Why the M4-M5 Link should be opposed
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 global warming and encourage more car use, quickly filling the increased road capacity. It is not a sustainable solution to Sydney's congestion problem. The impacts on the health and well-being of local community’s both in the construction and operation phases are unacceptable.
The fact that the State Government released this Environmental Impact Statement (EIS) just 2 weeks after submissions closed for comment on the M4-M5 Link Concept Design, undermines community confidence that this is a genuine consultation process.
Additionally, the 8 week consultation period for this EIS is inadequate and does not allow sufficient time for all stakeholders to articulate why this project must not proceed.
Privatising our transport
It is part of a plan to drastically increase privatised road transport throughout Sydney rather than to build long term environmentally sustainable, public transport. The recommendation to approve this infrastructure is dependent on the construction of more large, prohibitively costly tollroads north and south of Sydney which will lock out cheaper and more desirable public transport options for many decades.
Given the NSW government will sell the majority share ownership of this project as part of the sale of the Sydney Motorway Corporation, the costs and consequences of the project will be non-transparent and put the public’s interest at risk.
Destroying our health
WestConnex will impact negatively on the health and wellbeing of residents in the inner west specifically increasing toxic pollution levels near the proposed unfiltered ventilation stacks which are located in residential areas and also near schools and parks. Particulate Matter affects more people than any other pollutant and the most health-damaging particles are those with a diameter of 10 microns or less, (≤ PM10), which can penetrate and lodge deep inside the lungs which are those which will be concentrated in highly densely populated areas as a result of WestConnex.
Increasing traffic congestion
This plan will lead to decades of unacceptable traffic congestion in the inner west. The EIS shows that the project will cause increased congestion on the existing road network in already congested key road arteries in the inner west including parts of Mascot, on Frederick Street at Haberfield, Victoria Road north of Iron Cove Bridge, Johnston Street in Annandale and on the Western Distributor until other unfunded and unplanned major road projects are completed. This increase in traffic congestion and associated pollution is unacceptable.
The construction of tollroads has been shown to induce more traffic rather than to decrease it.
The traffic modelling in this EIS has been done by a company called AECOM. AECOM no longer does such modelling due to a successful legal action against them which found they were responsible for inaccurate modelling on the Brisbane Clem 7 freeway.
Negative impact on communities
The plan will lead to the imposition of extended clearways on key high streets in the inner west including King Street which will destroy businesses and impact negatively on the social and cultural fabric of the community.
The plan will impact on key high level heritage protection areas and sites in Newtown with a significant number of heritage protected buildings in the project’s footprint. The impact on these buildings is not quantified and damage to them will seriously impact our national cultural history.
Unacceptable risk with 'indicative' EIS
The level of uncertainty and risk which have to be resolved after planning approval for this project to eventuate is unacceptable. The M4-M5 Link EIS does not contain detail of the design and construction approach but is only indicative with significant elements of the project, including the actual route and real construction impacts, not planned. It is unacceptable to seek Planning approval for a project of this size, cost and social and environmental impact, without supplying this essential detail.
The proposal to construct three layers of tunnel and interchange under homes in Lilyfield and Rozelle is untried anywhere in the world and there are no existing safety guidelines for such a construction. Allowing a future private construction company to make fundamental decisions about infrastructure of this size is unacceptable and will place the community at severe health, social and environment risk.
Unacceptable risk to heritage properties and infrastructure due to tunneling
This EIS has not modeled the localised impact of settlement due to tunneling and excavation which will lead to groundwater withdrawal. Localised modelling is possible but has been deferred to be undertaken by the construction contractor even though this modeling comes under the Secretary's Environmental Assessment Requirements (SEARs) which requires the assessment of “impacts from any permanent and temporary interruption of groundwater flow, including then extent of drawdown……. and the potential for settlement” (SEARS (10(b)).
The studies undertaken for the EIS predict ground water withdrawal will permanently impact ground water levels at the end of construction up to 500 metres on either side of the tunnel alignment ( Appendix T p xii) and up to 1.4km over the longer term in some areas. This modelling predicts that at the end of construction, steep localised cones of depression will develop beneath Newtown and St Peters within the Ashfield Shale. (P19-29).
As no localised groundwater modelling has been undertaken at the EIS stage there is no transparency regarding which properties may be subject to potential exceedances of settlement criteria. The EIS does not state who will undertake the precondition surveys, how the findings will be published and who will be liable for ‘make good’ should the criteria be exceeded in practice. The EIS implies this may be the responsibility of the construction contractor which would be a clear conflict of interest.
Original rationale for WestConnex removed
The rationale and justification for WestConnex as a link from the west to the airport and Port Botany is no longer current. The WestConnex project and the M4-M5 Link has been justified as a State Significant Infrastructure (SSI) project by providing a link to Sydney’s west with the airport and the Port Botany precinct. This link is not now included in the WestConnex project plan and therefore the justification for the project is no longer valid and the whole project should be reassessed and withdrawn as SSI.
Inaccurate Business Case
The Business Case for this project is inaccurate and misleading and has not been amended to reflect the significant changes to this project’s scope from the March 2016 SEARS to revisions in Sept and then November 2016 which include extra kilometres of tunnel and stub infrastructure to link to further proposed infrastructure.
Additionally the removal of the proposed portals in Camperdown, means that the existing traffic modelling is more inaccurate particularly in relation to the St Peters Interchange and therefore the predictions of usage of WestConnex are also inaccurate.
Lack of good governance
The Australian National Audit Office made a series of strong criticisms of the federal government's financial support for Westconnex in February 2017. The report shows that the rationale for funding this project was deeply deficient. It condemns both the Liberal Coalition and the ALP, who were pushing the WestConnex project since 2012, well before even an initial business case was presented to the appropriate government departments for consideration
The Report finds that despite the consistent early advice from the Department of Infrastructure and Regional Development and Infrastructure Australia that the project could not be recommended for federal funding, both the ALP and the Coalition provided significant support for it.
The report shows the government bypassed key governance structures in pushing through up a $2 billion 34 year concessional loan and providing a $1.5billion grant. And that the public's interest was not fully represented in the terms of the concessional loan.
Impact on Aboriginal Sites
There are at least 13 significant Aboriginal sites within 500 metres of the WestConnex project corridor and the Iron Cove Link including rock art and shelters, middens, open artefact sites and potential archaeological deposits which may be negatively impacted by the M4-M5 works especially as the specific routes and construction methods are unknown and so the potential impact could be severe.
Climate Change Risk
There are significant high risks identified to the operation of the project related to climate change, including an increase in the intensity and frequency of extreme rainfall and an increase in frequency and intensity of extreme heat events. Of note is the extreme risk of flooding at Rozelle as a result of intense rainfall combined with sea level rise and an increase in extreme storm surges into Rozelle Bay. These risks have not been properly assessed and no mitigation proposals have been included in this plan. The expenditure of billions of dollars of public money on a project with risks such as these is irresponsible.
Now you’ve seen this summary of some of the key issues, make a submission via our site here or if you have made a donation to any political party or would like to see the full EIS, you can make your submission here.
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