Sydney Harbour Tunnel
Environmental Impact Statement

Educational Video



Video Production:

University of Sydney Television Service

Produced and Directed by John Moyle

Written and Devised by Sharon Beder

Video available from: Evelyne Tait,
University of Sydney,
NSW 2006, Australia
fax 61-2-351 2560
telephone 61-2-351 2651

Video runs for about 35 minutes and incorporates interviews and news footage with visual material of the area, traffic flows and the construction of the tunnel.


themes covered in the video

Who makes the final decision, who is involved in the decision-making process and how much influence do various parties have on the process?

specifically - Who decided an EIS was necessary? Who was responsible for compiling the EIS? Who made submissions on it? What impact did those submissions have? Who assessed the EIS? What impact did that assessment have. Who was the determining authority? Was there any right of appeal? Was there any political influence on the final decision? What was the purpose of the 1987 Harbour Tunnel Act?

How is the scope of an EIS decided and what is covered in an EIS?

specifically - What matters were included in the EIS? To what extent was the need for a tunnel addressed? To what extent were wider transportation and planning issues addressed? Were alternatives considered in the EIS? What was required by the legislation to be included? What was required by the Department of Environment and Planning?

To what extent can bias creep into an EIS when it is commissioned by the proponent of a project and are there mechanisms to correct it?

specifically - What assumptions were made in the EIS? Were those assumptions reasonable? How did EIS predictions and cost/benefit figures differ from those of other experts? Why do experts differ? To what extent did assessment of the EIS correct any biases?

How do EIS's fit into the whole Environmental Impact Assessment process and into environmental planning in general?

specifically - What steps were taken from project conception to approval? To what extent did the EIS address other planning instruments such as the City of Sydney Plan, the North Sydney Plan, the Metropolitan Strategy for the Sydney Region and the Centres Policy?


the people interviewed for the video

Mr Liam Bathgate, Public Affairs Manager, Sydney Harbour Tunnel Transfield-Kumagai Joint Venture. These are the people who are responsible for designing, financing and constructing the Tunnel.

Emeritus Professor Ross Blunden, foundation Professor of Traffic Engineering, University of New South Wales.

The Hon. Laurie Brereton, Minister for Roads at the time of the preparation of the EIS.

Ms Jenny Corner, spokesperson for Save Our Sydney, North Shore resident. Save Our Sydney no longer exists but it was formed to oppose the Tunnel.

Mr Jim Donovan, Action for Public Transport, University of Sydney. Action for Public Transport is opposed to the Tunnel.

Mr Alan Finlay, Manager Transport Policy,NRMA (NSW Roads and Motorists Association). The NRMA lobbies government for increased funding for roads and supports the Tunnel.

The Hon Nick Greiner, Leader of the NSW Opposition during the preparation of the EIS and Premier of NSW during construction of the Tunnel.

Dr John Gerofi, Enersol Consulting Engineers, Engineering consultant. Dr Gerofi conducted the North Sydney Municipal Council Inquiry on behalf of the Council.

Professor David Hensher, Director, Research Centre, Graduate School of Management and Public Policy, University of Sydney. Professor Hensher is an expert in transport economics

Dr Alan Jones, Research Scientist, Head of Division of Environmental Science, The Australian Museum. Dr Jones is an expert on marine ecology.

Mr Bruce Judd, Manager, Tunnel Project, Harbour Tunnel Group, Dept of Main Roads, DMR (the DMR is now the Roads and Traffic Authority, RTA). The DMR supported the Tunnel.

Mr Ted Mack, MP for North Sydney, then Mayor of North Sydney. Mr Mack is opposed to the Tunnel and his Council ran a public inquiry into the Tunnel.

Ms Caron Morrison, spokesperson for Coalition for Urban Transport Sanity. The Coalition for Urban Transport Sanity is opposed to the Tunnel.

Mr Alf Neilson, Director, Wargon Chapman Partners, Wargon Chapman were engineering consultants to Transfield-Kumagai Joint Venture.

Mr Richard Smyth, Richard Smyth Planning Consultants Mr Smyth was Director of the Department of Environment and Planning at the time.

Professor John Toon, Department of Urban & Regional Planning, University of Sydney. Professor Toon is an expert in planning and environmental law.

The Hon. Neville Wran, Premier of NSW at the time the EIS was prepared.

Dr Dennis Zines, Principal, Manager, Environmental Projects, Sinclair Knight & Partners (EIS consultants). Sinclair Knight & Partners were not consultants to the Tunnel but the actual EIS consultants declined to appear in the video.


