Part 2 Chris Standen: New M5 EIS fails to meet requirements

(Ed: The New M5 is being assessed under State Significant provisions of the NSW Environment, Planning and Assessment Act. Under this law, the Department prepares  the Secretary’s Environmental Assessment Requirements (SEARs). You can read a full copy of the SEARS here.

This is the second part of  Transport planning and modelling specialist Chris Standen’s  four part submission. In this part, Standen analyses the SEARS and finds the EIS does not meet a number of requirements. It’s worth noting that some local Councils and other experts agreed with Standen that the M4 EIS requirements were not met by the Westconnex EIS.  The failure to meet requirements should be a serious matter that if allowed to pass without examination undermines the entire assessment process. No decision has been made on the M4 East project yet.

( If you have missed the first part of his submission, read it here.)  

The submission has been presented by the People’s M5 EIS is a format that suits wordpress. The full submission will be uploaded later on the People’s M4 EIS. You can use this and other submissions on the People’s M5 EIS to develop your own response. 




The SEARS provide for  an analysis of feasible alternatives to the carrying out of the proposal and proposal justification, including:

  • an analysis of alternatives/options considered, having regard to the proposal objectives (including an assessment of the environmental costs and benefits of the proposal relative to alternatives and the consequences of not carrying out the proposal), and whether or not the proposal is in the public interest,
  • justification for the preferred proposal taking into consideration the objects of the Environmental Planning and Assessment Act 1979,
  • details of the alternative ventilation options considered during the tunnel design to meet the air quality criteria for the proposal,
  • details of the short-listed route and tunnel options from the tender process and the criteria that was considered in the selection of the preferred route and tunnel design, and staging of the proposal and the broader WestConnex scheme, and in particular access to Sydney Airport and Port Botany and improved freight efficiencies.

Standen’s finding: FAIL 

Comment: The EIS does not include cost-benefit analysis, modelling, or any other objective analysis of feasible alternatives. Only cursory descriptions are provided.

No alternative staging strategies are described or objectively assessed. Continue reading


Transport Planning expert Chris Standen identifies major flaws in New M5 EIS – Part One

Chris Standen is a Transport planning and modelling expert.  He has prepared this submission in response to the EIS for the New M5.  His submission will be published in four parts. Standen provides many important reasons for not supporting the project.  Draw on his ideas to prepare you own submission

  1. The EIS does not comply with the Secretary Environmental Assessment Requirements (SEARS).
  2. There are major issues with the Traffic and Transport Assessment. There is insufficient information about the modelling inputs, assumptions and methodology for the forecasts to be independently verified. There is no sensitivity analysis of key assumptions.
  3. The social and environmental impacts described in the EIS are unacceptable and far outweigh any benefits of the project. Because of flaws in the modelling, the actual impacts are likely to be even greater than those forecast.
  4. The project does not meet the project objectives.
  5. Many of the project objectives, such as congestion relief, could be met through better management of demand on the existing road network, e.g., through reform of road pricing. The corridor already has an extensive and high capacity road network; there is just too much demand at present for it to operate effectively. Adding more capacity will not lessen this demand; it will only serve to increase it.
  6. A claimed benefit of the project is that daily traffic on the existing M5 East would reduce by 20-40 percent due to the new tolls. If it is acknowledged that tolls alone can be effective in meeting the main project objective (reducing congestion), then what is the rationale for adding more capacity
  7. The project makes little sense from a transport planning and policy perspective. The role of motorways is to allow traffic to circumvent densely populated areas. For radial transport into and out of urban centres, mass transit is more efficient and economical, and has less impact on the human population.
  8. The project is not in the public interest. It will be used by less than 1% of the NSW population each day. The rest of the population will pay dearly in terms of higher traffic impacts, poorer air quality, and state and federal taxes being diverted from public transport and other more worthy causes?
  9. The project has a high financial risk. The flaws and optimistic assumptions in the traffic modelling mean that toll revenue is likely to be significantly lower than forecast. AECOM has a history of providing over-optimistic traffic forecasts for toll roads, resulting in previous financial failures (e.g., Clem7).
  10. The average daily travel time in Sydney has been stable at about 80 minutes per person for decades, while the average trip distance has increased substantially (see graph below). In this time, billions have been spent on tollways. Travellers are spending more than ever on tolls, yet are not spending any less time travelling. Time:Distance travelled StandenThe higher speed of tollways has simply encouraged people to move further from work, drive more, and make longer trips than before, for example, visiting shopping malls instead of local shops. It has made road more attractive than rail for freight.
  11. This predict and provide approach to transport planning has been a failure, and is being abandoned by advanced nations. In a city of 5 million people, we can never provide enough road capacity to enable everyone to live as far from work as they like, and drive wherever and whenever they like in free flowing traffic.


