NSW Department of Planning
Attention - Regional Director, Sydney East Region,
GPO Box 39, Sydney, 2001.
(by email innerwestsubregion@planning.nsw.gov.au)

Dear Sir/Madam,

Inner West Subregional Strategy

On 8 July 2008 the NSW Government invited submissions on its Draft Inner West Subregional Strategy ("the Draft"), with a closing date for submissions of 5 September 2008. The subregion is identified as lying between the Sydney CBD and Parramatta, and the Parramatta River and Parramatta Road / Georges River Road. This submission is in response to that invitation.

We first need to place this submission into context. Our particular interest is in the quality of the future accessibility and mobility of the residents, workers, and visitors to, the subregion. At the same time we would seek to minimise the negative impacts on the subregion of those people who will just be passing through.

The Department of Planning has previously issued draft subregional strategy documents for other subregions. We reviewed those documents at the time, and came to the conclusion that, so far as transport planning was concerned, the rationale within the so-called strategy was flawed. For example, the modest improvements in bus services, brought about by the implementation of the "Unsworth" strategic bus corridors, were far outweighed by the grander improvements to the roads system. We didn't believe the bus improvements would achieve the theoretical modal shift which the document claimed would be achieved. Hoping that some better qualified authority would draw attention to these shortcomings in the draft plans, we concluded that the plans were not genuine, and declined to lodge submissions.

But our hopes were in vain. The current document, the Draft Inner West Subregional Strategy, inherits the same gaps in logic as its predecessors, which is the main reason why, on this occasion, we have chosen to document our views.

The Draft purports to be a strategic planning document, looking forward to the year 2033. Part of its purpose is to solicit informed comment from the public. We would have expected a "draft" strategic planning document to present a vision for Sydney for 2033, and perhaps a number of alternative strategies for achieving that vision. This would have enabled respondents to consider the alternatives and become involved in the decision-making process. But the Draft adopts a "top-down" approach, and fails to solicit grass-roots opinions from the community. By so doing, the Draft does little to engender any sense of community ownership of the strategic planning process. Instead, it still contains the rhetoric about managing traffic demand and luring people onto public transport, but little about what the government intends to do between now and 2033 to implement the rhetoric, and seemingly more about what the government has already done.

We could not find any transport planning initiative in the Draft which hasn't already been announced.

In the Draft, the NSW Premier describes the document as "a vision for the management and development of the subregion over the next 25 years", with an emphasis on financial, economic, environmental and social sustainability.

The Draft's principal disappointment is its failure to discuss in any detail the three biggest impending impacts on the subregion: the proposed $12 billion North West Metro railway, the proposed $10 billion M4East Motorway, and the phenomenon known as Climate Change.

The concept of a new, high capacity, "metro" rail network was mooted in the Government's 2006 Urban Transport Statement. The Government's intention to build the first line, the North West Metro, was announced on 18 March 2008. The Draft is dated July 2008, but no further information on the Metro has been forthcoming in that four months to facilitate public discussion of the Draft. Metro stations will open in Rozelle and Drummoyne by 2017. Proper strategic planning would have considered land-use issues in the immediate vicinity of the stations. There is no mention of the Metro stations, let alone their impact on residential or other land-use densities, in Chapter C, "Housing".

The M4East Motorway has been mooted since 2003 but the Draft provides no information on the government's current plans. If built, the motorway will severely compromise any other strategy designed to achieve a modal shift from private to public transport. Despite the lack of information in the Draft, the Sydney Morning Herald revealed on 31 July 2008 that one of the options for the M4East includes a tunnel portal immediately to the south of the Iron Cove Bridge, well within the subregion under discussion. An indication of the care with which the Draft has been prepared is evident when it claims that "The NSW Government will release its proposal to extend the M4 Motorway for public comment in early 2008" (page 9). That proposal had still not been released when the Draft itself was released in July 2008.

The Metro, the M4East and the government's more advanced plans for what is termed a Victoria Road "Upgrade", must interact. The Draft does not even acknowledge any such relationship, let alone discuss it. However, a subtle shift of emphasis is noted regarding the Victoria Road "Upgrade". Until now, Government and Roads & Traffic Authority announcements, including a substantial advertising campaign, have promoted the "upgrade" as primarily to improve bus services on Victoria Road. The Draft places general traffic flow first (page 82) and bus improvements as secondary.

The Draft does not mention Climate Change. "Greenhouse" gets mentioned only in passing. We note that the transport sector's increasing contribution to greenhouse gases was acknowledged in the Government's 2006 Urban Transport Statement. An M4East Motorway, in any form, by offering higher average speeds, would encourage longer motorised trips, jeopardising any federal government initiatives to reduce greenhouse gas generation from the transport sector. The Draft does not address this issue.

The rhetoric of "enhanced transport ....through improved public transport" is there (p4) but the detail is missing. There are no new public transport initiatives which haven't already been announced. Far from being part of a "vision", as described by the Premier (page 3), the Rail Clearways program is well advanced, having been announced by the then Transport Minister as far back as 21 August 2003.

The Strategic Bus Corridors, upon which so much of the planned modal shift will depend, are similarly dated and already partially implemented.

These weaknesses in the Draft as a strategic plan for public discussion, must weaken in turn the quality and value of any public responses. This could undermine the transport planning process as a whole, leaving the process open to manipulation by vested interests, such as occurred with the approval and construction of the Sydney Harbour Tunnel, and further exemplified by the recent revelation of repeated lobbying by high-profile persons for a privately funded "Western FastRail" railway between Penrith and the Sydney CBD.

Given the above shortcomings, and the fact that the Draft opens with the enthusiastic endorsement of two politicians, but no attribution to any planning professional, some readers may be tempted to conclude that the 2008 Draft Inner West Subregional Strategy is perhaps part of a political strategy rather than a planning one.

Kevin Eadie
Convener
3 September 2008.