Main Video Transcript

The concept (view video)

Judd: The Roads & Traffic Authority's involvement with the Sydney Harbour Tunnel really goes back to about the late 1970s. At that stage it was known that a second harbour crossing was needed.

Neilson: About 6 years ago now we were approached by a guy who was an old friend of the company's who, with some of his associates, had an idea for a tunnel and they came to us with a route marked up on some road maps really and we took that concept and developed it into what we thought was an engineering solution to problem that we recognised. In about the end of 1985 we took our proposal to the Transfield constructions and they immediately seized on the opportunity. They in turn invited Kumagai-Gumi to participate.

Judd: The Roads and Traffic Authority reviewed that project, reviewed the costing of the project and finally accepted that that should be the project that we should proceed with.

Wran: It's at a cost which we think the motorist in this state can afford. We think its environ-mental impact is minimal and from an engineering point of view we are confident that its practical.

Brereton: Well, certainly we've got to go through all of the environmental processes. The laws of this state will be fully complied with. I am extremely confident that it will be built and that we'll start work on it before the end of next year.

Bathgate: What would happen if nothing were done basically would be that traffic levels on the bridge would continue to increase until by the year 2000 you are looking at traffic levels of about 230,000 plus on an average week day and that would translate into a peak period which extended from 12 to 13 hours a day. In other words not really clearing till fairly late in the evening and that would just mean that the congestion across the bridge would basically set in, that there'd be very little effective communication between both sides, enormous costs in fuel and transport usage and just a very deficient method of communication.

Blunden: A lot of peak spreading is natural but quite apart from that there's not much lost in scheduling your journey making to get the best utilisation of a very expensive facility. And of course whilst this is all happening public transport becomes relatively more attractive. People ask themselves whether they are living in the right place or working in the right place and so you get changes in the land use patterns.

Finlay: We felt that there was a real possibility of economic downturn for Sydney if congestion on the Bridge stayed the way it was. We considered it was really starting to effect business.

Mack: Congestion is actually an excellent thing because it is the main means of control, in fact it is the only means of control. It is an interesting thing throughout the world that when people do anything to increase the average speed of cars which interestingly enough is about 16 km/hr in most cities in peak hours. If you do anything to increase that speed, right, then simply more cars come till the level falls again to 16 km/hr. It all seems to work on a public acceptance level which is pretty common the world over. I know its often not a very publically acceptable argument, but really you don't have to do anything about the road problem. You just leave it the same and let congestion determine the shape of the city. Because if there's enough congestion around the North Sydney area a new business area will created at Hornsby, which is in fact what's happening.

Blunden: Politicians are well aware that their voting public are addicted to motor cars and paranoid about congestion and to dangle a carrot to get rid of it, my main claim is that you won't get rid of it, there'll be more. What you're going to do is convert the present bottle neck, and the bridge is a bottle neck, into a bigger bottle neck.

 

The Environmental Impact Statement (EIS) (view video)

Smyth: The EIS process consists of a number of parts. The first part is a concept development of a project and the preparation of an EIS. The EIS is usually prepared as the project is designed and problems are solved and an EIS produced. The EIS is intended to provide the whole basis for the project; all of the issues, the alternatives, economic, social justification for a project. Its meant to tell the community why the project's being built, how its being built, what its for, what its going to do; what the advantages and disadvantages of the project are and what all the impacts both positive and negative are.

Zines: Initially we would ascertain what the proponent wants to do and we would work out the legislative framework. We would then consult with, if it was a NSW matter we would consult with the Department of Planning and in other states or the Federal arena a similar sort of body, to ascertain the guidelines; what has to be studied in looking at the project.

Toon: Essentially, the Director of the Department of Planning issues a set of concerns that have to be covered and have to be dealt with. Partly that has been built up by experience, partly by a recognition that certain kinds of activities have certain externalities or consequences so they might say that these are the particular items that have to be referred to.

Zines: Well, the proponent quite often needs advice on the legislative and planning side of it. Whether he needs a review of environmental factors or an EIS, how much time it will take, what departments he has to consult with, what are the rules and regulations he has to meet. So the primary consultant would look to managing this documentation for him, carrying out the studies, hiring consultants, writing briefs, quality control, making sure the document is in good shape when it goes to the public.

Jones: A lot of EIS work has to be done to a deadline. It means there is very little time available. We know that ecosystems change a good deal through time. There are seasonal phenomena, there are annual phenomena, there may be floods. There may be recruitment events. If you only have time to go and sample once then you are most unlikely to be able to pick up the sorts of range of variations, the way we talk about it, in time.

