Appendix A: Submission Analysis
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environmental impact statement supplementary report Appendix A: Submission Analysis Northern Link Environmental Impact Statement Supplementary Report APPENDIX A SUBMISSION ANALYSIS June 2009 A.Submission Analysis Note: Issue No refers to a subset of issues drawn from the submissions generally relating to a particular concern or point being made in the submission. EIS Reference refers to a reference made in the submission to a particular area of the EIS documents. Response refers to the location in Appendix B where a response to the issue has been provided. “B” refers to Appendix B. The first number refers to the chapter headings of the responses based on the same chapters provided in the EIS Volume 1. The second number refers to the second level heading. The number following the backslash refers to the Issue Public Submission Summaries Submission No. 1 EIS Issue No. Reference Issue Summary Response 1 EIS The EIS does not establish broad community support for actually B.1.7 / 2 Newsletter, implementing Northern Link as indicated in the EIS newsletter. October, 2008 2 EIS Statement in newsletter that "project without connections is B.2.5 / 1 Newsletter, popular and accepted" attempts to generate impression that October, Northern Link, in some form or other, is inevitable, which without 2008 any evidence is not true. Was the 'no project' question ever asked? 3 EIS Improvement in west to east travel will never be achieved without B.2.5 / 6 Newsletter, river crossing to relieve congestion on Coronation Drive and October, Riverside Expressway heading east. 2008 4 EIS Statements that imply that the tendering process may find B.1.3 / 2 Newsletter, improved solutions hardly inspire confidence in the thoroughness October, of Northern Link's evaluation. What negatives remain to be 2008 identified? 5 EIS Vehicle distances and travel times in 2026 are utterly meaningless B.5.6 / 29 Newsletter, guesses. October, 2008 6 EIS There are no corresponding estimates of the enormous debt B.15.8 / 1 Newsletter, burden which will be imposed on Brisbane's ratepayers and October, taxpayers by 2026. 2008 7 EIS The estimate of travel time savings from Toowong to the airport is B.5.6 / 29 Newsletter, dishonest. Travel times were previously decreased by Hale Street October, and Inner City Bypass, and Northern Link will not contribute 2008 anything new. 8 EIS Brisbane would benefit from de-privatising the Air Train, quicker B.2.5 / 2 Newsletter, and at modest costs long before Northern Link become October, operational. 2008 PAGE A-2 9 EIS Wording regarding the impacts of Northern Link is deceptive. Statement Newsletter, There is an acknowledgement that noise and vibration could October, involve temporary relocation of residents and possibly some 2008 permanent structural modifications. 10 EIS Some buildings will be permanently destroyed. The "suitable B.1.3 / 10 Newsletter, management and mitigation techniques" do not disclose the likely October, fate of the occupants of the permanently destroyed buildings. 2008 11 EIS Northern Link proceeding weighs on the minds of some long- B.1.3 / 20 Newsletter, established citizens who are angry at what Council is doing in the October, twilight of their lives. 2008 12 EIS The Lord Mayor's vision appears to be a city for cars, not a city for B.2.1 / 7 Newsletter, people. October, 2008 Submission No. 2 EIS Issue No. Reference Issue Summary Response 1 1.3.1 (p. 11) The EIS creates room for the private sector to potentially override B.1.3 / 2 the consensus reached between the community and local government. 2 1.3.1 (p. 11) The justification for seeking innovation through the PPP tendering B.1.3 / 2 process is problematic because it: 1. Provides opportunity for the private sector to 'override' the shared community and local government preference (i.e. straight through option). 2. Overlooks the shadowy side of free enterprise. This move will increase the scope for rent-seeking behaviour (i.e. traffic funnelling, imposition of legal limits on Council Roads, introduction of T3 lanes on Milton Road and/or Coronation Drive) by the consortia expressing interest. 3 1.3.1 (p. 11) Innovation is unlikely in a monopolised market. There is evidence B.1.3 / 2 that insufficient genuine competition exists in the south-east Queensland large-scale road infrastructure market, with Leighton Holding achieving a (defacto) monopoly. This situation raises the fundamental question of why the PPP continues to be the preferred delivery model. "Seeking innovation through tender process" is misguided as it increases scope for rent-seeking behaviour, particularly in a defacto monopoly. Submission No. 3 EIS Issue No. Reference Issue Summary Response 1 The EIS appears to be incomplete, as the study area for the EIS B.1.3 / 1 does not include most of the Western Freeway corridor. The study ignored residents who live along this corridor. 