The rest of this submission is in four Section. This post covers only the first section which  describes general issues with the EIS, the project and the broader WestConnex scheme (Section 1). The following sections will deals with non-compliances with the SEARs (Section 2), non-compliances with the project objectives (Section 3), and major issues with the Traffic and Transport Assessment (Section 4).  Continue reading


Previous chapter: Critical State Significant Infrastructure declaration information

WestConnex New M5 – Revised SEARs

hi-res pdf: WestConnex New M5-Revised SEARs.pdf

Section Pages
1 Introduction 1-1
1.1 Project overview 1-1
1.2 Project location 1-2
1.3 Project features 1-2
1.4 Project benefits 1-9
1.5 Purpose of this environmental impact statement 1-9
1.6 Structure of this environmental impact statement 1-9
2 Assessment process 2-1
2.1 Approval framework 2-1
2.2 Environmental planning instruments 2-5
2.3 Other NSW legislation 2-6
2.4 Commonwealth legislation 2-7
3 Strategic context and project need 3-1
3.1 Strategic planning and policy framework 3-1
3.2 National strategic planning and policy framework 3-10
3.3 Why the project is needed 3-13
3.4 Business Case and economic appraisal 3-19
3.5 Project objectives 3-20
3.6 Summary 3-21
4 Project development and alternatives 4-1
4.1 History of the M5 East Motorway and WestConnex 4-5
4.2 Strategic alternatives 4-8
4.3 Motorway options 4-20
4.4 Eastern interchange options 4-31
4.5 Preferred motorway alignment 4-36
4.6 Design development of operational ancillary facilities 4-36
5 Project description 5-1
5.1 The project 5-2
5.2 The completed project 5-4
5.3 Project construction and operational footprint 5-4
5.4 Western surface works 5-23
5.5 Tunnels 5-45
5.6 St Peters interchange 5-65
5.7 Local road upgrades 5-81
5.8 Motorway operational ancillary infrastructure 5-113
5.9 Landfill closure infrastructure 5-146
5.10 Property access and acquisition 5-153
5.11 Urban design and landscaping 5-154
6 Construction work 6-1
6.1 Construction strategy 6-1
6.2 Construction program 6-2
6.3 Construction footprint 6-3
6.4 Construction methodology 6-13
6.5 Construction activities 6-15
6.6 Traffic management and access 6-70
6.7 Construction workforce and works hours 6-78
6.8 Plant and equipment 6-84
6.9 Construction noise attenuation 6-89
6.10 Construction waste management 6-90
6.11 Construction resource use 6-93
7 Consultation 7-1
7.1 Community and stakeholder engagement overview 7-2
7.2 Consultation objectives 7-4
7.3 Consultation process and activities 7-4
7.4 Summary of issues raised 7-22
7.5 Design considerations in response to early feedback 7-62
7.6 Future consultation 7-65
8 Overview of environmental issues 8-1
9 Traffic and transport 9-1
9.1 Assessment methodology 9-3
9.2 Existing environment 9-19
9.3 Assessment of potential impacts 9-52
9.4 Environmental management measures 9-148
10 Air quality 10-1
10.1 Assessment approach 10-3
10.2 Construction air quality assessment methodology 10-15
10.3 Alexandria Landfill air quality assessment methodology 10-19
10.4 Operational air quality assessment methodology 10-21
10.5 Existing environment 10-41
10.6 Assessment of air quality impacts during construction 10-64
10.7 Assessment of air quality impacts during Alexandria Landfill closure 10-64
10.8 Assessment of air quality impacts during operation 10-69
10.9 Assessment of cumulative impacts 10-179
10.10 Environmental management measures 10-189
11 Human health 11-1
11.1 Assessment methodology 11-1
11.2 Existing environment 11-5
11.3 Assessment of potential impacts 11-10
11.4 Environmental management measures 11-39
12 Noise and vibration 12-1
12.1 Assessment methodology 12-2
12.2 Existing environment 12-27
12.3 Assessment criteria 12-29
12.4 Assessment of potential impacts 12-46
