(The People’s EIS has already published a number of individual stories that demonstrate the severe social impact of the proposed project. We have suggested that the GHD Social and Economic Impact study that was prepared in conjunction with AECOM is inadequate. These reports were contained in Appendices M and N and were combined into a single chapter in the main report.)
The reports find major short term impacts would be experienced in Haberfield, Homebush and elsewhere. Here is a summary of the reports.
The consultant recommends mitigation for a number of potential impacts but overall the report fails the convey the seriousness and significance of impacts, some of which are already occurring.
This post presents some additional reasons why the social and economic impact reports are inadequate.
- a lot of the work for these reports was done in 2014 when the proposal was for a different route than the one finally chosen by the Westconnex Delivery Authority. This work consisted of a desktop collection of official socio-economic and demographic data and consultations with Councils and social infrastructure organisations. The report appears to have suffered from insufficient time or resources to adjust to the route announced in 2015. Despite the devastating impact of the preferred route on Haberfield and Ashfield, the consultant did not update the consultations with Ashfield Council and so the reports failed to convey the significance or seriousness of the impact of the removal of homes and loss of heritage in the Haberfield area. Most of the report consists of basic data with little analysis.
in the process of rushing to adjust to the new route, the consultant ignored potential impacts on some organisations such as the Dobroyd Point Primary school.
because she was not in touch with the area and had limited time, the consultant was not aware when she wrote the report of the extent of dislocation that is already being experienced by many people being forced to move from their homes. She recommends mitigation measures such as counselling support for people experiencing stress from forced relocation are quotes Westconnex as stating that this support now exists. The consultant appears to accept and restate Westconnex’s official version of their policies bu6 residents have reported to the People’s EIS that they have not received support from Westconnex. While more research is needed and it could be true that some residents are more satisfied than others, there is enough evidence to show that WDA assurances on mitigation measures cannot be taken at face value. The consultant also recommends further support as if social impacts due to forced acquisition would occur in the future when in reality they are already happening now. This is one of the ways in which the GHD study lacks sufficient independence from the WDA.
Framework for analysis not applied
The report sets up a three way methodological framework for analysis in space, time and strength of impact ( Chapter 14. Section 3) but barely refers to it again in the report. When asked about this the consultant said that in making her decisions and recommendations, she exercised her “professional judgement.” The approach is not transparent and is superficial. This is worrying when one considers that the consultant did not do any field work. This explains the very distanced tone of the report. There are few case studies or examples provided of impacts on the community.
It is difficult (including in the SIA and EIA appendices) to see how the methodology was used.
- how does the Economic Impact Assessment come to the finding that, ‘Overall, the assessment has concluded that the positive impacts on businesses and the economic benefits of the project are expected to outweigh any negative impacts that cannot be satisfactorily mitigated’ (Appendix N, p. 9–1)?
The social impacts of transport infrastructure, prior to analysis (given in the methodology section), are considered to be ‘property acquisition, community networks and amenity’ (Chapter 14, p. 2), an insufficient starting point for a project of this scope and impact.
‘City of Sydney Council LGA is outside the project footprint and would be indirectly affected’—at this scale transport infrastructure would be expected to affect traffic flows and the central city of the region in which it is implemented. The indirect impacts are not explored.
The methodology section also refers to extra social research that was conducted in additional to the desktop review. No bibliography was included for this and there is no indication in the report about this social research.
Case studies from failed projects
The Social Impact assessment uses social impact studies of earlier failed tollway projects as case studies without explaining that they failed. In these cases, social impact studies found that despite likely negative social impacts, the tollways were justified. It is surprising that AECOM which is currently being sued by investors in the Clem7 for negligent traffic modelling would put forward its social impact assessment as a useful case study. The intended purpose of the case studies is not clear. It appears to be ‘padding’.
The social impact study states there will be impacts without investigating their costs and depth. Simply listing social infrastructure within the study region cannot be defined as social impact assessment—nowhere (either in Chapter 14 or in the Social Impact Assessment) is there a systematic review of each piece of (social) infrastructure against a best-practice framework to determine whether it will be affected and, if so, the extent to which it will be. It is not sufficient to merely record the concerns of organisations such as occurred in the case of the Willows Nursing Home.
Minimal Stakeholder and Community Involvement:
- there were no direct consultations conducted with local businesses for the economic impact report. This would appear to be a major gap in the collection of data.
