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Hobsons Bay City Council 14 November 2017 Ordinary Council Meeting Agenda Appendix 7 Response to Joint Letters - West Gate Tunnel Project EES - Inquiry and Advisory Committees

Appendix - hobsonsbay.vic.gov.au · for the southern tunnel ventilation stack use the existing maintenance track connecting New Street along the southern side of the freight rail

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Page 1: Appendix - hobsonsbay.vic.gov.au · for the southern tunnel ventilation stack use the existing maintenance track connecting New Street along the southern side of the freight rail

Hobsons Bay City Council 14 November 2017

Ordinary Council Meeting Agenda

Appendix 7

Response to Joint Letters -West Gate Tunnel Project EES -

Inquiry and Advisory Committees

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1

Attachment 1

West Gate Tunnel Project

Summary of HBCC Recommendations and current Project Position October 2017

HBCC Recommendations Comments and WGT Project Position of WDA (at completion of IAC Hearings) A. Traffic and Transport

1. That a comprehensive Traffic Study be undertaken by Western Distributor Authority (in consultation with VicRoads and local government) that considers the full impacts of the West Gate Tunnel Project (WGTP) on Hobsons Bay and identifies adequate mitigation measures to be implemented by the Project.

Partially provided. Traffic assessment and modelling extended to include additional intersections and impacts on HB, including Millers Road, Kororoit Creek Road and The Avenue. Extra mitigation has included removal of the toll point west of Millers Road and truck bans in Blackshaws Road and Hudsons Road.

2. That truck bans be introduced on all of Blackshaws Road, Hudsons Road, North Road, High Street, Mason Street, Kororoit Creek Road east of Millers Road and Millers Road between Kororoit Creek Road and Geelong Road. Noting that local businesses with an origin/destination point within these areas would be exempt from the truck bans.

Partially provided. Truck bans have been included in the Project for Blackshaws Road and Hudsons Road only.

3. That Grieve Parade be upgraded as the preferred truck route (via Princes Highway) to access the WGF to facilitate the displaced trucks from Yarraville and Footscray due to the truck bans.

Not provided. WGTP assumes Millers Road will accommodate the extra trucks.

4. That the proposed direct tolls on trucks between Grieve Parade and Melbourne Road be removed, or at the very least the tolling point between Grieve Parade and Millers Road be removed

Partially provided. Tolls on trucks between Grieve Parade and Millers Road has been removed.

5. That the Victorian Government finance the project via a “shadow toll/availability charge”, as implemented on the Peninsula Link. This would mitigate the risk of traffic displacement due to toll avoidance.

Not provided.

6. The toll operation and avoidance should be actively monitored and tolls adjusted as necessary to optimise the WGT Project objectives. This should include careful location of the tolling points, toll capping for trucks along the West Gate Freeway section, time of day variable tolls to incentivise traffic off roads in residential areas and tolls on the Hyde street ramps set to restrict the ramps being used by general traffic to avoid the tunnel tolls.

Partially provided. Some provision has been made for toll capping and pricing to discourage access on some ramps.

7 Provide further details on pedestrian and cyclist path connections, safety and dedicated infrastructure onto the Federation Trail from key local roads, overpasses, and through interchanges.

Generally provided. To be further considered during detailed design. Some connections and improvements have not been

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included, e.g. on road paths in Millers Road and at Hyde Street.

8 Grade separation of Federation Trail at Millers Road and Hyde Street with a seamless connection to the Coastal Bay Trail, including an upgrade of the shared use path between the end of Federation Trail and the West Gate bike punt.

Not provided.

9 The proposed upgrade of Federation Trail west of Millers Road to be a full reconstruction in concrete, including public lighting should be included along the upgraded and new alignment of the Trail.

Partially provided. To be further

considered during detailed design.

10 The proposed temporary diversion of Federation Trail using Millers Road and Francis Street results in significant extra distance and travel time on very busy roads with high truck volumes and is not supported. A safer alternative should be provided.

Partially provided. To be further

considered during detailed design.

11 Provide dedicated bus lanes and priority measures to assist bus operations and services. Public transport should be prioritised/augmented during construction to assist managing traffic capacity/performance along the Project corridor.

Not provided.

12 Transit lanes should be provided to encourage multi-occupant passenger vehicles on the Freeway.

Not provided.

13 Provision of a shared path through the disused land along the southern edge of the Freeway east of Millers Road and connecting the State Government land to the east of Beevers Street (that could also be used for emergency vehicle access).

Not provided.

14 Consider in the design of the two pedestrian overpass upgrades the current access to the ramps and that connections are provided to a high standard in consultation with HBCC.

Provided. Details to be further

considered during detailed design.

15 All proposed new and upgraded active transport linkages should be delivered as early as possible to encourage travel behaviour change and ongoing local connectivity.

To be further considered during

detailed design.

16 Provide further details of traffic impacts arising from the construction compounds and haul routes including microsimulation models showing peak congestion conditions during construction and also the analysis to assess traffic performance during construction.

Partially provided. An additional

assessment has been made on the

haul routes of New Street and

Simcock Avenue indicating

satisfactory performance. An EPR

has been included to monitor

impacts during construction.

17 Separation of residential and freight traffic particularly at Millers Road between the West Gate Freeway and Geelong Road. Reconfigure the road cross section of Millers Road between the West Gate Freeway and Geelong Road including consideration of the existing entry/exits for the Brooklyn community and rationalisation of traffic lights. Consider treatments within and intersections at Primula and Cypress Avenues.

Not provided. (Whilst some

concessions have been made to

mitigate the truck traffic impacts on

residents, this remains a key

concern).

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18 Review and upgrade the Grieve Parade/Geelong Road, Geelong/Millers Road and Francis Street and the Geelong Road/McDonald Road intersections.

Partially provided, some

improvements considered by

VicRoads at Millers and Geelong

Road intersection.

19 Further traffic assessment required on the performance and capacity on the Kororoit Creek Road, Grieve Parade, Millers Road, Melbourne Road and Hyde Street entry and exit ramps.

Partially provided. Some further

data has been provided on

capacity of the off ramps, the on

ramp metering will be managed by

VicRoads.

20 Further detail required on the proposed impacts on Buchanan Road at Lynch Road to accommodate the freeway widening.

To be further considered during

detailed design.

21 Include provision for additional ramps at Grieve Parade and/or at Dohertys Road to improve north south connectivity to the M80 from the Altona North industrial precinct

Not provided. Not considered to be

within project scope or supported

by VicRoads.

22 Seeks as part of the Project, an additional north south connection across the freeway corridor between the existing freeway interchanges, to reduce demand on already congested routes specifically Williamstown/Melbourne Road, Millers Road and Grieve Parade.

Not provided, however provision to

be provided for possible future

connection.

23 Reconfigure the road cross section of Millers Road between Blackshaws Road and the West Gate Freeway to increase capacity, maintain access to existing bus services and shops, and address pedestrian and cyclist safety. Consider treatments within and intersections at Marigold/Cyclamen/Clematis and Beevers Streets.

Not provided. Some widening will

be included within the freeway

interchange only.

24 That the Project contribute to LATM Plans to review and assess the cumulative impacts on local streets:

a. east and west of Precinct 15 including intersections with Millers Road and Melbourne Road,

b. residential streets in Brooklyn north of the Freeway and,

c. in Spotswood south of the Freeway to address the conflict between industrial and general traffic accessing the freeway and local traffic..

Not provided.

25 That construction traffic accessing the construction compound for the southern tunnel ventilation stack use the existing maintenance track connecting New Street along the southern side of the freight rail line to Hardie Road instead of New Street and Blackshaws Road.

Partially provided. Access options

will be further considered during

detailed design.

26 Consider in the design for shared path connectivity, pedestrian/cycling links to Spotswood and Newport Rail stations.

Partially provided. A new shared

path included along Hall Street.

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27 Provision of a link between the proposed open space at Precinct 15 and Edwards Reserve through the establishment of a shared path along the railway reserve.

Not provided.

28 That design changes be implemented to address the undesirable issue of Freeway access from the local street network via Simcock Avenue and Stephen Street, i.e. intersection treatments, parking and local access consideration.

Not provided.

29 That Hall Street not be used as a construction traffic route due to the environmental, amenity and visual impacts on the Emma McLean Kindergarten and an alternative access is required to be identified.

Not provided.

30 The proposed construction compounds at 2 Watson Street and

on the Lynch Street Reserve abut residential properties and

require suitable mitigation measures to protect residents from

noise, vibration, air and visual impacts.

Partially provided. An EPR has been included that controls to some extent use on these sites and also to monitor and mitigate impacts.

31 Exempt trucks travelling to and from the Spotswood Industrial Precinct from the proposed Francis Street truck ban, so that they can continue to access the Freeway ramps at Melbourne/Williamstown Road and not use Hudsons Road or North Road.

Not provided. A truck ban has been included on Hudsons Road.

32 Further analysis required in regard to the traffic impact on Douglas Parade and Hyde Street.

Provided. Further assessment undertaken indicating sufficient capacity however the intersection at Francis Street will experience congestion.

33 Key earthworks or construction activities should be carefully

managed and coordinated with the Melbourne Metro and Level

Crossing Removal projects to ensure that construction traffic

minimises impacts to the adjoining communities while also

minimising disruptions to businesses and the general travelling

public.

Provided. Coordination with other key projects in the region will be included.

34 Further detail required on likely frequency and impacts of tunnel closures during operation and incidents and the stated use of the Hyde Street ramps to detour traffic.

Provided. Further detail provided that includes requirement for a traffic managment plan for these events..

B. Air, Noise, Health and Amenity

35 Further assessment of peak noise (Lmax), particularly at night

time and night time noise levels should be provided for the

West gate Freeway section and other surface roads impacted.

Partially provided – construction only. No specific night time noise controls exist during operation.

36 Temporary or permanent noise walls be erected prior to the

demolition of existing noise walls to provide protection from

both operation and construction activities associated with the

Project.

Provided.

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37 That the detailed design include durable, high quality, attractive

and effective sound walls, barriers and lighting to protect the

amenity of residents, open space, facilities and future residential

development sites (e.g. along the Precinct 15 and the Brooklyn

Terminal Station boundary) along the entire Project corridor

through Hobsons Bay.

Generally provided. Design exceeds the VicRoads policy requirements and additional walls added to protect open space. Noise wall gap remains at Precinct 15 on the basis that it is currently not a sensitive use site..

38 The Project mitigate adverse noise impacts along residential

roads where traffic will increase as a result of the Project, such

as Millers Road, Geelong Road and Blackshaws Road.

Partially provided. Includes noise mitigation treatment of houses in Millers Road and monitoring to be undertaken.

39 Convert the temporary air quality monitoring stations to

permanent stations within the EPA monitoring network with

monitoring results released to the public via the Air Watch web

site.

Not provided. An EPR will require some public reporting of air quality results.

40 An EPR should be included that establishes an Air Quality

Community Consultative Committee to review and provide

advice on the location of the community based monitoring

stations; construction and operation environmental

management plans, compliance tracking reporting, audit

reports or complaints and provide advice on dissemination of

monitoring results and other information on air quality issues.

Not provided.

41 That monitoring of ultrafine air particles be undertaken for the

Project and ensure that pollution control equipment can be

included (or at least retrofitted) into the ventilation stacks.

Partially provided. Ultrafine particulates to be measured as a subset of PM2.5 particle measurement. Provision to retrofit air filtration in the vent stack to be provided.

42 Implement a roadside air quality monitoring program for PM2.5

that is designed in consultation with EPA, Council and

community. Results of the monitoring are to be made publicly

available on an accessible website or through EPA’s Air

Watch.

Not provided.

43 That all practicable measures be taken to mitigate the impacts

associated with the Project during construction on the amenity

of local residents, open space and the transport network.

Partially provided. EPR’s established to monitor and address impacts as they arise.

44 That the Project mitigate pollution emissions, noise and any

loss of open space or facilities for the Emma MacLean

Kindergarten as a result of the Project.

Partially provided. Some impact may result from construction traffic using Hall Street.

45 That the Project mitigate loss of or impact to open space and

club facilities specifically for the Spotswood Football Club and

Spotswood Cricket Club based at Donald McLean Reserve.

Provided. EPR’s will mitigate impacts. A number of issues to be further considered during detailed design, e.g. possible relocation of cricket nets.

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Requires that the Project team mitigate any loss to existing

open space and functionality for community use and enjoyment

specifically the Stony Creek Reserve, The Avenue Reserve,

Lynch Road Reserve and WLJ Crofts Reserve.

46 That the Project replaces any vegetation and tree canopy

removed or adversely impacted by the proposal in accordance

with Appendix I of Council’s submission. Evidence also needs

to be provided that shading from the flyovers and noise

barriers will not permanently affect plant growth.

Partially provided. While the numbers of replacement trees will exceed those removed, detail on the planting locations is still to be resolved during design.

47 That the Project seeks confirmation from other land managers

such as VicRoads and VicTrack of their intentions for remnant

land adjacent to or in the vicinity of the Project so as to

maximise opportunities to improve the amenity or the

functionality of these sites consistent with the Council’s

position on the Project.

Partially provided. To be further considered during detailed design.

48 A number of mature trees along the southern edge of the

Freeway provide significant amenity and should be retained

where possible or offset with suitable semi mature trees and

located in consultation with HBCC.

Partially provided. To be further considered during detailed design.

49 That State Government/WDA purchase some existing privately

owned land in Simcock Avenue (south of the West Gate

Freeway) and convert this land to public open space creating

links to the Stony Creek Reserve and to Scienceworks

Museum.

Not provided.

50 That West Gate Tunnel Project contribute to the development

of the Masterplan for the WLJ Crofts Reserve, and that the

practice wickets be relocated to a more appropriate area in

accordance with the Masterplan.

Not provided.

51 Significant tree planting should be undertaken in appropriate

locations throughout the WLJ Crofts Reserve consistent with

the Masterplan.

Partially provided. To be further considered during detailed design.

52 That compliance reporting for amenity issues (noise, vibration,

air quality impacts etc.) be publicly reported during the

construction and commissioning phases of the Project. A clear

comparison between baseline conditions in open space areas

adjacent to the Project and conditions post construction is

required.

Provided. An EPR requiring monitoring and reporting has been included.

53 C. Other

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54 That the EPR’s for excavation and transport management for the Project include;

a. the identification of appropriately licensed landfill sites suitable for the different classes of spoil

b. the identification of transport routes to each of these licensed landfill sites; and

c. guidelines for the transportation of contaminated material to these landfill sites.

Provided.

55 That the surface water management issues are well managed,

monitored and controlled.

Partially provided. To be further considered during detailed design.

56 Minimise impacts on Council assets and infrastructure, including within public open space. Where relocation, modification or replacement of Council assets or infrastructure is required to facilitate the Project, this must be done to the satisfaction of Council. An EPR is required that includes conditions and performance requirements for HBCC assets and infrastructure including roads, drains, kerb and channels, footpaths, street lighting and nature strips.

Partially provided. To be further considered during detailed design. A specific EPR has not been provided that includes conditions and performance requirements for HBCC assets and infrastructure including roads, drains, kerb and channels, footpaths, street lighting

and nature strips.

57 That the proposed new sporting facility in Donald McLean

Reserve meet HBCC and tenant requirements and must be

compatible with the Donald McLean Reserve Masterplan. A

detailed EPR should be developed that commits the contractor

to the standards and quality required.

Partially provided. To be further considered during detailed design.

58 That adequate protection is provided for heritage buildings and features in consultation with HBCC:

a. Melbourne Glass Bottle Works amenities building on Simcock Avenue

b. Bluestone bridge over Kororoit Creek c. Brooklyn Pump station on Millers Road d. West Gate memorial on Hyde Street.

Partially provided by a general EPR to protect adjacent properties, these heritage sites should require specific protection from the work zone, particularly the Melbourne Glass Bottle Works amenities building located close to the work site on Simcock Avenue.

59 That an EPR be included that requires the contractor to

establish a Community Involvement and Participation Plan

that assists building social interaction, connectedness and

cohesiveness throughout the construction period which could

include running community events, festivals, sponsorships of

local sporting clubs, and the establishment of community

support grants.

Partially provided. An EPR has been included that establishes a Community Liaison Group but does not include a community grant program.

60 Management of spoil must ensure that dust is controlled

including when stock piling and on site storage of spoil and for

permanently placed fill. Haulage routes for excavated material

must avoid residential and sensitive areas and not impact

significantly on public traffic.

Provided. An EPR has been included to address this.

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61 Undergrounding powerlines and removal of the 220KV towers

where practicable including along the north side of the

Freeway in Lynch Road Reserve.

Partially provided. Some 66KV lines will be placed underground and some towers replaced with monopoles.

62 Effects of reflectivity of the ventilation shaft must be considered

in the detail design to prevent increased sun glare to both road

users and neighbouring properties.

Provided, this has now been considered by the Project.

63 Further detail on the impacts from the proposed maintenance

area for the WGT southern portal is required.

Partially provided. To be further considered during detailed design.

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Attachment 2

Councillors Hobsons Bay City Council

21 September, 2017

Re: Joint letter from Spotswood and South Kingsville Residents Group Inc., Brooklyn Residents Action Group, and Don’t Destroy Millers Rd Group

Dear Councillors

We have read the Council Submission to the Inquiry and Advisory Committee (IAC) on the Environment Effect Statement for the West Gate Tunnel Project (the project) and we have listened to, and read, the evidence presented by the proponents and other parties.

