WestConnex - M4 East Upgrade

To the Director, Major Planning Assessments, Department of Planning,

I am writing to express my strong objection to the proposed WestConnex M4 East motorway. Spending billions of dollars on a motorway, in a time when the onset of global warming means that we need to reduce car use rather than encourage it, when evidence from around the world shows that public and active transport is the solution to traffic congestion, is not only a waste of money but is actively harmful for the people of NSW.

In particular, I strongly object to the proposed motorway on the following grounds:

1. The proposed motorway does not solve the traffic congestion problem. Modeling in the EIS shows the M4 East will reach capacity by 2031, thus the motorway is not a solution, rather it is a stop-gap. WestConnex M4 East will only encourage more traffic and in the end make traffic congestion worse, as demonstrated by the the independent modelling performed by SGS for the City of Sydney. The real solution is to build more public transport infrastructure - buses, trains and light rail, and invest in rail transport for freight as an alternative for road transport. Further, active transport should be supported by building pedestrian-friendly streets and grade-separated bicycle ways. These constitute actual solutions to traffic congestion by addressing the root cause: reducing the amount of traffic on the road.

2. It is not clear the proposed motorway is being built in the public interest. Instead, all indications point to the primary motivation for it is private financial gain: The full business case for the motorway has still not been released, hence it can only be assume that there is no net economic benefit from its construction. Parsons Brinckerhoff and Booz Allen Hamilton, advisors for WestConnex, were found to have falsified numbers on traffic forecasts previously for the Lane Cove Tunnel while financially benefiting from its construction. There is no reason to suppose they are not acting similarly for WestConnex. Without the release of the full business case, this is impossible to determine. The NSW Auditor-General has indicated that proper process is being followed in planning for the motorway and has indicated many conflicts of interest in the governance body for the project. Finally, the independent modelling by SGS for the City of Sydney has also demonstrated the lack the economic basis for building the motorway.

3. The motorway is environmentally damaging, unsustainable and poses real health risks. The claim made in the EIS that WestConnex will result in less pollution is directly contradicted by modelling in the EIS itself. Air quality across the M4 East area will greatly exceed the proposed national standard of 8 microns per cubic metre of air by 2021. East-west traffic will increase by over 50% by 2031, negating any gains from improved efficiency from free-flowing traffic. When levels of congestion have returned to today's levels by 2031 (as shown by the EIS), even these efficiency gains will be lost. The EIS does not provide any modelling of levels of carcinogenic fine particle matter released by diesel exhaust, hence we can only assume this will also increase by over 50% over the same time period. The EIS has itself stated that its investigation into the long term impact on the natural environment and biodiversity has been insufficient, and the EIS has not accounted for the loss of mature trees and green areas. Further, the EIS has not given proper consideration to the impact on waterways from construction and pollution in water runoff.

4. Public and local government consultation has been insufficient. Proper consultation is impossible since the business case has not been released. Property was compulsorily acquired before any consultation had taken place. Local resident and business concerns have been ignored. Local governments were only consulted using a provisional plan, before the final route had been set.

I call for the application for the motorway to be rejected outright and I request a formal response to the concerns I have raised.

Yours sincerely,
Michael Gratton
PO Box 418
Newtown NSW 2042

To the Director, Major Planning Assessments, Department of Planning

I write to express my strong objection to the WestConnex M4 East motorway proposal.

Global experience of major toll road construction has demonstrated conclusively that these projects are enormously expensive and counter-productive. WestConnex will increase air pollution and encourage more car use, quickly filling the increased road capacity. It is not a long-term solution to Sydney's congestion problem.

The fact that the State Government has already signed multi-billion dollar contracts for WestConnex before this EIS was even placed on public exhibition undermines community confidence that this is a genuine consultation process.

This EIS considers benefits for all stages of the project but doesn't address the negative impacts along the whole route.

I object to this proposal as it will contribute to greenhouse gas emissions and global warming by increasing fuel consumption and air pollution.

Submission: WestConnex M4 East Environmental Impact Statement (SSI 6307)

To the Director, Major Planning Assessments, Department of Planning.

I write to express my strong objection to the WestConnex M4 East motorway proposal.
Global experience of major toll road construction has demonstrated conclusively that these projects are enormously expensive and counter-productive. WestConnex will increase air pollution and encourage more car use, quickly filling the increased road capacity. It is not a long-term solution to Sydney's congestion problem.
The fact that the State Government has already signed multi-billion dollar contracts for WestConnex before this EIS was even placed on public exhibition undermines community confidence that this is a genuine consultation process.
This EIS considers benefits for all stages of the project but doesn't address the negative impacts along the whole route.
I object to this proposal as it encourages more cars instead of public transport, and fails to provide a long term solution to traffic and congestion.


I write to submit in relation to the Environmental Impact Statement for the WestConnex M4 East project.

I am opposed to both the M4 East project and all other proposed stages of WestConnex. I request a response to my concerns outlined in this submission. (20151030 SL Final Part A)

I am a resident of Annandale, and live in community that is going to be greatly and adversely impacted by this project. My home is located within a residential Heritage Conservation Area. If this project goes ahead then I will be living beside a massive construction zone for a minimum of three years.

During the construction period, there will be severe impacts on my home, life and community during the building of a large tunnel ventilation and associated facilities site; two interchanges, and four separate civic construction areas. (These separate and distinct construction sites are the Wattle St road surface construction site, the Dobroyd Parade/Reg Coady road surface construction site, the Northcote St road surface construction site, and the Parramatta Rd road surface construction site.)

On a deeply personal level I object to all this disruption and loss for no good purpose or end result.

Westconnex won't meet stated aims or objectives
Overall, I object because:
WestConnex as proposed is not going to meet its stated aim of being the best transport solution for Sydney and is not going to solve our transport problems.
There has been no proper consideration of improved and integrated public transport as an alternative to WestConnex.
The EIS refers to the M4East providing a connection between the Blue Mountains and Sydney, yet there is no evidence there has been any information provided, or consultation with the residents or Council about the M4 East project and it's supposed need or benefit to those living or working in the Mountains.
The traffic modelling presented in the EIS does not add up, and the EIS figures show no long term or permanent improvements.
No business case for the project has been publicly released.
The planning process is ad hoc, corrupted and lacks transparency.
Contracts have been signed, approval assumed and work commenced prior to planning approval and any proper community engagement.

Failure in community consultation
There has been inadequate and conflicting information provided at EIS community sessions.
WestConnex community consultations have been lacking in real engagement and have been nothing but sham PR exercise.
I also strongly object to the project because the EIS display period and time for the public to submit has been too short and has significantly impacted on the community's ability to formulate a complete and detailed response to many concerns arising from the proposed M4 East project.
I object to statements by the proponents and supporters of the project that the community should `trust' project development and planning process for the M4 East and support the project because it is in the `best interests of the majority of the people'; and that necessarily `some people will be inconvenienced or suffer some impacts.'
I object to the planning and development of the M4East proposal that has been seriously compromised by the involvement of AECOM in so many aspects of the project.
Construction site trucks to exit onto Bland Street
I object to the location of a construction site traffic exiting directly onto Bland St, Ashfield.
The Parramatta Rd interchange construction site vehicle exit onto Bland St, Ashfield will cause considerable and unacceptable noise, vibration pollution and traffic congestion in this location. Many people who live work and travel near the Bland St and Parramatta Rd intersection at Ashfield/Haberfield will be adversely impacted. I object to this loss of amenity.
The location of the Bland St construction site is on narrow road, very close to intersection lights. This construction exit will enter directly onto a traffic lane travelling in a north and south direction. Within a few metres past the proposed exit site, the north travelling lane expands into 2 lanes immediately before traffic lights. This is to enable north travelling traffic to turn right or left onto Parramatta Rd, or to travel straight across the intersection to immediately merge into 1 lane onto Bland St Haberfield. Also, construction vehicles entering Bland St, Ashfield and turning left onto Parramatta Rd to travel in a westerly direction will occupy the two turning lanes before the intersection.
The construction site exit will increase congestion along Bland St, Ashfield and Haberfield - a significant north/south and connecting road. It will be a very tight turn for construction vehicles turning left onto Parramatta Rd from Bland St.
Further, what is to stop construction vehicles turning right into Parramatta Rd, or even travelling straight ahead on Bland St, Haberfield as they try to avoid the inevitable traffic congestion in the area, or as they use this route as a de-facto `marshalling' strategy as they await their turn and space to load up spoil, or to deliver goods and equipment in and out of the civil construction site. I object to this likelihood occurring during the construction period.
I object to the dangers likely to be caused by construction site traffic exiting onto Bland St, Ashfield to all road users and pedestrians passing through the Parramatta Rd intersection, and not only because of danger to school children and carers travelling to and from school.

