SUBMISSION TO THE INQUIRY INTO THE MANAGEMENT OF THE INLAND RAIL PROJECT BY THE AUSTRALIAN RAIL TRACK CORPORATION AND THE COMMONWEALTH GOVERNMENT.

22 November 2019

Submission by Ms Barbara Deans

Coonamble, NSW

Our farming property is in the investigation corridor of the proposed Narromine to section of the Inland Rail Project in NSW (N2N).

This submission relates to this proposed section of the Inland Rail corridor. We object to this proposed new Greenfields track and want Inland Rail to run on existing track in this region. Existing track is serviced by existing infrastructure, connected to the towns and will encourage growth in towns and communities.

1. SUMMARY

In my view the Inland Rail project is not about growing regional , apart from a couple of hand-picked locations.

It appears that the benefits of the project will flow to large corporations and a small number of inland towns. There has been insufficient attention given to ensuring that this ‘nation-building project’ benefits areas that the line passes through, especially the Greenfield Narromine to Narrabri (N2N) section where I am located.

The N2N section seems to have been handled like an after-thought with basic investigations not done, missing key steps, decisions made without proper information, lack of transparency and without genuine engagement with communities and landholders.

The process to select the Greenfield corridor in the N2N section has been so badly handled that ARTC are unable to provide evidence of how it was selected, what the positive and negative impacts will be and how they will be addressed.

ARTC have acknowledged the substantial opposition to the chosen corridor in the N2N section. ARTC and Commonwealth Government representatives appear to be saying that they acknowledge it has been done badly but are forging on regardless. That would appear to be reckless waste of taxpayer money when better and significantly cheaper options are available.

I sincerely hope that this Inquiry will result in the options for alignment of the N2N section being thoroughly independently reviewed. What is needed and should have been done is an independent Business Case Study including a Socio-Economic Benefit Study for N2N section.

It is my view that upgrading the existing line and utilizing and energizing the impacted 4 regional Shires of Coonamble, Warrumbungle, Gilgandra and Walgett would be better value and grow this part of regional Australia.

The two reports by ANAO1 and ACCC2 I feel support my concerns.

1 https://www.anao.gov.au/work/performance-audit/management-inland-rail-pre-construction-program Point number 11

2 https://www.accc.gov.au/regulated-infrastructure/rail/artc-interstate-access-undertaking https://www.accc.gov.au/system/files/ARTC%20-%20IAU%20-%202018%20Draft%20Decision.pdf A. financial arrangements of the project

1. The cost far outweighs the benefit

The BCR (benefit-cost ratio) has been noted in many reports as being marginal at the spend of 8.4 billion over 50 years3. Melita Lanigan-King, Director – Regional and Industry benefits Inland Rail Division, at the Narrabri Forum on 8th August 2019 conducted by Ernest Young, said “Inland rail would cost $16 billion.” She corrected the E&Y speaker when he said $8 .4 billion. If this is correct, the total cost has already doubled. A revised budget needs to be presented to the public.

2. It appears ARTC have based their options costing decisions on the 2010 report which contains errors and out of date information.

The ‘Rail Alignment Study (2010) Final Report Appendix D4: Identified Route Options’ made cost comparisons using the then Class 5 track between Curban and Coonamble. However, upgrade works have been carried out on the to Coonamble line5 since the 2010 IRAS assessment. It is my understanding that these works completed in 2013/2014 brought the Dubbo to Coonamble line to a high standard (22.5 ton /axle @80kms heavy rail) comparable with much of the rest of the 1300km brownfield inland rail line.6 There is no evidence that these upgraded works were properly considered when comparing the Greenfield N2N route cost with use of more of the existing line in the N2N section.

In a letter 22 August 2018 to NSW Farmers from Mr McCormack DPM, it was stated Curban through Coonamble to is 30% more expensive than Greenfield Curban to Gwabegar. This was based on appendix E7. However, the Appendix E information is incorrect. It was based on upgrading a class 5 line. This is wrong. ARTC and Dept. of infrastructure should have known this fact. The 550,000 ton of the 2016 harvest would not have been able to be sold and moved out of Coonamble GrainCorp silo on a class 5 rail track.

3. ARTC’s 2010 costings are unreliable

We have been repeatedly told that it is cheaper to build a new line rather than use the existing line between Gilgandra and Coonamble. However, the 2010 costings are out of date and unreliable. Michael Clancy, ARTC Manager Business Development, at a CCC meeting in July 2019, stated that our section of existing line, Gilgandra to Coonamble, is much the same as the line from Melbourne to Brisbane, and all it needs is refurbishing to bring it to the Inland Rail standard.

A report by ARTC’s Mitch Carr to the NSW Dept. of Planning in May 2018, stated that the estimated Approximate Construction Value of a new build in N2N section would be $1.6 billion. [page 4]. I ask the question, where is the costing for everything else? Such as land acquisition, dispute resolution, easement preparation, road diversions, etc. It is our view that the economic argument to keep inland rail on existing rail and Crown Land in N2N is strong. We understand the cost would be in the order of $600m making a saving of approximately one billion dollars.