In our joint letter to you, 26 June 2017, we asked that the Council not endorse or support this project as it offered no benefit to the residents of Hobsons Bay and there are significant negative impacts associated with it. The only benefits are in legacy projects not intrinsic to the expansion of the freeway and building of the tunnel which are being pitched as vital for the Port of Melbourne which will operate 24 hours a day. At that meeting, although all Councillors, individually, did not support the project, you decided to maintain your policy of support.

It appears some concessions have been made that mitigate some effects in Hobsons Bay:

63dba is agreed as the noise standard to be applied even over recreational space;

Truck bans have been announced on Hudsons Rd and Blackshaws Rd but not MillersRd at the conclusion of the project (2022);

Extension of noise barriers along recreation areas (although not on the South, HydeSt ramp); and Precinct 15 (to be confirmed); and

The proposed removal of a tolling point on Grieve Pde that will lessen toll avoidanceonto Millers Rd seems to have agreement of parties but the announcement bygovernment media release misrepresented the change as a reduction when, in fact,it is still an increase of 4000 trucks a day on current volumes which are alreadyintolerable.

As residents, we are of the view that the project does not fulfil its own objectives and will make Melbourne and Melbourne’s west a poorer place in urban design and transport terms. Hobson’s Bay is disproportionately bearing the truck and traffic burden in the inner west and the concomitant air quality and noise issues that comes with increased traffic and truck volumes leading to decreasing health. The project was meant to remove this burden completely from the inner west but it has simply been redistributed further west to a community that already has poor amenity.

A number of other areas remain completely unsatisfactory for Hobsons Bay residents:

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Millers Rd is regarded as an arterial road to which Vic Roads standards for noise and air quality apply. The mitigation measures offered in the EPRs to residents facing Millers Rd are both unclear and, the suite offered to date, is unlikely to mitigate the impact on the residents in Brooklyn.

The safety issue for Simcock Ave is likely to be treated in the same way as Millers Rd once it is declared an arterial road. Hope St already has exceedance of noise and air quality standards and mitigation at the existing VicRoads level is unlikely to relieve residents’ or kindergarten concerns;

It seems unlikely that the EPRs will cover traffic management in Hobsons Bay and further studies and actions are unlikely to be funded by the project;

Exceedances are predicted for the area near the portal which is required to meet zero exceedances yet filtration has been ruled out.

Open land provided as a legacy has been assessed by expert witnesses as not useful as an offset for those effected by the project, and its proximity to the portal, freeway expansion and access difficulties doesn’t add to the social amenity it purports to provide;

The portal to the tunnel will provide ventilation not in-tunnel filtration adding to the burden of poor air quality in the vicinity of the freeway which is expected to cater for an increase of 37,000 vehicles per day; and

Construction sites and access on Hall St and New St remain unchanged and are unacceptable to residents of Hobsons Bay.

We remain perturbed that the position taken by the Council to support the project with conditions is not proving fruitful. Many of the conditions set have not been met in the WDA closing submission or in the EPRs. The time has come for you to stand up for the amenity of your residents and to publicly reject this project’s scope and design. As the local government body representative of a community highly impacted by this development, this stance should not affect the obligations of the proponent to continue to involve Hobsons Bay City Council and its officers in construction and operation of the project should it go ahead. Yours sincerely Rosa McKenna Spotswood South Kingsville Residents Group Inc.

Chris Dunlevy Don’t Destroy Millers Rd Group

Bert Boere Brooklyn Residents Action Group

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Attachment 3

25 September 2017 Cr Sandra Wilson Mayor of the City of Hobsons Bay Civic Centre 115 Civic Parade ALTONA, VIC 3025

Dear Cr Wilson I am writing to inform you of the submission which a group of concerned Hobsons Bay residents and former residents have presented to the IAC panel on the West Gate Tunnel Project EES Evaluation. I have attached a copy of the submission with the associated presentation slides to this letter. The submission has now received the endorsement of the Newport Branch of the Labor Party. We have also briefed our local member, Hon. Wade Noonan MP. We now seek to brief you on the concerns we hold about the project, as set out in the submission. We request that this letter be tabled at Council, and seek a meeting to discuss it with you and senior Council officers responsible for the Hobsons Bay submission to the same Panel. Briefly, these concerns relate to the questionable traffic modelling which underpins the EES, the lack of transparency by the proponent WDA during the hearings relating to this matter of modelling, and the legal and political pressure put on the panel by WDA not to request the key independent peer review of the modelling by Mr Allard. Further to this, there are very real impacts that the project will have on communities in Hobsons bay, not the least of which are the increased air and noise pollution on communities along the freeway, but especially along Millers Road, and the impact that the design of various intersections and on-ramps associated with or affected by the Hyde St ramps. We share many of the concerns raised in the City of Hobsons Bay submission, however it is perplexing why Hobsons Bay legal representatives did not question the traffic modelling or the route of the tunnels. City of Melbourne strongly opposed most aspects of the project in their submission. We believe that alternative options to this project exist and should be modelled to compare the outcomes with the current project before any final decision is made to proceed. Several other groups presented these options as well as ourselves. Trusting that you are open to hearing the concerns of your ratepayers and active members on this key project, we await your response. Regards

Jacob Holley Secretary Newport Branch For Pat Love, M Monahan, J Holley, J Harrison, G Hjorth Email: [email protected]

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SUBMISSION TO IAC HEARING ON WEST GATE TUNNEL EES

Dr P Love, Mr G Hjorth, Ms M

Monahan, Mr J Holley

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OUR SUBMISSION SUMMARYProject Objectives

Who is the proponent?

Strategic Misrepresentation: Private v Public information

Relevant New Data on evaluating the bottom line of the EES:

Port access

CBD Access

Western Distributor ramps and route upgrade Hyde St Francis St intersection, Whtehall St duplication

Simcock Ave ramp – v one entry exit point

Air quality

Sound barriers

Recommendations

Expert Evidence Dr J Stone

Expert Evidence Mr Doug Harley (5.40 pm Tuesday)

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3: PROJECT OBJECTIVES

Improve transport performance in M1 Corridor

Reduce reliance on West Gate Bridge

Improve freight access to Port

Improve community amenity on local streets in inner west

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4: WHO ARE THE PROPONENTS?

WDA

Transurban Transurban build freeways and tunnels that make profit from charging tolls over a long period of time

State Government accepted a market-led proposal put forward by Transurban, and checked by their own experts

prepared a business case based on the proposal and data led by the proponent, heavily redacted version only for public

chose not to release the Business Case in full, nor the full VLC modelling behind it, nor the peer review of the traffic model

Some questions: Why did Transurban come to the Government?

Why claim “commercial in confidence” cover on essential financial and traffic modelling information? Creating doubt!

Identify huge commercial risk or

Strategic Misrepresentation – where organisational or political objectives get in the way of transparency

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CHART5: TOLL ROAD PERFORMANCE AROUND AUSTRALIA

Source: chartingtransport.com website, accessed 29 August 2017

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6: TOLL ROAD PERFORMANCE AROUND AUSTRALIA

Source: chartingtransport.com website, accessed 29 August 2017

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7: TOLL ROAD PERFORMANCE AROUND AUSTRALIA

Source: chartingtransport.com website, accessed 29 August 2017

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8: IMPACT OF FREEWAY WIDENING ON PT PATRONAGE 2011-12

City Link

opens

MCW

widening

East

Link

Source: chartingtransport.com website, accessed 29 August 2017

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9 WHY NOW?

CityLink traffic volumes are stagnant and declining in 2016

(Financial Report 2015-16)

E-W project cancelled

Melbourne Metro is opening 2026

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10 STRATEGIC MISREPRESENTATION: PUBLIC V PRIVATE INFORMATION

Is this a case where commercial risk justifies public ignorance?

OR

Do organisational and political objectives obscure the proponents case to ensure success?

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11: RELEVANT DATA TO EVALUATE EESOR THE ALTERNATE FACTS

Population Forecasts for M1 corridor

Green House Gas emissions

Traffic model and Induced traffic estimates

Vehicle ownership and density Melbourne and Australia

VKT trends and Melbourne

Public transport performance in Melbourne

Impact of freeway widening on PT patronage 2011-12

Impact of traffic congestion on PT patronage

VISTA 2012-14 for Wyndham

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12 DEMOGRAPHY

0

100000

200000

300000

400000

500000

600000

700000

800000

900000

LGA GreaterGeelong

Wyndham Hobsons Bay Total Population

POPULATION GROWTH WESTERN CORRIDOR 2011-

2031 VICINFUTURE 2016

2011 2021 2031

0

100000

200000

300000

400000

500000

600000

700000

800000

900000

1000000

LGA 2011 2016* 2021 2026 2031

Population Growth Western Corridor 2011-2036: ID

2016

LGA Greater Geelong Wyndham Total Population

Source: id.com website, accessed 14 August 2017Source: vicinfuture.vic.gov.au website, accessed 14 August 2017

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13 WESTERN REGION: 20 TO 60 YOS 2011-2036

0

50,000

100,000

150,000

200,000

250,000

300,000

2011 2036 Change between 2011 and 2036

Population Age Structure M1 Corridor+ Melton: 2011-2036

City of Greater Geelong City of Wyndham Hobsons Bay City City of Melton City of Brimbank Moorabool Shire Golden Plains Shire

Source: id consulting website, accessed 14 August 2017

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14 M1 CORRIDOR + MELTON: 20 TO 60 YOS 2011-2036

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

2011 2036 Change between 2011 and 2036

Population Age Structure M1 Corridor+ Melton: 2011-2036

Total M1 Corridor Total M1 Corridor + Melton

Source: id consulting website, accessed 14 August 2017

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15 VICTORIAN GHG EMISSIONS TARGETS

Zero net emissions of GHG by 2050

Will set interim target by 2020 for 2025 and 2035

Aiming to achieve a 15 to 20% net emissions reduction by 2020

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16: ENVIRONMENTAL EFFECTS - GHG

Source: chartingtransport.com website, accessed 29 August 2017

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17 GHG EMISSIONS

Business case – reduction 2.3 million tons of GHG with project

EES – increase of 0.23% with project, increase of 0.04% without project

Without project reduction of 0.31% in vehicle emission intensity (g co2/vehicle km travelled)

VLC –Forecast additional 37,000 vehicles on West Gate Freeway in 2031 with project

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18 TRAFFIC FORECASTS

Forecasts produced by a private company

Only the outcomes available

Model is not transparent (hidden assumptions, processes,etc)

Criticisms of the model through the EES

Single distribution loop

Induced traffic – should all 6 factors be included in the model

VISTA Data and behaviours based on 2007 behaviour patterns

Strategic misrepresentation - the selective use of models and data which better makes the proponents case

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CHART 19: MOTOR VEHICLE OWNERSHIP PER 100 PERSONS 18-84: 2006-16 MAJOR CITIES

Source: chartingtransport.com website,

accessed 29 August 2017

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CHART20: MOTOR VEHICLE OWNERSHIP PER 100 PERSONS 18-84: 2006-16

Source: chartingtransport.com website, accessed 29 August 2017

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CHART 21: MOTOR VEHICLE OWNERSHIP PER 100 PERSONS 18-84: 2006-16

Source: chartingtransport.com website, accessed 29 August 2017

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CHART 22: MOTOR VEHICLE OWNERSHIP AND POPULATION DENSITY IN MAJOR CITIES: 2006-2016

Source: charting.com website, accessed 29 August 2017

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CHART 23: VEHICLE KILOMETERS TRAVELLED (VKT)

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CHART 24: VKT - MASS TRANSIT SHARE

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CHART 25: VEHICLE OWNERSHIP AND KILOMETRES TRAVELLED (VKT)

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CHART 26: RELATIONSHIP BETWEEN PT PATRONAGE AND FREEWAY TRAFFIC VOLUMES 2001-11

City Link

opens

MCW

widening

East

Link

Source: chartingtransport.com website, accessed 29 August 2017

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CHART 27: IMPACT OF FREEWAY WIDENING ON PT PATRONAGE 2011-12

Source: chartingtransport.com website, accessed 29 August 2017

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Table 2: VISTA 2012-14 Wyndham residents work related travel 18-84 year olds

Destination

Destination

Share

Destination

Groups

Rail PT

Share

Wyndham 27% 27% 2%

Melbourne 22% 51% 51%

Inner City (Yarra, Port Phillip) 9%

Inner West (Hobsons Bay, Maribyrnong, Mooney Valley)20% 0%

Eastern & Southern suburbs 6% 12% 21%

Northern 6%

Outer Western (Melton, Brimbank, 8% 10% 0%

Geelong 2% 50%

Total 100% 20%

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29: JOURNEY TO WORK DESTINATIONS 2011

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30 METHOD OF TRAVEL TO WORK: 2006-2011

Method of travel to workCity of Wyndham -

Employed persons

(Enumerated)

2011 2006

Change

Main method of

travelNumber % Western Region % Number % Western Region % 2006 to 2011

Train 8,171 10.7 11.9 4,035 7.6 10.0 +4,136

Bus 524 0.7 1.2 275 0.5 1.1 +249

Tram or Ferry 40 0.1 0.7 28 0.1 0.7 +12

Taxi 103 0.1 0.2 70 0.1 0.2 +33

Car - as driver 50,562 65.9 63.0 35,812 67.5 63.8 +14,750

Car - as passenger 4,731 6.2 5.3 3,371 6.4 5.7 +1,360

Truck 560 0.7 0.7 500 0.9 0.9 +60

Motorbike 302 0.4 0.4 248 0.5 0.4 +54

Bicycle 248 0.3 0.9 176 0.3 0.8 +72

Walked only 836 1.1 1.4 637 1.2 1.6 +199

Other 721 0.9 0.9 396 0.7 0.8 +325

Worked at home 1,912 2.5 2.6 1,230 2.3 2.4 +682

Did not go to work 6,827 8.9 8.7 5,317 10.0 9.4 +1,510

Not stated 1,157 1.5 1.8 972 1.8 2.2 +185

Total employed

persons aged 15+76,694 100.0 100.0 53,067 100.0 100.0 +23,627

Source: Australian Bureau of Statistics, Census of Population and Housing 2006 and 2011. Compiled and presented by .id , the population experts.

(Enumerated data)

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31: 2006 – 2011 METHOD OF TRAVEL TO WORK

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32: PUBLIC TRANSPORT SHARE UNDER VLCMODEL

Public transport on M1 corridor is forecast to be 14% in 2031 by VLC model

VISTA data (2012-14) indicates it may already be 20% in Wyndham

This project will decrease the potential PT share, disguising it as an increase on 2011

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Table 1: Rail Services on M1 Corridor compared with lines across Melbourne

Lines Servicing M1 CorridorNumber of rail services

Station

AM Peak

(7-9am) Frequency

PM Peak

(4-6 pm) Frequency

Williamstown 6 20.00 6 20.00

Newport 23 5.22 22 5.45

Altona 6 20.00 6 20.00

Laverton 18 6.67 17 7.06

Aircraft 13 9.23 11 10.91

Williams Landing 13 9.23 11 10.91

Hoppers Crossing 13 9.23 11 10.91

Werribee* 13 9.23 11 10.91

Wyndham Vale (RR) 10 12.00 6 20.00

Tarneit (RR) 9 13.33 7 17.14

Other Metro Services

Craigieburn* 15 8.00 18 6.67

Frankston* 14 8.57 13 9.23

Glen Waverley* 14 8.57 12 10.00

South Morang* 12 10.00 13 9.23

Sunbury (Watergardens)* 15 8.00 17 7.06

Lilydale* 12 10.00 10 12.00

Belgrave* 11 10.91 10 12.00

Ringwood 27 4.44 23 5.22

Blackburn 33 3.64 31 3.87

Alamein 7 17.14 6 20.00

Pakenham* 11 10.91 12 10.00

Cranbourne* 7 17.14 8 15.00

Dandenong 22 5.45 24 5.00

Average of the main lines 12.4 10.1 12.4 10.2

* Main Train Lines

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34: PORT ACCESS

International Ports – (Hamburg, Rotterdam) transport systems best practice target 45-50% containers transported by rail

Container storage systems – keep empty containers in the port precinct for speedy loading on ships

Problem of empty containers around inner west by road between port and container storage parks

Level of the toll and container transport viability - $30 for an empty container to be delivered

McKenzie Rd ramps are a visual blight on the river, and a potential congestion point

Exit tunnels onto the east side of river, feeding into Footscray Rd

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35: PORT ACCESS: TUNNELS TO WRONG PORT

Mr Barlow’s evidence indicated Webb dock will be the future port, Swanston Dock is the present port

Container growth forecast for Webb dock – not assisted by this proposal

Freight (>80%?) will be heading over West Gate

If Port forecasts are not met, then operators will be forced to scale back

Swanston Dock will be first part of the port to be closed, scaled back

Tunnels should have been directed to Webb dock under the Yarra

C7 - Possible to include road & rail freight access as well as Metro 2

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36: PORT ACCESS - RECOMMENDATIONS

1. Control the transport of empty containers around Melbourne by:

Identify & use best-practice, more efficient container storage systems within the Port and its environs

Flower market conversion for container storage, port operations

Banning trucks with empty containers on local roads

Use rail to carry single empty containers between distant container parks and the port (Medium term)

2. Investigation of the C7/Metro 2 option Infrastructure Vic

including rail freight tunnel into Webb dock from Newport

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37: DATA SUMMARY – EVALUATE EES

Melbourne is changing – unique amongst Australian cities car ownership per 100 persons of driving age is declining, density increasing

PT usage is booming, particularly amongst the young, and in the trips to CBD, but elsewhere as well

VKT for passenger cars is declining, even while population is increasing on the outer fringe because PT options were made available

GHG from transport will decline if we continue to pursue these policies

Melbourne Metro will speed up these trends

Expanding freeways to CBD including Citylink/WGT will slow these trends

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38: OPTIONS FOR CITY CHANGE

8 Options in Chapter 3 evaluated

Eddington Report quoted as outlining a northern route as preferred route

Business Case preferred Pathway 1 – including freeways in northern and southern corridors (WGT being southern route)

This project is said to be only the first part. Next part required in 15 years

Option C7 – rail and road tunnel from Newport to Fishermans Bend and the Port and beyond was also identified

This was described as a truly “city changing option”,

but dismissed as too expensive

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39: C7 OPTION FOR TUNNELS

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40: METRO 2 – RAIL AND ROAD FREIGHT OPTIONS

3.1km

1.1 km

2.2 km

6.9kms

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41: METRO 2 – ACCESS TO NEW EMPLOYMENT CENTRES

3.1km

1.1 km

2.2 km

6.9kms

50,00

0 jobs1500

0 jobs

30,000 jobs

Legend

Melbourne Metro

Metro 2

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42: WHAT SORT OF FUTURE?

