WestConnex - M4 Widening

See attached

Please see the correspondence that is attached to this submission.
Thanks and regards
Daryl Kerry

see attached

I write to express my absolute opposition, in the strongest possible terms, to the WestConnex M4 Widening Project. I believe that the project is dangerously flawed and utterly misguided. The urban problems faced by Sydney will not be addressed by vast new motorway construction - a response which, it seems, only Australia among nations of the developed world seems not to have learnt is doomed to failure.

The proposal represents an out-of-date and dangerous approach to a real problem. Experts in traffic modeling and transport planning, such as Dr Michelle Zeibots at the University of Technology Sydney, have demonstrated that the construction of larger motorway systems does not solve the problem of traffic congestion in anything but the shortest of terms: in fact they generate higher levels of uptake in road use which rapidly exceed the capacity of the new road, in the mean time leaving the urgently-needed complementary provision of high-quality public transport alternatives denuded of support. The proposal is also out of line with the clear wishes of Sydney's population, which has been increasingly seeking to use public transport over roads (see 7 below); and with the solutions that look to the greater health of the environment and its human population.

I do not want my children to grow up in a city that is polluted and congested, that is run, effectively, by property developers, and where ordinary citizens are kept in the dark about decisions that affect them so directly (see 1 and 8 below). I want to live in a city that I can be proud of, which leads the way in sustainable urban development - WestConnex would be a missed opportunity for Sydney to shine.

Given the extremely short period allowed for public consultation (see 1 below), I am obliged to keep my comments brief.

1. The period during which the EIS is available for public study and response is completely inadequate. When such huge sums of public money are involved, this is inexcusable and suggests a furtive intent to keep public scrutiny to an absolute minimum.
2. The WestConnex M4 Widening Project is only one segment of the much larger WestConnex project. The EIS shows that any success that may be claimed to emerge from the M4 Widening Project is predicated on the entire project being implemented. Given the fact of its integral relationship to the other phases of the WestConnex project, it would be wrong to approve the M4 Widening Project. Such approval would prejudice judgment on its later phases. The entire WestConnex project should be presented and considered as the whole which it is advertised to be.
3. The EIS makes it plain that the proposed widening will have no real wider benefits without the full WestConnex project (see 2 above). The creation of the wider segment of motorway will inevitably generate greater traffic congestion at its end-point. This is a demonstrated fact known to all traffic and transport experts, as well as being easily deducible by common sense. The improvement alleged for the travel times is in any case based on the introduction of 4 tolled lanes of motorway which will, it is anticipated, handle lower flows of traffic, while it is assumed by the M4 Widening Project that large numbers of trucks and other vehicles will move to the non-tolled Parramatta Road. This management by economic charge of traffic flows will have, among its many negative consequences, the effect of considerably increasing the pollution and other loss of amenity in precisely the areas targeted for `urban regeneration' along the Parramatta Road. This problem was seen and expressed explicitly more than 18 months ago by Mr Thomas van Drempt, a Senior Transport Engineer at Parsons Brinckerhoff Inc., who was contracted to work on transport options along the Parramatta Road corridor (see http://www.smh.com.au/nsw/emails-reveal-doubts-on-westconnex-parramatta-road-revival-20140807-10121c.html).
4. Furthermore, many or all of the improvements in travel time are based on entirely inadequate, soft statistical projections (the absence of adequate usage projection estimates as recently as April of this year was revealed by the release of working papers on WestConnex under Freedom of Information legislation) or are completely trivial. For instance, at page ii of the Executive Summary it is stated that `When completed, the widened M4 Motorway would save motorists around one minute on an evening peak westbound journey from Homebush Bay Drive to Church Street.' It is risible, or rather rampantly irresponsible, to propose the expenditure of $15 billion of public monies to achieve such a result.
5. The EIS fails adequately to address the potential solutions provided by public transport to the real problems facing Sydney's transport systems.
One of the most critical issues identified by the EIS - the high demand for west-to-east transport generated by the demography of employment distribution - could much more easily and cost-effectively be solved by improving existing public transport systems and building new ones. Evidence of the Government's own Traffic and Transport Working paper shows that it acknowledged that the lack of adequate public transport is the real problem: `Fragmented economic development across Sydney has meant that many jobs are in non-centre locations that are poorly served by public transport. There are more jobs in Sydney's east compared to Sydney's west, generating a net flow of journey to work trips from west to east. Furthermore, many jobs in the east are also out of centre jobs not in Sydney CBD (e.g. the southern part of the Global Economic Corridor). Strategic centres hold 41 per cent of jobs within Sydney's east. These areas are not well served by public transport, particularly from Sydney's west and WestConnex would support travel to these out of centre jobs.' To conclude that a motorway will solve the public transport shortages identified by the Government is ludicrous.
6. The WestConnex M4 Widening Project (and the larger Westconnex project) not only fail to conform to the NSW Government's own 2021 Policy, they directly subvert it: namely, for instance, Goal 20, Build liveable centres, with the target to `Increase the percentage of the population living within 30 minutes by public transport of a city or major centre in metropolitan Sydney'; while under Goal 19 Invest in Critical Infrastructure, the Government has committed to `Enhance rail freight movement: double the proportion of container freight movement by rail through NSW ports by 2020′. The EIS makes it abundantly clear that the WestConnex M4 Widening Project will do nothing to achieve this, but rather erode available funding to achieve these ends for many years to come.
7. The information provided by the Government in the EIS and associated literature such as the WestConnex Factsheet (December 2012) claims that Westconnex should be built in order to cut travel times. But the figures provided show that this is a misleading interpretation of the data. For instance, the WestConnex Factsheet (December 2012) states that the trip by road from Parramatta to the Airport will take 66 minutes with WestConnex. However transportnsw's own trip-planner shows that, even at peak times, the trip can be made in around 47 minutes, on the city's present system of public transport. Imagine how swift it would be if even a fraction of the $15 billion proposed for expenditure on WestConnex were instead diverted to the more productive, forward-looking and intelligent provision of public transport. All the statistical evidence currently available shows that the growth in uptake and further appetite for public transport in Sydney is on the increase. See esp. the NSW 2011/12 Household Travel Survey, which shows that in the past decade, the demand for trains in Sydney has grown by 23%, nearly twice the extent of the increase in the city's population over the same period (12%); while the demand for buses has similarly increased at a rate (16%) greater than that of the population.

