| Comment # | Location in document (section and page) | Comment |
|---|---|---|
| 1 | At a glance p.1 | We are very glad to see the assumption of fixed land use reconsidered. It was always nonsense |
| 2 | 2.1 Historical context p.4 | We note the reference to half an hour access to key centres, the inference being that this is by public transport. We suggest this is a good maximum time to target, for reasons of social equity and reduced carbon emissions.
Any accessibility map will show that large swathes of Australia's cities do not achieve this standard. An example from the 2010 Metropolitan Transport Plan for Sydney is shown below. |
| 3 | 2.2 Theoretical framework p.4 | We support the concept of accessibility as the basis of transport planning but reiterate that the appropriate target relates to accessibility to jobs, education, training, health and opportunities for social interaction within 30 minutes by public transport. Access by car within that time limit is highly likely to be achieved as well, but the target should be set by reference to the experience of public transport passengers. |
| 4 | 2.3 Impact of major transport interventions p.5 | Cervero is demonstrating the dispersal effect of highway enhancements empirically. We stress the importance of empirical research to anything claiming to be 'evidence-based'. While it is good to see the interdependence of transport and land use recognised in this report, it is unsettling to see an immediate leap to computer models that are understandable to only a handful of people.
There are other volumes of the ATAP guidelines that have also built in the assumption of static land use and reliance on the four-step model developed in the 1950s (aka the predict and provide model) .Given the urban damage wrought by the four-step model we suggest they should all be reviewed |
| 5 | 2.4 Australia's planning context, p.6 | This paragraph references the "low population densities" and "car dependence" of Australian cities, the inference being that the first causes the second. Why is this included in an ATAP paper which correctly recognises that transport shapes land use? It perpetuates the same thinking that led to a failure to provide public transport to suburbs created after the US model of city planning was (regrettably) imported in the 1960s. It repeats the assumption that density determines modal choice, a mistake embedded in the four-step model.
The European Commission density figures referred to calculate density by numbers of people per square km. This is bound to produce misleading figures. In Sydney's case, there are large bodies of water and national parks within the Greater Sydney area that have few parallels in other countries. There is also no indication of whether the city boundaries used are comparable. It is very important to use density figures for truly comparable boundaries rather than relying on official metropolitan boundaries There are in fact much higher densities in the older parts of Sydney which developed around trams and rail, and those developed on the assumption that these services were no longer needed; so little to none was provided. Not surprisingly, people failed to use public transport that wasn't there. This has now been taken to mean that the density of development is responsible for low public transport (specifically, bus) usage. The circularity of the argument is evident. The north shore has higher public transport usage than Sydney's western suburbs not because they have fewer detached houses - they don't - but because they were provided with serious public transport from the outset. Car-dependent development must devote extravagant amounts of land to roads and parking which then becomes unavailable for any other use, including homes. This reduces density. It would also be worth mentioning that dispersal of employment (as opposed to residential density) has a major impact on public transport usage that tends to be overlooked. Land use policies designed to concentrate employment and major retail centres in areas with excellent public transport links and limited free parking are effective ways to reduce car-dependence. |
| 6 | 2.4 Australia's planning context, p.7 | It is said on p.7 that Australia's planning and funding processes for major infrastructure involve CBA. This may be factually true, but it is becoming increasingly apparent that the usefulness of project BCR as a basis for funding decisions is questionable. We note the statement that the ATAP guidelines are influenced by the UK's Transport Analysis Guidance. A review of the Green Book in the UK in 2020 accepted that its CBA guidance was undermining the UK's efforts to reach net zero and its attempts to "level up" opportunity in different parts of the UK - although it attempted to put the blame on users of the guidance and not the guidance itself. |
| 7 | 2.5 Common application of LUTI models, p.8 | On p.8 it is stated that LUTI models can support a 'vision and validate' modelling approach. If this is now recognised as more appropriate than the 'predict and provide' approach it would come as a great relief. There are however many uncritical references to the four-step model which is intrinsically part of the 'predict and provide' approach. |