Where is Melbourne’s transport and land use policy heading?

Balance (WDA): We need both roads and public transport projects

To create real change: incentives for public transport or for roads, not both

Investigate C7 option (Tunnels to Webb dock, Metro 2 + freight rail to Webbdock)

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43: WESTERN DISTRIBUTOR RAMPS

The Hyde St Ramps were the original Western Distributor project originally proposed by the government and taken to the election.

This assumed that trucks would be taken off the freeway, and redirected along Hyde St and Whitehall St to the port, removing them from Francis St in particular.

This route would work if Whitehall St was upgraded along its full length and Shepherd’s Bridge widened.

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44: HYDE ST/SIMCOCK AVENUE RAMPS

Currently no sound barriers on the ramps, although freeway proper is being retrofitted along the same alignment

Southern on-ramp is directed via Simcock Avenue

Dangerous access off Hyde St

Brings heaviest trucks with most dangerous loads within 100m of Scienceworks (4000 vehicles per day – Francis St)School children and families access the site 7 days a week in large numbers

Alternative route via Hyde St directly, swing under the freeway, Engineered to protect possibility of accidents near bridge structures

Only one intersection on Hyde St required

Possible to protect the heritage building on corner of Simcock Ave

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45: SIMCOCK AVENUE ON-RAMP

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46: HYDE ST – WHITEHALL ST WIDENING

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47: HYDE ST FRANCIS ST INTERSECTION AND WHITEHALL STREET DUPLICATION

Douglas Parade / Hyde St is one of only two roads that residents of Newport, Williamstown and Spotswood have to exit the area by car.

Under the current project design, the Hyde St Francis St intersection is not designed to work(LOS = D in AM and F in PM)

VicRoads indicated that they considered F LOS rating in the afternoon and D rating in the morning “not a disbenefit” of the project

It is not designed to work - encourage trucks to use the tunnels?

What about the community??

Solution: duplicate the small section of Francis St east of Hyde, and the 500 m section of Whitehall St south of Somerville Road. This is already a wide road, although only marked for one lane each way.

Result in better traffic flow from Hyde St into Francis and then onto Whitehall St.

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48: AIR QUALITY & SOUND BARRIERS

WGF section of road is highest level of traffic volume in Victoria

Heavy vehicles will be attracted to it – diesel fumes highly toxic

Noise of traffic now exceeds standards regularly – this will increase

Argument that these people have lived with that noise (and air pollution) previously therefore can do so in future is outrageous (Mr Stead)

Higher standards than normal should be applied to quality of sound barriers

Filtering of the emissions of the tunnel stack should apply

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49: CBD ACCESS: NORTH MELBOURNE RAMPS

State policy – Integrated land use transport planning – PT is preferred

Sustainability - over-reliance on cars – this is not a trend we should be encouraging – 70% of trips to CBD are on PT, this project will reduce it

Do we need Footscray Road duplication?

Tunnels emerge east side of Maribyrnong, into Footscray Road, with road Port access

Good access to Citylink (NBD / SBD)

Improved Dudley St / Wurundjeri Way intersection may work

North Melbourne Dynon Rd ramps should be deleted

Future rail access (Melb Metro) should cater for increased demand

Footscray Road to Dynon St link might be worthwhile and could be built above rail lines

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50: RECOMMENDATIONS

Short Term (0-5 years)1. Increase metro services on Werribee line with matching bus service levels

2. Ban trucks on Blackshaws Rd, Hudsons Road, Douglas Parade, & Millers Road (south of freeway), if do not originate or finish their journeys in businesses there

3. Build Western Distributor ramps with Whitehall St widening

4. Metro 2/C7 route investigation to be funded and completed by 2022

5. Port Authority to investigate an empty container storage solution within port and investigate how to implement target of 50% of all container movement by rail by 2036

Medium Term (5 to 10 years)1. Build road / rail tunnels, either along existing route or to Webb dock with PT/freight rail component

2. Ban transport of empty containers by truck outside of port area

3. Port Authority to implement empty container storage solution within port

Long Term1. Metro 2

2. Port Authority to implement increased rail movement of containers to 50% by 2031

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METRO 2: PLANNING

Infrastructure Victoria 30 year Strategy Recommenation 10.10.2. recommended that this be investigated in the next 5 years for possible completion in the 2031-2046 time frame

Supported by Mr Barlow‘s evidence

We think that the planning on this an important piece of infrastructure is essential if the M1 Corridor is be fully serviced with an alternative to car-based transport into CBD and employment centres around it, particularly in Fisherman’s Bend

Encourage the IAC to recommend to the government to allocate funds to complete an investigation. Only with this information can decisions be made, and planning for the project proceed so that it can be ready by 2031

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EXPERT EVIDENCE – DR J STONE. UNIVERSITY OF MELBOURNE TRANSPORT PLANNING

What are we doing here?

Planning for the present?

Planning for complete change?

Strategic Misrepresentation

International experience

Road pricing

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EXPERT EVIDENCE – MR D HARLEY FORMER NETWORK PLANNING MANAGER, VICROADS

VITM model for traffic forecasts

Development and use

Government owned

Open platform for use by all

Strengths and weaknesses of Zenith

Proprietary model – closed platform

Freight forecasts

Multi-modal forecasts

Induced demand

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1

Final Submission – Western Distributor Tunnel Project EES Process By (Dr) Pat Love, Geoff Hjorth, Marlene Monahan, Jacob Holley, Jenny Harrison

1. Achieving the Project Objectives

1.1 Why are we doing this project? (slide 3)

The EES identifies four objectives as targets that this project is designed to meet: (3)

Improve transport performance in M1 Corridor

Reduce reliance on West Gate Bridge

Improve freight access to the Port of Melbourne

Improve community amenity on local streets in inner west

All of these are worthy goals. If transport is understood in its broadest sense – road, rail and active

transport - then improving connectivity and providing transport options and building in network

resilience is important for our long-term economic sustainability and liveability. However, this

submission holds that this project of itself will not achieve all these aims. It is essentially a road

project. It is transport in its narrowest definition. The addition of cycling infrastructure is window-

dressing, and will not of itself ensure that more people of the M1 Corridor take up more active

transport options, such as walking and cycling.

The WDA presentation did not allude to any other city in the world taking these or similar steps to

solve the future problems of amenity, transport connectivity and resilience. Melbourne is not the

only city in the world with a traffic congestion problem. Is London proposing to build urban freeway

through Shoreditch to the City? Is New York building an expressway through Manhattan? Not since

Jane Jacobs defeated Robert Moses in protecting the Village. Where were references either in the

EES or in the Business Case to the successful examples of cities other than Australia’s east coast

capitals and US car-dependent mega-sprawl cities?

The short answer is, there are none.

We are in the minority in the OECD and the developed world in looking to these types of solutions in

order to build our way out of congestion, just as are also in the minority in the developed world in

trying to build clean coal power stations.

When asked can be build our way out of congestion, many experts called by the proponent gave the

view that “we need both” road and public transport. This submission will argue that it is a mistake to

say this is just one road project, and public transport will be provided by other projects. We intend

to provide you with evidence in this submission that building this road will reduce public transport

patronage, as well as reversing the trends that have been occurring in Melbourne over the last

decade. It will make those PT projects less viable.

Further, this submission argues that the IAC is being presented with a strategic misrepresentation of

the facts by WDA in the EES. This is primarily through the traffic modelling that has been done in

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2

secrecy, without appropriate transparency. Dr Stone will give an explanation of this phenomenon of

strategic misrepresentation, and why this EES represents an example of this phenomenon.

We submit that VLC has tailored the model to achieve the strategic outcomes that the proponent

requires, i.e. to have you believe that the outcomes are reliable, that they point to a congestion

problem that can only be solved by this project as it is, without modification. Mr Doug Harley,

former Network modelling and Analysis in VicRoads will present evidence that the Zenith model

should not be used in projects such as these precisely because of this point of transparency. No one

else is allowed to view the model to critique it, to test it against other models. Why would they do

that if they were confident of its reliability and applicability?

From your perspective, it must be so reassuring to get volumes of glossy documents full of tables of

figures and diagrams showing just how much work has been put into the detail behind the project

rationale. It gives you confidence, something to engage with. The EES gives you data about this

aspect or that, this intersection or that tunnel, which inclines you never to question the whole basis

on which it stands – the assumptions and data that has gone into the traffic modelling, and the

subsequent representation of the transport situation on the M1 corridor and West Gate Bridge.

This submission will provide you with “alternate facts”, evidence that tells a different story about the

performance of transport on the M1 corridor. We believe they are reliable indicators that point to a

changing city, new and old communities in a corridor who are using public transport in greater

numbers despite lower service levels than elsewhere, who are travelling by car less often, own fewer

cars, now and hopefully into the future.

We argue that this is not an accident but the result of decades of integrated transport and land use

planning policies in the form of Growth Areas strategies, comprehensive PSP planning by Victorian

Planning Authority, State Government plans that encouraged a more compact city, linked by public

transport – Melbourne 2030, Melbourne@5 million, Plan Melbourne and previous iterations. These

policies encouraged infill developments that increased density, and lead to transport projects such

as regional rail and extensions to the bus and tram and rail networks to new suburbs. While some

consider that it has been slow, too stop-start, one step forward two back at times, it has had an

effect which we hope to demonstrate.

We hold that proceeding with the project as it is will jeopardise these gains.

Consequently, this submission will present you with a recommendation that the original Western

Distributor project, the ramps onto Hyde St, should proceed now, with some small modifications.

We recommend that the remainder of the project be put on hold until the route of the tunnels be

re-investigated and re-evaluated against the C7 route option.

We recommend that the traffic modelling for such a re-evaluation be conducted openly and

transparently by the proponents using VITM.

We recommend that the investigation of the C7 option include freight rail to Webb Dock, public

transport in the form of Metro 2 style services, as well as road access to the Dock. As the EES itself

says in Chapter 3, this option would be “city changing”.

We make a number of other recommendations about the improving bus and rail public transport

services, increasing air quality and noise attenuation measures, and deletion of the city access

ramps, should the project go ahead in its present form.

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3

1.2 So why is this project being proposed now?

Infrastructure Victoria did not rate the project as a high priority in its 30 year assessment of needs.

To understand the urgency in the EES we should first understand who the proponents are.

2. Who are the Proponents? (slides 4-10) The proponent is WDA, but the EES explains that this is a made up entity of the State Government

and Transurban. (4) Indeed, Transurban came to the government with a solution to the problems of

capacity on the M1 corridor, Port access, and inner west amenity.

Transurban operate the largest toll road in Australia – Citylink- four times the size of any other toll

road in Australia. (5) Traffic volumes have grown in just about every year since completion in 2000,

apart from a short period in 2008-9 and in 2016. (See slide 6). In both cases, road works to widen or

extend the freeway were in train, most recently the Tullamarine and reworking the Bolte Bridge on-

ramps to the West Gate in 2016-17.

No other toll road in Australia approaches this toll road in volumes of traffic and therefore in

revenue generation capacity. Transurban’s most recent company report shows us the extent of this

reliance on Citylink. The comparison in slide 7 of the downturn in traffic on Citylink and other toll

roads is cyclical, and they are on the slope of another downturn. As you know, they were also going

to be the beneficiary of the East West project, now defunct, as it would pour thousands of cars into

the Citylink network starting in 2020.

While major projects are in train in other cities, notably Brisbane and Sydney, the West Gate Tunnel

project is the largest project on their horizon. Their contribution is expected to be $3.5 to 4 billion,

which they may to fund in part by issuing more shares. Unfortunately, the downturn in Citylink

revenue also coincides with the delivery of Melbourne Metro. There is no doubt this will have a

significant effect on Citylink traffic volumes. That is the purpose of the Metro rail project, to transfer

more people to mass transit style services, running down largely the same corridor as Citylink. Chart

8 notes the relationship between Metro Rail patronage and Citylink traffic volumes, over the last 10

years. The big increase in public transport occurred when traffic volumes plateaued (2005-2009), but

equally when capacity was increased on the freeway (2001, 2010) then PT patronage slows or

declines. So opening the WGT project first will be an important jump on the opposition so to speak.

However, will it work? To know this, we rely on the outputs from the VLC Zenith traffic model. The

fact that these cannot be checked against the other model, VITM, developed locally by VicRoads, is a

concern. The expert witness, Mr Doug Harley, will give evidence later that leaving such a crucial

factor to the proponent alone is not advisable. We cannot get inside the model to examine it. VLC

have not run the data through VITM to compare the outputs, as advised. If we were allowed to see

the independent report by Mr Allard, it may show that the model was appropriate, that it has the

appropriate rigour, and the assumptions are correct. However, it also may show up serious flaws in

methodology and data input into the model. As with all computer models, rubbish in rubbish out.

The decision to keep it secret clouds the proponent’s case considerably.

Why would Transurban do this now? (9) As we noted above, a number of factors come together

right now for them. This is an opportunity to shore up their position in Melbourne prior to the Metro

rail project, and the loss of the East West project. While I am not suggesting that they are being

dishonest, there is no requirement for them to use the same model in the EES and the business case.

The model used in the EES may exaggerate the traffic volumes early in the life of the project to

convince you in the course of the EES process, while relying on a different model used in the

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confidential business case. The latter may produce outcomes that are more realistic. Both may be

versions of Zenith, or indeed VITM. We argue that this could well represent a case of strategic

misrepresentation. (Slide 10)

Congestion / Road Pricing: If the project is allowed to proceed, the private toll company will become

the de facto congestion-pricing instrument on our freeways. Although the current government does

not favour the policy, Transurban holds no such qualms.

Is this what Melbourne needs? Particularly now, as we face challenges on multiple fronts including

the dual economic challenges of under-employment and affordable housing, and environmental

challenge of reducing GHG emissions.

3. Who will pay for this project?

At heart, this project is a toll road. The government will provide $1.5 billion dollars, coming

ultimately from State taxes presumably. Transurban is providing the rest ($3.5 – 4 billion). However,

they will take out debt/issue equity to pay for this upfront. The debt of course will be financed by

the income provided by the tolls. To assist them in this, the Government will allow Transurban a ten-

year to fifteen year extension on the Citylink concession agreement (tolling licence) on the whole of

Citylink. As we saw above, this means most Melbournians will contribute to this repayment plus

providing Transurban with a profit. Therefore, whether it is the State Government contribution via

taxation or the Transurban contribution via tolls, we are all paying for it. Therefore, the public need

to be confident that this project makes good long-term transport planning sense. It should be

transparent to all of us, not just the readers of the private business case of Transurban.

You, the IAC, are our instrument in ensuring that the public gains a net community benefit over time,

not just Transurban.

4. Data to evaluate the bottom line of an Environmental Effects

Statement (11)

4.0 Demography (slides 12-14) The overwhelming growth in the M1 Corridor is from the Wyndham municipality. Geelong also has a

growth contribution.

4.1 State Policies on Green House Gas Emissions and Climate Change (slides 15-17)

The State Government has recently lifted the renewable energy target (RET) to 20% of all power by

2020 and 50% by 2030. (15) This supports a policy of zero net GHG emissions by 2050. (Ref:

https://www.climatechange.vic.gov.au/reducing-emissions/emissions-targets). It will set interim

targets by 2020, for 2021-2025 and 2026-2030, but is aiming to reduce emissions by 15 to 20% in the

interim.

