VICTORIA ROAD "UPGRADE"

Submission No. 2 to the Department of Planning from Action for Public Transport on Application No MP 08 _0136 - The Roads & Traffic Authority's proposal for a second Iron Cove Bridge and "tidal" traffic flow facilities on Victoria Road.

This submission is based on information provided by the NSW Roads & Traffic Authority (RTA) in its 4-volume Environmental Assessment (EA) for the above project dated October 2008, and other events which have occurred since the release of the EA. It supplements our Submission No. 1 which we lodged on 27 October 2008. That submission is available at http://www.aptnsw.org.au/documents/vicrd.html. This submission again opposes the RTA proposal, on the following grounds.
  1. The Proposed M4East Motorway receives too little attention in the EA

    The State Government has repeatedly announced that it intends to build an M4East Motorway, in some form, between Strathfield and White Bay. This idea in itself defies three decades of modern urban planning, in which inner-urban radial expressways have long been discredited. That the RTA should produce such a major document as the EA, for public information, with only passing reference to plans for an M4East in the immediate vicinity, and with which Victoria Road must interact, is at best misleading (Vol. 1, p 7-24).

    The EA dismisses changes in traffic volumes "on Victoria Road" resulting from the operation of an M4East as unlikely to adversely affect the operation of bus priority measures (Vol. 1, p7-24). However, it conveniently ignores the impact that M4East traffic would have on the operation of buses across Anzac Bridge.

    When it is considered that all the major decision-makers in this whole approval process, including, presumably, the minister charged with approving or not approving the project, are fully aware of the RTA's options for an M4East, the charade purporting to be public participation in the planning process approaches high farce.

    Before making a decision on the project, the Approval Authority, (the Minister for Planning) should direct the RTA to revise the EA, taking into consideration the full impact on bus services of the most likely design for an M4East motorway.

  2. The project is not economically viable

    The benefit/cost ratio (BCR) for the project is 0.94 (Vol. 1, p 3-24). That is to say, in lay terms, the cost of the project outweighs the benefits. The RTA's accompanying arguments, defending the low BCR, are selective and biased, failing to acknowledge the negative aspects of the BCR.

    We note that this project has been funded in the State Government's November 2008 "mini-budget". The Approving Authority should seek clear explanations from Treasury as to why this project, with its negative economic rating, is preferred over other projects having positive economic benefits.

  3. The Rozelle "Metro" Railway is not properly accounted for

    The EA assumed a NorthWest metro railway, with a station at Rozelle, would be operational by 2017. Since the EA was released, the government has announced the construction of a shorter metro, between Central and Rozelle. This much shorter metro can be expected to become operational well before 2017. The Rozelle terminal station will be within one kilometre of this project. Given that this project is supposed to be primarily aimed at improving peak hour bus travel times to the city, and that promotional material for the NorthWest metro on the same route advertised metro travel times of five minutes between Rozelle and Wynyard (MetroLink, March 2008, p7), it would seem that this project and the metro must inter-act, and that they should be considered together.

    We recommend that the Approval Authority direct the RTA or other transport planning entity to revise the EA, treating the Victoria Road bus improvements proposal, and the Rozelle metro railway, as inter-dependent.

  4. This "road" project ill-fits broader urban planning requirements in the Inner West

    We urge the Approving Authority to consider the relationship between this road-building project and the broader urban planning issues of the Inner West Sub-region. Our review of the government's July 2008 Draft Inner West Subregional Strategy may be viewed at http://www.aptnsw.org.au/documents/InnerWestPlan1.html.

  5. The project fails Greenhouse criteria

    We note that this project offers a nett annual saving of 212 tonnes of carbon dioxide equivalent greenhouse gases (Vol.1, p7-20). However, greenhouse gasses attributed to construction are estimated at 30,096 tonnes (p7-19). The offset period has been calculated as up to 140 years (p7-20).

    On this criterion alone, the Approving Authority should refuse to approve the project.

  6. The flawed logic of acquiring part of Brett Park for car-parking

    Recent news reports suggest that parts of Brett Park will be used for car parking, temporarily or permanently, in compensation for the loss of car parking spaces elsewhere as a consequence of the project. APT would strongly oppose any such move. An equally compelling argument could be made for the reverse; converting some street-space to parkland, in compensation for parkland lost for use as construction sites.

    We recommend that the Approving Authority direct that only the minimum amount of parkland be permitted to be used for construction site purposes, and that no existing parkland be used, temporarily or permanently, for the purpose of parking motor vehicles.




Kevin Eadie
Convener
Action for Public Transport (NSW) Inc.
PO Box K606, Haymarket NSW 1240.
http://www.aptnsw.org.au
24 November 2008.