Increase in Noise
I object to the increase of noise to be caused around the four construction sites in Haberfield and Ashfield. This cumulative increase of noise in our neighbourhood will cause a significant loss of amenity for all. In particular I object to the increased noise caused by construction vehicles exiting direct onto Bland St, Ashfield.
These construction vehicles will be heavily laden and will require revving in order to power up the incline towards the Parramatta Rd intersection. This will cause noise disturbance to all who live and work around the intersection. Because of the way noise travels, (increasing in volume and spread as it moves upwards) construction truck noise fwill also impact upon residents in Bland St, Haberfield, as well as upon the Haberfield Public School community.

Hundreds of polluting diesel trucks a day
I also object to the increase in localised pollution around construction sites. In particular around the Parramatta Rd construction exit onto Bland St, Ashfield by large numbers of diesel vehicles heavily laden, revving up or idling and thus spewing out the most dangerous pollutants. Pollutants which will sit and hang low around the natural gully which surrounds the Parramatta Rd and Bland St intersection, and pollutants that may not disperse quickly or at all, - depending on the local weather conditions and volume of trucks using this location.
I object to the likelihood of local streets being used as `marshalling areas' for trucks waiting to enter the construction site.
I object to the likelihood of local streets being used for parking by construction workers on the project.

Lack of detail in EIS
I object to the lack of detail in the EIS in relation to the planned mitigation to be offered to individual premises. (Noise, vibration, dust, smell, light and pollution.)
There is mention in the EIS of 300 homes to be offered various mitigation measures along the project route. (Volume 2E, page vi) But within the EIS I have found no details of the exact locations or premises to be offered such mitigation. And no WestConnex or CIMIC (Leightons) Joint Venture employee was willing to find out or share this information with me. I was repeatedly told that this information was private and confidential. I object to this lack of identification which is not for the benefit of the public.
In the EIS (Table 2.1 Indicative construction program overview, page 12, Vol 2E) three years of impacts has been given as likely for neighbourhoods surrounding the Wattle St interchange, the Parramatta Road interchange and the Eastern Ventilation facility (bordered by Walker Ave, Wattle St, Parramatta Rd and Allum St).
But I have found no specific mention of construction impacts on the neighbourhood around Parramatta Rd, between Northcote St and Wattle St, Haberfield. Only that this residential and commercial neighbourhood is identified as the 4th area to be impacted and is marked up as the C7 Northcote Tunnel site (Figure 2.2 Overview of construction footprint and construction ancillary facilities, page 13, Volume 2E).
I object that the EIS does not identify, confirm or recommend specific mitigation for all the residents and businesses impacted by the four (4) construction zones in Haberfield and Ashfield around the:
* Parramatta Rd, Ashfield/Haberfield interchange site (on road surface and tunnel construction areas);
* City Link/ Dobroyd Parade, Haberfield interchange site (on road surface and tunnel construction areas,);
* Wattle St and Walker Avenue (on road and tunnel construction areas);
* Northcote St and Parramatta Rd construction site (on road surface and tunnel construction areas).
There is reference in the EIS re noise and vibration impacts (page 85, Section 6.5.1, Volume 2E) that the Noise and Vibration Assessment has found that `much of the project area is already exposed to high noise levels from existing traffic with many properties already exceeding noise limits. As a result, the Noise and Vibration Impact Assessment has identified 310 properties that may be eligible for treatments to mitigate primarily existing noise impacts.'
I object that these 310 specific properties and locations have not been identified within the EIS to allow residents to know whether their homes or business are to be offered mitigation for noise and vibrations impacts.
I have also found reference regarding amenity impacts in the EIS (page 92, Section 7.4.1, Volume 2E) stating that: `There are 310 instances where noticeable noise increases could be experienced, primarily as a result of adjacent properties which had previously acted as noise barriers to these properties or where new noise road sources or traffic volumes increase.'
I object that these 310 properties and locations have not been identified within the EIS to allow residents or businesses to know whether their premises are to be offered mitigation for noise impacts during construction, or after completion of the project, due to adjacent properties being demolished for the project.
Also with reference to human health, (page 93,Section 7.4.3, Volume 2E) in relation to pollution the EIS states that: `... for a number of areas where traffic on the surface roads is expected to increase as a result of the project a small increase in pollutant concentration may occur.' Also, within the same assessment it is noted that: `...where property treatments are required to mitigate traffic noise, these measures are to protect people from adverse health impacts where they spend most of the day (i.e. indoors). These treatments assume that residents take up these measures and where they do, they keep external windows and doors shut and have minimal use of outdoor areas.'
I object that the EIS does not identify the location and properties know to be affected by an increase in pollution due to the project, yet the EIS assumes mitigating treatment will be provided and taken up by residents. But without specific identification of the location where pollution will increase, residents or businesses will not know if their premises require or are to be offered mitigation for increased pollution.

I object to the lack of information, or consideration within the EIS of the likely cumulative health and social impacts upon people who not only live within the project area, but who may both work, live and study within that same or different project area. The health and social impacts upon these people will be significantly greater than on others who spend less time within the project area.

I object that within the EIS, there is no reference or table that clearly lists or documents the total number of residents likely to be impacted by the project that also includes a break down and identification of single or combined impacts.

Project boundary too narrowly defined
I object that the project boundary and areas identified as affected is only 50 metres. The impact of this major road project will go far wider than 50 metres of the indicative route. By restricting the footprint of the projects impact to just 50 meters along the indicative route, the true number of properties and people adversely impacted is hidden, and the true costs of mitigation avoided. I object that much of the mitigating costs of the impacts of this project are to be borne by individual residents or businesses and not by the proponents.

Loss of vegetation, open space and trees
I object to the loss of any vegetation along the project route. Given that the route will go through a highly urbanised environment, any loss of vegetation, on either private or public land, constitutes an unacceptable loss and degradation.

I object that this loss is proposed for no good purpose, as WestConnex is not a solution to Sydney's transport problem, and traffic modelling suggests that congestion will remain a problem in many areas after construction of the M4 East project.

I object to the loss of any vegetation planted as part of the rehabilitation/landscaping works following the construction of the M4 motorway. I have often been forced to travel on the M4 between the Sydney and the Blue Mountains. Over many years, I have watched side vegetation grow and provide visual relief, shade and refuge. I object to watching this vegetation being torn down, especially as once upon a time, the construction of the M4 motorway was then supposed to be the answer to Sydney's east/west transport problems. I object that this existing motorway vegetation is seen to have no real value within the EIS.
I object to the impact upon the habitat of birds and animals which live, forage and shelter amongst the vegetation and trees to be lost due to the construction or operational needs of the project.
I object to the fact that the project will result in the know removal of about 15.7 hectares of vegetation, comprising 12.9 hectares of planted trees and screening vegetation (mainly from alongside the M4) and about 2.8 hectares of grassland with scattered trees (such as from Cintra Park and Reg Coady Reserve).
I object to the loss of open space available for passive recreation and enjoyment and loss of trees from the Reg Coady reserve. There is too little green space available for passive enjoyment these days. Any loss is an unacceptable loss. As our urban environment is built up and becomes more densely populated, there is an increasing need for green space available for passive enjoyment, not less.

I object to the loss of the `scattered trees' within the Reg Coady reserve. Some of which are magnificent specimens and the home and staging posts for local birds. I object to the loss of cool, shade and shelter due canopy loss with the removal of trees in the reserve.

Tree in Reg Coady Reserve would be destroyed if M4 East goes ahead
I object to public land (Council or State Government) being taken solely for the purpose of building a toll motorway that is not a solution to Sydney's transport problems.

I object to public land being seized to build a road that will force Sydneysiders into greater car dependency, induce more traffic into our city, and inevitably increase road congestion throughout all of Sydney.

I object to the loss and threat to the Grey-headed Flying-fox, a vulnerable fauna species listed under the TSC Act and the EPBBC Act. The Grey-headed Flying Fox has been recorded with the project footprint.

I also object to the threat caused by the M4 East project to the threatened microbat species, such as the Eastern Bentwing Bat and the Large-footed Myots. These are species that roost under bridges and culverts. Roosting bats, if present would be disrupted by construction activities. There is no suitable breeding habitat for these species within the construction footprint or adjoining areas. The project would also remove areas of foraging habitat (planted trees along roads and in parks) for the Eastern Bentwing Bat.

I object that the EIS recommends that a `formal biodiversity offset is not considered necessary to compensate' for `minor and localised residual impacts' of the M4East project. I believe that a formal biodiversity offset would be required.

I object that EIS does not recommend referral of the M4East project to the Australian Government Department of the Environment for further assessment or approval under the EPBC Act. I believe that the M4 East project, in all proposed stages, and because of its cumulative impact should be referred to the Australian Government under the EPBC Act.

Inadequate Social Impacts Assessment should be redone
I object to the validity of the Social Impacts Assessment (SIA) because baseline information and much of the research material used was not collected independently. I object that much of the material and information used as a basis for the GHD SIA had been collected and supplied to the SIA team by WestConnex Delivery Authority. I object to this lack of independence of the SIA from the proponent of the project.

I object to the project because of poor and limited methodology used in the compilation of the SIA. How meaningful is the identification of the true and complete social impacts of the M4 East project on the Haberfield and Ashfield communities, - and what chance of redress and mitigation given such bias and limitation in the development of the SIA?

