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


How to make a submission to the New M5 East

The New M5 EIS was published by the NSW Department of planning on November 27, 2015. The end of the exhibition period and the current deadline for submissions is January 29, 2016. Currently the Greens and community campaign groups are pushing for an extension to this deadline which would make it extremely difficult for Councils, groups and individuals to prepare an adequate response to the massive EIS over the Summer holidays. The EIS is massive because there are thousands of potential risks to sustainable transport for Sydney, the health and safety of communities and the survival of species and habitat.

This link tells you how to make a formal submission to the EIS. You will note that the Department promises to publish a list of submitters with their suburb and submission with attachments. In relation to the M4 East EIS this has turned out to be a lie. Despite an explicit undertaking this has not been done. Instead nearly 4000 submissions have been dumped in 60 big PDFs that are not even searchable. The People’s M4 East is currently attempting to get Brent Devine, planner in charge of the M4 EIS to meet this obligation.

If you are making a submission directly to the Department of Planning for the New M5 EIS make sure you include this statement: “I make this submission on the understanding that you will publish a list of submitters including my name, suburb and submission.”

The People’s New M5 EIS will be publishing lots of material that will help you produce your submissions. You can make more than one. MPs and community groups such as the Westconnex Action Group will also be preparing submissions that you can adopt and add your own comments.

We welcome contributions and ideas.  You can send them to If you have skills in environmental science, transport planning, heritage, community planning, sociology, economics, maths or accountancy, health work, journalism, editing, internet or multimedia production, photography, interviewing, transcribing  or any other relevant occupation or interest, please consider assisting us in reading sections of the EIS and providing summaries of key issues, critical analysis and research.