12.5 Environmental management measures 12-96
13 Land use and property 13-1
13.1 Assessment methodology 13-2
13.2 Existing environment 13-2
13.3 Assessment of potential impacts 13-37
13.4 Environmental management measures 13-72
14 Visual impacts and urban design 14-1
14.1 Assessment methodology 14-2
14.2 Existing environment 14-9
14.3 Assessment of potential impacts 14-31
14.4 Environmental management measures 14-82
15 Social and economic 15-1
15.1 Assessment methodology 15-2
15.2 Existing environment 15-7
16 Soil and water quality 16-1
16.1 Assessment methodology 16-2
16.2 Existing environment 16-13
16.3 Assessment of potential impacts 16-33
16.4 Environmental management measures 16-55
17 Contamination 17-1
17.1 Assessment methodology 17-2
17.2 Existing environment 17-7
17.3 Assessment of potential impacts 17-25
17.4 Environmental management measures 17-35
18 Flooding and drainage 18-1
18.1 Assessment methodology 18-1
18.2 Existing environment 18-3
18.3 Assessment of potential impacts 18-15
18.4 Environmental management measures 18-33
19 Groundwater 19-1
19.1 Assessment methodology 19-1
19.2 Existing environment 19-12
19.3 Assessment of potential impacts 19-31
19.4 Environmental management measures 19-67
20 Non-Aboriginal heritage 20-1
20.1 Assessment methodology 20-2
20.2 Existing environment 20-6
20.3 Assessment of potential impacts 20-31
20.4 Environmental management measures 20-50
21 Biodiversity 21-1
21.1 Assessment methodology 21-3
21.2 Existing environment 21-15
21.3 Assessment of potential impacts 21-45
21.4 Environmental management measures 21-59
22 Greenhouse gas 22-1
22.1 Assessment methodology 22-1
22.2 Existing environment 22-3
22.3 Assessment of potential impacts 22-4
22.4 Environmental management measures 22-19
23 Aboriginal heritage 23-1
23.1 Assessment methodology 23-2
23.2 Existing environment 23-7
23.3 Assessment of potential impacts 23-11
23.4 Environmental management measures 23-14
24 Resource use and waste minimisation 24-1
24.1 Assessment of potential impacts 24-1
24.2 Environmental management measures 24-19
25 Climate change risk and adaptation 25-1
25.1 Assessment methodology 25-1
25.2 Existing environment 25-3
25.3 Assessment of potential impacts 25-7
25.4 Environmental management measures 25-8
26 Hazard and risk 26-1
26.1 Assessment of potential impacts 26-1
26.2 Environmental management measures 26-29
27 Cumulative impacts 27-1
27.1 Nature of cumulative impacts 27-1
27.2 Assessment methodology 27-2
27.3 Existing and proposed projects 27-2
27.4 Cumulative impacts of WestConnex component projects 27-8
27.5 Cumulative impacts of nearby projects 27-13
27.6 Management of impacts 27-15
28 Sustainability 28-1
28.1 What is sustainability? 28-1
28.2 Sustainability policy framework 28-1
28.3 Sustainability management on the project 28-14
28.4 Ecologically sustainable development 28-15
29 Environmental risk analysis 29-1
29.1 Environmental risk analysis process 29-1
29.2 Preliminary environmental assessment 29-2
29.3 Assessment of the key issues identified in the SEARs 29-2
29.4 Risk analysis summary 29-3
30 Summary of environmental management measures 30-1
31 Project justification and conclusion 31-1
31.1 Project justification 31-1
31.2 Conclusion 31-9
32 References 32-1
33 List of tables 33-1
34 List of figures 34-1

Next chapter: Vol 1A 00 Executive summary ToC certification and glossary

Vol-2A App-A-to-App-C-SEARS-Environmental-Planning-and-Assessment-Regulation-2000-Part-3-of-Schedule-2-checklist-Geological-Long-Section

Chapter: Vol 1A Chapter 06 Construction work

Appendix Vol 2A App A to App C SEARS, Environmental Planning and Assessment Regulation 2000, Part 3 of Schedule 2 checklist, Geological Long Section

Hi-res pdf: New M5 EIS Vol 2A App A to App C.pdf

Next appendix: Vol 2A App D Properties affected by acquisition