This project will increase GHG emissions over the no-project base case in 2031, despite assurances

made in the Business Case that GHGs in the form of vehicle emissions will be reduced by 2.3 million

tonnes annually (SBC p 6). However, the Executive Summary of Technical Report Q indicates that this

will not eventuate (p 7 of 124) (17)

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“It is estimated there would be a marginal increase in vehicle traffic emissions from the metropolitan

Melbourne road network in 2021 and 2031 under the with-project scenario compared with the no-

project scenario (0.23% and 0.04% respectively). However, the greenhouse gas intensity of the

metropolitan Melbourne road network (kg CO2-e/vehicle kilometre travelled (VKT) is estimated to

reduce marginally under the no project scenario in 2021 and 2031 (0.24% and 0.31%). The

greenhouse gas-related elements of the EES evaluation objectives for waste management and the

environmental management framework (EMF) would be met through the EPRs set out in this report.”

Transport emissions represent approximately 25% of all GHG emissions in Australia. Chart 16 shows

that these have peaked and plateaued since 2012. The latest forecasts project that these emissions

will continue to increase by 1% per annum under current BAU assumptions. Assuming that the car

fleet will convert to electric vehicles is a long way off the mark according to the car companies.

Australia has the lowest take up rate of electric cars, because the critical charging technology is not

being built. Renault Australia, who make one of these cars, recently decried the future of electric

vehicles in Australia (ref). You can therefore not assume that the 2050 scenario will be different.

Nevertheless, you must factor in the increase in traffic that this project will generate, and therefore

the likelihood of higher GHG emissions over the next 15 years at least.

4.2 Traffic Model Deficiencies: Traffic Generation Effect of the West Gate Tunnel

on M1 (slide 18) The EES states that this project will reduce the problem of congestion on the M1 and improve travel

times by up to 20 minutes (See Summary of Western Distributor Business Case, p9). This submission

argues that this project would only free up the system for a short period, before more congestion

returns. The Business Case, and therefore this EES, is based on a classic predict and provide

methodology, utilising a traffic model that remains hidden.

A number of deficiencies in the Zenith model’s four step design have already been uncovered by Mr

Tweedie on behalf of the Melbourne CC, including the single distribution looping approach instead

of the double distribution loop preferred by VITM and other models. We will not revisit this.

We contend that the model has a number of other deficiencies, including the way it treats induced

demand, and the use of 2007-10 VISTA household survey data to “calibrate” each of the four steps

of the model (based on Mr Veitch’s evidence to Westgate tunnel panel hearing).

On induced travel demand, we contend that the project will be subject to the normal induced traffic

effects, including new trip generation, over the long term. The traffic model explicitly excludes this

last category, and two others (induced land use, and changed departure time) that the Auditor

General says should be included, arguing that their effects are negligible (Technical Report A

Appendices p 19). Mr Veitch confirmed this in his presentation. VicRoads agrees with this position in

their draft position paper on Induced Traffic, published in 2011 (Induced Travel Demand, draft

position paper, Dept of Transport, Nov 2011)). While it says there are studies in the US and

elsewhere that draw the same conclusion, it does not cite these studies’ peer-reviewed references

for us to confirm the evidence.

On the other hand, the work of transport researchers Newman and Kenworthy (1999), Mees (2000)

and others in Australia, and J M Thomson (1977), Anthony Downs (1992), Robert Cervero (1998) and

others in the US, the Royal Commission into Environmental Pollution in the UK (1997) and many

others have confirmed that creating more road space, especially urban freeways, does not lead to a

less congested road system. They all include amongst the factors of induced traffic not only the

tendency for the extra road capacity to cause a shift in modes and travel patterns, but also to induce

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or generate new traffic on top of what is predicted using ordinary models. VITM includes this factor.

Until the project is run through the alternate VITM model, you will not know whether Mr Veitch’s

view is correct, or the weight of expert opinion here and elsewhere.

Even without these extra induced traffic factors included, the 2031 with project scenario predicts an

additional 37,000 vehicles per day using the West Gate Freeway section of the project compared to

the 2031 no project scenario (Chapter 11 Effects on Transport, p 11-30). In answer to my question,

Mr Veitch also confirmed that up to 2000 passengers would transfer from public transport to cars,

mostly from rail. Although the EES describes this decline as not a significant shift (11-30), it amounts

to two full trains per day. If the way that induced travel has been curtailed in this model, it may not

generate the level of traffic immediately to make the case for urgency.

Further to this, and according to Mr Veitch, the model uses the 2007-10 VISTA data to calibrate the

four steps of the model. Without being able to understand exactly how this happens, it was used to

calibrate the trip generation, the destination choice, the mode choice and trip assignment

propensity of households in each SA1, which is then used to generate traffic volumes to feed into

the system.. Why not use more recent data, such as the 2012-14 VISTA data set? This may better

reflect the significant increase in mode choice of PT in Melbourne from 2010 to now. (We will

provide more evidence around the importance of this later.)

For now, we raise the questions in the context of the strategic misrepresentation argument - the

selective use of models and data which better makes the proponents case.

4.3 The changing character of Melbourne and reliance on the West Gate Bridge

(slides 19-25) This submission argues that Melbourne is a city in transition. It is densifying, inner areas are

gentrifying, and there is a commitment in Plan Melbourne to the 20-minute city, which

translates into more local services and jobs near homes. Is it working or is it all talk?

Two measures of this are the number of cars that Melbournians own, and the distance they

travel in them each day.

Chart 19 shows that vehicle ownership rates per 100 people aged 18 to 84 have declined in

Melbourne in three consecutive Census counts between 2006 and 2016. This is unique in

Australian cities, even compared to Sydney, which has seen an increase, even though they have

lower overall rates of car ownership.

Chart 20 shows that this change is not just happening in inner city locations. This is also

occurring in places like Tarneit and Truganina in Werribee, in Mernda and Doreen in Whittlesea,

and Deer Park – Derrimut in the west. All have seen a decline in car ownership, despite huge

population increases.

Chart 21 – a map shows the picture across Melbourne in 2006 on the left and in 2016 the

amount of change over the ten years. The M1 Corridor is not alone in showing many green and

blue areas of decline. The common theme is investment in public transport options, such as the

Regional Rail in Tarneit/Truganina, new stations in Williams Landing for Point Cook, and

extensions to the rail line in Craigieburn, Mernda and Doreen, and in Cranbourne.

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New residents are taking up these options.

As well as that, the density of Melbourne is increasing due to land use planning policies applied

at least over the last decade, encouraging greater density. The combination creates a very

different picture of Melbourne going forward, when compared to any other major city in

Australia. (Chart 22)

Source: charting.com

Why is this important? This is derived from the most recent 2016 Census data. It may translate

into fewer vehicle kilometres travelled than VLC assumed. Remember that the VLC model uses

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Vista data from 2007-10 as the base assumption of trip generation. This 2016 data questions

that base. The data certainly shows that this is the case.

Chart 23 shows that VKT has been declining for a decade across all Australian cities. Mr Veitch

argued that this decline was deceptive because of the scale on the graph, and cited reasons such

as lower licensing rates for young people, and fuel price increases, which may revert. In fact, as

we have shown, there are a number of other reasons such as declining car ownership and

greater density is causing people to choose to walk, cycle and take public transport in greater

proportions, requiring fewer cars.

The assumption that it will increase lies at the heart of the traffic forecasts. Chart 24 below shows

that mass public transit has increased its share of the motorised passenger kilometres in Melbourne

since 2004-5. However, it peaked in 2011-12, according to BITRE in 2016.

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When combined with the trends in vehicle ownership however, it assumes a different picture. Chart

25 shows the increase in mass public transport’s share compared to cars in five major Australian

cities, which outstrips population growth. Recall that Melbourne is bucking the trend in terms of car

ownership and density.

In the end, Melbourne is on a very different trajectory to other cities in Australia. Are these

assumptions built into the VLC model? Is the future going to be different, or will we have more of

the same? Dr Stone will provide more evidence about this.

The result is that we may not be more reliant on the West Gate Bridge than we are now. As people

travel more in their own local area, take up jobs and opportunities locally, and take public transport

options when they are provided, their reliance on car travel will decline.

4.4 What is the likely direction in the future with further investment only in roads

on this corridor? (slides 26-34) The impact of a freeway only solution on these trends could be significant. Chart 26 / 27 shows

the history of PT patronage and traffic volumes on Citylink between 2001 and 2011. When

Citylink opened in 2011, PT patronage remained flat as Citylink grew. It reached a capacity in

2008/9, when freeway-widening works were conducted on Monash and Tullamarine. Pt grew

quickly while traffic volumes plateaued. Once opened in 2009/10, Citylink traffic took off while

PT patronage slowed. There is a pattern, and perhaps a direct relationship. Every so many years,

freeway capacity is reached. Congestion is apparent, and public transport takes off. The

implication for this project is clear. Investing solely in freeway works will result in a reduction in

or slowing in PT patronage on the M1 corridor, which is counter to the policies that produced

what is happening across Melbourne.

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Table 2 below shows the 2012-4 VISTA travel data for work related travel in the city of

Wyndham.(slide 28) It shows that 20% of travel to all destinations is by public transport (rail).

This is sub grouped into travel in Wyndham itself, Melbourne CBD, Other Inner municipalities,

municipalities in the inner west, Eastern southern, Northern municipalities, and Other Western

and Geelong. This shows that 51% of all travel for work is to the Melbourne and Inner City, and

51% of this is by rail. Although a little lower than all travel to the Inner city (60% in 2011), it is

consistent with 2011 Census data for Wyndham. (29-31)

However, the real point of this data is that it shows a higher public transport share than the 14%

that the VLC model generates (32). This is a significant difference. The largest growing

municipality in the M1 corridor is already operating at a higher level of public transport usage for

work-related travel than the 2031 project scenario generates.

Table 2: VISTA 2012-14 Wyndham residents work related travel 18-84 year olds

Destination

Destination

Share

Destination

Groups

Rail PT

Share

Wyndham 27% 27% 2%

Melbourne 22% 51% 58%

Inner City (Yarra, Port Phillip) 9% 33%

Inner West (Hobsons Bay, Maribyrnong, Mooney Valley)20% 0%

Eastern & Southern suburbs 6% 12% 0%

Northern 6% 44%

Outer Western (Melton, Brimbank, 8% 10% 0%

Geelong 2% 50%

Total 100% 20%

Source: VISTA 2012-14

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Why would this be true? Is it the use of 2007-10 VISTA data in the Zenith model, which has lower

rates of PT usage, or other factors? It is not clear, but it could lead to very real over-provision of

road capacity, when aligned with the other trends we have identified on VKT and car ownership.

Of course, provision of more roads will induce demand back to car travel. This may well be the

aim of the proponents/the freeway operators, and by keeping the model under tight security,

we will not be able to test this.

4.5 The transport capacity and performance of the M1 Corridor (slides 33) The assessment of the capacity and performance of transport in the M1 corridor should include PT

and road based options.

The much-quoted Eddington Report highlighted the significant deficit in public transport options in

the western suburbs when compared to the rest of Melbourne. While major road improvements

were suggested such as the East West link (both parts), key recommendations involved public

transport options for the western region, including lifting service levels on trains and buses.

The Table 1 below shows the number of services on the M1 Corridor and comparisons to other rail

lines in Melbourne in the peaks (7 to 9 am and 4 to 6 pm).

Table 1: Rail Services on M1 Corridor compared with lines across Melbourne (33)

Lines Servicing M1 CorridorNumber of rail services

Station

AM Peak

(7-9am) Frequency

PM Peak

(4-6 pm) Frequency

Williamstown 6 20.00 6 20.00

Newport 23 5.22 22 5.45

Altona 6 20.00 6 20.00

Laverton 18 6.67 17 7.06

Werribee* 13 9.23 11 10.91

Wyndham Vale (RR) 10 12.00 6 20.00

Other Metro Services

Craigieburn* 15 8.00 18 6.67

Frankston* 14 8.57 13 9.23

Glen Waverley* 14 8.57 12 10.00

South Morang* 12 10.00 13 9.23

Sunbury (Watergardens)* 15 8.00 17 7.06

Lilydale* 12 10.00 10 12.00

Belgrave* 11 10.91 10 12.00

Ringwood 27 4.44 23 5.22

Blackburn 33 3.64 31 3.87

Alamein 7 17.14 6 20.00

Pakenham* 11 10.91 12 10.00

Cranbourne* 7 17.14 8 15.00

Dandenong 22 5.45 24 5.00

This table shows that the other main lines in the west, Sunbury/Watergardens, Craigieburn, have

more services scheduled in the AM and PM peaks. Werribee line services need boosting to their

level to cater for the existing demand (minimum 15 per peak period), without considering the

potential demand from the forecast growth. In addition the Geelong regional rail services through

Wyndhamvale/Tarneit could be increased as recommended by Infrastructure Victoria in the next 5

to 10 years (1.3.4).

Further to this, the bus services meeting trains at stations on this line are generally at a 20-minute

frequency, or roughly, they arrive at every second train. Car parks are full to overflowing by 7.30am

or 7.45am. Catching a bus to the station is the only option but these are so infrequent that people

resort to the freeway sometimes out of convenience, but usually of necessity. Outer Metropolitan

Growth area bus services is given a specific urgent priority (0-5 yrs) by Infrastructure Victoria (1.3.2).

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If the line had two or three more services of a morning, and 4 more of an evening, and buses ran as

frequently as the trains in the peak hours, and regional rail increased by 4 services in peaks then the

recommendations of the Eddington Report would be met, for now. The transport capacity of the M1

would be improved immeasurably, and people would have an option to the freeway.

The capacity of the freeway is being stretched by population growth. It is also being stretched

because of the under-servicing by rail and bus. Addressing this issue would give us more time to

implement this project and other solutions. Implementing this project without addressing the deficit,

would provide more incentive for rail commuters to transfer to the freeway.

During construction of the project, if it goes ahead, the improvement in train and bus services is

essential. VicRoads have not responded to my request for their estimate of the delays on the

freeways caused by the road works, which will take 4 years to complete.

During the critical construction period, the EPRs indicate that they will keep all four lanes open in

each direction during the peaks, but speeds will be limited to 80 kms per hour. With 100 kms limits

now, the queueing of traffic onto the bridge of a morning extends to Point Cook turnoff on

occasions. Of an evening, the whole corridor is stop start.

The road works must lengthen travel times over the trip even more. Adding conservatively 15 mins

to what was a one-hour trip to Werribee of an evening might take 75 mins during construction, or

half an hour extra travelling each day for up to four years. A child is born, learns to walk, talk, goes to

childcare, and is completing kindergarten in that time. A parent loses half hour each day interacting

with the child, which could well be in bed by the time the parent gets home at 6.30 pm. certainly

picking up or dropping off the child at childcare is more difficult. A rail service currently takes 40

mins in either direction, which leaves 20 mins to get home, and still have 15 mins with a child.

This submission holds that should the project proceed, the project should not be implemented

without a significant upgrade of rail and bus services in the corridor.

We will later present a case for an investigation of the Metro 2 proposal be completed, as

recommended by Infrastructure Victoria, to inform a decision about the viability of a metro style

service runs from Newport to the city under Fishermans Bend.

4.6 Port Access: Which part of the Port? (slides 34-36) Rotterdam and Hamburg are two of the largest ports in Europe. They are investing or

have invested in more rail connections in an out of their ports, to keep containers to a

minimum. Hamburg has a target of 50% of containers moved by rail within 5 years. They

already have 45% on rail. Port rail shuttles and Webb Dock rail access are mentioned as

priorities by Infrastructure Victoria (13.3.1, 13.3.4) in its 30 year assessment.

The EES assumes only 10% moved by rail in this project, even though it acknowledges

that more investment in this option will be required. Does this effect the freight

assumptions for the tunnels?

The rail connection we have now is only to Swanston Dock. Mr Barlow gave evidence

that the Webb Dock is the area of greatest growth over the next 35 years. The tunnels

provide access only to Swanston Dock, which will be the first area to be discarded once

the new port in Pt Wilson is created. This is only 35 years from now.

Should we re-think the direction of the tunnels, to provide a freight rail option for the

Webb dock area? It aligns much better with the C7 option discussed in chapter 3.

Perhaps prematurely discarded by the EES.

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Such a connection would also take much of the freight off the West Gate Bridge in future

years.

If this were explored in more depth, in conjunction with an investigation of the Metro 2

study, then we will have a project that is truly significant for the Port, for Melbourne,

and for the M1 Corridor.

4.7 Do we need an inter-connected freeway system, or a connected road and rail

based transport system? (slides 38-42) What does Melbourne need now? In chapter 3, the EES assumes that other road projects in the M1

corridor are required, even on completion of this project. Is this what the city needs?

The data presented above lends a strong case that Melbourne is in transition. Land use and

transport policies over the last decade or more have resulted in behavioural shifts of seismic

proportions. The city needs an integrated road, rail and bus and cycling solution in order to continue

this trend, rather than another road-only project. Therefore, at the very least the EES

recommendations should ensure that other options for commuters, freight and business are part of

the plan in the short and medium term if the M1 corridor transport performance is to be improved.

It is the minimum position of this submission that this project must be accompanied by investment

in public transport, not only to support sustainable transport and GHG targets the state has set, but

to make sure that the project does not jeopardise the gains made already in land use planning and

transport.