Zines: How can we prepare an EIS in less time than it takes to gather scientific evidence and so it really...probably the answer to that is that EIS's aren't really scientific documents in the real sense. They need to be based on scientific information and I think the answer to that is that it is very important to qualify within your document exactly what the data is you have and what sources they were. And in defining that sort of data it puts some sort of validity on how far you can predict beyond there.

One has to remember that certain investments have a certain time frame, what they call a window of opportunity, whereby if you don't proceed at that stage then the economic circumstances are not as favourable at a later time.

Morrison: Another problem with Environmental Impact Statement is that there is no requirement for them to do an environmental audit after. That is a commitment that they have made in the Environmental Impact Statement may not be adhered to and how do you tell? Now if the Environmental Impact Statement was prepared in a fashion that the impacts were quantified and could be checked at regular intervals afterwards then maybe we'd be able to take the Environmental Impact Statement with a little bit more credibility.

Predictions in the EIS (view video)

Judd: Traffic projections were done initially by the proponent. They employed consultants to do this. They based it on historical records. From memory the traffic growth on the Sydney Harbour Bridge from the order of 1965 to about 1975 was about 3%. Then that falls off somewhat from there on to about 2%. The figures that the consultants came up with was for a traffic increase of about one and a half percent. Our people reviewed this. We slightly lowered what their projections were and at the moment the traffic projections that we are looking at now is approximately compounding at about the order of 1.2%.

Hensher: The traffic projections were undertaken by the Roads and Traffic Authority based on data that was very very old indeed. In fact a lot of the data they used was something like 10 years old and they updated this with some most unusual assumptions like the growth in traffic, the assumptions on how operating costs increasing through time, how public transport fares are changing through time. These are all very important parameters. If one looks at the land-use strategies and the growth of jobs and so on, they are not taking place in the locations where this traffic is claimed to be going to. Where the growth is occuring is in directions that would not benefit someone who uses the Tunnel.

Neilson: Our recent experience with our actual traffic as compared with our projections has not been very good. There has been less cross harbour traffic, particularly in the direction that's paying tolls than what we had projected and the reason for this I think is two-fold. One is that the resistance to paying a higher toll may have been higher than we expected. But I think more importantly is the general economic conditions and the price of petrol, the difficult times that we are experiencing at the moment.

Bathgate: Remember they are long term forecasts. We're into the tunnel construction and these are predicated on close to a 35 year run so over the longer term some of those swings and bumps will probably even out.

Toon: I think those projections were used because they supported the need for a tunnel.

Jones: The overall benefit/cost ratios that were looked at for the Sydney Harbour Tunnel - in the EIS from memory I think the joint venture came up with a figure of 1.2. That was questioned, criticised by the Director of the DEP. They came up with figures that I've read through recently of about .78. We then carried out quite extensive benefit cost ratios ourselves and the sensitivity analysis that we did brought in figures between 1 and 1.5.

Smyth: When the cost benefit analysis didn't produce a benefit that was high enough one of the variables, a key variable in the equation was actually doubled in its value. In that way the DMR managed to get a cost benefit analysis that looked respectable even if it left a lot to be desired.

Hensher: Coincidentally at that time I had been asked, not by any of these organisations, but by the Victorian Roads and Traffic Authority, to provide some guidelines on the new dollar values that should be placed on travel time savings. I came up with a figure that was roughly twice what was currently in practice. Since something like 60-70% of time savings or should I say 60-70% of the benefits of road investments are time savings if you double your value of time savings you can have a major impact on the net benefit, the outcome that is. My figures were only suggestions but at the time Laurie Brereton who was the Minister for Roads, when he heard that my new values would actually double time savings benefits, it was suggested they use them. Consequently we noted a 70% increase in net benefits.

Bathgate: The cost benefit ratio achieved, is it too low? I don't believe so, particularly taking into account the fact that this is not a project which is making a drain on the global borrowing facility of the State's finances.

Jones: Well our findings for the Review Committee was that the initial marine biological work done did have some failings. Indeed they failed in fact to describe the environment which is one of the requirements for Environmental Impact Statements. For example, there was no direct studies and empirical data of the communities of animals that live on the bottom of the harbour where the Tunnel was to be built. So that there was dependence on work done further up the Harbour in different circumstances and we thought that was not really adequate.

The question of bias (view video)

Hensher: There is always the risk that the consultant hired to undertake the cost benefit study or the Economic Impact Statement has already been advised by the client what is the expected outcome and they will rationalise with their information to try and satisfy that.