2 Increased traffic noise from haulage of spoil westward down the B.9.3 / 1 Western Freeway and other construction vehicles has been ignored in the EIS? 3 There are no effective noise barriers along the Western Freeway. B.9.5 / 2 In many places, there is only a chain link fence between the PAGE A-3 freeway and the nearest properties. 4 Noise mitigation measures along the Western Freeway should be B.9.5 / 2 specified as part of the design brief for the EIS. These should include full height noise barriers and reduction in speed limit to 80 km/hr. Submission No. 4 EIS Issue No. Reference Issue Summary Response 1 A strong protest is registered against the proposed Toowong B.8.1 / 1 entrances and exits to the tunnels. Existing issues with parking B.9.5 / 3 and traffic on Bayliss Street, Toowong would be made worse by the Project. Widening of Croydon Street will increase traffic B.5.6 / 11 volumes, noise and fumes. Submission No. 5 EIS Issue No. Reference Issue Summary Response 1 The apparent plan to increase the traffic flow on Jephson Street B.4.2 / 9 leading to and from Croydon Street will severely impact the quality of life for residents in this area. As this is not in the scope of the current plans, one can only infer that the impact on Jephson Street residents is not of concern to planners. 2 At present, the plans only show the widening of Croydon Street, B.4.2 / 9 however, it is obvious that the seven lanes from the current four is designed to increase the flow of traffic from Moggill Road through [Jephson Street] to the western links. Concerned that the seven lanes finish at the junction of Sylvan Road. Submission No. 6 EIS Issue No. Reference Issue Summary Response 1 Will have no security and will be exposed to noise of patrons B.13.3 / 9 leaving the Normanby Hotel, which is already high. Currently have a natural buffer with houses between Kelvin Grove Road and our property. There will be a significant increase in the potential for vandalism, crime and safety. 2 The uncertainty of the final design is having detrimental effects on B.13.3 / 20 our health. We need security and peace of mind as we are about to retire. Submission No. 7 EIS Issue No. Reference Issue Summary Response 1 Strongly oppose the proposed secondary local access to the B.3.4 / 2 Northern Link Tunnel at Toowong. Urge Queensland Government and Brisbane City Council to remove the Toowong connection from the Northern Link Project. 2 The Northern Link Tunnel, in aiming to improve traffic flow and B.2.2 / 2 decrease congestion, appears to be aimed at enhancing our city's liveability. Its primary value will be to take traffic away from PAGE A-4 existing local roads. 3 The anticipated benefits of the Northern Link tunnel will be B.3.4 / 3 achieved through the Western Freeway connection, without needing to construct the secondary access at Toowong. 4 The Toowong access is not needed for people beyond the inner B.3.4 / 3 suburbs as the tunnel can be accessed from the Western Freeway. A secondary access at Toowong is unnecessary and illogical. 5 A secondary access point at Toowong would lead to division of the B.13.3 / 14 suburb through the radical widening of Milton Road and Croydon Street. 6 A secondary access point at Toowong would lead to the B.11.2 / 6 resumption and demolition of more than 100 properties that are B 12.2 / 1 considered Character Homes in the Brisbane City Plan 2000. 7 A secondary access point at Toowong would lead to nine B.4.2 / 12 permanent disruptions to the flow of local vehicular or pedestrian traffic affecting Milton Road, Morley Street, Croydon Street, St Osyth Street, Bayliss Street, Sylvan Road, Valentine Street, Quinn Street, Frederick Street and Gregory Street. 8 A secondary access point at Toowong would lead to reduced ease B.13.3 / 16 of local travel across Toowong, particularly to Toowong State School. 9 A secondary access point at Toowong would lead to loss of visual B.13.3 / 8 amenity, including the reduction of Quinn Park, in a character B.13.3 / 13 suburb through the loss of trees, parkland and character housing. B.14.5 / 1 10 There is no way to construct the access point at Toowong without B.13.3 / 8 an extensive loss of amenity to the community. 11 The secondary access at Toowong will drastically decrease B.13.3 / 8 liveability in Toowong and do nothing good for the liveability of my community. Submission No. 8 EIS Issue No. Reference Issue Summary Response 1 The Northern Link Tunnel, in aiming to improve traffic flow and B.3.4 / 3 decrease congestion, appears to be aimed at enhancing our city's liveability.