5. Other transport options including various alternative modes to be

included with the project Seven practical steps can be taken to provide these alternative transport options for commuters and

business. These include short, medium and long term options. (Slide 50)

Short Term Options

More public bus services to be added during construction and retained post-construction

across the inner and outer western suburbs, enabling more commuters to access the

additional rail services without relying on their motor vehicles. (Rated a high priority by

Infrastructure Victoria 1.3.3)

o Without buses on a 10 minute frequency schedule to provide commuters with

alternatives to use of private cars on already congested roads in the inner west,

during the construction period the congestion will become continually worse. These

could be retained after the construction period if successful. This measure will lonely

work if there is more rail capacity along the M1 corridor (Werribee, Altona and

Williamstown lines). See below.

A commitment to replace the Geelong VLine services transferred to the regional rail route

with extra Metro services to be given for implementation by the end 2018.

o Following the initiative to increase buses, there needs to be more rail services on

this route to accept these new passengers. There is significant unused capacity on

the Werribee line due to Geelong VLine trains being re-routed through Sunshine.

o At least two more morning peak and four evening peak services are required.

(Although this may create congestion in Flinders St, Frankston line and other

services can be re-rerouted for a short period to assist in this critical period for

Melbourne while Metro 1 is being built).

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Banning trucks on Blackshaws Rd, Hudsons Road, Douglas Parade, & Millers Road (south of

freeway), which do not originate or finish their journeys in businesses there.

o Support for the proposal in the Hobsons Bay City Council submission to stop trucks

that do not start of finish their journeys in these local roads from using them to

avoid tolls or transport congestion.

o Recent government announcements are a positive start in this regard.

Port to investigate the target of moving 50% of all containers by rail by 2031, and the

storage of empty containers within the port area by 2027.

Metro 2 – C7 route investigation to begin asap (the much needed mass transit link between

Newport and Clifton Hill, via a tunnel connecting Fishermen’s Bend, Southern Cross Station

and Clifton Hill station), with freight rail to Webb Dock.

o Both investigations were recommended by Infrastructure Victoria (10.12.2 & 13.3.4)

o This option is a re-evaluation of the C7 route for the project in the EES.

Medium Term Options

Build road / rail tunnels, either along existing route or to Webb dock with PT/freight rail

component depending on the outcome of the Metro 2 C7 route investigation.

Banning the use of trucks to carry single empty containers between container parks and the

port.

o As per the report in The Age (5 July 2017?), there is a significant number of daily

journeys to and from the Port with empty containers.

More efficient means of storing empty containers used to top up ships within the port itself.

o If above is to be successful, then the solution to where empty containers can be

stored is essential. Much can be gained by finding an alternative solution such as

storing more containers within the port or finding a faster rail transport solution

outside the Port. Port authorities must accept that they should find a solution that

does not impose costs on the city commuters and other businesses such as this

project will do.

o Best practice in international ports is to aim for 50% of container movement by rail.

Long Term Options

Metro 2 to begin in 10 years or following Melbourne Metro subject the outcome of the

investigation.

o Bringing forward this key, city-changing project by beginning the planning for it now

will be important..

Planning to begin for the infrastructure that will allow the majority of container freight to be

carried between the port and inland ports planned for Truganina, Epping and Dandenong by

rail, where trucks can then distribute it.

o Comment: The long-term objective of shifting freight out of the Port of Melbourne

by rail to three inland ports serviced by rail predominantly is now more important

than ever. Trucks were not intended for this purpose and are not suited for it. Rail

could also deliver empty containers to and from the port on a daily basis much more

efficiently then trucks.

6. Environmental pollution monitoring of small particulates (slide 49) Expert reporting to the meeting of the Spotswood Residents Association (Dr Keogh, Qld University of

Technology, Brisbane) has highlighted the fact that environmental pollution monitoring on the

project may not include particulates smaller than 2.5 microns. This was seen to be an important

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omission, as diesel engines generate much of this pollution. Benchmarks should be established that

meet current best-practice health standards internationally. The following measures should

therefore be included:

1. Monitoring of ultrafine particles (<2.5 microns) be undertaken in conjunction with monitoring of

PM2.5 and PM10. That there be a commitment by the project to ultrafine particulate matter levels,

PM2.5 and PM10 not increasing after the project is completed, as compared to levels measured pre-

construction.

2. Monitoring stations for air quality, including for ultrafine particles, be set up at four locations in

Spotswood, West of Melbourne Road; Donald McLean Reserve; on Simcock Avenue near

Scienceworks and at the Emma McLean Kindergarten.

3. Annual particle number and particle mass inventories of motor vehicle particle emissions be

prepared for both the motorway and the on-ramp used by trucks for different vehicle types

covering the full size range of particles generated by motor vehicles (from ultrafine size (particle

number) to PM1, PM2.5 and PM10) using appropriate tailpipe emission factors and traffic data for

light duty vehicles, heavy duty vehicles and buses. (Refer method in Keogh et al. 2009, Keogh et

al.2010 & Kumar et al. 2014). This is a simple and cost effective method for quantifying and

monitoring pollution rates over time on individual road links.

7. Quality of freeway infrastructure and finishes (slide 49) Hobsons Bay City Council has highlighted the discrepancy between finishes of freeway sound walls

and other infrastructure on the Westgate, compared to those of the Eastern and East Link Freeways.

Fairness and equity dictates that the people of the western suburbs should see the same level of

finish as freeways in other parts of Melbourne.

8. Replacement of Public Open Space and protection of sensitive land

uses The replacement of public open space lost to the project should be made up by the Project so that

there is a zero sum equation between areas lost and new areas created. Sensitive uses should also

be protected, such as the kindergartens, childcare centres and pre-schools near the road. Possible

ways this could be done include:

Purchasing brownfield sites near the freeway and converting these into POS.

Rehabilitating polluted or damaged sites in the area, such as along waterways along Stony

Creek, Kororoit Creek, and along the Maribyrnong and Yarra River banks.

Childcare centres and informal outdoor recreation areas are defined as sensitive land use

areas by the EPA Victoria (2013, p. 17). A recent review of buffer distances applied

internationally to sensitive land use areas, such as childcare centres, recommended a

separation distance from the road edge of strategic routes (e.g. motorways) of at least 150m

(Wickham, 2012, p. 78).

The project requires that trucks not be permitted within 150 metres of the Donald McLean

Reserve or Emma McLean Kindergarten (3-5 yo children) and Scienceworks, measured either

from the motorway or from any local street near the two sensitive land use sites.

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16

9. North Melbourne / Docklands access to the CBD (slide 48) Critics of the Project, including many residents of North Melbourne, indicate that much of the extra

traffic created by the Project will be due to the provision of a new route into the CBD. This is

facilitated by the plan to redirect Wurundjeri Way to connect with the end of the freeway in North

Melbourne. This new connection will also impact on the possible regeneration of the area known as

EGate, and the rail yards in North Melbourne, by redirecting all this extra traffic through it.

If the primary purpose of the project is not to make travel into the CBD easier, but rather to ease the

congestion on the M1 for freight, then there is no need to change Wurundjeri Way at all. The

existing connection with Footscray Road could service it quite well. Those who wish to use the route

to travel into the city will have to endure this extra traffic on Footscray Road, which will discourage

some from taking this route. The duplication of Footscray Road should be dropped. Footscray Road

is an eight-lane boulevard into the city. The concept of a freeway over such a road is just

unnecessary, and only designed to feed into the CBD and Citylink.

The tunnels should emerge on the eastern side of the river onto Footscray Road, preserving the

riverbank regeneration on both sides of the Maribyrnong onto Footscray Road.

10 Hyde St Ramps (Slides 43-44) The Hyde St on ramp is designed currently to use Simcock St. This is a small local road near

Scienceworks.

This is a highly trafficked area by families and school groups on a daily basis.

Trucks passing within 150 meters of the facility would not be an acceptable outcome.

Re-designing this ramp to pass either under or over the freeway to join up with the off ramp

would create only one intersection on Hyde St. This will have far less impact on traffic along

Hyde St and Douglas Parade.

11 Hyde St Francis St intersection and Whitehall Street duplication

(slides 45-47) The Hyde St Ramps were the original part of the Western Distributor project originally

proposed by the government and taken to the election.

This assumed that trucks would be taken off the freeway, and redirected along Hyde St and

Whitehall St to the port, removing them from Francis St in particular.

Douglas Parade and Hyde St is only the second route or two that residents of Newport,

Williamstown and Spotswood have to exit the area by car. Williamstown Road will be

congested most mornings and evenings, with or without the project. Hyde St is the only

route that actually works well.

Under the current project design, the Hyde St Francis St intersection is not designed to work.

VicRoads, when asked, indicated that they did consider the F LOS rating in the afternoon and

E rating in the morning “a disbenefit” of the project. In other words, it is not designed to

work, and will encourage trucks to use the tunnels.

If implemented this will result in most residents of the peninsula south of the freeway

having no workable exit to the north. The tunnels do not benefit these residents, as they are

accessible only from Millers Road.

The solution is to duplicate the small section of Francis St east of Hyde, and the 500 m

section of Whitehall St south of Somerville Road. This is already a wide road, although only

marked for one lane each way.

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17

The result would be a better traffic flow from Hyde St into Francis and then onto Whitehall

St. Trucks and residents could access Footscray Road to go to the port, into the city, or to

other destinations. This would truly reduce reliance on the West Gate Bridge for these

residents, and would ensure all trucks stay out of local roads, including Francis St.

It may result in some trucks avoiding the tunnel tolls, but is this a small price to pay for a

workable overall solution.

12 Conclusion (slide 50) The submission concludes that the EES has been presented in a way that precludes most of us from

accessing the data we need to test whether the project meets its objectives.

Transport performance on the M1 corridor has been improving markedly over the last

decade, although traffic congestion on the freeway will remain a reality, with or without the

project.

The project will ensure vehicle traffic increases on the corridor, and GHG emissions will rise,

compared to the case without the project.

The project as it stands will impact the patronage on public transport, perhaps by as much as

6% (14% v 20%) , and may well be designed to do so, to ensure their tolls are collected to

support the debt and make Transurban a profit.

The project will result in a private company able to reap the benefits of a de facto

congestion-pricing regime on all three major transport corridors for a further 10-12 years.

The Government, meaning that the public will be deprived of these funds to invest in public

transport options. The result is that we will be paying for this, and not reaping the benefits.

A proper investigation of the C7 option in the EES should be recommended by the IAC, so

that we can evaluate the alternative cost benefits of a Metro 2 and rail freight tunnel option

into Webb Dock, Fishermans Bend and beyond. Infrastructure Victoria recommends both

studies be done in the next 5 years. The answers are critical for this project, which if it goes

ahead in its present form, will make the others more marginal.

In the meantime, the Western Distributor option of the ramps could be implemented

immediately. It would involve constructing the Hyde St Ramps with a minor design alteration

to the on-ramp and widening and duplication of a small part of Francis St and Whitehall St to

Somerville Road.

If the tunnels are recommended, then the public transport improvements outlined in section

4.3 and section 5 are important and necessary, with the following provisos:

o The option of CBD access ramps should be dropped from any proposal.

o The duplication of Footscray Road should be dropped. An eight-lane boulevard into

the port and the city already exists. The concept of a freeway over such a road is just

ridiculous.

o The tunnels should emerge on the eastern side of the river onto Footscray Road,

preserving the riverbank regeneration on both sides of the Maribyrnong onto

Footscray Road.

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SUBMISSION TO IAC HEARING ON WEST GATE TUNNEL EES

Dr P Love, Mr G Hjorth, Ms M

Monahan, Mr J Holley

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OUR SUBMISSION SUMMARYProject Objectives

Who is the proponent?

Strategic Misrepresentation: Private v Public information

Relevant New Data on evaluating the bottom line of the EES:

Port access

CBD Access

Western Distributor ramps and route upgrade Hyde St Francis St intersection, Whtehall St duplication

Simcock Ave ramp – v one entry exit point

Air quality

Sound barriers

Recommendations

Expert Evidence Dr J Stone

Expert Evidence Mr Doug Harley (5.40 pm Tuesday)

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3: PROJECT OBJECTIVES

Improve transport performance in M1 Corridor

Reduce reliance on West Gate Bridge

Improve freight access to Port

Improve community amenity on local streets in inner west

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4: WHO ARE THE PROPONENTS?

WDA

Transurban Transurban build freeways and tunnels that make profit from charging tolls over a long period of time

State Government accepted a market-led proposal put forward by Transurban, and checked by their own experts

prepared a business case based on the proposal and data led by the proponent, heavily redacted version only for public

chose not to release the Business Case in full, nor the full VLC modelling behind it, nor the peer review of the traffic model

Some questions: Why did Transurban come to the Government?

Why claim “commercial in confidence” cover on essential financial and traffic modelling information? Creating doubt!

Identify huge commercial risk or

Strategic Misrepresentation – where organisational or political objectives get in the way of transparency

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CHART5: TOLL ROAD PERFORMANCE AROUND AUSTRALIA

Source: chartingtransport.com website, accessed 29 August 2017

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6: TOLL ROAD PERFORMANCE AROUND AUSTRALIA

Source: chartingtransport.com website, accessed 29 August 2017

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7: TOLL ROAD PERFORMANCE AROUND AUSTRALIA

Source: chartingtransport.com website, accessed 29 August 2017

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8: IMPACT OF FREEWAY WIDENING ON PT PATRONAGE 2011-12

City Link

opens

MCW

widening

East

Link

Source: chartingtransport.com website, accessed 29 August 2017

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9 WHY NOW?

CityLink traffic volumes are stagnant and declining in 2016

(Financial Report 2015-16)

E-W project cancelled

Melbourne Metro is opening 2026

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10 STRATEGIC MISREPRESENTATION: PUBLIC V PRIVATE INFORMATION

Is this a case where commercial risk justifies public ignorance?

OR

Do organisational and political objectives obscure the proponents case to ensure success?

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11: RELEVANT DATA TO EVALUATE EESOR THE ALTERNATE FACTS

Population Forecasts for M1 corridor

Green House Gas emissions

Traffic model and Induced traffic estimates

Vehicle ownership and density Melbourne and Australia

VKT trends and Melbourne

Public transport performance in Melbourne

Impact of freeway widening on PT patronage 2011-12

Impact of traffic congestion on PT patronage

VISTA 2012-14 for Wyndham

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12 DEMOGRAPHY

0

100000

200000

300000

400000

500000

600000

700000

800000

900000

LGA GreaterGeelong

Wyndham Hobsons Bay Total Population

POPULATION GROWTH WESTERN CORRIDOR 2011-

2031 VICINFUTURE 2016

2011 2021 2031

0

100000

200000

300000

400000

500000

600000

700000

800000

900000

1000000

LGA 2011 2016* 2021 2026 2031

Population Growth Western Corridor 2011-2036: ID

2016

LGA Greater Geelong Wyndham Total Population

Source: id.com website, accessed 14 August 2017Source: vicinfuture.vic.gov.au website, accessed 14 August 2017

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13 WESTERN REGION: 20 TO 60 YOS 2011-2036

0

50,000

100,000

150,000

200,000

250,000

300,000

2011 2036 Change between 2011 and 2036

Population Age Structure M1 Corridor+ Melton: 2011-2036

City of Greater Geelong City of Wyndham Hobsons Bay City City of Melton City of Brimbank Moorabool Shire Golden Plains Shire

Source: id consulting website, accessed 14 August 2017

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14 M1 CORRIDOR + MELTON: 20 TO 60 YOS 2011-2036

0

100,000

200,000

300,000

400,000

500,000

600,000

700,000

2011 2036 Change between 2011 and 2036

Population Age Structure M1 Corridor+ Melton: 2011-2036

Total M1 Corridor Total M1 Corridor + Melton

Source: id consulting website, accessed 14 August 2017

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15 VICTORIAN GHG EMISSIONS TARGETS

Zero net emissions of GHG by 2050

Will set interim target by 2020 for 2025 and 2035

Aiming to achieve a 15 to 20% net emissions reduction by 2020

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16: ENVIRONMENTAL EFFECTS - GHG

Source: chartingtransport.com website, accessed 29 August 2017

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17 GHG EMISSIONS

Business case – reduction 2.3 million tons of GHG with project

EES – increase of 0.23% with project, increase of 0.04% without project

Without project reduction of 0.31% in vehicle emission intensity (g co2/vehicle km travelled)

VLC –Forecast additional 37,000 vehicles on West Gate Freeway in 2031 with project

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18 TRAFFIC FORECASTS

Forecasts produced by a private company

Only the outcomes available

Model is not transparent (hidden assumptions, processes,etc)

Criticisms of the model through the EES

Single distribution loop

Induced traffic – should all 6 factors be included in the model

VISTA Data and behaviours based on 2007 behaviour patterns

Strategic misrepresentation - the selective use of models and data which better makes the proponents case

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CHART 19: MOTOR VEHICLE OWNERSHIP PER 100 PERSONS 18-84: 2006-16 MAJOR CITIES

Source: chartingtransport.com website,

accessed 29 August 2017

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CHART20: MOTOR VEHICLE OWNERSHIP PER 100 PERSONS 18-84: 2006-16

Source: chartingtransport.com website, accessed 29 August 2017

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CHART 21: MOTOR VEHICLE OWNERSHIP PER 100 PERSONS 18-84: 2006-16

Source: chartingtransport.com website, accessed 29 August 2017

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CHART 22: MOTOR VEHICLE OWNERSHIP AND POPULATION DENSITY IN MAJOR CITIES: 2006-2016