I believe that the SIA must be redone, in order for the full social impacts of the project to identified and addressed.

I object that much of the SIA work was done in preparation for the concept plan when the `baseline' work was completed and before the preferred route was announced.
I object that there was no SIA consultation with Ashfield Council after initial discussions around the concept plan phase, and not in direct relation to the preferred and indicative route released in 2015. I strongly object to this serious omission, as the route and the impacts of the M4East project changed significantly from those associated with the concept phase announced in 2013.
I object that after the community `consultation' re the 2013 concept plan there was no direct engagement with residents in the development of the SIA for the EIS of the preferred route released in 2015.
I object that only residents whose homes were notified of acquisition in 2013 and 2015 were considered `consulted' in relation to the SIA for the EIS.
I object to how little knowledge or information about Haberfield and Ashfield Social Infrastructure Providers (SIPs) is revealed or referred to in the SIA of the EIS.

I object that Dobroyd Public School, St Joan of Arc Primary School, Ella Community centre and outreach programs, the Ella residential care facility, Ella childcare, and another child care centre in Ramsay St, Haberfield were omitted from direct consultation in the development the SIA.

I object that these important local services were not consulted in relation to the SIA, because they were considered outside the area affected by the route and project area.

I object that only SIPs located directly along the route and very close to it were regarded as within the project area to be considered for the SIA.
I object that many other social infrastructure providers from Homebush to Haberfield must also have been excluded for consideration and consultation in preparation of the M4East EIS.
I object because it is most likely that there will be many other aged, child and community centres and services that will have been overlooked in the EIS.

Important social impact neglected because considered outside the project
I object to the lack of consideration of by the SIA of the considerable impact on residents, schools and community caused by local street changes required due to a new right hand turn into Waratah St, Haberfield. I understand that these impacts were omitted from the SIA, because they were seen as being outside the project area required to be considered by the SIA.

I object to the complete omission within the SIA and consideration of resulting social impacts from proposed traffic changes and restrictions at the intersection of City West Link with Timbrell Avenue and Mortley Avenue, Haberfield. I understand that these impacts were omitted from the SIA, because they were seen as being outside the project area required to be considered by the SIA.

I object to the lack of attention by the SIA of the impacts on residents in Ashfield & Haberfield cause by trucks exiting into Bland St, Ashfield, from a construction site in the middle of a densely populated area.
I object to the SIA of the EIS because it is a poor and inadequate report insulting to all of us who live in Annandale, Leichhardt, Haberfield and Ashfield.

Failure to consult with businesses
I object that only `consultation' undertaken for the Economics Impact Assessment with commercial property owners and business operators along Parramatta Rd, was after the concept design was released, and then only in relation to acquisitions proposed on the Haberfield side of Parramatta Rd, between Alt St and Rogers Avenue.

I object that some businesses on the Haberfield side of Parramatta Rd were initially being pressured to negotiate and settle on a `voluntary' acquisition price before any planning approval for the project.

I object that other businesses to be left standing were desperately seeking and not receiving information and support from WDA and RMS after the concept route was released.

I object that there are businesses along Parramatta Rd, Haberfield that have been left in limbo land for the past 2 years, and are unlikely to receive adequate compensation for business losses that occurred during the post concept and preferred route phase.

I object to current acquisition of property and the loss of businesses on the Ashfield side of Parramatta Rd.

I object that businesses, remaining in situ on Parramatta Rd that have already suffered considerable disruption and business loss, believe they will continue to lose more money and business in the next phases of the M4 East project.

I object to the lack of any real consultation between WDA/JV consortia and businesses in Haberfield and along Parramatta Rd (Haberfield and Ashfield).

I object because the WDA/JV `teams' have no real knowledge or understanding of the Haberfield village, businesses or community. Whilst there was some acknowledgment of the likely chaos and impacts to be caused by the M4East project, the only compensation or sympathy offered by the WDA/JV `team members' was that all the workers would be buying their coffees and lunches in Haberfield during construction.

I object to the fact that the Economic Impact Assessment `consultation' has only been around specific issues related to the acquisition of individual commercial premises and businesses.

Insufficient time to respond
I object that that EIS response period has been truncated into a very short period. The document itself is not easy to digest and contains many internal contradictions.

I object that we have inadequate time to highlight all its inadequacies.


1) I strongly object to the M4 East project, and to the broader WestConnex scheme.
2) The EIS has failed to model the impacts of implementing the proposed project (M4 East) relative to not implementing the proposed project (the `future do minimum' scenario). The `future do something' scenarios, on which the traffic, air quality, health and greenhouse modelling is based, include the M4 East project plus another uncommitted project to convert kerbside general traffic lanes on Parramatta Road to bus priority. With these additional bus lanes, the capacity of Parramatta Road would be significantly reduced and traffic volumes would fall accordingly, with drivers opting to use the M4 East tunnel instead. As such, the traffic volumes for the M4 East tunnel have been dramatically overestimated, and the traffic volumes for Parramatta Road have been dramatically underestimated in the `future do something' scenarios.
The impacts of the project as proposed by the proponent (and as defined in Section 5 of the EIS), that is, the M4 East Tunnel with no new priority bus lanes on Parramatta Road, has not been presented in the EIS, as required by the SEARs.

(3) The stated objectives for the project 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.
(4) The EIS has not modelled alternative policy scenarios that could meet the transport/accessibility needs of NSW's growing population, e.g.
a) Greater investment in public transport;
b) Road pricing reform;
c) Land use planning that places more homes closer to employment and services.
(5) It is no secret that the real purpose of the WestConnex scheme is to increase the road freight accessibility of Port Botany and Sydney Airport, and that private passenger vehicles have been included as a means of paying for it (through tolls). However, there are various policy alternatives for dealing with the growing freight task that do not appear to have been considered, e.g.:
a) Increase the capacity and reliability of rail freight
b) Increase rail freight subsidies to match/surpass those of road freight.
c) Divert container operations to other ports outside the city centre. Very few cities concentrate container operations in the city centre where road access is costly and has significant impacts on highly populated areas.
(6) The M4 East will be used by less than 1% of the NSW population each day. The costs will be borne by the whole population. It can hardly be argued that it is providing for the "greater good".
(7) The Traffic and Transport Assessment does not stand up to scrutiny. There is not enough information about the methodology, input data or assumptions for the forecasts to be independently verified.
(8) There is no sensitivity analysis in the Traffic and Transport Assessment. The effects of varying key assumptions (e.g., willingness to pay the M4 East toll) have not been disclosed.
(9) The Traffic and Transport Assessment has not modelled the travel time and accessibility impacts for non-motorised modes (walk and bicycle).
(10) The issue of induced demand has not been fully addressed in the Traffic and Transport Assessment.
(11) Given the seriously flawed Traffic and Transport Assessment, there can be no confidence in the accuracy of the other impact analyses in the EIS that are dependent on the traffic forecasts, in particular:
a) Air quality,
b) Noise and vibration,
c) Human health,
d) Greenhouse gas emissions.
(12) The role of motorways in a multimodal urban transport network is to allow traffic to circulate around the edge of a city connecting low density suburbs, where the traffic does not directly impact highly populated areas. For radial transport into and out of employment/activity centres, mass transit (e.g., rail) is more quick/efficient, requires less space, and has fewer impacts on highly populated inner-urban areas.
(13) The EIS does not consider the cumulative costs of adding more urban motorways to those previously built through the heart of Sydney since the 1950s. Although the economic, social and environmental costs of each individual motorway (as reported in an EIS) may be considered by some stakeholders to be acceptable, the cumulative costs are considerable:
(a) Following decades of road expansion and consequential sprawl, Sydney now spends about 13% of its GDP on transport, while the average European or Asian city spends only between 5% and 8%.1 (1)
(b) Serious human health impacts due to petrochemical vehicle emissions/smog, including:
i) Lung cancer,
ii) Asthma,
iii) Heart disease,
iv) Impaired lung development in children living near motorways/exhaust stacks.
(c) Waterways contaminated with road runoff (heavy metals and carcinogens in brake and clutch dust, exhaust particulates etc.).
(d) High traffic crash costs (of deaths/traumatic injuries and material damage).
(e) Urban sprawl and increasing commuting distances.
(f) Social isolation for non-drivers living in car-dependent suburbs.
(g) Noise pollution from traffic and its impacts on sleep.
(h) Impacts on visual amenity (pollution stacks, concrete interchanges, concrete flyovers).
(i) Extreme summer temperatures (urban heat island effect).
(j) Community destruction and severance.
(k) Destruction of heritage.
(l) Less incidental physical activity from walking and cycling (including to/from public transport), resulting in higher rates of obesity, diabetes, cancer and heart disease.
(m) Increased chauffeuring burdens for parents and carers.n)
(n) Less independence for children.
(o) High per-capita greenhouse gas emissions.