Mack: Most people would like to see Environmental Impact Studies as fair as possible and to be a genuine evaluation of a project in all its aspects. When it is the proponent that prepares it obviously they're going to downplay or minimise all the problems.

Bathgate: In the first place its a bit of a cheap shot I think. Really just saying `Well its biased' doesn't really get you anywhere. You have got to examine an EIS critically, have a look at it, and then relate what is studied to the effectual knowledge in the area and then make statements on the basis of that. In the case of our EIS it was conducted by us, sorry for us, by an independent consultant, who's got their own reputation on the line.

Zines: The consultant is employed by the proponent to actually assist him in preparing his EIS and the EIS supports a development application. Its a supporting document amongst other documents that go towards the proponent's case for his development being considered favourably.

Smyth: When the EIS is produced it is exhibited and that's the opportunity for the community and government agencies and councils to review the EIS and make their submissions to the proponent and Department of Environment and Planning or the Department of Planning gets a copy. When that is completed the report goes to the determining authority or the proponent authority and it assesses all of the submissions, that report if there is one, the EIS and then decides whether or not the project will proceed.

Toon: You will get effective scrutiny when its out in the public arena. In the end it doesn't pay - now I don't think there are many consultants who would deliberately use data that was either known to be inaccurate or known to be obsolete or known to be false.

Smyth: The Department of Planning, or Environment and Planning as it was then, is responsible for the administration of the Environmental Impact Assessment process, seeing that EIS's are done properly, evaluating EIS's, maintaining standards of EIS production, assessing those and reporting appropriately to government.

Our recommendation was that the project shouldn't proceed in the form it was in at that time until the alternatives had been evaluated and a number of other matters had been addressed.

Neither the Department nor I in particular were very popular about an assessment report that was critical of a project that was being driven by an ambitious and fairly high profile minister.

Brereton: The DEP, like so many other departments, have put forward a view. That's a view that's contested very strenuously by the Department of Main Roads.

Scope (view video)

Jones: And so this leads me to one of the other problems of EIS procedure and that is that every project is considered isolated from all others and one of the things that we are concerned about is the problem of cumulative effects so that any one of which.... Any one project may not have a serious effect but if you add them up over a period of time you wind up perhaps with very serious effects.

Zines: More often than not, if we talk about the broader issue of sustainable development then I think you can say very clearly that Environmental Impacts do very little at present to contribute to sustainable development. They're small isolated cases that fit into a whole picture.

Morrison: Chiefly my interest at the moment is in the low level of air quality in the Western region of Sydney; the high levels of ozone and photochemical smog and those areas are currently experiencing up to two and a half times the World Health Organisation levels of photochemical smog and ozone and 75% of those problems are caused by road based transport.

High levels of pollution aren't being created there. They're being created on the Eastern Seaboard and being blown inland and they're trapped there by the Blue Mountains.

I think it is acknowledged that cars are a major contributer to the Greenhouse Effect, cars and trucks; road based transport generally.

Toon: The other side to it is that if you increase capacity you've got to then have a system, particularly in the Central Business District, which is going to be able to absorb additional cars. What that really means is that you've got to have more streets in the city, more space for cars in the city simply to absorb the higher number of cars.

Hensher: I might also add that the traffic forecasts did make some strong assumption about the great majority of that traffic being through traffic and that's since shown to be absolutely incorrect. In fact a substantial amount of that traffic will be terminated in the Central Business District and you could argue, is that a good thing?

Judd: The Sydney Harbour Tunnel will bring slightly more into the city, We don't see that as a problem at all.

Toon: It didn't actually fit with a whole range of other government policies. It wasn't really related to issues of metropolitan growth. It wasn't related to really the crisis points where we need to invest money in roads. I mean there are many parts of the metropolitan area where we have major congestion and nothing is being done about it. All the major congestion points are out in the West, they're not in the inner city area at all.

Hensher: The question that should have been asked at the beginning when any major investment like a tunnel or whatever is being considered is what are our priorities from an overall planning and strategic land-use transport point of view. That question was never asked in the context of this tunnel.

Judd: The RTA's transport policy is really a two fold policy; and that's to manage the road system that we have, to improve it. And the other is to improve/develop the network of roads itself. Now the Sydney Harbour Tunnel falls of course into improvement in the network itself.

Assessment (view video)

Smythe: The DMR's assessment report came at the end of the process as a prelude to the final decision. It was a report that seemed to me to be done to oblige the politicians, to make the politicians answer their job easier, to provide some justification for going ahead. The figures were fiddled and a number of outside consultants were used to boost the DMR's own stocks although there work wasn't acknowledged in the report.