Source: charting.com website, accessed 29 August 2017

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CHART 23: VEHICLE KILOMETERS TRAVELLED (VKT)

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CHART 24: VKT - MASS TRANSIT SHARE

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CHART 25: VEHICLE OWNERSHIP AND KILOMETRES TRAVELLED (VKT)

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CHART 26: RELATIONSHIP BETWEEN PT PATRONAGE AND FREEWAY TRAFFIC VOLUMES 2001-11

City Link

opens

MCW

widening

East

Link

Source: chartingtransport.com website, accessed 29 August 2017

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CHART 27: IMPACT OF FREEWAY WIDENING ON PT PATRONAGE 2011-12

Source: chartingtransport.com website, accessed 29 August 2017

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Table 2: VISTA 2012-14 Wyndham residents work related travel 18-84 year olds

Destination

Destination

Share

Destination

Groups

Rail PT

Share

Wyndham 27% 27% 2%

Melbourne 22% 51% 51%

Inner City (Yarra, Port Phillip) 9%

Inner West (Hobsons Bay, Maribyrnong, Mooney Valley)20% 0%

Eastern & Southern suburbs 6% 12% 21%

Northern 6%

Outer Western (Melton, Brimbank, 8% 10% 0%

Geelong 2% 50%

Total 100% 20%

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29: JOURNEY TO WORK DESTINATIONS 2011

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30 METHOD OF TRAVEL TO WORK: 2006-2011

Method of travel to workCity of Wyndham -

Employed persons

(Enumerated)

2011 2006

Change

Main method of

travelNumber % Western Region % Number % Western Region % 2006 to 2011

Train 8,171 10.7 11.9 4,035 7.6 10.0 +4,136

Bus 524 0.7 1.2 275 0.5 1.1 +249

Tram or Ferry 40 0.1 0.7 28 0.1 0.7 +12

Taxi 103 0.1 0.2 70 0.1 0.2 +33

Car - as driver 50,562 65.9 63.0 35,812 67.5 63.8 +14,750

Car - as passenger 4,731 6.2 5.3 3,371 6.4 5.7 +1,360

Truck 560 0.7 0.7 500 0.9 0.9 +60

Motorbike 302 0.4 0.4 248 0.5 0.4 +54

Bicycle 248 0.3 0.9 176 0.3 0.8 +72

Walked only 836 1.1 1.4 637 1.2 1.6 +199

Other 721 0.9 0.9 396 0.7 0.8 +325

Worked at home 1,912 2.5 2.6 1,230 2.3 2.4 +682

Did not go to work 6,827 8.9 8.7 5,317 10.0 9.4 +1,510

Not stated 1,157 1.5 1.8 972 1.8 2.2 +185

Total employed

persons aged 15+76,694 100.0 100.0 53,067 100.0 100.0 +23,627

Source: Australian Bureau of Statistics, Census of Population and Housing 2006 and 2011. Compiled and presented by .id , the population experts.

(Enumerated data)

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31: 2006 – 2011 METHOD OF TRAVEL TO WORK

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32: PUBLIC TRANSPORT SHARE UNDER VLCMODEL

Public transport on M1 corridor is forecast to be 14% in 2031 by VLC model

VISTA data (2012-14) indicates it may already be 20% in Wyndham

This project will decrease the potential PT share, disguising it as an increase on 2011

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Table 1: Rail Services on M1 Corridor compared with lines across Melbourne

Lines Servicing M1 CorridorNumber of rail services

Station

AM Peak

(7-9am) Frequency

PM Peak

(4-6 pm) Frequency

Williamstown 6 20.00 6 20.00

Newport 23 5.22 22 5.45

Altona 6 20.00 6 20.00

Laverton 18 6.67 17 7.06

Aircraft 13 9.23 11 10.91

Williams Landing 13 9.23 11 10.91

Hoppers Crossing 13 9.23 11 10.91

Werribee* 13 9.23 11 10.91

Wyndham Vale (RR) 10 12.00 6 20.00

Tarneit (RR) 9 13.33 7 17.14

Other Metro Services

Craigieburn* 15 8.00 18 6.67

Frankston* 14 8.57 13 9.23

Glen Waverley* 14 8.57 12 10.00

South Morang* 12 10.00 13 9.23

Sunbury (Watergardens)* 15 8.00 17 7.06

Lilydale* 12 10.00 10 12.00

Belgrave* 11 10.91 10 12.00

Ringwood 27 4.44 23 5.22

Blackburn 33 3.64 31 3.87

Alamein 7 17.14 6 20.00

Pakenham* 11 10.91 12 10.00

Cranbourne* 7 17.14 8 15.00

Dandenong 22 5.45 24 5.00

Average of the main lines 12.4 10.1 12.4 10.2

* Main Train Lines

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34: PORT ACCESS

International Ports – (Hamburg, Rotterdam) transport systems best practice target 45-50% containers transported by rail

Container storage systems – keep empty containers in the port precinct for speedy loading on ships

Problem of empty containers around inner west by road between port and container storage parks

Level of the toll and container transport viability - $30 for an empty container to be delivered

McKenzie Rd ramps are a visual blight on the river, and a potential congestion point

Exit tunnels onto the east side of river, feeding into Footscray Rd

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35: PORT ACCESS: TUNNELS TO WRONG PORT

Mr Barlow’s evidence indicated Webb dock will be the future port, Swanston Dock is the present port

Container growth forecast for Webb dock – not assisted by this proposal

Freight (>80%?) will be heading over West Gate

If Port forecasts are not met, then operators will be forced to scale back

Swanston Dock will be first part of the port to be closed, scaled back

Tunnels should have been directed to Webb dock under the Yarra

C7 - Possible to include road & rail freight access as well as Metro 2

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36: PORT ACCESS - RECOMMENDATIONS

1. Control the transport of empty containers around Melbourne by:

Identify & use best-practice, more efficient container storage systems within the Port and its environs

Flower market conversion for container storage, port operations

Banning trucks with empty containers on local roads

Use rail to carry single empty containers between distant container parks and the port (Medium term)

2. Investigation of the C7/Metro 2 option Infrastructure Vic

including rail freight tunnel into Webb dock from Newport

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37: DATA SUMMARY – EVALUATE EES

Melbourne is changing – unique amongst Australian cities car ownership per 100 persons of driving age is declining, density increasing

PT usage is booming, particularly amongst the young, and in the trips to CBD, but elsewhere as well

VKT for passenger cars is declining, even while population is increasing on the outer fringe because PT options were made available

GHG from transport will decline if we continue to pursue these policies

Melbourne Metro will speed up these trends

Expanding freeways to CBD including Citylink/WGT will slow these trends

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38: OPTIONS FOR CITY CHANGE

8 Options in Chapter 3 evaluated

Eddington Report quoted as outlining a northern route as preferred route

Business Case preferred Pathway 1 – including freeways in northern and southern corridors (WGT being southern route)

This project is said to be only the first part. Next part required in 15 years

Option C7 – rail and road tunnel from Newport to Fishermans Bend and the Port and beyond was also identified

This was described as a truly “city changing option”,

but dismissed as too expensive

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39: C7 OPTION FOR TUNNELS

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40: METRO 2 – RAIL AND ROAD FREIGHT OPTIONS

3.1km

1.1 km

2.2 km

6.9kms

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41: METRO 2 – ACCESS TO NEW EMPLOYMENT CENTRES

3.1km

1.1 km

2.2 km

6.9kms

50,00

0 jobs1500

0 jobs

30,000 jobs

Legend

Melbourne Metro

Metro 2

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42: WHAT SORT OF FUTURE?

Where is Melbourne’s transport and land use policy heading?

Balance (WDA): We need both roads and public transport projects

To create real change: incentives for public transport or for roads, not both

Investigate C7 option (Tunnels to Webb dock, Metro 2 + freight rail to Webbdock)

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43: WESTERN DISTRIBUTOR RAMPS

The Hyde St Ramps were the original Western Distributor project originally proposed by the government and taken to the election.

This assumed that trucks would be taken off the freeway, and redirected along Hyde St and Whitehall St to the port, removing them from Francis St in particular.

This route would work if Whitehall St was upgraded along its full length and Shepherd’s Bridge widened.

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44: HYDE ST/SIMCOCK AVENUE RAMPS

Currently no sound barriers on the ramps, although freeway proper is being retrofitted along the same alignment

Southern on-ramp is directed via Simcock Avenue

Dangerous access off Hyde St

Brings heaviest trucks with most dangerous loads within 100m of Scienceworks (4000 vehicles per day – Francis St)School children and families access the site 7 days a week in large numbers

Alternative route via Hyde St directly, swing under the freeway, Engineered to protect possibility of accidents near bridge structures

Only one intersection on Hyde St required

Possible to protect the heritage building on corner of Simcock Ave

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45: SIMCOCK AVENUE ON-RAMP

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46: HYDE ST – WHITEHALL ST WIDENING

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47: HYDE ST FRANCIS ST INTERSECTION AND WHITEHALL STREET DUPLICATION

Douglas Parade / Hyde St is one of only two roads that residents of Newport, Williamstown and Spotswood have to exit the area by car.

Under the current project design, the Hyde St Francis St intersection is not designed to work(LOS = D in AM and F in PM)

VicRoads indicated that they considered F LOS rating in the afternoon and D rating in the morning “not a disbenefit” of the project

It is not designed to work - encourage trucks to use the tunnels?

What about the community??

Solution: duplicate the small section of Francis St east of Hyde, and the 500 m section of Whitehall St south of Somerville Road. This is already a wide road, although only marked for one lane each way.

Result in better traffic flow from Hyde St into Francis and then onto Whitehall St.

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48: AIR QUALITY & SOUND BARRIERS

WGF section of road is highest level of traffic volume in Victoria

Heavy vehicles will be attracted to it – diesel fumes highly toxic

Noise of traffic now exceeds standards regularly – this will increase

Argument that these people have lived with that noise (and air pollution) previously therefore can do so in future is outrageous (Mr Stead)

Higher standards than normal should be applied to quality of sound barriers

Filtering of the emissions of the tunnel stack should apply

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49: CBD ACCESS: NORTH MELBOURNE RAMPS

State policy – Integrated land use transport planning – PT is preferred

Sustainability - over-reliance on cars – this is not a trend we should be encouraging – 70% of trips to CBD are on PT, this project will reduce it

Do we need Footscray Road duplication?

Tunnels emerge east side of Maribyrnong, into Footscray Road, with road Port access

Good access to Citylink (NBD / SBD)

Improved Dudley St / Wurundjeri Way intersection may work

North Melbourne Dynon Rd ramps should be deleted

Future rail access (Melb Metro) should cater for increased demand

Footscray Road to Dynon St link might be worthwhile and could be built above rail lines

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50: RECOMMENDATIONS

Short Term (0-5 years)1. Increase metro services on Werribee line with matching bus service levels

2. Ban trucks on Blackshaws Rd, Hudsons Road, Douglas Parade, & Millers Road (south of freeway), if do not originate or finish their journeys in businesses there

3. Build Western Distributor ramps with Whitehall St widening

4. Metro 2/C7 route investigation to be funded and completed by 2022

5. Port Authority to investigate an empty container storage solution within port and investigate how to implement target of 50% of all container movement by rail by 2036

Medium Term (5 to 10 years)1. Build road / rail tunnels, either along existing route or to Webb dock with PT/freight rail component

2. Ban transport of empty containers by truck outside of port area

3. Port Authority to implement empty container storage solution within port

Long Term1. Metro 2

2. Port Authority to implement increased rail movement of containers to 50% by 2031

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METRO 2: PLANNING

Infrastructure Victoria 30 year Strategy Recommenation 10.10.2. recommended that this be investigated in the next 5 years for possible completion in the 2031-2046 time frame

Supported by Mr Barlow‘s evidence

We think that the planning on this an important piece of infrastructure is essential if the M1 Corridor is be fully serviced with an alternative to car-based transport into CBD and employment centres around it, particularly in Fisherman’s Bend

Encourage the IAC to recommend to the government to allocate funds to complete an investigation. Only with this information can decisions be made, and planning for the project proceed so that it can be ready by 2031

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EXPERT EVIDENCE – DR J STONE. UNIVERSITY OF MELBOURNE TRANSPORT PLANNING

What are we doing here?

Planning for the present?

Planning for complete change?

Strategic Misrepresentation

International experience

Road pricing

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EXPERT EVIDENCE – MR D HARLEY FORMER NETWORK PLANNING MANAGER, VICROADS

VITM model for traffic forecasts

Development and use

Government owned

Open platform for use by all

Strengths and weaknesses of Zenith

Proprietary model – closed platform

Freight forecasts

Multi-modal forecasts

Induced demand

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Final Submission – Western Distributor Tunnel Project EES Process By (Dr) Pat Love, Geoff Hjorth, Marlene Monahan, Jacob Holley, Jenny Harrison

1. Achieving the Project Objectives

1.1 Why are we doing this project? (slide 3)

The EES identifies four objectives as targets that this project is designed to meet: (3)

Improve transport performance in M1 Corridor

Reduce reliance on West Gate Bridge

Improve freight access to the Port of Melbourne

Improve community amenity on local streets in inner west

All of these are worthy goals. If transport is understood in its broadest sense – road, rail and active

transport - then improving connectivity and providing transport options and building in network

resilience is important for our long-term economic sustainability and liveability. However, this

submission holds that this project of itself will not achieve all these aims. It is essentially a road

project. It is transport in its narrowest definition. The addition of cycling infrastructure is window-

dressing, and will not of itself ensure that more people of the M1 Corridor take up more active

transport options, such as walking and cycling.

The WDA presentation did not allude to any other city in the world taking these or similar steps to

solve the future problems of amenity, transport connectivity and resilience. Melbourne is not the

only city in the world with a traffic congestion problem. Is London proposing to build urban freeway

through Shoreditch to the City? Is New York building an expressway through Manhattan? Not since

Jane Jacobs defeated Robert Moses in protecting the Village. Where were references either in the

EES or in the Business Case to the successful examples of cities other than Australia’s east coast

capitals and US car-dependent mega-sprawl cities?

The short answer is, there are none.

We are in the minority in the OECD and the developed world in looking to these types of solutions in

order to build our way out of congestion, just as are also in the minority in the developed world in

trying to build clean coal power stations.

When asked can be build our way out of congestion, many experts called by the proponent gave the

view that “we need both” road and public transport. This submission will argue that it is a mistake to

say this is just one road project, and public transport will be provided by other projects. We intend

to provide you with evidence in this submission that building this road will reduce public transport

patronage, as well as reversing the trends that have been occurring in Melbourne over the last

decade. It will make those PT projects less viable.

Further, this submission argues that the IAC is being presented with a strategic misrepresentation of

the facts by WDA in the EES. This is primarily through the traffic modelling that has been done in

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secrecy, without appropriate transparency. Dr Stone will give an explanation of this phenomenon of

strategic misrepresentation, and why this EES represents an example of this phenomenon.

We submit that VLC has tailored the model to achieve the strategic outcomes that the proponent

requires, i.e. to have you believe that the outcomes are reliable, that they point to a congestion

problem that can only be solved by this project as it is, without modification. Mr Doug Harley,

former Network modelling and Analysis in VicRoads will present evidence that the Zenith model

should not be used in projects such as these precisely because of this point of transparency. No one

else is allowed to view the model to critique it, to test it against other models. Why would they do

that if they were confident of its reliability and applicability?

From your perspective, it must be so reassuring to get volumes of glossy documents full of tables of

figures and diagrams showing just how much work has been put into the detail behind the project

rationale. It gives you confidence, something to engage with. The EES gives you data about this

aspect or that, this intersection or that tunnel, which inclines you never to question the whole basis

on which it stands – the assumptions and data that has gone into the traffic modelling, and the

subsequent representation of the transport situation on the M1 corridor and West Gate Bridge.

This submission will provide you with “alternate facts”, evidence that tells a different story about the

performance of transport on the M1 corridor. We believe they are reliable indicators that point to a

changing city, new and old communities in a corridor who are using public transport in greater

numbers despite lower service levels than elsewhere, who are travelling by car less often, own fewer

cars, now and hopefully into the future.

We argue that this is not an accident but the result of decades of integrated transport and land use

planning policies in the form of Growth Areas strategies, comprehensive PSP planning by Victorian

Planning Authority, State Government plans that encouraged a more compact city, linked by public

transport – Melbourne 2030, Melbourne@5 million, Plan Melbourne and previous iterations. These

policies encouraged infill developments that increased density, and lead to transport projects such

as regional rail and extensions to the bus and tram and rail networks to new suburbs. While some

consider that it has been slow, too stop-start, one step forward two back at times, it has had an

effect which we hope to demonstrate.

We hold that proceeding with the project as it is will jeopardise these gains.

Consequently, this submission will present you with a recommendation that the original Western

Distributor project, the ramps onto Hyde St, should proceed now, with some small modifications.

We recommend that the remainder of the project be put on hold until the route of the tunnels be

re-investigated and re-evaluated against the C7 route option.