2 Issues with the Traffic and Transport Assessment ( Appendix G)
2.1 General Comments
(14) The Traffic and Transport Assessment does not stand up to scrutiny. There is not enough information about the methodology, input data or assumptions for the forecasts to be independently verified.
(15) There is no sensitivity analysis in the Traffic and Transport Assessment. The effects of varying key assumptions (e.g., willingness to pay the M4 East toll) have not been disclosed.
**(16) Travel time and accessibility impacts for non-motorised modes (walk and bicycle) have not been modelled.
(17) Impacts of disruptive technology on future driving demand have not been not considered (e.g.automated vehicles).
(18) Inter-generational changes in vehicle ownership, driver licensing and transport preferences have not been considered.
(19) Changes in aggregate transport measures have not been provided for the various scenarios.For example:
(a) Overall increase in VKT (Vehicle Kilometres Traveeled.)
(b) Change in average trip distance.
2.2 Comments on Specific Sections
2.2.1
(20 One of the stated purposes of the report is to "complete a holistic traffic and transport assessment including crash analysis, travel speeds and travel time analysis and opportunities to enhance public and active transport networks within the project area". However, the report does not provide any travel time forecasts for active transport.
(21) Another purpose is to "Recommend a suite of measures to mitigate and manage traffic and transport impacts of the project for construction and operational scenarios". The general consensus among transport experts is that the most effective way to manage traffic demand is through demand management, e.g., road pricing reform. However, the report does not recommend any demand measurement measures.
2.2.2 Section 3 - Strategic Context
(22) The stated justification for the project is based on the discredited `predict and provide' approach to transport planning, whereby it is assumed that transport demand will continue to grow, and that capacity must be increased to accommodate it. In practice, transport demand in cities is limited by capacity: as capacity increases, so does demand (induced demand). It is geometrically impossible to provide enough roadway capacity to accommodate all the latent demand for driving (i.e., where everyone can live and work where they want, and make all the driving trips they want, when they want, to wherever they want in free-flow traffic) in a city of Sydney's population.
(23) Furthermore, the most efficient way to accommodate the transport and accessibility needs of a growing population is through mass transit and better land use-transport integration. Urban motorways are a very inefficient way of moving people around. A single traffic lane can transport a maximum of only 2000 people per hour (in ideal conditions); a single railway line can transport 20,000 people per hour.
(24) The statement "It is acknowledged that any investment in motorway infrastructure has to be aligned with supporting public and active transport initiatives to achieve an increase in capacity, while aiming to reduce the reliance and demand of private vehicles on the future road network" is contradictory: increasing motorway capacity will only serve to increase private vehicle demand.
2.2.3 Section 4:Assessment Methodology
(25) There is not enough information about the modelling methodology for it to be replicated and the outputs independently verified.
(26) The transport model (WRTM) has not been made available for independent verification.
(27) The model input data and assumptions have not been made available for independent verification.
What toll prices have been assumed?
(28) The model coverage area is too small to capture all the transport impacts of the project. The project will affect transport demand and behaviour across the whole metropolitan area.
(29) More detail on the Value of Travel Time Saving (VTTS)/Willingness to Pay (WTP) model is needed.
(a) The form and parameters of the model have not been given.
(b) If it was based on stated preference surveys, then how has the issue of hypothetical bias been addressed?
(c) Has the model been validated? Previous toll choice models in Australia have overestimated WTP for toll roads.
(d) Does it include the negative utility of the tunnel environment (monotony, no natural light, poor air quality)?
(30) The weekend period has not been modelled, despite current weekend traffic volumes being higher than weekday traffic volumes on many corridors.
(31) Insufficient information about the travel zone structure in the WRTM:
(a) What are the travel zones based on? How big are they?
(b) How are intra-zonal trips modelled?
(c) How are trips to/from external zones modelled?
(32) Induced demand has not been fully addressed:
a) The model ignores the impact of the project on the long-term transport decisions of individuals and firms, including:
(1) Residential location choice - the project will encourage more people to move further from work (sprawl), thereby increasing average travel distances/demand.
(2) Work location choice - the project will encourage more people to work further from home, thereby increasing average travel distances/demand.
(3) Car ownership choice - the project will encourage more car ownership.

(4) Firm location choice - the project will encourage firms to locate in locations further away from their labour supply/customers/suppliers than they otherwise would, thereby increasing travel distances/demand.

(b) To my knowledge, there has been no long-term evaluation/verification of the methodology used to forecast induced demand (New Zealand Transport Agency Economic Evaluation Manual (EEM)). Induced demand by its nature materialises over several years, as people gradually move home/work location etc. Without a long-term evaluation/verification of the methodology, there can be no confidence in the induced demand forecast produced.
(33) Insufficient detail on origin-destination demand matrix generation:
(a) What are the form and parameters of the generalised cost function?
(b) How were shortest paths calculated?
(34) Insufficient detail on trip generation:
(a) What are the form and parameters of the trip production function, and how was it estimated?
(b) What are the form and parameters of the trip attraction function, and how was it estimated?
(c) Were trips were balanced towards attractions, or towards productions?
(35) Insufficient detail on trip distribution/modal split:
(a) What are the form and parameters of the gravity model used?
(b) What are the form and parameters of the deterrence function used?
(c) How has modal split been estimated?
36 Insufficient detail on road traffic assignment:
(a) Is assignment stochastic or deterministic?
(b) What link loading/flow function was used?
(c) Were intersection delays included?
(37) Insufficient detail on public transport assignment:
(a) How were access and egress points determined?
(b) How were route strategies determined?
(38) Non-motorised trips have not been included in the WRTM or LinSig modelling.
(39) Impacts on accessibility have not been modelled. Most transport is not an end in itself - it is a means to access work, education, services etc. How does the project affect population accessibility?
(40) Equity and equality impacts not described.
(a) How many people are better off with the project?
(b) How many people are worse off with the project?
(c) Do benefits/impacts accrue to any population groups more than others, e.g., people with a disability or on low incomes?
(41) Downs-Thomson Paradox not considered.
The project will attract passengers away from public transport to road. As such, public transport patronage will be lower than it would be without the project. This could result in public transport service levels being cut, which will encourage further mode shift from public transport to road.
(42) No sensitivity analysis.
Given the numerous assumptions and approximations in the model, there needs to be some sensitivity analysis, e.g.: How will traffic volumes be affected if (when) the WTP for the toll turns out to be higher than the point estimate used?
2.2.4 Section 7 Assessment of construction impacts
(43) Impacts on walking/bicycle demand and travel times have not been modelled.
(44) Does the LinSig intersection modelling take into account the impact that changes in intersection LOS will have on travel demand?
2.2.5 Section 8 Future year traffic volumes and patterns
(45) Impacts on walking/bicycle demand and travel times have not been modelled.
(46) Does the LinSig intersection modelling take into account the impact that changes in intersection LOS will have on travel demand?
2.2.6 Section 8 Future conditions without the project
(47) Impacts on walking and bicycle demand and travel times have not been modelled.
(48) Does the LinSig intersection modelling take into account the impact that changes in intersection LOS will have on travel demand?
2.2.7 Section 9 Assessment of operational impacts
**(49) Impacts on walking and bicycle demand and travel times have not been provided.
3 References 1 Newman P, Kenworthy J. Costs of automobile dependence: global survey of cities. Transp. Res. Rec. J. Transp. Res. Board 1999;1670(1):17-26. doi:10.3141/1670-04.

Urban Design and Heritage Issues:
1. It is claimed that the design of the various components of the Westconnex have been designed in accordance with a set of Urban Design guidelines or Principles.
These Guidlelines have not been made public.

What do we know?
Twenty-five heritage items will be destroyed in the Haberfield area through the construction of the WestConnex M4 East tunnel.
Of these, 16 are locally-listed heritage items and nine are potential heritage items (a place that is not lis­ted on a heritage register but has been assessed to have heritage significance).

The Westconnex EIS does not clearly state the buildings and sites that have a heritage listing.
The EIS shows areas that are being acquired but does not indicate those buildings or areas that are not required after the various works are contracted out and the works designed and built.
What will happen to these buidlings and areas then?
If they are sold then will the original owners be compensated?

Long-time heritage ­advi­ser to Ashfield Council, Robert Moore, said he was in disbelief by the damage that would be done in the local area. "Everything from Parramatta Rd through to where Waratah meets the Distributor is going to go," Mr Moore said.

"It's not all of heritage ­interest, but the area is and has been managed by council accordingly, so it's a great concern."

As part of the project, a number of street trees which form part of two separate heritage listings will be rem­oved, and items that are lis­ted and contributory items in the Powells Estate and Haberfield heritage conservation areas will be demolished.

Haberfield Heritage Society President Emma Brooks Maher is dismayed by the effects the WestConnex will have on the local area.

The Environmental Imp­act Statement also states that across the project ­footprint and in adjacent areas, heritage items may be affected by changes to setting and visual amenity from temporary construction works or the operational project.

The detailed design, ­documentation and construction of the project should be managed to ensure that, as far as possible, the identified potential for heritage and arch­aeological imp­acts is avoided or minimised.

