger/commuter needs is not included in assessing the need for the WestConnex project in this discussion. The bus service discussion is focused on moving commuters west to east as mass transit and dismisses local and suburban services in three sentences which are all about Parramatta Rd. Bus service needs further west are not mentioned. The discussion of active transport (cycling and cycle paths mostly) also goes no further west than Parramatta.
The summary discussion of public transport “constraints” is very general. It is focused on the need to relieve congestion on arterial roads, not the cross suburban needs of people living and working in Western Sydney. The benefit of the WestConnex stage 3 project is dependent on reducing the surface road traffic on Parramatta Rd and Victoria Rd but it is not at all clear that this project will have that impact and in any case depends on other separate projects, principally the Sydney Gateway.
Demand management is dismissed as either taking too long to have an effect, or it is dependent on psychology or the demographics are against it. This is not a serious discussion of using pricing or other measures to encourage people to time their road use differently or change transport modes. On the other hand the experience already of the impact of the new tolls on the widened M4 demonstrates the real effect of pricing signals.
The section on tolls in the Social and economic Assessment Technical Working paper is remarkably brief given their impact on the drivers of Sydney will last for 43 years.
It is outrageous to quote in support of tolls studies paid for by a tollway owner – Transurban.
No one would be surprised to find the studies assert:
“NSW’s toll roads have directly contributed $14 billion in economic, social and environmental benefits over 10 years”. (Road tolling. 8.6.3 p.162).
The accounting firms, Ernst and Young and KPMG, are not independent sources. There are no details of how their studies arrived at the findings so it is not possible make an independent assessment of them. We are left guessing what is considered a social or environmental benefit. Citing studies paid for by a tollway owner undermines the credibility to the EIS’s discussion of tolls.
The proposed distance-based tolls will increase by 4% a year or by the CPI, whichever is higher. No justification for the increases is provided. The EIS discussion has to admit that the tolls are inequitable. The people of Western Sydney tend to have lower household incomes than the inner and northern suburbs so a distance-based toll is a double burden. When wages are falling even below a low inflation rate, to impose increases well above the inflation rate is an unfair burden on road users without adequate public transport alternatives.
The EIS reports that people on lower average incomes driving to work find the burden of daily tolls a significant financial cost and therefore they prefer to drive longer distances to avoid paying tolls. The shift of traffic onto Parramatta Rd when the toll on the widened M4 was re-imposed is evidence of drivers already avoiding the tolls.
Tolls are supposed to lead to “alterations to … reduced or redirected emissions, reduced traffic accidents, vehicle operation cost savings” but there is no evidence provided of how these effects are achieved. While the new roads are tolled and the old routes remain free, there is every incentive for drivers to use the old routes and save their money. In an era of stagnant wages and precarious employment saving money is likely to be a more significant motive than this discussion recognises. This effect is evidently not taken into account when assessing the impact of the overall project in operation on driving patterns because the EIS predicts “no major shifts in daily forecast traffic onto alternative, parallel routes” (Appendix H Technical Working Paper, Traffic and transport). This is not credible.
The section refers to finding community concern in a consultation, but this is dismissed with this assertion:
“Although road tolling would be a cost to individuals, the benefits of tolling to the broader economy is (sic) a greater socio-economic consequence. Effects would be long-term and benefit the Greater Sydney Region.” (Appendix H, p.163.)
In other words the people on lower incomes in western Sydney with fewer public transport alternatives than further east are being asked to pay more for driving, to reduce congestion on roads for the benefit of greater Sydney! Since all the benefits of the WestConnex project the EIS states are linked to other projects to come – the western harbour tunnel or the Sydney gateway – it is not clear that western Sydney commuters will ever get any direct benefit for paying ever increasing tolls for 40+ years. I object to the tolls, with their built-in increase of 4% a year, which seem imposed principally to make the project saleable to a private corporation, like Transurban.