4. There are errors and inconsistencies in the ARTC 2015 Business Case Study.

3 See ‘Final Inland Rail Project Evaluation Summary’ by Dept. of Infrastructure. 4 https://s3-ap-southeast-2.amazonaws.com/ehq-production- australia/1b15e8d2713f1b18d3db295bcb930c92ad42d837/documents/attachments/000/080/024/original/IR_AS_APPENDIX_A-E.pdf?1529024873 page 54 5 http://www.abc.net.au/local/stories/2010/08/25/2993402.htm 6 http://www.abc.net.au/local/stories/2010/08/25/2993402.htm 7 Melbourne – Brisbane Inland Rail Alignment Study – Final Report 41 Appendix E: Route Development page 41 For example: Inland Rail Group Implementation Report page 283, 2015 Business Case Study8 states 2 million tons of agriculture will be attracted from road, whereas page 17 of the Summary of the 2015 case for inland rail9 (same report) refers to 9 million tons of agricultural freight. Where did the extra 7 million ton come from? Where are the figures to prove this?

B: Route planning and selection processes

1. I question the validity of information used to determine the corridor along N2N.

The North–South Rail Corridor Study (Department of Transport and Regional Services, 2006) and the Melbourne– Brisbane Inland Rail Alignment Study (ARTC 2010) appear to be the source documents for everything ARTC are doing in N2N section.

These documents are 13 and 9 years old and contain errors and assumptions and should not be relied on to make the route selection in to build Greenfield N2N section.

2. Flood risk:

The proposed N2N corridor was determined using desktop studies. Representatives of GHD have advised that there are no flood studies and no official recording stations to refer to in relation to floods.

This is significant. It is my view that the current route selection has failed to take into consideration the substantial flood risk from water flow from the Warrumbungle Mountains. ARTC’s facts are incorrect. The ARTC 2010 report on the N2N section had the route going through “flat country with a good amount of water” but which it described as “flowing at very slow pace.” This is not accurate. The proposed route for Inland Rail will make it essentially a levee bank on the base of the mountains, perpendicular to the east west flow of water from the Warrumbungle Mountains. This area has multiple fast-flowing ephemeral creeks (over 120) that feed the second fastest flowing river in . The erosion protection of the proposed inland rail line will have to “5 star”, sufficient to withstand substantial fast flowing water from the Warrumbungle mountains. We envisage both construction and maintenance will, as a consequence, be expensive and require significant ongoing maintenance. This fact alone, will make it essential that the line is built to specifications not to budget.

ARTC’s description ‘’the flow velocity is low due to the flat nature of the topography therefore minimal erosion protection will be required ‘’ is actually describing the existing Gilgandra to Coonamble line and not the proposed new portion of inland rail, which is west of the Warrumbungle Mountains.10

3. The preferred option to stay in main road corridors and use existing rail corridors was not properly investigated in N2N section.

We, the agricultural sector, will make better use of Inland Rail if it runs on the existing line to Gilgandra, , Curban, Armatree and Coonamble where the silos, road networks and existing infrastructure are, with potential for growth with our towns.

4. There has been no Multi Criteria Analysis (MCA) for the section of N2N from Mt Tenandra to .

8 https://s3-ap-southeast-2.amazonaws.com/ehq-production- australia/5de589db79424a8f1344e2e42e171fc205104b99/documents/attachments/000/029/855/original/InlandRailBusinessCase.pdf?1448785278

9 https://www.accc.gov.au/system/files/ARTC%20-%20IAU%20-%202018%20Draft%20Decision.pdf https://s3-ap-southeast-2.amazonaws.com/ehq-production- australia/573b865247760681cf086584fcf8dad522def603/documents/attachments/000/106/353/original/IR_897_The_Case_for_Inland_Rail.pdf?1559016526 10 https://s3-ap-southeast-2.amazonaws.com/ehq-production- australia/3c5698b4bb14f693b4f4ff046b312cc570d6db2d/documents/attachments/000/080/027/original/IR_AS_APPENDIX_J-M.pdf?1529024994 This is unacceptable. We were told that this is because there is “only one corridor between Mt Tenandra and Baradine” because of the need to “capture potential construction fill material in this area”. The properties in this section are to be sacrificed and destroyed so ARTC can access the gravel at Square/Tabletop Mountain. I was later advised that the geological tests at Square Mountain failed (i.e. passed the first and second tests but failed the third) and a top ARTC representative said they are very disappointed at this. Can the Senate confirm if Square Mountain is viable for fill and whether the route is being determined by proximity to construction material rather than best cost/best route /best regional growth?

5. Incomplete documents have been used to determine alignment.

In comparing critical factors relating to alignment, the MCA11 documents contain 76 points marked ‘To Be Announced’; 24 points that ‘Assume similar impacts’; 64 marked ‘Not Applicable’; 144 ‘similar’; 8 ‘unknown’; and 17 ‘not complete’. Route comparisons for the N2N appear to have involved a significant lack of information and these incomplete documents were used in route selection. At what point will these assumptions be tested, and the gaps filled so that we can have faith in the decision on the investigation corridor?