Vibration Impacts:
Heritage items, potential heritage items and heritage conservation areas above the proposed tunnels and in the vicinity of construction works may be subject to ­vibration impacts.

Vibration could affect the condition of heritage fabric through cracking and settlement and, in the worst case, compromise a heritage item's structural integrity.

Appropriate vibration criteria would be established to minimise harmful impact and condition surveys of ­potentially impacted buildings would be undertaken.


Landscape and Urban Design Elements:
This is an objection by the Sydney and Northern NSW Branch of the Australian Garden History Society with such amendments and additions by myself, David Springett, as a qualified heritage architect concerning the need to relocate and redesign parts of this project to avoid adverse impacts on state and local heritage landscape items in Haberfield and Ashfield.

The Society is the leader in concern for and conservation of significant cultural landscapes and historic gardens through committed, relevant and sustainable action. We have around 1600 members Australia-wide with three branches in NSW.

WestConnex Stage One proposes widening the M4 to Haberfield to 3 lanes each way, with tunnel portals and ramps in Haberfield and Ashfield. Although at the preliminary design concept stage detailed maps and drawings are not provided, it appears that tunnel entry ramps and portals and additional lanes will slice off the front 10-30m (we understand 40m off Yasmar's `front') of land currently (or historically) part of two state-heritage listed gardens and one arguably state-significant historic park in Haberfield and Ashfield. This is something we categorically oppose. There must be a better option and we want to see this seriously pursued.

Options such as locating tunnel entry ramps and portals further east (e.g. Taverner's Hill, Rozelle Rail Yards as in an earlier incarnation of this project) or further west (Concord, Burwood, Canada Bay or Croydon) in areas lacking the concentration of heritage items that Ashfield and Haberfield have. Another option altogether would appear to be a truck tunnel or widening of the entire length of Centenary Drive to the west, avoiding the inner west entirely - if traffic movement to the port and airport are the real goal. Of course rail freight (rather than encouraging truck movements through the city) would offer an entirely different alternative, freeing up roads for non-truck traffic. This does not appear to have been considered.

1) Reasoning for choice of `take' lands / alignments:
Public parks and publicly-owned gardens are a public benefit that (as land gets scarcer) require the highest standard of consideration, management and avoidance of impacts, or at the very least, fair compensation to be paid enabling rehabilitation and upgrades as the result of impacts of unavoidable public infrastructure project impacts. They are not simply `free assets' to be exploited, without the more obvious public outcry (or lobby groups) that resuming private lands brings. WestConnex ought to be aware that many value these public assets, particularly so as urban densities increase and private open space dwindles in amount, extent and quality.

Ashfield/Leichhardt and Annandale municipality residents value their parks and open spaces, having less per capita than most Council areas. In addition they value historic properties with gardens occasionally open to visit, such as Yasmar and The Bunyas. Ashfield Park is the prime public park in the municipality. Residents don't want to see these `chopped up' for traffic, for benefits that might be achieved in other less-damaging ways. Like serious investment in public transport, not wider roads for cars.

It appears (not from the publicly exhibited website material, but from public meetings and other sources) it is intended to take over all of Ashfield Park and Reg Cody Reserve in Haberfield for works depots, stockpiling spoil, storing machinery and batching plants - for what would appear to be up to 9 years of construction. This is completely unacceptable. Other locations must be found for such elements, particularly given the time span involved. Removing public open space for up to 9 years (with the exception of Ashfield Bowling Club) is not an option that residents will support, once they realize this is planned. So far media coverage has focused on private properties being resumed (or anxious about that possibility), ignoring public lands.

The Branch and with such amendments and additions by myself as a qualified heritage architect objects to the `take public land first' approach that seems to be guiding the location of elements such as tunnel ramps, portals and entries and additional lanes. Alternative sites need to be canvassed, costed and design for such structures that do not impinge on or require adverse impacts (works, visual impacts, environmental impacts such as reduced air quality or increased noise) on historic landscapes such as Yasmar and The Bunyas in Haberfield and Ashfield Park need to be considered on an equal basis to private land. This does not appear to be the case with the preferred (and only) option currently presented.

2) Lack of project design detail to comment on:
The `Preliminary Design Concept' stage is vague on detail. The Branch, and with such amendments and additions by myself as a qualified heritage architect objects to the lack of clarity on where key elements will be and a complete absence of consideration of alternatives. We understand that a 16/12/13 public meeting hosted by Ashfield Municipal Council attracted over 400 residents, who rejected Stage one, calling for much more detail and consideration of alternative options.
We consider there is a need (well before the end of 2014 when the environmental impact assessment is ready) for detailed maps, plans and impacts to be shown on maps on the www.westconnex.com website and for more public meetings to enable the community to understand precise on-ground impacts, e.g. where will the 3 ventilation stacks, tunnel entries/exits, i.e. portals, ramps, construction site compounds, stock piles, batching plants, machinery stores and proposed mitigation measures such as sound walls be? And have an opportunity to suggest alternative locations or resolution. This could save the project money!

It would appear that 6-8 lanes (once widened) of Parramatta Road east to Haberfield will then be `pinch-pointed' to two lanes each way east of Liverpool Road, with obvious `constriction points' at Battle Bridge (another heritage item). It is unclear how this `choke point' will be managed, or transitions between the two dealt with to avoid bottlenecks (much the same as currently occurs at the now-eastern Strathfield North end of the M2, meeting Parramatta Road. All Stage one will achieve will be moving that bottleneck a few suburbs east. Not a solution! We understand WestConnex has sent out packages to pre-tenderer companies before even preparing or making public an environmental Impact assessment. That presupposes the concept will be built as it is, with little room for relocation or redesign on wider consultation and review. That seems at best unwise and likely to cause `blow outs' on budget.

We also understand that Ashfield Local Environmental Plan was gazetted by the NSW Minister for Planning before christmas 2013, listing additional local heritage items on Parramatta Road, for instance east of Ashfield Park.

Avoidance of adverse impacts on these new heritage items need to be considered in Stage One documentation along with all existing heritage items.

3) Detailed concerns:
Branch concerns focus on avoiding any adverse impacts to three major state-significant `garden' heritage items in Haberfield and Ashfield deserving far better treatment and understanding.

A) Yasmar, 185 Parramatta Road, Haberfield loses up to 40m of front garden, having its front gates and fence moved for `cut and fill', then a `lid' and a form of `roof garden' for a tunnel ramp and portal

This site was home to the Learmonth /Ramsay family who once owned the whole peninsula of what is now called Haberfield. Its site is a rare (unique?) example of a (the only?) mid-19th century suburban villa in its garden setting on Parramatta Road - our oldest road (1792) - that remains in relatively intact condition. Such estates within 5km of Sydney are now all-but-extinct - subdivision leading to the loss of former component elements such as orchards, cow or horse paddocks, stables, kitchen or vegetable gardens, pleasure grounds.

Yasmar's large and diverse `gardenesque' garden with curving drive, formal gates and richly planted shrubberies has a plant collection outstanding in richness, with some species otherwise only known from the Royal Botanic Garden or Camden Park estate. Even if Yasmar's gates have been moved in the past, its land parcel is relatively intact and its presence as a thickly- vegetated `forest' of a garden is in sharp contrast to much of the inner-western extent of Parramatta Road. This needs respecting and conserving. Not digging up for `cut and cover'.

Elements framing and contributing to this sense of `historic suburban villa garden', with grand gates, drive, entry forecourt etc - need to be conserved and interpreted to the community. Not dug up and `recreated' on top of a tunnel roof, poorly. That makes a mockery of heritage conservation and runs contrary to good conservation practice per the ICOMOS Burra Charter.

It appears some 40m of Yasmar's front garden, including entry area, outer and inner fences, gates, drive and shrubberies east and west of the drive (including large and significant trees and shrubs, some extremely rare) for a distance of 40m in from Parramatta Road's current verge are to be dug up and lost, for a `cut and fill' tunnel, then `roofed' and in some form `replanted'. Again this is not clear from the project website material, but has been gleaned from public meetings. We suggest the public is barely, if at all, aware of this proposed outcome.

No new (i.e. eventually to reach at maturity) 30-40m high trees can be supported on the type of `roof' likely to be built on top of a tunnel or ramp. What will be destroyed could not be recreated on such a substrate to any convincing degree. We note that the Palmer Street ramp `roof' at Potts Point (part of the Eastern Distributor tunnel feeder network) has concrete and no `planting' at all on top of it. Is that the realistic outcome envisaged for Yasmar? That is completely unacceptable given its garden is listed on the NSW State Heritage Register, as a garden, rich in original and early plantings, including of large (and rare) trees, shrubs and more. No such replacement planting or outcome can be achieved on top of a tunnel ramp roof.

As Yasmar is listed on the NSW State Heritage Register, the Heritage Council of NSW must be consulted and have early input into Stage one options and detailed resolution. In addition to Yasmar being so-listed, the suburb of Haberfield as a whole has been nominated for consideration for listing on the NSW State Heritage Register - it is that significant.