WestConnex Stage 1 M4 Widening and reintroduction of Tolls: Submission by Councillor Rochelle Porteous to the Environmental Impact Statement (EIS):

I am opposed to the WestConnex Stage 1 M4 Widening and reintroduction of Tolls for the following reasons:

1) Consideration of the EIS of WestConnex Stage 1 requires a publically available detailed business case, concept plan, the detailed cost benefit analysis and detailed information about the final route and Stages 1a, 2 and 3. None of this information has been provided. Nor has the EIS for Stage 1 been informed by the impacts of the projected Parramatta Road Urban Renewal Program which is reported to bring up to 50,000 new dwellings (with their associated additional population, additional vehicles and road and public transport users) all added to the Parramatta Road corridor but their impacts not considered as part of this EIS.

2) Traffic congestion and travel times are identified as key issues which the WestConnex seeks to address however this EIS does not consider alternative and potentially better and cheaper solutions to the traffic congestion and travel times such as investment in public transport infrastructure rather than investment in widening the M4 and the reintroduction of tolls.

3) It would appear that the traffic data used to develop traffic modelling for this EIS is not up to date, and in fact it seems that some of the data is as old as 2006. Traffic data and traffic counts need to be based on 2014 figures for this EIS and traffic modelling needs to be extended to include where the traffic impacts further down the corridor and small residential streets located nearby to the corridor.

4) More road capacity on the M4 will, over time, encourage more private vehicle use. Higher use of private vehicle use will see many of those vehicles travelling into or through the Inner West, hence increasing traffic congestion and parking pressures.