We recommend that the traffic modelling for such a re-evaluation be conducted openly and

transparently by the proponents using VITM.

We recommend that the investigation of the C7 option include freight rail to Webb Dock, public

transport in the form of Metro 2 style services, as well as road access to the Dock. As the EES itself

says in Chapter 3, this option would be “city changing”.

We make a number of other recommendations about the improving bus and rail public transport

services, increasing air quality and noise attenuation measures, and deletion of the city access

ramps, should the project go ahead in its present form.

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1.2 So why is this project being proposed now?

Infrastructure Victoria did not rate the project as a high priority in its 30 year assessment of needs.

To understand the urgency in the EES we should first understand who the proponents are.

2. Who are the Proponents? (slides 4-10) The proponent is WDA, but the EES explains that this is a made up entity of the State Government

and Transurban. (4) Indeed, Transurban came to the government with a solution to the problems of

capacity on the M1 corridor, Port access, and inner west amenity.

Transurban operate the largest toll road in Australia – Citylink- four times the size of any other toll

road in Australia. (5) Traffic volumes have grown in just about every year since completion in 2000,

apart from a short period in 2008-9 and in 2016. (See slide 6). In both cases, road works to widen or

extend the freeway were in train, most recently the Tullamarine and reworking the Bolte Bridge on-

ramps to the West Gate in 2016-17.

No other toll road in Australia approaches this toll road in volumes of traffic and therefore in

revenue generation capacity. Transurban’s most recent company report shows us the extent of this

reliance on Citylink. The comparison in slide 7 of the downturn in traffic on Citylink and other toll

roads is cyclical, and they are on the slope of another downturn. As you know, they were also going

to be the beneficiary of the East West project, now defunct, as it would pour thousands of cars into

the Citylink network starting in 2020.

While major projects are in train in other cities, notably Brisbane and Sydney, the West Gate Tunnel

project is the largest project on their horizon. Their contribution is expected to be $3.5 to 4 billion,

which they may to fund in part by issuing more shares. Unfortunately, the downturn in Citylink

revenue also coincides with the delivery of Melbourne Metro. There is no doubt this will have a

significant effect on Citylink traffic volumes. That is the purpose of the Metro rail project, to transfer

more people to mass transit style services, running down largely the same corridor as Citylink. Chart

8 notes the relationship between Metro Rail patronage and Citylink traffic volumes, over the last 10

years. The big increase in public transport occurred when traffic volumes plateaued (2005-2009), but

equally when capacity was increased on the freeway (2001, 2010) then PT patronage slows or

declines. So opening the WGT project first will be an important jump on the opposition so to speak.

However, will it work? To know this, we rely on the outputs from the VLC Zenith traffic model. The

fact that these cannot be checked against the other model, VITM, developed locally by VicRoads, is a

concern. The expert witness, Mr Doug Harley, will give evidence later that leaving such a crucial

factor to the proponent alone is not advisable. We cannot get inside the model to examine it. VLC

have not run the data through VITM to compare the outputs, as advised. If we were allowed to see

the independent report by Mr Allard, it may show that the model was appropriate, that it has the

appropriate rigour, and the assumptions are correct. However, it also may show up serious flaws in

methodology and data input into the model. As with all computer models, rubbish in rubbish out.

The decision to keep it secret clouds the proponent’s case considerably.

Why would Transurban do this now? (9) As we noted above, a number of factors come together

right now for them. This is an opportunity to shore up their position in Melbourne prior to the Metro

rail project, and the loss of the East West project. While I am not suggesting that they are being

dishonest, there is no requirement for them to use the same model in the EES and the business case.

The model used in the EES may exaggerate the traffic volumes early in the life of the project to

convince you in the course of the EES process, while relying on a different model used in the

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confidential business case. The latter may produce outcomes that are more realistic. Both may be

versions of Zenith, or indeed VITM. We argue that this could well represent a case of strategic

misrepresentation. (Slide 10)

Congestion / Road Pricing: If the project is allowed to proceed, the private toll company will become

the de facto congestion-pricing instrument on our freeways. Although the current government does

not favour the policy, Transurban holds no such qualms.

Is this what Melbourne needs? Particularly now, as we face challenges on multiple fronts including

the dual economic challenges of under-employment and affordable housing, and environmental

challenge of reducing GHG emissions.

3. Who will pay for this project?

At heart, this project is a toll road. The government will provide $1.5 billion dollars, coming

ultimately from State taxes presumably. Transurban is providing the rest ($3.5 – 4 billion). However,

they will take out debt/issue equity to pay for this upfront. The debt of course will be financed by

the income provided by the tolls. To assist them in this, the Government will allow Transurban a ten-

year to fifteen year extension on the Citylink concession agreement (tolling licence) on the whole of

Citylink. As we saw above, this means most Melbournians will contribute to this repayment plus

providing Transurban with a profit. Therefore, whether it is the State Government contribution via

taxation or the Transurban contribution via tolls, we are all paying for it. Therefore, the public need

to be confident that this project makes good long-term transport planning sense. It should be

transparent to all of us, not just the readers of the private business case of Transurban.

You, the IAC, are our instrument in ensuring that the public gains a net community benefit over time,

not just Transurban.

4. Data to evaluate the bottom line of an Environmental Effects

Statement (11)

4.0 Demography (slides 12-14) The overwhelming growth in the M1 Corridor is from the Wyndham municipality. Geelong also has a

growth contribution.

4.1 State Policies on Green House Gas Emissions and Climate Change (slides 15-17)

The State Government has recently lifted the renewable energy target (RET) to 20% of all power by

2020 and 50% by 2030. (15) This supports a policy of zero net GHG emissions by 2050. (Ref:

https://www.climatechange.vic.gov.au/reducing-emissions/emissions-targets). It will set interim

targets by 2020, for 2021-2025 and 2026-2030, but is aiming to reduce emissions by 15 to 20% in the

interim.

This project will increase GHG emissions over the no-project base case in 2031, despite assurances

made in the Business Case that GHGs in the form of vehicle emissions will be reduced by 2.3 million

tonnes annually (SBC p 6). However, the Executive Summary of Technical Report Q indicates that this

will not eventuate (p 7 of 124) (17)

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“It is estimated there would be a marginal increase in vehicle traffic emissions from the metropolitan

Melbourne road network in 2021 and 2031 under the with-project scenario compared with the no-

project scenario (0.23% and 0.04% respectively). However, the greenhouse gas intensity of the

metropolitan Melbourne road network (kg CO2-e/vehicle kilometre travelled (VKT) is estimated to

reduce marginally under the no project scenario in 2021 and 2031 (0.24% and 0.31%). The

greenhouse gas-related elements of the EES evaluation objectives for waste management and the

environmental management framework (EMF) would be met through the EPRs set out in this report.”

Transport emissions represent approximately 25% of all GHG emissions in Australia. Chart 16 shows

that these have peaked and plateaued since 2012. The latest forecasts project that these emissions

will continue to increase by 1% per annum under current BAU assumptions. Assuming that the car

fleet will convert to electric vehicles is a long way off the mark according to the car companies.

Australia has the lowest take up rate of electric cars, because the critical charging technology is not

being built. Renault Australia, who make one of these cars, recently decried the future of electric

vehicles in Australia (ref). You can therefore not assume that the 2050 scenario will be different.

Nevertheless, you must factor in the increase in traffic that this project will generate, and therefore

the likelihood of higher GHG emissions over the next 15 years at least.

4.2 Traffic Model Deficiencies: Traffic Generation Effect of the West Gate Tunnel

on M1 (slide 18) The EES states that this project will reduce the problem of congestion on the M1 and improve travel

times by up to 20 minutes (See Summary of Western Distributor Business Case, p9). This submission

argues that this project would only free up the system for a short period, before more congestion

returns. The Business Case, and therefore this EES, is based on a classic predict and provide

methodology, utilising a traffic model that remains hidden.

A number of deficiencies in the Zenith model’s four step design have already been uncovered by Mr

Tweedie on behalf of the Melbourne CC, including the single distribution looping approach instead

of the double distribution loop preferred by VITM and other models. We will not revisit this.

We contend that the model has a number of other deficiencies, including the way it treats induced

demand, and the use of 2007-10 VISTA household survey data to “calibrate” each of the four steps

of the model (based on Mr Veitch’s evidence to Westgate tunnel panel hearing).

On induced travel demand, we contend that the project will be subject to the normal induced traffic

effects, including new trip generation, over the long term. The traffic model explicitly excludes this

last category, and two others (induced land use, and changed departure time) that the Auditor

General says should be included, arguing that their effects are negligible (Technical Report A

Appendices p 19). Mr Veitch confirmed this in his presentation. VicRoads agrees with this position in

their draft position paper on Induced Traffic, published in 2011 (Induced Travel Demand, draft

position paper, Dept of Transport, Nov 2011)). While it says there are studies in the US and

elsewhere that draw the same conclusion, it does not cite these studies’ peer-reviewed references

for us to confirm the evidence.

On the other hand, the work of transport researchers Newman and Kenworthy (1999), Mees (2000)

and others in Australia, and J M Thomson (1977), Anthony Downs (1992), Robert Cervero (1998) and

others in the US, the Royal Commission into Environmental Pollution in the UK (1997) and many

others have confirmed that creating more road space, especially urban freeways, does not lead to a

less congested road system. They all include amongst the factors of induced traffic not only the

tendency for the extra road capacity to cause a shift in modes and travel patterns, but also to induce

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or generate new traffic on top of what is predicted using ordinary models. VITM includes this factor.

Until the project is run through the alternate VITM model, you will not know whether Mr Veitch’s

view is correct, or the weight of expert opinion here and elsewhere.

Even without these extra induced traffic factors included, the 2031 with project scenario predicts an

additional 37,000 vehicles per day using the West Gate Freeway section of the project compared to

the 2031 no project scenario (Chapter 11 Effects on Transport, p 11-30). In answer to my question,

Mr Veitch also confirmed that up to 2000 passengers would transfer from public transport to cars,

mostly from rail. Although the EES describes this decline as not a significant shift (11-30), it amounts

to two full trains per day. If the way that induced travel has been curtailed in this model, it may not

generate the level of traffic immediately to make the case for urgency.

Further to this, and according to Mr Veitch, the model uses the 2007-10 VISTA data to calibrate the

four steps of the model. Without being able to understand exactly how this happens, it was used to

calibrate the trip generation, the destination choice, the mode choice and trip assignment

propensity of households in each SA1, which is then used to generate traffic volumes to feed into

the system.. Why not use more recent data, such as the 2012-14 VISTA data set? This may better

reflect the significant increase in mode choice of PT in Melbourne from 2010 to now. (We will

provide more evidence around the importance of this later.)

For now, we raise the questions in the context of the strategic misrepresentation argument - the

selective use of models and data which better makes the proponents case.

4.3 The changing character of Melbourne and reliance on the West Gate Bridge

(slides 19-25) This submission argues that Melbourne is a city in transition. It is densifying, inner areas are

gentrifying, and there is a commitment in Plan Melbourne to the 20-minute city, which

translates into more local services and jobs near homes. Is it working or is it all talk?

Two measures of this are the number of cars that Melbournians own, and the distance they

travel in them each day.

Chart 19 shows that vehicle ownership rates per 100 people aged 18 to 84 have declined in

Melbourne in three consecutive Census counts between 2006 and 2016. This is unique in

Australian cities, even compared to Sydney, which has seen an increase, even though they have

lower overall rates of car ownership.

Chart 20 shows that this change is not just happening in inner city locations. This is also

occurring in places like Tarneit and Truganina in Werribee, in Mernda and Doreen in Whittlesea,

and Deer Park – Derrimut in the west. All have seen a decline in car ownership, despite huge

population increases.

Chart 21 – a map shows the picture across Melbourne in 2006 on the left and in 2016 the

amount of change over the ten years. The M1 Corridor is not alone in showing many green and

blue areas of decline. The common theme is investment in public transport options, such as the

Regional Rail in Tarneit/Truganina, new stations in Williams Landing for Point Cook, and

extensions to the rail line in Craigieburn, Mernda and Doreen, and in Cranbourne.

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New residents are taking up these options.

As well as that, the density of Melbourne is increasing due to land use planning policies applied

at least over the last decade, encouraging greater density. The combination creates a very

different picture of Melbourne going forward, when compared to any other major city in

Australia. (Chart 22)

Source: charting.com

Why is this important? This is derived from the most recent 2016 Census data. It may translate

into fewer vehicle kilometres travelled than VLC assumed. Remember that the VLC model uses

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Vista data from 2007-10 as the base assumption of trip generation. This 2016 data questions

that base. The data certainly shows that this is the case.

Chart 23 shows that VKT has been declining for a decade across all Australian cities. Mr Veitch

argued that this decline was deceptive because of the scale on the graph, and cited reasons such

as lower licensing rates for young people, and fuel price increases, which may revert. In fact, as

we have shown, there are a number of other reasons such as declining car ownership and

greater density is causing people to choose to walk, cycle and take public transport in greater

proportions, requiring fewer cars.

The assumption that it will increase lies at the heart of the traffic forecasts. Chart 24 below shows

that mass public transit has increased its share of the motorised passenger kilometres in Melbourne

since 2004-5. However, it peaked in 2011-12, according to BITRE in 2016.

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When combined with the trends in vehicle ownership however, it assumes a different picture. Chart

25 shows the increase in mass public transport’s share compared to cars in five major Australian

cities, which outstrips population growth. Recall that Melbourne is bucking the trend in terms of car

ownership and density.

In the end, Melbourne is on a very different trajectory to other cities in Australia. Are these

assumptions built into the VLC model? Is the future going to be different, or will we have more of

the same? Dr Stone will provide more evidence about this.

The result is that we may not be more reliant on the West Gate Bridge than we are now. As people

travel more in their own local area, take up jobs and opportunities locally, and take public transport

options when they are provided, their reliance on car travel will decline.

4.4 What is the likely direction in the future with further investment only in roads

on this corridor? (slides 26-34) The impact of a freeway only solution on these trends could be significant. Chart 26 / 27 shows

the history of PT patronage and traffic volumes on Citylink between 2001 and 2011. When

Citylink opened in 2011, PT patronage remained flat as Citylink grew. It reached a capacity in

2008/9, when freeway-widening works were conducted on Monash and Tullamarine. Pt grew

quickly while traffic volumes plateaued. Once opened in 2009/10, Citylink traffic took off while

PT patronage slowed. There is a pattern, and perhaps a direct relationship. Every so many years,

freeway capacity is reached. Congestion is apparent, and public transport takes off. The

implication for this project is clear. Investing solely in freeway works will result in a reduction in

or slowing in PT patronage on the M1 corridor, which is counter to the policies that produced

what is happening across Melbourne.

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Table 2 below shows the 2012-4 VISTA travel data for work related travel in the city of

Wyndham.(slide 28) It shows that 20% of travel to all destinations is by public transport (rail).

This is sub grouped into travel in Wyndham itself, Melbourne CBD, Other Inner municipalities,

municipalities in the inner west, Eastern southern, Northern municipalities, and Other Western

and Geelong. This shows that 51% of all travel for work is to the Melbourne and Inner City, and

51% of this is by rail. Although a little lower than all travel to the Inner city (60% in 2011), it is

consistent with 2011 Census data for Wyndham. (29-31)

However, the real point of this data is that it shows a higher public transport share than the 14%

that the VLC model generates (32). This is a significant difference. The largest growing

municipality in the M1 corridor is already operating at a higher level of public transport usage for

work-related travel than the 2031 project scenario generates.

Table 2: VISTA 2012-14 Wyndham residents work related travel 18-84 year olds

Destination

Destination

Share

Destination

Groups

Rail PT

Share

Wyndham 27% 27% 2%

Melbourne 22% 51% 58%

Inner City (Yarra, Port Phillip) 9% 33%

Inner West (Hobsons Bay, Maribyrnong, Mooney Valley)20% 0%

Eastern & Southern suburbs 6% 12% 0%

Northern 6% 44%

Outer Western (Melton, Brimbank, 8% 10% 0%

Geelong 2% 50%

Total 100% 20%

Source: VISTA 2012-14

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Why would this be true? Is it the use of 2007-10 VISTA data in the Zenith model, which has lower

rates of PT usage, or other factors? It is not clear, but it could lead to very real over-provision of

road capacity, when aligned with the other trends we have identified on VKT and car ownership.

Of course, provision of more roads will induce demand back to car travel. This may well be the

aim of the proponents/the freeway operators, and by keeping the model under tight security,

we will not be able to test this.

4.5 The transport capacity and performance of the M1 Corridor (slides 33) The assessment of the capacity and performance of transport in the M1 corridor should include PT

and road based options.

The much-quoted Eddington Report highlighted the significant deficit in public transport options in

the western suburbs when compared to the rest of Melbourne. While major road improvements

were suggested such as the East West link (both parts), key recommendations involved public

transport options for the western region, including lifting service levels on trains and buses.

The Table 1 below shows the number of services on the M1 Corridor and comparisons to other rail

lines in Melbourne in the peaks (7 to 9 am and 4 to 6 pm).