In addition Yasmar's `sunken garden' in its western shrubbery may be impacted by this `40m take'. Given this is an extremely rare surviving early water feature, pond / sunken garden / shade house its removal (and later presumed reconstruction) is completely unacceptable. Fragile structures like this should be conserved and repaired, not dismantled and poorly reconstructed on top of tunnel ramp roofs. This `cut and fill' tunnel ramp needs relocation outside Yasmar's grounds. We suggest directly across Parramatta Road is a large vacant site eminently suitable for such a structure with no adverse impact on Yasmar's garden. That or other locations need to be considered in the EIS.

At the very least funds to enable upgrading of the public presentation of Yasmar's southern, main Parramatta Road frontage and the public must be a `deliverable' outcome of WestConnex. Any proposed sound walls between it and Parramatta Road would have to be sensitively designed and detailed to avoid `shutting off' public views and appreciation of its front garden.

Improved fencing, planting and maintenance are a minor benefit the project could bring, for some community gains. Identification and consideration of alternatives such as pushing the land-take southwards across Parramatta Road off Yasmar should be considered and costed.

B) Ashfield Park has its front (northern edge) 10-20m sliced off for tunnel ramp/ portal entry/ies and will be `locked up' (except the Bowling Club) as spoil stockpiles, works depot, machinery store and batching plant - for up to 9 years!
Ashfield Park is a delightful and relatively rich, intact Federation era 1904 public park formed from an 1885 Crown land purchase in response to agitation by local groups (e.g. the Bowling Club, which occupies its north-west) and individuals. It faces Parramatta Road and many know it from carpet bedding with colourful annual displays picking out the name: "Ashfield Park" to motorists and pedestrians. That bedding and lawn terrace on which it sits (20-30m it seems) would be entirely sliced off for a (the Marrickville Truck) tunnel ramp currently proposed.

It seems the project's three-stage approach means that Stage 3's Petersham access ramps will make this Ashfield tunnel ramp redundant - so why sacrifice any park land at all? Why not move the ramp east (e.g. Taverner's Hill) or west (Croydon/Burwood/Strathfield) to avoid adverse impact on Ashfield Park? Have alternative options such as this been considered to avoid direct adverse impacts? If not why not consider them, now?

Ashfield Park is listed as a local heritage item on Ashfield Local Environmental Plan, but in the Branch's view it should be listed on the NSW State Heritage Register. Relatively intact inner-urban suburban parks from the great 1880s era of municipal park creation (celebrating the centenary of NSW's colonization) like this are increasingly rare and lack the heritage recognition they deserve. Every effort should be made to avoid adverse impacts on Ashfield Park.

If (as a last resort) some `cut' into the park was unavoidable, the treatment of this edge, with retaining walls, sound walls or similar would need the utmost care in sensitive design and detailing to ensure public appreciation of the park, and park users' appreciation of it from `inside' were not diminished by excessive height or ugly monumental walls, cutting off connection.

The cutting off of pedestrian access to Ashfield Park from Haberfield by a wider, deeper `trench/tunnel' of Parramatta Road would need to be addressed by either a pedestrian bridge or set of lights - otherwise Haberfield residents using the park will struggle to do so in future.

We totally reject the proposal (again not evident on your website concept plan but gleaned from public meetings) that the park will be `commandeered' for spoil stockpiling, works depot, machinery storage and batching plant, for up to 9 years. That is completely unacceptable, robbing the residents of Ashfield and Haberfield of their principal open space (except bowlers!). Alternative sites must be found for these elements.

We understand that Reg Cody Reserve in Haberfield is also slated for a works depot - again something completely unacceptable.

3) The Bunyas, 5 Rogers Avenue, Haberfield - regains a `frontage' to Parramatta road, but loses its privacy and gains traffic much closer, sound walls, noise etc
This house was built in 1904-7 for real estate agent and entrepreneur developer Richard Stanton as his own home in his model garden suburb of Haberfield. It is sited on the location of the former homestead of Dobroyde Estate (which he had progressively bought and subdivided to make Haberfield), contains an exemplar Arts & Crafts house and large garden once fronting Parramatta Road on a ridge line for district views (in - that is, of it; and out - from it).
Its garden once stretched east to Dalhousie Street and south to Parramatta Road. After the Stanton family left it was subdivided in 1928 (leading to the existing car yard to the south and blocks of flats to the east). Unsurprisingly given its name, the garden retains Bunya pines (as does Yasmar) which, planted on a ridge, are visible from some distance away. These sit in still- spacious generous grounds with expansive lawns and other established trees including figs, Illawarra flame tree, jacaranda, desert fan palm (Washingtonia robusta), jelly palm (Butia capitata) and Cocos Island/Queen palms (Syragus romanzoffianum). WestConnex will remove that car yard, which perhaps is a public benefit, opening up community views to The Bunyas again. Of course this also removes much of the privacy enjoyed by its inhabitants.

Having greatly increased traffic flows much closer to the house and garden would be an adverse impact on the `private enjoyment' of The Bunyas, perhaps outweighing any public benefit of others being able to more easily `see into' it. Any proposed sound walls between The Bunyas and Parramatta Road would have to be sensitively designed, scaled and detailed to avoid overly `shutting in' its inhabitants, shutting off public views, and diminishing any potential `gains' of public appreciation of its front garden presentation to the road.

The Branch might be prepared to accept that outcome if there were more detail about how this new `front' will be treated. We trust that there will be no high, bleak and blunt sound walls to Parramatta Road, no overly-urban treatment of what for much of the last 190 years has either been woodland, paddock or leafy front garden. When will such detail be available to view? Will options to treat this `front' sensitively to retain some privacy for the owners of The Bunyas, yet allow the community to `see' The Bunyas' roof and garden from Parramatta Road be published?

The Bunyas is listed on its NSW state heritage register listing and thus the Heritage Council of NSW should have early opportunity to provide input on this project to avoid or mitigate adverse impacts on the property and ensure some benefit to the setting of The Bunyas ensues.

Based upon the Submission by the National Trust:
The National Trust notes, with such amendments and additions by myself as a qualified heritage architect, that this M4 East is only one section of the WestConnex Motorway and that there will be additional heritage impacts relating to the St Peters Interchange and the future link between Haberfield and St Peters.

In the Trust's and my view the heritage impacts of the WestConnex Motorway are severe. The Trust, and myself, must question whether the financial commitment for the total project in today's dollars of $15 billion (inevitably set to rise) would be much better allocated to public transport.
The National Trust (NSW) objects to the destruction of so much heritage and argues that the Westconnex motorway system is a flawed policy that does not justify the loss. The People's EIS recommends this submission to those concerned about the loss of heritage.
The submission begins by reiterating a few points drawn from its
February, 2014 submission to the WestConnex Delivery Authority M4 concept design.
* It concerns the Trust that, at the Environmental Impact Statement assessment stage of this massive project, contracts may already have been signed and commitments made to commence construction when the full impacts of the development may only be coming to the public attention.
* Over the past fifteen years the Trust has continued to express concern at the heritage impacts of inner urban motorway proposals and has supported mass transport options such as light and heavy rail in preference to inner urban motorways.
* While acknowledging that the increased mobility and affluence of our society and an expanding population require much improved transport facilities, the National Trust opposes further motorways being brought into the inner suburbs and central business district if they threaten areas of historical, architectural, scenic and social importance.
* The National Trust believes that the provisions of public/private partnership agreements for urban motorways should be made public and that such agreements must not contain penalty provisions for compensation payments to a motorway operator if a public transport system competes effectively with the motorway.
* The National Trust would oppose public/private agreements that disadvantage the public who do not choose to use the toll roads constructed under those agreements and believes that massive expenditure on motorway development will divert much needed public and private investment away from public transport development which can move large numbers of people more effectively and with much less adverse heritage impact.
* The constant daily movement of large transport trucks severely degrades the urban environment and the National Trust urges that rail transport should be the preferred means for transporting container goods related to Port Botany and Sydney Airport. The Trust would oppose motorway proposals which promote increased large truck movements through urban precincts, particularly those with heritage significance.
* The National Trust acknowledges that inner city motorway development will be inextricably linked to residential/commercial redevelopment of higher densities in the zones adjoining the
motorway and consequently, would oppose such development, or elements of that redevelopment when it: -
impacts upon, or degrades the values of adjoining, Heritage Conservation Areas
involves the demolition of Listed Heritage Items
involves the demolition of places which have been removed from Heritage Lists on non heritage-based grounds
involves the demolition of places which, in the Trust's view are of indisputable heritage significance, but which have been denied statutory heritage recognition.
National Trust history in campaigning with community
The National Trust has had a long history and involvement in campaigning with the community to protect inner urban heritage.
In 1972 the National Trust opposed the North-Western and Western Expressways which would have cut a swathe through Glebe, demolishing 800 homes and the property "Lyndhurst", to the steps of the Sydney Town Hall.
On 26 February, 2014 the Board of the National Trust of Australia adopted a Policy on the Heritage Impacts of Urban Motorways. This Policy built on and reiterated earlier positions and policy statements including:
* National Trust: Policy Statement on Urban Freeways (1976)
* National Trust Policy on Urban Freeways (1981)
* National Trust Discussion Paper: Towards a Transport Policy for the National Trust (1989)
* National Trust Policy Paper: Transport - The Heritage Implications (1995)
* Trust Alert: Motorway proposals threaten inner city Urban Conservation Areas (2005)
National Trust Policy on the Heritage Impacts of Urban Motorways (2014)
1 While acknowledging that the increased mobility and affluence+

I wish to express my strong objection to the Westconnex M4 East motorway proposal. If built it will funnel extra, unnecessary traffic into already congested inner and middle-aged city roads, requiring a destruction of hundreds of homes and businesses and the destruction of the public domain in order to necessarily widen existing roads.