Greiner: The old putting Dracula in charge of the Blood Bank principle. If you have the principle construction authority, the people who are gung-ho to build it whose Minister is personally politically committed to it, if you have them in charge of the Environmental Impact Statement, it is obvious that you're going to get a view that is in favour of construction.

Nielson: The Harbour Tunnel was a very visible project. It was treated by the politicians as an opportunity to score points. So it became a very public debate, fairly heated, a lot of information was promoted that really had no validity. I guess at the end of the day the RTA was able to sift through the debate and I believe at the end of it was able to make sensible decisions about how the proposal should be modified to make it more environmentally sensitive.

Judd: From what I understand of it is that the process that we went through was exactly the correct process and I can't understand people saying that's biased if its been done by the consultant when I think that's exactly what the EP&A Act requires.

Toon: I mean it seems to me that there must ultimately be that power to make a political decision and I believe all the decisions and all environmental decisions are ultimately political decisions, not anything else.

Morrison: At the moment my feeling is that the politicians perceive that there is more money that needs to be spent on roads and I think that that's probably a true perception. However, I think that the public tends to want more money spent on fixing the local roads, on fixing the pot-holes. But the politicians, it seems to me, are misinterpreting those calls from the public and they're looking for high visibility projects, something that they can pork-barrel with if you like.

The opposition (view video)

Corner: The main concerns of the Save Our Sydney Foundation and local residents were the way that the alternative was chosen, the lack of consideration of other alternatives, the problems that were going to be caused by the funnelling of additional traffic through a bottleneck, the bottleneck of North Sydney, the fact that we'd be spending vast amounts of public money on a project that really didn't solve the problem.

Mack: Well I think that the proposal for Sydney Harbour Tunnel was actually agreed politically some years before it was ever known publicly.

Corner: The EIS was a document that was put together to justify a decision that was already made.

Morrison: I think that one of the ways of improving that system is to open up the whole decision-making process, that is, to allow greater public participation in transport planning and planning for Sydney at a much earlier stage. That it really isn't acceptable to the community any more to be presented with a fait accompli and to be asked to make a submission.

Judd: There were a whole series of submissions received as part of the EIS. From memory I think there was about 450 of them. Each one was reviewed to see exactly what the content was and then every area in that was addressed.

Smyth: There was no opportunity for people who objected to the Tunnel to appeal. The government in making its decision to proceed with the project decided to bring forward legislation that tidied up any loose ends one might say and removed any rights of appeal.

Mack: In New South Wales I guess there's a long history of bizarre legislation but the Sydney Harbour Tunnel Act probably was the daddy of them all. It was introduced at about 1 am in the morning as I remember. It virtually wiped all other legislation in respect of the Sydney Harbour Tunnel and gave all power to the Minister.

Toon: If one considers whether governments should or should not have the power to pass special legislation, of course they have, there's no doubt that government can pass any legislation it wants. I think though it circumvents the intention of the legislation which was that not only should environmental considerations be weighed properly in development proposals but that the public should be able to comment and review and indeed assess those development proposals.

Corner: The Liberal Party campaigned in this electorate on the basis that if Greiner was elected he would stop work on the Tunnel, hold a public inquiry and publicly review the contract. None of those things happened with some fairly feeble justification.

Greiner: What Labour has effectively done is to hog tie us in such a way that both the government and the people have no option other than to continue with the Tunnel.

Reflections

Corner: The Environmental Impact Statement process, as far as we were concerned with the Sydney Harbour Tunnel, was totally inadequate.

Morrison: I think it is accepted that the Environmental Impact Statement process isn't working at the moment, that a lot of community groups are very concerned about the inadequacies in the system.

Nielson: The environmental process is frustrating the economic development of this nation.

Zines: I don't think we should get carried away too much with whether the process is excellent or fine or whatever it is. I think we should try and look to the expediency of producing a very efficient process that doesn't hold up development.

Bathgate: Yes, we were reasonably happy with the EIS process. I mean inescapably its pretty lengthy, its time consuming, and it consumes a lot of money. But I think in the case of a major project like this, that's inescapable.

Jones: The purpose of EIS's is really a tool to help manage the environment and as such they are valuable in so far as they can make predictions and make recommendations as to how to evade any impacts which are predicted to be particularly damaging.

Question: I don't know whether you want to comment on this. The Environmental Impact Statement consultants refused to appear on this video. Do you care to comment on why that might have been?

Toon: No! laughter...


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