When evaluated against the international IAP2 Public Participation Spectrum the ‘community involvement’ centres around ‘informing’ (the lowest stage on the spectrum with the least impact on decisions) and only rarely could be considered ‘consultative’ (the second lowest). There have been many complaints about the whole consultation process and slow and vague information provision. This is relevant to the entire planning process but is particularly concerning in relation to the social impact assessment because the consultant openly acknowledges that she did not directly consult with anyone in 2015 preferring to pass questions through Westconnex communications staff who were also promoting the project, dealing with media inquiries, managing EIS sessions and communicating with people who were being forced to move. This compromised the independence of the SIA and EIA reports. It also explains why the feedback tables provided in the report are out of date and do not take account of the impacts of the new route.
On page 95 of Appendix M, the consultant states that a preconstruction consultation framework would be developed,
The framework would ensure that local residents, businesses and workers are provided timely and clear information in regard to local changes and progression of project construction and operation. Project communication would consider the cultural and linguistic diversity in the project local study area in communicating project information effectively in community languages (i.e. through translation, use of interpreters, specific language broadcast services and cultural organisations).
This recommendation is well-meaning but is hard to take seriously when there have been constant complaints about the nature of the consultation and communication provided.
Minimal mention of health and heritage impacts
While seemingly significant heritage effects are identified in Appendix M as well as concerns raised by local councils regarding this, the only mention in the main document’s Chapter 14 Social and economic comes briefly under ‘Section 14.4.2 Changes in amenity’ (‘loss of heritage items and changes to streetscapes’) and concerns brought up during community consultation (Section 14.1.4).
Health impacts are mentioned in Appendix M (p. 87) as ‘worst case assessments without mitigation would likely generate health impacts for some receivers during some works’. These are not elaborated.
Chapter 14. Mentions of ‘health’ are otherwise limited to issues raised during community consultation (section 14.1.4), under construction impacts and operational impacts as ‘Health of the community’ (though no further information is given), and in broad terms (such as ‘Relocation health risks’ or ‘important for community health’).
Given community health concerns (and those raised during consultation with the public and councils), this issue needs to be better addressed to ensure the appropriate ‘mitigation’ measures as mentioned are followed.
Inadequate Economic Impact Assessment
The EIA (Appendix N) is not based on a sound business case or cost-benefit analysis, thus limiting detail and the accuracy of any findings made. For instance there is no consideration of negative, direct or indirect effects to the ‘wider state economy’ (Appendix N, p. 6–1), despite consideration of several positive indirect or cumulative effects.
For the purpose of the EIA, an affected business has been defined as a ‘business that would be impacted by property acquisition, changes in amenity, changes to accessibility or changes in the volume of passing trade due to the construction and operation of the project’—though a figure for the actual total number of businesses these changes affect is not provided in the EIS.
The geographical scope was wider (including the wider state economy) for the EIA (Appendix N) than the SIA (Appendix M) but this is not explained in Chapter 14 Social and Economic where analysis takes places seemingly simultaneously between social and economic impacts, at differing scales. This is extremely confusing.
In ‘Chapter 14 Social and Economic’, Appendix M and Appendix N, cumulative benefits are given preference – such as overall travel time improvements to 2031 once all project sections are complete, while cumulative negative impacts of the overall project are largely overlooked.
If cumulative negative aspects were considered, the opportunity cost of not spending $15.4 billion on a more efficient transportation system (or any public asset) could be evaluated (if the benefits are considered for the whole project at a NSW scale, so too should the negative aspects). Instead, the EIA is by its own admission predominantly ‘a qualitative assessment of the impacts’ (Appendix N, p. 3–4), despite its use of economic multipliers as a quantitative measure.
Relationship to other technical reports
The consultant claims to have reviewed all the other technical reports but since most of these were not ready until shortly before submission, the review is unlikely to have been an in-depth one. Any deficiencies in these reports -e.g. the noise report – would have implications for the social and economic impacts of the proposed project and be an additional reason to review the findings in these reports.
Lack of Independence from commercial interests
There are independent social researchers both in universities and elsewhere who could have done a high quality social and economic assessment including a cost benefit analysis of the M4 East proposal. GHD is in a number of infrastructure markets. These markets do not include social infrastructure or research. This raises questions about whether there is sufficient protection of the public interest in the planning process.
(Wendy Bacon, Anthony McClosker and Nicole Gooch have contributed to this post)
For other reports relevant to Social and Economic Impacts read:
Summary of Social and Economic Impacts: https://m4eis.org/2015/10/04/summary-of-m4eis-social-and-economic-impact-reports/