| 8 | 2.8.2 Accessibility as the mediator between land use and transport, p.18 | As noted in relation to 2.2 above, the concept of accessibility to a range of opportunities within 30 minutes by public transport, from anywhere in the metropolitan area, has a great deal of merit. It is not clear where an approach seeking access to a full range of opportunities by public transport within 30 minutes (or less) sits within the list of possible accessibility measures. It seems closest to the location-based measure, but the clarity of the idea is lost at this point. |
| 9 | 2.8.3 Types of transport models, p.19 | The four step model shown at Figure 2-10 is the classic predict and provide model which assumes that public transport usage is a function of density and has nothing at all to say about the actual availability of service, other than to recommend against providing any because ... usage is a function of density. If we are to move to a 'vision and validate' paradigm this model must be retired. |
| 10 | 3.1 How LUTI modelling is used in practice, p.21 | We cannot say which LUTI model has most merit, but we suggest that the US is more likely to be a source of cautionary tales than exemplars in the field of public transport. We would expect the better choices are likely to be found in places with excellent public transport systems, namely in Europe or Japan. |
| 11 | 4. Principles of good practice p.27 | We do not think "represent demand" is a "should have" principle. In fact, supply often creates demand, which may be a good thing (if the aim is to shift modal split towards more sustainable modes) or a bad thing (as it has been in the case of inducing more traffic to occupy additional road space). It is a little confusing in any case because it seems that at p.34 the discussion is not about demand for travel but demand for buildings of various types. Perhaps this could be clarified on p.27. |
| 12 | 4.2 Model approach and assumptions must be transparent, p.28 | Transparency is very desirable so that ordinary people can understand what assumptions are being made and can make sensible judgments on whether their government is meeting their needs. Transparency is instead linked in the paper to a 'burden of proof' on a project proponent; there is an anti-taxation, small government tenor to this passage. |
| 13 | 4.3 Model must represent accessibility, p.29 | We agree with the accessibility approach, but we do not agree that travel costs should include 'value of time'. This takes us straight back to the practice in CBA of undertaking 'willingness to pay' surveys despite it being abundantly clear that willingness to pay reflects ability to pay and favours projects that benefit high-income earners |
| 14 | 4.3 Model must represent accessibility - travel cost components p.29 | The discussion of road congestion and public transport crowding is somewhat peculiar. Both are called forms of 'impedance'. In the case of road congestion, the impedance is caused by other vehicles. In the case of road based public transport (mostly buses), the impedance is likewise other vehicles - not other passengers. This seems to have been taken from the four-step model in an attempt to make some reference to transit in a model actually built around car travel, but it is not convincing.
Lack of capacity on a public transport service (being left waiting for the next bus, or the one after that) is a capacity problem and/or a frequency problem, not an 'impedance' issue. |
| 15 | 4.3 Trip-weighted average generalised costs, p.30. | Mention is made here of the possibility that one approach could lead to accessibility appearing to worsen although train travel times have improved. This illustrates the point made above, that the accessibility target for transport planning should be related to travel times by public transport; 30 minutes maximum travel time to a wide range of opportunities is a good place to start. If a model cannot support this approach it is not appropriate as it stands. |
| 16 | 4.4 Model should be well calibrated, p.31 | It is stated on p.31 that model validation involves comparing modelled outcomes with observed historical data. We are very pleased to see some empirical content proposed. Is there any reason the inputs should not equally reflect observed empirical data in preference to theoretical assumptions? |
| 17 | 4.8 Model should represent supply constraints appropriately, p.37 | There is reference on p.37 to 'ultimate capacity', the amount of development a given area can support. There seems to be potential circularity in this reasoning in the context of delivering a transport project, because the 'ultimate capacity' will be much higher if rail is the mode delivered, lower for light rail, lower still for bus systems, and lowest for total reliance on private vehicles. |
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