5) The reintroduction of tolls will mean the avoidance of the M4 for many vehicles, including large numbers of heavy vehicles which will seek to use alternative routes such as Parramatta Road and Victoria Road in order to avoid the tolls. This will mean more intensive use of major arterial roads throughout the Inner West and subsequent higher use of local residential streets as motorists and heavy vehicle drivers rat run in order to seek out alternative routes to avoid paying the tolls. These impacts of this are in no way adequately addressed in this EIS.

6) This EIS has been very poorly advertised and the period of submissions has been too short. I have spoken to a number of residents and business owners in Ashfield, Haberfield, Leichhardt, Annandale and Marrickville who want to put in a submission but were unaware of the EIS and now feel that they will not be able to make a submission in time. This is a large and costly project funded by the taxpayer and with widespread impacts it should be open for submissions for a further month and notification should be significantly improved.

See attached. I object to this project going ahead as proposed in the EIS.

Document uploaded below

As ACPE is a member of the Sydney Olympic Park Business Association (SOPBA), please see SOPBA's full submission

My submission opposing the WestConnex EIS is attached.

Please see attachment, included below is only the cover letter.

Submission to SSI 13_6148
Regarding the M4 Western Motorway - WestConnex M4 Widening
From NoW Public Transport Inc - September 2014

Dear Sir/Madam,

I am writing on behalf of the members and member groups of the non-profit NSW incorporated association: NoW Public Transport. I am writing to oppose the widening of the M4 Motorway as detailed in the Environmental Impact Statement attached to the application #SSI 13_6148.

We shall use the names Roads and Maritime Services (RMS) to refer to the agency, the Sydney Motorways Project Office (SMPO) and the Westconnex Delivery Authority (WDA) as their actions show no clear boundary between the entities. The subordinate organisations have shown they are driven largely by the agenda and actions of their parent agency.

We believe Roads and Maritime Services has certainly failed to satisfy the spirit of the legislation, and we put it to you that they have failed to fulfil the requirements necessary to complete the process.

Firstly there has been inadequate community consultation. By seeking the minimal legal time for the process, the community has been unable to fully assess and respond to the extremely complex application to alter the public's lands and environment. There is simply not enough time to find, read, and assimilate the information and then to write a thorough considered response

The EIS itself is over 300 pages of complex technical description. With extensive citations the EIS require an understanding of at least the NSW Long Term Transport Master Plan , the Sydney Strategic Transport Model, the State Infrastructure Strategy 2012-2032, the Draft Metropolitan Strategy 2013, and the NSW Freights and Ports Strategy. In addition there are several complex and significant appendices that are required to understand the agency's proposal and how it was developed, Further, there are many significant omissions that limit consideration of the above material. For example the reader is often unable to properly compare traffic volumes as they are from different baselines and cover different time periods.

The community has been given insufficient notice of the process, with very little advertising and no use of the agencies extensive contacts within the media. Also, the Department of Planning is improperly preventing search engines from spidering their Major Projects Register. It is inappropriate for a department in a democracy to use "Disallow: / "for "User-agent: * in their robots.txt and it is certainly against the spirit of a public exhibition.

For these reasons alone the proposal should be rejected and a further 60 day consultation period should be undertaken, with a wider awareness public campaign, and the robots.txt should be removed from majorprojects.planning.nsw.gov.au.
However those are not the only reason to reject this proposal.

The RMS and the state and commonwealth governments have not followed the "Appraisal Guidelines" from the "National Guidelines for Transport System Management in Australia". These guidelines where developed by the state and commonwealth governments to ensure that unwarranted projects did not consume taxpayers funds. The COAG approved appraisal process requires a detailed assessment of the project before a ministerial decision. In the case of the Westconnex the EIS clearly shows the modelling was done after the announcement of and commitment of funds to the project. The community can only conclude that is why it is currently being redesigned every few months. The agency and the government continue to improperly retain the commitment to fund and build a project that has not finished its initial planning.