I object to the practice of awarding tenders for a project before public participation in a full EIS publishing and review process. This makes a mockery of the public's right.

Government funding for the proposal - as part of the entire Westconnex project - will claim an extraordinary proportion of the state transport budget for years to come. The lack of an honest discussion of its social, environmental and economic impacts or a proper consideration of more efficient public and active transport solutions demonstrates the blind misallocation of such a huge chunk of the transport budget.

In particular I draw attention to the failure to:
Factor in the population rise that will accompany the construction of 40 000 new apartments along the corridor, bringing extra traffic which has not been considered.

Honestly and genuinely discuss public transport and freight rail alternatives

Publish a robust business case to justify expenditure of billions of dollars of taxpayer funds

Actually consider the impacts of resultant air pollution and other greenhouse gases from this project on scientifically proven climate change

Consider more sustainable public and active transport options that will produce a lower level of greenhouse gas emissions

Decades of global experience of urban motorway construction has demonstrated conclusively that big new urban roads are counterproductive. They generate a flood of new road traffic and rapidly reach capacity. This is why, globally, they have fallen out of favour and are no longer seen as a solution to congestion.

Please accept that we are in the 21st century, and don't damn my future.

Ryde Community Alliance objects to the Westconnex proposal which has not been demonstrated to address the long-term needs of the Sydney Region for an integrated public transport system.

In addition, the project will destroy many historic areas of residential and commercial development which provide a range of housing and an environment that encourages positive community outcomes.

The Alliance strongly supports all those groups and individuals who are opposing the wasteful spending of funds that are desparately needed for more productive investment n schools and public transport.

The loss of heritage listed buildings and areas is an indictment of the flawed approach to environmental planning adopted by the NSW Government.

Submission: WestConnex M4 East Environmental Impact Statement (SSI 6307)

To the Director, Major Planning Assessments, Department of Planning

I write to express my strong objection to the WestConnex M4 East motorway proposal.

Global experience of major toll road construction has demonstrated conclusively that these projects are enormously expensive and counter-productive. WestConnex will increase air pollution and encourage more car use, quickly filling the increased road capacity. It is not a long-term solution to Sydney's congestion problem.

The fact that the State Government has already signed multi-billion dollar contracts for WestConnex before this EIS was even placed on public exhibition undermines community confidence that this is a genuine consultation process.

This EIS considers benefits for all stages of the project but doesn't address the negative impacts along the whole route.

I object to this proposal as it encourages more cars instead of public transport, and fails to provide a long term solution to traffic and congestion.

Regards
Francesca Christie

Dear WestConnex,
Could I please request an extension of a couple of days as I have been unwell and need to gain approval from the PHAA Executive before submitting. The NSW Branch of the PHAA are volunteers and thus work and family commitments limit the time to make such submissions.

Thank you.
Please contact me if you require further information.

Regards,

Jude

Jude Page

President, NSW Branch

Public Health Association of Australia
Ph 0439 987954
E: [email protected]

I strongly object to the WestConnex M4 East motorway proposal.

It is quite clear that this massive project will be hugely expensive and will not achieve its objectives. As overseas experience has amply demonstrated, projects like this only increase air pollution and actively encourage more cars on to the road, rapidly using up any increased road capacity created.

The WestConnex M4 East motorway is NOT a long-term solution to Sydney's congestion problem.

The fact that the State Government signed multi-billion dollar contracts for the development of this scheme PRIOR to the Environment Impact Statement even being put on public display completely undermines my confidence that this is a genuine consultation process.

The EIS enunciates BENEFITS for all stages of the project ... but does not address the NEGATIVE impacts along the whole route.

The principal objections to this proposal are:

1. The WestConnex M4 will, if built, encourage MORE CARS instead of PUBLIC TRANSPORT. It would fail to provide a long term solution to traffic and congestion. If you build more roads, you just get more cars. It is as simple as that.

2. The WestConnex M4 will, if built, create significant air pollution and damage the health and wellbeing of people who live nearby, especially children.

3. The WestConnex M4 will, if built, divide local communities and force hundreds of people out of their homes and neighbourhoods. It will do enormous damage to the fabric of Sydney's inner west community, including small businesses and families.

4. The WestConnex M4 will, if built, contribute to Australia's greenhouse gas emission and global warming by promoting an increase in fuel consumption and creating significant air pollution. This is not progress. It is regressive. Last century.

5. The WestConnex M4 will, if built, pollute local waterways and groundwater, and destroy precious green space and parklands that are so important to the local community.

6. This proposal fails to include any evaluation or consideration of alternative public transport options.

7. This proposal is not justified by any publicly-released business case.

In short, this is a community destroying, polluting, regressive and economically suspect proposal.

I wish to object in the strongest terms to the WestConnex M4 East motorway proposal. The proposal is fundamentally flawed in many different ways. It's not just the damaging effects of the road itself on the urban fabric, including residential areas. No small adjustments to the proposal will alleviate the fact that the entire proposal will be deleterious to the environment in that it encourages the usage of cars and therefore the creation of more air pollution and carbon emissions. This is quite apart from the fact that, as traffic experts agree, the proposal will not solve Sydney's traffic problems. What is needed - as other global cities have already realised - is investment in public transport.

I also wish to object to the way in which the Westconnex project has been carried out. It is quite wrong that tenders have already been awarded before a full business case has been realised, and before the EIS had been published, and before the public has been allowed its right to respond - as I am now doing - to the EIS. This is not the correct procedure and makes a mockery of the entire 'public consultation' process.

I wish to express my strong objection to the WestConnex M4 East motorway proposal. If built it will generate additional traffic, funnelling it into heavily congested middle-ring and inner city roads, requiring the demolition of hundreds of homes and businesses to make way for road widenings on the surface road network to distribute the traffic from the motorway.
I also wish to register my objection to the government awarding tenders for the project before a full business case has been publicly released and before the EIS had been published and the public has exercised its right of participation.
The EIS process is supposed to allow for genuine public input and to result, potentially, in approval, non-approval, or approval with modifications, of the project. The present procedure makes a mockery of that right.
Government funding for this proposal - as part of the whole WestConnex proposal - will claim an extraordinary proportion of the state transport budget for years to come. This being the case, I am outraged that the EIS has failed to honestly and fully discuss its social, environmental, and economic impacts or to explain why it is preferable to other, alternative public- and active transport solutions.
In particular I draw attention to the EIS's failure to:
* Factor into the traffic modelling the very large increase in apartment construction - and therefore of population - that has been promoted by the WestConnex Delivery Authority and other agencies as a major rationalisation for the proposal.
* Honestly discuss public transport and freight rail alternatives.
* Publish a robust business case to justify expenditure of billions of dollars worth of taxpayers' funds.
* Properly describe the long term impacts of air pollution generated by the increased traffic volumes the project is designed to facilitate.
* Consider more sustainable public and active transport options that will produce a lower level of greenhouse gas emissions.
Decades-long global experience of urban motorway construction has demonstrated conclusively that big new urban roads are counterproductive. They generate a flood of new road traffic and rapidly reach capacity. That is why, globally, they have fallen out of favour and are no longer seen as a solution to congestion.
- See more at: http://westconnex.info/?p=348660#sthash.Zq5leCXw.dpuf

I strongly object to the WestConnex M4 East motorway proposal.

It is quite clear that this massive project will be hugely expensive and will not achieve its objectives. As overseas experience has amply demonstrated, projects like this only increase air pollution and actively encourage more cars on to the road, rapidly using up any increased road capacity created.

The WestConnex M4 East motorway is NOT a long-term solution to Sydney's congestion problem.

The fact that the State Government signed multi-billion dollar contracts for the development of this scheme PRIOR to the Environment Impact Statement even being put on public display completely undermines my confidence that this is a genuine consultation process.

The EIS enunciates BENEFITS for all stages of the project ... but does not address the NEGATIVE impacts along the whole route.

The principal objections to this proposal are:

1. The WestConnex M4 will, if built, encourage MORE CARS instead of PUBLIC TRANSPORT. It would fail to provide a long term solution to traffic and congestion. If you build more roads, you just get more cars. It is as simple as that.

2. The WestConnex M4 will, if built, create significant air pollution and damage the health and wellbeing of people who live nearby, especially children.

