In September 2015 Marrickville Council reaffirmed its “absolute opposition to the WestConnex project”. Its EIS submission to the M4 East is a powerful rejection of the project. Its staff and independent experts evaluated the EIS and concluded:
- That the EIS does not justify that the significant expenditure on Westconnex would benefit the broader community including public transport users, pedestrians, cyclists and communities generally. The benefits for toll paying motorists indicated in the EIS are also dubious.
- There has been no real analysis of alternatives to the M4 East and alternatives that are considered are assessed in isolation of integrated solutions.
- The EIS assumes that all sections of WestConnex (with the possible exception of the Western Harbour Tunnel) are completed by 2031. If all sections are not completed simultaneously the traffic flowing from the M4 East will have adverse impacts on the inner
west and central Sydney.
- To properly evaluate the WestConnex project there needs to be an over-arching EIS for the entire project, i.e. Stages 1, 2, 3, the Southern Gateway and The Sydney Gateway; possibly also the Northern and Southern extensions.
- The EIS itself acknowledges that the forecasted peak traffic patterns appear to be counter intuitive – westbound in the morning peak and eastbound in the afternoon peak. When compared to recent traffic trends in Sydney this outcome is hard to comprehend. The EIS explanation of this outcome is contrived and complicated and a more likely explanation is a miscalculation in the transport modelling.
- The EIS does not explain how toll levels and people’s perception of tolls changes into the future. Given the impacts this can have on existing surface roads and the recent toll road failures in Sydney this appears to be a significant omission.
- The EIS is not very detailed in relation impacts from other components of the project such as the M5 extension/expansion and M4-M5 link and this shortcoming hides further impacts
that would be experienced through the Marrickville LGA (i.e. M4 and M5 extensions without the M4-M5 link). Even with the 2031 ‘do something’ case which includes all the Westconnex stages, there is still little detail on the impact on the roads south of Parramatta Road.
- The EIS must identify the likely impacts of induced traffic on residential streets in the Marrickville LGA ,by means of an appropriate local area traffic management study, and mitigate those impacts by Local Area Traffic Management works. The study should include post implementation reviews to identify and address any unforeseen impacts.
- The transport model used by the M4 East EIS does not include public transport assignment or public transport demand forecasting. Due to the lack of a mode split process in the transport modelling, the competing disbenefits of traffic congestion and rail crowding have not been tested for the EIS.
- The implications of increased bus traffic along Parramatta Road into the Sydney city centre are not addressed by the M4 East EIS. How the central city road network will deal with increased bus traffic is unknown.
- The absence of a long term modelling (for example 2041) from the M4 East EIS means that any longer term traffic or socioeconomic impacts are not being identified, mitigated or monitored.
The ‘worst case’ assessment presented in the Air Quality Assessment does not consider the maximum emission rates (in g/s); hence the worst case scenario is not in fact considered.
- The health impact assessment should be reviewed to include a comprehensive assessment of the health impacts, in consultation with affected people and communities, to identify positive impacts and better mitigation measures for negative impacts.
Director General’s requirement ignored
- The EIS does not satisfy the Director-General’s Requirements “consideration of the WestConnex Urban Revitalisation Project” as evidenced by the location of the Powells Creek M4 on-ramp at the centre of a place that is earmarked for major urban amenity transformation in the Homebush Precinct under the Parramatta Road Urban Transformation Strategy.
Cycling alternative ignored
- No pedestrian and cycling report has been included in the EIS on the basis that the M4 East would operate in parallel with Parramatta Road. Cycling is a viable transport option and it should reasonably be expected that the EIS would evaluate the strategic opportunities for providing cycleway and pedestrian transportation to create connectivity and integrate with the surrounding communities.
Poor economic assessment
- The economic impact assessment in the EIS does not provide justification for the proposal as it lacks a comprehensive assessment of the impacts, based on detailed modelling, cost/benefit analysis, inclusion of opportunity costs and a business case.
Social Impact assessment weak
- The social impact assessment needs to be reviewed to include a comprehensive assessment of the social impacts, in consultation with affected people and communities, to identify positive impacts and better mitigation measures for negative impacts.
- No scoping of the population groups who will potentially be affected undertaken – apart from the people whose land will be acquired (referred to as properties rather than people in the report) and some social infrastructure is not included (the people who use the social infrastructure are not mentioned,)
- No direct consultation has been carried out with the people and population groups who will be directly affected (had they been appropriately identified). It would have been useful to ask them what they needed to manage the impacts on their lives
Soil Contamination investigation need to be done
- The investigation undertaken and outlined with respect to contamination could only be considered a Preliminary Site Investigation as per the Guidelines for Consultants Reporting on Contaminated Sites (NSW EPA 2011). The scale of the proposal, lack of information about past activities, and known presence of contamination and contaminating processes over the entire project site warrant a Detailed Site Investigation prior to approval, and not deferred to a later stage.
- There are significant gaps and inadequacies in the methodology used and assessment of biodiversity impacts.
Sustainability and Climate Change
- Commentary should be included on the comparison of car versus public transport emissions and how the NSW Long Term Transport Master Plan objective to grow the proportion of travel by sustainable modes such as public transport is being addressed.
- The EIS does not adequately address the impact of the project on future climate change. This project must be considered with reference to Australia’s commitment to emissions reduction and Ecologically Sustainable Development as outlined in the Protection of the Environment Administration Act 1991 (NSW) and the Environment Protection and Biodiversity Conservation Act 1999.
It is evident based on ths evaluation that the ** decision to proceed with WestConnex was made prior to a thorough assessment of whether or not the project was the best way to manage Sydney’s transport needs in the context of the role that WestConnex is intended to serve. Moreover, it is evident that the role of the EIS for this project has been limited to an assessment of impact and mitigation measures that could be applied as opposed to a genuine consideration of alternatives to the proposal. For these reasons the project is and has been flawed from inception and should not proceed based on the assessment within the EIS.**
Council’s submission finds that the project has no basis to proceed and recommends that alternatives to the M4 East should be further evaluated, including:
– Expansion of the new Metro:
- from Bankstown to Parramatta and Epping/Macquarie Park
- from Parramatta to CBD via Ryde/Drummoyne and/or Strathfield/Olympic Park
- from Strathfield/Burwood north to Macquarie Park and southeast to Green
Square/Airport and Randwick/Bondi Junction
- New road connection from Port Botany to M5 to enable better dispersal of freight from port;
upgrade A3/A6 for freight heading north
- Increased services along Western Rail Line
- Improved connections to stations along Airport/Revesby line including park and ride options
at major stations; increase frequency of services along this line
- New stations on the Airport Line in the Green Square area
- New and improved bus or light rail connectivity/priority along Parramatta Road; investigate
- Expansion of growing light rail network
- Light rail network for Parramatta City
Revised approach to WestConnex would ideally be based on the following principles:
- Creating healthy built environments by encouraging people to walk, cycle and recreate
more and use active transport.
- Improving equity – pursuing an outcome that does not destroy one persons’ amenity to improve someone else’s amenity – that is not equitable.
- Actually committing to helping people to manage the changes (in their lives), rather than leaving it at suggestions (this help should be thought out and planned for implementation with the start of any project).
Read the whole Marrickville Council submission : 07. Marrickville Council EIS Submission