Further the modelling was hurriedly undertaken, incorrectly using a model that was both out of date and empirically limited. The assumptions underpinning the model have been disproven and that means the Strategic Travel Model is incapable of predicting the future travel patterns in Sydney. It did not predict the last decades decline in private vehicle travel, in fact this observed mode shift breaks the model. The model assumes no mode shift and so predicts massive traffic volumes for the future of Sydney. These massive traffic volumes are then used to compute travel times which are then used to compute the inflated travel time savings which are used to justify the proposal.

The lack of adaptability is a known and documented limitation of the Strategic Travel Model. The models prediction of a two hour road travel time from Penrith to the CBD is unreasonable when the network travel time is the one hour time of the rail journey. Transport planners know that traffic volumes decrease when the travel time exceeds the network travel time. In addition, this model was developed using 2006 data and is out of date when compared to the observed 2011 data. As well, this model assumes different scenario to current government policy and so contains terminated projects while missing essential policy like Badgerys Creek Airport and the 50,000 unit Parramatta Road Urban Activation Precinct.
It is an unacceptable omission to ignore the massive traffic impacts of an additional 75,000, or more, private vehicles from the governments planned Parramatta Road Urban Activation Precinct, despite it being an integral part of the integrated Westconnex plan. A large UAP surrounding the M4 section underassessment will totally alter the scale and thus the impacts of traffic, noise, and other pollution. The proposal cannot be accepted until this UAP has been modelled and its impacts properly assessed by the agency and then the community.

What is more, the agency has failed to properly model and assess the alternative proposed by the governments, councils and independent reviews. The STM is designed to make it simple to model alternative proposals like the Parramatta-Olympic Park or the Light Rail and Parramatta Rd Light Rail. The agency must update their model and undertake public peer reviewed assessment of the alternatives to fulfil their requirements under the Act.

For all these reasons and many others, detailed below and in other submission, we believe there is only one reasonable and rational conclusion: reject the application.

The agency will then have time to do a thorough appraisal that fulfils national guidelines and also the requirements of the Act.

Sincerely,
Mathew Hounsell
President NoW Public Transport

Please see uploaded Submission

Please see submission in PDF attachment

Regards,
Sandra Langtree

Submission: M4 Widening for WestConnex

I am against the proposed widening of WestConnex, and the WestConnex project as a whole for the following reasons:

* No convincing statistics to show that travel time will be faster than taking the train (based on travel times given by the Sydney Rail site, which are in fact shorter than those provided in the WestConnex project data)

* Building more roads has been shown to increase traffic rather than alleviate it, and therefore has the potential to increase traffic and resulting problems along the proposed thoroughfare

* Funds should be diverted into providing sustainable solutions to road congestion, i.e. better public transport

* Better public transport would be a more cost-friendly, inclusive and equitable solution to improving transport from Western Sydney to the city for people living in Western Sydney

* Particularly as the Federal Treasurer has noted that "poor people do not drive cars", building roads rather than public transport will make travel to the city and access to employment least possible for those who can least afford it, thus widening the gap between rich and poor and not addressing barriers to employment

* Exhaust stacks do not have filters, and the concentrated exhaust that will be released as is into the atmosphere, posing a public health hazard - particularly as this corridor passed through highly-populated residential areas, and increased residential density is planned for these areas

* Increase in carbon emissions from increased traffic, at a time when world scientists and the UN agree that we should be desparately trying to reduce carbon emissions

* Work on this project should not go ahead until all details have been released to the public and have been duly debated and assessed. I refer to the incident of a local MP getting the government to agree to save Ashfield Park in return for not requesting information on the development. Avoidance of community consultation through acts such as this, and also through hiding the portal for submissions using the `robot.txt' extension is underhanded, and the lack of transparency indicates that the government is wilfully hiding information about the development which is not in the public interest.

Thank you for your consideration.

Thales supports this Govt initiative

See attachment.

Please see attached submission.

Please find attached Parramatta City Council's submission to the EIS for WestConnex M4 Widening project.

Please refer attached letter.