| Action for Public Transport (N.S.W.) Inc. |
| P O Box K606 |
| Haymarket NSW 1240 |
| 30 April 2024 |
Action for Public Transport (NSW) or "APTNSW" is a transport advocacy group which has been active in Sydney since 1974. We promote the interests of beneficiaries of public transport - passengers and the wider community alike.
Our basic position with respect to tollways is that they are inimical to the development of good public transport. Public transport works best when focussed on dense centres. Decisions to build tollways are generally based on the opportunity for the builder to make a profit on the deal by charging traffic. They invariably bypass the centres (Hurstville, Chatswood, Parramatta, Blacktown, ...) which define the structure of Sydney's older suburbs. This weakens those centres. Instead, tollways facilitate rapid trips between points remote from all centres.
While the fact of their toll mitigates the effect somewhat, there can be no doubt that Sydney's tollways increase the kilometres travelled by private transport (and the present Review agrees - see finding 15 and recommendation 5). Our view is that they generally decrease public transport patronage. Contrariwise, the M2 is reportedly protected by contract terms against loss of patronage due to, inter alia, competition from new public transport services. However it is not clear whether opening of the railway to Tallawong triggered any consequences arising from those terms.
We would also like to make some comments that don't have any obvious connection to public transport.
Hands are tied
The interim report notes that changing any aspect of tolls on Sydney's many privately-owned toll roads can't happen immediately and probably can't happen until each road's concession period expires. This extends to tweaks such as reducing tolls outside peak hours although perhaps not to changing cashback arrangements. However, no such difficulty applies to imposing new tolls on other roads. In fact, concession holders could expect increased patronage if parallel routes ceased being free.
The present Review's function is to find courses of action that would make things better. There is no need to limit the Review to the constraints of existing contracts or government policies (but we concede that s.90 of the Constitution won't change). The Review should feel free to recommend toll structures that reduce congestion, for example, even if those structures are inconsistent with pre-election promises.
State TollCo(m)
We think that this body could play a vital role in planning Sydney. Among other things, it could affect the attractiveness of public transport by making competing car trips more costly in time or money. We suggest it should be under close government control and perhaps should be set up as State TollCom rather than looking like something that's supposed to make a profit. One of its important functions will be educating the public on why there should be tolls on some roads that aren't tolled already; profit-making bodies are unconvincing moralists.
SHB/SHT/ED tolls
The review suggests making the tolls apply to both directions of travel. Two remarks:
Notwithstanding government policy, the present Review seems to accept the position of Professors Hensher and Levinson that new tolls should one day be imposed on existing streets that parallel tollways. We agree; it's called road access pricing. The Review should look into how best this might be accomplished and when.
Although road access pricing has been ruled out from time to time, it is on its way. It was foreshadowed by Fletcher1 as discussed by Gittins2.
Declining distance-based pricing
One of the functions of State TollCo will be processing gantry data in order to identify long trips and levy tolls accordingly. This will presumably involve making assumptions that will sometimes be quite wrong, causing some drivers to be debited for more than they would expect. We suggest it would be easier, and would yield very similar results, to charge a lower amount per kilometre in the western suburbs (west of Lidcombe) than in the east. The quote from the TWU submission reprinted on page 106 of the interim report clearly shows the close relation between longer trips and trips in the western suburbs:
The distance-based methodology does not account for the fact that Western Sydney motorists live further out from central locations, and as such, are required to travel upon the full gamut of tolled roads and pay the maximum associated toll charge in order to access their destination. In effect, charges calculated via the distance-based methodology punish motorists living, working or frequently travelling to, from and throughout Western Sydney.This punishment is unnecessary and should not happen.
NYC
Tolls on vehicles entering Manhattan via certain routes come into effect in a few weeks' time. Interestingly, electric vehicles will at first be exempt from the new tolls. The present Review could usefully examine these new tolls and compare them with what is envisaged for Sydney.
Evading ANPR
We understand that ANPR is widely used in USA when levying tolls. To evade the tolls, a surprising number of vehicles are fitted with fake number plates (or none at all). A small industry has sprung up supplying devices that the driver can activate to conceal a car's number-plate. Some of these devices are available on E-bay3. The Inquiry should confirm that our electronic tags are more difficult to falsify.