Table 1: Rail Services on M1 Corridor compared with lines across Melbourne (33)

Lines Servicing M1 CorridorNumber of rail services

Station

AM Peak

(7-9am) Frequency

PM Peak

(4-6 pm) Frequency

Williamstown 6 20.00 6 20.00

Newport 23 5.22 22 5.45

Altona 6 20.00 6 20.00

Laverton 18 6.67 17 7.06

Werribee* 13 9.23 11 10.91

Wyndham Vale (RR) 10 12.00 6 20.00

Other Metro Services

Craigieburn* 15 8.00 18 6.67

Frankston* 14 8.57 13 9.23

Glen Waverley* 14 8.57 12 10.00

South Morang* 12 10.00 13 9.23

Sunbury (Watergardens)* 15 8.00 17 7.06

Lilydale* 12 10.00 10 12.00

Belgrave* 11 10.91 10 12.00

Ringwood 27 4.44 23 5.22

Blackburn 33 3.64 31 3.87

Alamein 7 17.14 6 20.00

Pakenham* 11 10.91 12 10.00

Cranbourne* 7 17.14 8 15.00

Dandenong 22 5.45 24 5.00

This table shows that the other main lines in the west, Sunbury/Watergardens, Craigieburn, have

more services scheduled in the AM and PM peaks. Werribee line services need boosting to their

level to cater for the existing demand (minimum 15 per peak period), without considering the

potential demand from the forecast growth. In addition the Geelong regional rail services through

Wyndhamvale/Tarneit could be increased as recommended by Infrastructure Victoria in the next 5

to 10 years (1.3.4).

Further to this, the bus services meeting trains at stations on this line are generally at a 20-minute

frequency, or roughly, they arrive at every second train. Car parks are full to overflowing by 7.30am

or 7.45am. Catching a bus to the station is the only option but these are so infrequent that people

resort to the freeway sometimes out of convenience, but usually of necessity. Outer Metropolitan

Growth area bus services is given a specific urgent priority (0-5 yrs) by Infrastructure Victoria (1.3.2).

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If the line had two or three more services of a morning, and 4 more of an evening, and buses ran as

frequently as the trains in the peak hours, and regional rail increased by 4 services in peaks then the

recommendations of the Eddington Report would be met, for now. The transport capacity of the M1

would be improved immeasurably, and people would have an option to the freeway.

The capacity of the freeway is being stretched by population growth. It is also being stretched

because of the under-servicing by rail and bus. Addressing this issue would give us more time to

implement this project and other solutions. Implementing this project without addressing the deficit,

would provide more incentive for rail commuters to transfer to the freeway.

During construction of the project, if it goes ahead, the improvement in train and bus services is

essential. VicRoads have not responded to my request for their estimate of the delays on the

freeways caused by the road works, which will take 4 years to complete.

During the critical construction period, the EPRs indicate that they will keep all four lanes open in

each direction during the peaks, but speeds will be limited to 80 kms per hour. With 100 kms limits

now, the queueing of traffic onto the bridge of a morning extends to Point Cook turnoff on

occasions. Of an evening, the whole corridor is stop start.

The road works must lengthen travel times over the trip even more. Adding conservatively 15 mins

to what was a one-hour trip to Werribee of an evening might take 75 mins during construction, or

half an hour extra travelling each day for up to four years. A child is born, learns to walk, talk, goes to

childcare, and is completing kindergarten in that time. A parent loses half hour each day interacting

with the child, which could well be in bed by the time the parent gets home at 6.30 pm. certainly

picking up or dropping off the child at childcare is more difficult. A rail service currently takes 40

mins in either direction, which leaves 20 mins to get home, and still have 15 mins with a child.

This submission holds that should the project proceed, the project should not be implemented

without a significant upgrade of rail and bus services in the corridor.

We will later present a case for an investigation of the Metro 2 proposal be completed, as

recommended by Infrastructure Victoria, to inform a decision about the viability of a metro style

service runs from Newport to the city under Fishermans Bend.

4.6 Port Access: Which part of the Port? (slides 34-36) Rotterdam and Hamburg are two of the largest ports in Europe. They are investing or

have invested in more rail connections in an out of their ports, to keep containers to a

minimum. Hamburg has a target of 50% of containers moved by rail within 5 years. They

already have 45% on rail. Port rail shuttles and Webb Dock rail access are mentioned as

priorities by Infrastructure Victoria (13.3.1, 13.3.4) in its 30 year assessment.

The EES assumes only 10% moved by rail in this project, even though it acknowledges

that more investment in this option will be required. Does this effect the freight

assumptions for the tunnels?

The rail connection we have now is only to Swanston Dock. Mr Barlow gave evidence

that the Webb Dock is the area of greatest growth over the next 35 years. The tunnels

provide access only to Swanston Dock, which will be the first area to be discarded once

the new port in Pt Wilson is created. This is only 35 years from now.

Should we re-think the direction of the tunnels, to provide a freight rail option for the

Webb dock area? It aligns much better with the C7 option discussed in chapter 3.

Perhaps prematurely discarded by the EES.

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Such a connection would also take much of the freight off the West Gate Bridge in future

years.

If this were explored in more depth, in conjunction with an investigation of the Metro 2

study, then we will have a project that is truly significant for the Port, for Melbourne,

and for the M1 Corridor.

4.7 Do we need an inter-connected freeway system, or a connected road and rail

based transport system? (slides 38-42) What does Melbourne need now? In chapter 3, the EES assumes that other road projects in the M1

corridor are required, even on completion of this project. Is this what the city needs?

The data presented above lends a strong case that Melbourne is in transition. Land use and

transport policies over the last decade or more have resulted in behavioural shifts of seismic

proportions. The city needs an integrated road, rail and bus and cycling solution in order to continue

this trend, rather than another road-only project. Therefore, at the very least the EES

recommendations should ensure that other options for commuters, freight and business are part of

the plan in the short and medium term if the M1 corridor transport performance is to be improved.

It is the minimum position of this submission that this project must be accompanied by investment

in public transport, not only to support sustainable transport and GHG targets the state has set, but

to make sure that the project does not jeopardise the gains made already in land use planning and

transport.

5. Other transport options including various alternative modes to be

included with the project Seven practical steps can be taken to provide these alternative transport options for commuters and

business. These include short, medium and long term options. (Slide 50)

Short Term Options

More public bus services to be added during construction and retained post-construction

across the inner and outer western suburbs, enabling more commuters to access the

additional rail services without relying on their motor vehicles. (Rated a high priority by

Infrastructure Victoria 1.3.3)

o Without buses on a 10 minute frequency schedule to provide commuters with

alternatives to use of private cars on already congested roads in the inner west,

during the construction period the congestion will become continually worse. These

could be retained after the construction period if successful. This measure will lonely

work if there is more rail capacity along the M1 corridor (Werribee, Altona and

Williamstown lines). See below.

A commitment to replace the Geelong VLine services transferred to the regional rail route

with extra Metro services to be given for implementation by the end 2018.

o Following the initiative to increase buses, there needs to be more rail services on

this route to accept these new passengers. There is significant unused capacity on

the Werribee line due to Geelong VLine trains being re-routed through Sunshine.

o At least two more morning peak and four evening peak services are required.

(Although this may create congestion in Flinders St, Frankston line and other

services can be re-rerouted for a short period to assist in this critical period for

Melbourne while Metro 1 is being built).

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Banning trucks on Blackshaws Rd, Hudsons Road, Douglas Parade, & Millers Road (south of

freeway), which do not originate or finish their journeys in businesses there.

o Support for the proposal in the Hobsons Bay City Council submission to stop trucks

that do not start of finish their journeys in these local roads from using them to

avoid tolls or transport congestion.

o Recent government announcements are a positive start in this regard.

Port to investigate the target of moving 50% of all containers by rail by 2031, and the

storage of empty containers within the port area by 2027.

Metro 2 – C7 route investigation to begin asap (the much needed mass transit link between

Newport and Clifton Hill, via a tunnel connecting Fishermen’s Bend, Southern Cross Station

and Clifton Hill station), with freight rail to Webb Dock.

o Both investigations were recommended by Infrastructure Victoria (10.12.2 & 13.3.4)

o This option is a re-evaluation of the C7 route for the project in the EES.

Medium Term Options

Build road / rail tunnels, either along existing route or to Webb dock with PT/freight rail

component depending on the outcome of the Metro 2 C7 route investigation.

Banning the use of trucks to carry single empty containers between container parks and the

port.

o As per the report in The Age (5 July 2017?), there is a significant number of daily

journeys to and from the Port with empty containers.

More efficient means of storing empty containers used to top up ships within the port itself.

o If above is to be successful, then the solution to where empty containers can be

stored is essential. Much can be gained by finding an alternative solution such as

storing more containers within the port or finding a faster rail transport solution

outside the Port. Port authorities must accept that they should find a solution that

does not impose costs on the city commuters and other businesses such as this

project will do.

o Best practice in international ports is to aim for 50% of container movement by rail.

Long Term Options

Metro 2 to begin in 10 years or following Melbourne Metro subject the outcome of the

investigation.

o Bringing forward this key, city-changing project by beginning the planning for it now

will be important..

Planning to begin for the infrastructure that will allow the majority of container freight to be

carried between the port and inland ports planned for Truganina, Epping and Dandenong by

rail, where trucks can then distribute it.

o Comment: The long-term objective of shifting freight out of the Port of Melbourne

by rail to three inland ports serviced by rail predominantly is now more important

than ever. Trucks were not intended for this purpose and are not suited for it. Rail

could also deliver empty containers to and from the port on a daily basis much more

efficiently then trucks.

6. Environmental pollution monitoring of small particulates (slide 49) Expert reporting to the meeting of the Spotswood Residents Association (Dr Keogh, Qld University of

Technology, Brisbane) has highlighted the fact that environmental pollution monitoring on the

project may not include particulates smaller than 2.5 microns. This was seen to be an important

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omission, as diesel engines generate much of this pollution. Benchmarks should be established that

meet current best-practice health standards internationally. The following measures should

therefore be included:

1. Monitoring of ultrafine particles (<2.5 microns) be undertaken in conjunction with monitoring of

PM2.5 and PM10. That there be a commitment by the project to ultrafine particulate matter levels,

PM2.5 and PM10 not increasing after the project is completed, as compared to levels measured pre-

construction.

2. Monitoring stations for air quality, including for ultrafine particles, be set up at four locations in

Spotswood, West of Melbourne Road; Donald McLean Reserve; on Simcock Avenue near

Scienceworks and at the Emma McLean Kindergarten.

3. Annual particle number and particle mass inventories of motor vehicle particle emissions be

prepared for both the motorway and the on-ramp used by trucks for different vehicle types

covering the full size range of particles generated by motor vehicles (from ultrafine size (particle

number) to PM1, PM2.5 and PM10) using appropriate tailpipe emission factors and traffic data for

light duty vehicles, heavy duty vehicles and buses. (Refer method in Keogh et al. 2009, Keogh et

al.2010 & Kumar et al. 2014). This is a simple and cost effective method for quantifying and

monitoring pollution rates over time on individual road links.

7. Quality of freeway infrastructure and finishes (slide 49) Hobsons Bay City Council has highlighted the discrepancy between finishes of freeway sound walls

and other infrastructure on the Westgate, compared to those of the Eastern and East Link Freeways.

Fairness and equity dictates that the people of the western suburbs should see the same level of

finish as freeways in other parts of Melbourne.

8. Replacement of Public Open Space and protection of sensitive land

uses The replacement of public open space lost to the project should be made up by the Project so that

there is a zero sum equation between areas lost and new areas created. Sensitive uses should also

be protected, such as the kindergartens, childcare centres and pre-schools near the road. Possible

ways this could be done include:

Purchasing brownfield sites near the freeway and converting these into POS.

Rehabilitating polluted or damaged sites in the area, such as along waterways along Stony

Creek, Kororoit Creek, and along the Maribyrnong and Yarra River banks.

Childcare centres and informal outdoor recreation areas are defined as sensitive land use

areas by the EPA Victoria (2013, p. 17). A recent review of buffer distances applied

internationally to sensitive land use areas, such as childcare centres, recommended a

separation distance from the road edge of strategic routes (e.g. motorways) of at least 150m

(Wickham, 2012, p. 78).

The project requires that trucks not be permitted within 150 metres of the Donald McLean

Reserve or Emma McLean Kindergarten (3-5 yo children) and Scienceworks, measured either

from the motorway or from any local street near the two sensitive land use sites.

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9. North Melbourne / Docklands access to the CBD (slide 48) Critics of the Project, including many residents of North Melbourne, indicate that much of the extra

traffic created by the Project will be due to the provision of a new route into the CBD. This is

facilitated by the plan to redirect Wurundjeri Way to connect with the end of the freeway in North

Melbourne. This new connection will also impact on the possible regeneration of the area known as

EGate, and the rail yards in North Melbourne, by redirecting all this extra traffic through it.

If the primary purpose of the project is not to make travel into the CBD easier, but rather to ease the

congestion on the M1 for freight, then there is no need to change Wurundjeri Way at all. The

existing connection with Footscray Road could service it quite well. Those who wish to use the route

to travel into the city will have to endure this extra traffic on Footscray Road, which will discourage

some from taking this route. The duplication of Footscray Road should be dropped. Footscray Road

is an eight-lane boulevard into the city. The concept of a freeway over such a road is just

unnecessary, and only designed to feed into the CBD and Citylink.

The tunnels should emerge on the eastern side of the river onto Footscray Road, preserving the

riverbank regeneration on both sides of the Maribyrnong onto Footscray Road.

10 Hyde St Ramps (Slides 43-44) The Hyde St on ramp is designed currently to use Simcock St. This is a small local road near

Scienceworks.

This is a highly trafficked area by families and school groups on a daily basis.

Trucks passing within 150 meters of the facility would not be an acceptable outcome.

Re-designing this ramp to pass either under or over the freeway to join up with the off ramp

would create only one intersection on Hyde St. This will have far less impact on traffic along

Hyde St and Douglas Parade.

11 Hyde St Francis St intersection and Whitehall Street duplication

(slides 45-47) The Hyde St Ramps were the original part of the Western Distributor project originally

proposed by the government and taken to the election.

This assumed that trucks would be taken off the freeway, and redirected along Hyde St and

Whitehall St to the port, removing them from Francis St in particular.

Douglas Parade and Hyde St is only the second route or two that residents of Newport,

Williamstown and Spotswood have to exit the area by car. Williamstown Road will be

congested most mornings and evenings, with or without the project. Hyde St is the only

route that actually works well.

Under the current project design, the Hyde St Francis St intersection is not designed to work.

VicRoads, when asked, indicated that they did consider the F LOS rating in the afternoon and

E rating in the morning “a disbenefit” of the project. In other words, it is not designed to

work, and will encourage trucks to use the tunnels.

If implemented this will result in most residents of the peninsula south of the freeway

having no workable exit to the north. The tunnels do not benefit these residents, as they are

accessible only from Millers Road.

The solution is to duplicate the small section of Francis St east of Hyde, and the 500 m

section of Whitehall St south of Somerville Road. This is already a wide road, although only

marked for one lane each way.

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The result would be a better traffic flow from Hyde St into Francis and then onto Whitehall

St. Trucks and residents could access Footscray Road to go to the port, into the city, or to

other destinations. This would truly reduce reliance on the West Gate Bridge for these

residents, and would ensure all trucks stay out of local roads, including Francis St.

It may result in some trucks avoiding the tunnel tolls, but is this a small price to pay for a

workable overall solution.

12 Conclusion (slide 50) The submission concludes that the EES has been presented in a way that precludes most of us from

accessing the data we need to test whether the project meets its objectives.

Transport performance on the M1 corridor has been improving markedly over the last

decade, although traffic congestion on the freeway will remain a reality, with or without the

project.

The project will ensure vehicle traffic increases on the corridor, and GHG emissions will rise,

compared to the case without the project.

The project as it stands will impact the patronage on public transport, perhaps by as much as

6% (14% v 20%) , and may well be designed to do so, to ensure their tolls are collected to

support the debt and make Transurban a profit.

The project will result in a private company able to reap the benefits of a de facto

congestion-pricing regime on all three major transport corridors for a further 10-12 years.

The Government, meaning that the public will be deprived of these funds to invest in public

transport options. The result is that we will be paying for this, and not reaping the benefits.

A proper investigation of the C7 option in the EES should be recommended by the IAC, so

that we can evaluate the alternative cost benefits of a Metro 2 and rail freight tunnel option

into Webb Dock, Fishermans Bend and beyond. Infrastructure Victoria recommends both

studies be done in the next 5 years. The answers are critical for this project, which if it goes

ahead in its present form, will make the others more marginal.

In the meantime, the Western Distributor option of the ramps could be implemented

immediately. It would involve constructing the Hyde St Ramps with a minor design alteration

to the on-ramp and widening and duplication of a small part of Francis St and Whitehall St to

Somerville Road.

If the tunnels are recommended, then the public transport improvements outlined in section

4.3 and section 5 are important and necessary, with the following provisos:

o The option of CBD access ramps should be dropped from any proposal.

o The duplication of Footscray Road should be dropped. An eight-lane boulevard into

the port and the city already exists. The concept of a freeway over such a road is just

ridiculous.

o The tunnels should emerge on the eastern side of the river onto Footscray Road,

preserving the riverbank regeneration on both sides of the Maribyrnong onto

Footscray Road.