Director, Major Infrastructure Assessments
Department of Planning
GPO Box 39
SYDNEY NSW 2001
(diane.fajmon@planning.nsw.gov.au)
Dear Sir/Madam,
CBD Metro
Exhibition of Environmental Assessment and Station Plans DoP Ref. No. MP 09_0036
Submission by Action for Public Transport.
This submission is in response to a display advertisement by the NSW Department of Planning in the Sydney Morning Herald of 23 September 2009. It relates to both the Environmental Assessment (the EA) and the Station Plans.
Action for Public Transport (APT) is a member-funded sustainable transport advocacy group, based in Sydney, and active since 1974. Our website is at http://www.aptnsw.org.au/
As required by the DoP advertisement, APT hereby states that it has made no declarable political donations in the past two years.
1 - Overview-
APT supports the concept of a Metro network for Sydney. The revelation in the EA, that among the world's fifty largest cities in terms of GDP, Sydney, Tampa, and Seattle are the only cities without a metro, has reinforced that view. We accept the argument that a CBD sector should be built early, to relieve congestion on CityRail's CBD stations. We do not agree that the proposed route, or the chosen interim terminii, best serve the public interest. This submission highlights errors and omissions in the displayed documents.
2 - Interchange with Line 2-
We have read all five volumes on public display by the Department of Planning. The most blatant omission is the failure to consider efficient passenger interchange between Line 1 of the Sydney Metro (Rozelle to Central, and later, Westmead), and Line 2, tentatively to run between Malabar and the Northern Beaches. There are in the EA, many detailed and oft repeated references to the opportunities and requirements for passenger access and interchange facilities between Metro and other forms of transport, including CityRail trains, buses, motor vehicles, cycling and walking. There is however very limited reference to the most important interchange of all, and that is between Line 1 and Line 2, when Line 2 is eventually built.
A metro station is fundamentally a machine for processing people. It must function best when under greatest stress. The time taken to process the people is crucial, as it can contribute significantly to their individual journey times. Long pedestrian transfer routes between platforms lengthen those journey times, and also increase capital costs (escalators, lifts...) and operating costs (power, cleaning, maintenance...).
Sydney Metro's failure to consider and plan for cross-platform interchange between Lines 1 and 2 at the CBD station(s) where the lines will tangent is a major flaw in the design and in the Environmental Assessment. Cross-platform interchange is a fundamental feature of good metro design. It will become even more so with an aging population and a rising awareness of the needs of the mobility-impaired. It was provided nearly 100 years ago on Sydney's fledgling electric railway system, at Town Hall and Central stations.
There is little point in building CBD Metro stations with trains on opposite sides of an island platform serving the same line in opposite directions. The station plans on exhibition do not even hint at how interchange between the two metro lines, if it is not to be across-the-platform, might be achieved. The Environmental Assessment's brief reference to Future Proofing Metro (p. 67) by providing metro-to-metro interchange at Central, Martin Place, and Barangaroo (p. 68), and the reference to CBD station design for metro-to-metro interchange (p. 511) are insufficient.
Sydney Metro should be directed to resolve inter-line passenger transfer as a condition of approval for this project.
3 - Integration with CityRail-
It is in the nature of medium to high frequency rail networks that any change or development in one part of the network will have some impact on the efficient functioning of other elements in the network. This applies particularly between the proposed Metro and the present and future CityRail network, as each will provide similar levels of service to similar markets. Sydney Metro's plans, despite the intention to relieve congestion at CityRail's CBD stations, pay too little attention to the planning of the combined rail network, to ensure that synergies between the two systems, Metro and CityRail, are maximised. Any improvement in one should support and enhance the functioning of the other. The Environmental Assessment's "allowing for the potential reconfiguration of CityRail network" (p. vi) lacks specifics and is inconclusive.
Sydney Metro should be required to detail the expected impact on the CityRail network of each stage of the proposed Metro network as it is implemented.
4 - Integration with other modes-
The planning principles mentioned above should be applied also to the bus and other-mode sectors of the public transport network. The Environmental Assessment deals mainly with Metro's interaction with the existing characteristics of the other modes. It does not adequately address Metro's interaction with future developments in the other modes.
Notably missing is the relationship between Metro's Town Hall Square station and State Transit's plans for a Mid-city Bus Interchange above it, in Park Street. The proposal for the interchange is acknowledged (p.56, Vol. 2). Convenient and covered transfer between buses and the two railway stations at Town Hall is not.
5 - Rozelle Station-
Rozelle Station will be the initial terminus of the CBD Metro. Given the vagaries of public transport funding in NSW, it is likely to remain the terminus for many years. The EA declares a deliberate policy of not re-developing the precinct near the proposed station. This lack of any holistic transport/land use plan for the area surrounding the new station, and the absence of any purpose-designed bus-rail interchange facility, is likely to cause unpredictable traffic and social impacts, given the impact that such a large development as a Metro station will have.
The potential for conflict between cyclists on the Regional Bicycle Route's shared pathway on the northern side of Victoria Road, and passengers boarding and alighting from buses on the same road, is neither analysed nor resolved. To suggest that cyclists might be encouraged or required to use the circuitous alternative route via Terry, Beattie, Evans and Collins Streets (p. 111, Vol 2) is naive.
Provision should be made for Metro passengers to access the station from the vicinity of the intersection of Wellington Street and Victoria Road. Widely dispersed station entrances are a feature of metros elsewhere in the world. The separation of motor and pedestrian traffic, the provision of weather protection to Metro users, and the avoidance of the need for patrons to climb the Victoria Road hill, in conflict with cyclists on the shared pathway, will be seen in the long term as worthwhile.
The provision of this access should be made a condition of any approval.
6 - Funding-
Estimated to cost $5.3 billion, the CBD Metro is an expensive piece of railway by any standard. The EA acknowledges that the CBD Metro would potentially generate total economic activity of about $12.3 billion, concluding that that would represent a moderate positive macroeconomic impact (p.352). It also predicts that property values around stations are likely to increase but that that process may not reach completion until two or three years after commissioning (P.352).
APT is disappointed that the government has apparently made no effort to harvest the potential increase in property values for use toward the public good. We would classify it as negligence. We cite as an example of good practice, the Hong Kong Mass Transit Railway (MTR) Corporation's policy of direct ownership and/or management of railway related properties. These properties generate significant income, helping to sustain low fares for passengers.
7 - Fares and Tickets-
We understand the CBD Metro is to be operated by a commercial, profit-oriented, consortium. It will be easy for the consortium to establish fares which will maximise profit. It is likely that such fares would be higher than fares set so as to optimise the efficiency of the CBD transport network, all modes considered.
Most powered-vehicle travel in Sydney, including motor cars, is subsidised by government. The CBD Metro should be no different. However, it is difficult to see how the project can be approved in the public interest if the fares policy and the rate of subsidy are not known to the approval authority beforehand. The oft used escape, that the smartcard will solve all that, is not relevant. The much-delayed smartcard is just a ticket. It is not a substitute for a rational fares policy.
Please ensure that the above matters are brought to the attention of the Approval Authority for this project, the NSW Minister for Planning.
Yours sincerely,
(signed) Kevin Eadie
Convener
Action for Public Transport (NSW) Inc.
| f\515.9\MetroEA1 |
| cc | Ron Christie AM |
| Chairman | |
| Independent Public Inquiry - Long Term Public Transport Plan for Sydney | |
| GPO Box 249, Sydney, 2001 | |
| (submissions @transportpublicinquiry.com.au) |