3. The WestConnex M4 will, if built, divide local communities and force hundreds of people out of their homes and neighbourhoods. It will do enormous damage to the fabric of Sydney's inner west community, including small businesses and families.

4. The WestConnex M4 will, if built, contribute to Australia's greenhouse gas emission and global warming by promoting an increase in fuel consumption and creating significant air pollution. This is not progress. It is regressive. Last century.

5. The WestConnex M4 will, if built, pollute local waterways and groundwater, and destroy precious green space and parklands that are so important to the local community.

6. This proposal fails to include any evaluation or consideration of alternative public transport options.

7. This proposal is not justified by any publicly-released business case.

In short, this is a community destroying, polluting, regressive and economically suspect proposal.

I wish to express my strong objection to the WestConnex M4 East motorway proposal. If built it will generate additional traffic, funnelling it into heavily congested middle-ring and inner city roads, requiring the demolition of hundreds of homes and businesses to make way for road widenings on the surface road network to distribute the traffic from the motorway.
I also wish to register my objection to the government awarding tenders for the project before a full business case has been publicly released and before the EIS had been published and the public has exercised its right of participation.
The EIS process is supposed to allow for genuine public input and to result, potentially, in approval, non-approval, or approval with modifications, of the project. The present procedure makes a mockery of that right.
Government funding for this proposal - as part of the whole WestConnex proposal - will claim an extraordinary proportion of the state transport budget for years to come. This being the case, I am outraged that the EIS has failed to honestly and fully discuss its social, environmental, and economic impacts or to explain why it is preferable to other, alternative public- and active transport solutions.
In particular I draw attention to the EIS's failure to:
* Factor into the traffic modelling the very large increase in apartment construction - and therefore of population - that has been promoted by the WestConnex Delivery Authority and other agencies as a major rationalisation for the proposal.
* Honestly discuss public transport and freight rail alternatives.
* Publish a robust business case to justify expenditure of billions of dollars worth of taxpayers' funds.
* Properly describe the long term impacts of air pollution generated by the increased traffic volumes the project is designed to facilitate.
* Consider more sustainable public and active transport options that will produce a lower level of greenhouse gas emissions.
Decades-long global experience of urban motorway construction has demonstrated conclusively that big new urban roads are counterproductive. They generate a flood of new road traffic and rapidly reach capacity. That is why, globally, they have fallen out of favour and are no longer seen as a solution to congestion.
- See more at: http://westconnex.info/?p=348660#sthash.Zq5leCXw.dpuf

I strongly object to the WestConnex M4 East motorway proposal.

It is quite clear that this massive project will be hugely expensive and will not achieve its objectives. As overseas experience has amply demonstrated, projects like this only increase air pollution and actively encourage more cars on to the road, rapidly using up any increased road capacity created.

The WestConnex M4 East motorway is NOT a long-term solution to Sydney's congestion problem.

The fact that the State Government signed multi-billion dollar contracts for the development of this scheme PRIOR to the Environment Impact Statement even being put on public display completely undermines my confidence that this is a genuine consultation process.

The EIS enunciates BENEFITS for all stages of the project ... but does not address the NEGATIVE impacts along the whole route.

The principal objections to this proposal are:

1. The WestConnex M4 will, if built, encourage MORE CARS instead of PUBLIC TRANSPORT. It would fail to provide a long term solution to traffic and congestion. If you build more roads, you just get more cars. It is as simple as that.

2. The WestConnex M4 will, if built, create significant air pollution and damage the health and wellbeing of people who live nearby, especially children.

3. The WestConnex M4 will, if built, divide local communities and force hundreds of people out of their homes and neighbourhoods. It will do enormous damage to the fabric of Sydney's inner west community, including small businesses and families.

4. The WestConnex M4 will, if built, contribute to Australia's greenhouse gas emission and global warming by promoting an increase in fuel consumption and creating significant air pollution. This is not progress. It is regressive. Last century.

5. The WestConnex M4 will, if built, pollute local waterways and groundwater, and destroy precious green space and parklands that are so important to the local community.

6. This proposal fails to include any evaluation or consideration of alternative public transport options.

7. This proposal is not justified by any publicly-released business case.

In short, this is a community destroying, polluting, regressive and economically suspect proposal.

Submission: WestConnex M4 East Environmental Impact Statement (SSI 6307)

To the Director, Major Planning Assessments, Department of Planning

I write to express my strong objection to the WestConnex M4 East motorway proposal.

Global experience of major toll road construction has demonstrated conclusively that these projects are enormously expensive and counter-productive. WestConnex will increase air pollution and encourage more car use, quickly filling the increased road capacity. It is not a long-term solution to Sydney's congestion problem.

The fact that the State Government has already signed multi-billion dollar contracts for WestConnex before this EIS was even placed on public exhibition undermines community confidence that this is a genuine consultation process.

This EIS considers benefits for all stages of the project but doesn't address the negative impacts along the whole route.

I object to this proposal as it encourages more cars instead of public transport and bicycle paths, and fails to provide a long term solution to traffic and congestion.

I object to the WestConnex M4 East motorway proposal as I believe it will encourage more cars, therefore we worse for the environment and worse for our health; it will divide communities & destroy neighbourhoods and there has not been adequate transparency or regard for community sentiment.
Thank you for your consideration of my concerns.
Regards

Fiona Steele

I object to the WestConnex M4 East proposal as it encourages more use of private cars so it bad for air pollution, greenhouse gas emissions, pollution of waterways and ultimately our health.
This proposal is also bad for our community. Suburbs will be divided and many areas lost. let's fix public transport instead of taking steps backwards.
Regards
.Ursula Buchan

I object to the WestConnex M4 East proposal as it encourages more use of private cars so it bad for air pollution, greenhouse gas emissions, pollution of waterways and ultimately our health.
This proposal is also bad for our community. Suburbs will be divided and many areas lost. let's fix public transport instead of taking steps backwards.
Regards
.Ursula Buchan

I object to the WestConnex M4 East proposal as it encourages more use of private cars so it bad for air pollution, greenhouse gas emissions, pollution of waterways and ultimately our health.
This proposal is also bad for our community. Suburbs will be divided and many areas lost. let's fix public transport instead of taking steps backwards.
Regards
.Ursula Buchan

I would like to lodge an objection to the West Connex project as a whole. The bloody minded lack of vision and planning for the future of our wonderful city is astonishing. It is clear that the billions of dollars spent on delivering more motor vehicles into a city centre that has in large part, banned cars, is stupid. Sydney will be a laughing stock in a world where walkable cities and urban centres are mushrooming in keeping with the growth of knowledge economies. The absence of a business case before the exhibition of the project is at best, negligent. It is clear that a properly constructed financial analysis would never endorse this backward looking folly.

I am strongly opposed to Westconnex. Spending $15.4 billion in state taxpayer funds for a saving of 6 minutes in travel time (which will proportionally decrease as traffic increases) is irresponsible and wasteful. Particularly when carbon-induced climate change has been identified as the greatest challenge of our time, we should be moving away from roads to more equitable, efficient, sustainable transport solutions. This spending should go into improving public transport infrastructure, not roads for individual motorists.

I am deeply concerned that contracts were signed before the release of the business case to the public, and before planning approval. This is the reverse of standard process, and the lack of transparency around these commitments suggests that vested interests, not community interests, are being served. It deeply undermines my trust in the current State Liberal Government, and by extension also the Federal Liberal Government.

I am also deeply concerned that the project is being pushed ahead despite concerns about its viability expressed by the NSW Auditor General.

Further aspects that are highly problematic are:
1) There are no plans to diffuse traffic where the City West Link comes out at Ashfield/Haberfield, and increasing traffic flow from Western Sydney to this area will only serve to intensify already poor traffic flow and conditions.
2) The potential flow-off effect onto local roads from the tollway during congested periods.
3) There are currently no plans to filter the smoke stacks, which are located near residential areas and schools. Smoke stacks must be filtered.
4) The noise and vibrations generated from 24/7 truck access to and from construction areas during construction periods will impede quality of life and devalue properties of local residents. These hours should be restricted.
5) Encouraging greater use of fossil-fuel-reliant motor vehicles is irresponsible as it will encourage greater use of fossil fuels at a time when we should be making efforts to reduce fossil fuel use to combat climate change.
6) There needs to be a feasibility study around the likelihood of Western Sydney residents paying a toll to access the road. As an example, the Cross-City Tunnel is an expensive yet under-utilised piece of infrastructure, and tolls are being raised to cover costs that are not being met due to lower-than-projected use. Will motorists be willing to pay tolls to use the road? Given that Western Sydney is home to some of Sydney's lower socioeconomic tiers, the likelihood that motorists will continue using the surface road and avoid tolls is conceivably high. The business case should be released.
7) Crossing Parramatta Rd between Ashfield and Haberfield will become difficult, hampering access to amenities for locals.
8) Destruction of the Haberfield heritage area.

Please consider these concerns. I look forward to seeing them address in the response to submissions. Thank you.