I refer you to Australian National Auditors Office report (ANAO_Report_2017-2018_9) which mentions probity, record keeping and inconsistencies relating to important processes. Please see attached.

6. Throughout the process the number of affected landowners in the N2N section has been downplayed/misrepresented.

In the Senate Estimates, the ARTC CEO Mr Fullerton said “there were only 30 landowners to be affected" in the N2N section. Subsequently, ARTC put out information saying about 180 landowners affected. Mr Coulton MP went on local radio stating that it was only 60 landholders affected. There are 180 landholders directly impacted, and many more indirectly impacted by proposed road closures as a consequence of the new route across agricultural land.

These inaccurate statements belittle the real situation. Members of parliament should not mislead Senate Estimates or the public. In my opinion, these statements were to downplay the seriousness of the situation of the community’s anger in relation to the N2N section and turn the wider public against voices that were trying to be heard. In fact, many landholders impacted by the proposed route oppose the route.

C. Connections with other freight infrastructure, including ports and intermodal hubs

Connections with roads and branch lines in the N2N section are not confirmed and at this stage no provisions have been made for these connections. This undermines any claims of branch line interface or regional benefit along the N2N section.

There are no port connections to achieve good inland rail outcomes at this stage. Each port end should be completed to Inland Rail specifications before the Greenfield sites are planned. One doesn’t build a house and do the foundations last.

I agree with the CEO of Port of Brisbane Roy Cummins who is calling for Inland Rail go to Brisbane port to be successful, see www.railexpress.com.au.

D. Engagement on route alignment, procurement and employment;

In relation to this item I make the following comments:

 From the outset, the engagement by ARTC has been shrouded in secrecy. 11 https://s3-ap-southeast-2.amazonaws.com/ehq-production- australia/a673088c7b5b97634613d2f0697b91bf0783352c/documents/attachments/000/077/116/original/NSW_N2NMCAWorkshopReport_Oct2016.pdf?15355 00180 https://s3-ap-southeast-2.amazonaws.com/ehq-production- australia/48122c32b7a625ea6ded1476d8c692b4dd4c644d/documents/attachments/000/077/115/original/NSW_N2NMCAWorkshopReport_Dec2016.pdf?1535 500196  ARTC & Inland Rail are not adhering to their own timelines. Rebecca Pickering, Director Engagement, Environment and Properties told the Coonamble Council in July 2019 that ARTC had only had 30 one-on-one out of 180 meetings with landholders. I understand that ARTC is way behind schedule and not giving landholders the flood information that was promised and some landowners are saying NO, not until an inquiry and the right investigations and studies are done.  ARTC came to Gilgandra in May 2016 and had on display the Investigation Corridor. There was no advertising in the local press.

 The ARTC staff at the beginning were dismissive of our suggestion that this Greenfield N2N section was totally unreasonable. ARTC maps were deceptive because they were vague and unclear. ARTC could and should have had great maps from day one.

 We thought we were talking to ARTC in good faith, since their first communication with us through their Community Engagement Officer, Mary Diab. It was later discovered she is in fact employed by AECOM as well. A construction company that may want to build the Inland Rail. Is there conflict of interest?

 This pervasive lack of transparency has prompted people to question the rationale behind the choice by ARTC of this current preferred Greenfield Route instead of upgrading existing lines and growing our part of regional Australia. To this point ARTC are refusing to provide their analysis.

 On Saturday 21 April 2018, at the ARTC tent at Gilgandra Show and also on a farm visit to two families, ARTC were asked ‘’where is the rest of the access agreement that you want me to sign? This is an appendix.” The ARTC representative said ‘’you sign these 3 pages, we will send it away and we will then get you the rest of contract’’. This is unacceptable behaviour and possibly unlawful.

 This lack of transparency has pit farmer against farmer. ARTC has singled people out to pacify them to allow movement of the line to achieve a pathway. Some farmers have not been consulted at all. One tactic of ARTC was to hold meetings at critical times for farmers, for example, at planting and harvest. ARTC and Commonwealth Government are not in touch with the farming community.

 Stakeholder engagement: On 2 June 2016, at the very beginning, ARTC organised a meeting at Curban. A lot of famers and community wanted to attend but were excluded. We were told that farmers were not considered stakeholders. Town-based groups and Rural Fire Service were apparently considered the stakeholders, along with Shire Councils. ARTC tried to have these people sign Confidentiality agreements. This was farcical, as legal advice showed these agreements were employment agreements for the ARTC employees.

 This lack of transparency, together with ARTC’s unwillingness to provide factual evidence supporting their choice of route, has prompted NSW Farmers to advise their members not to interact with ARTC personnel.

 At public meetings and CCC meetings, ARTC staff are ill-equipped and unable to answer reasonable questions from directly affected members of the community. CCC members have brought this to the attention of NSW Department Planning. Urban and regional economic development opportunities;

The proposed Greenfield N2N corridor runs through our shires but nowhere near our towns, silos and hubs. We are told our towns are being bypassed to save approximately 15 minutes of the time to travel from Melbourne to Brisbane. If this Greenfield corridor happens, this vastly productive agricultural area of NSW will not benefit at all from Inland Rail.

BELOW ARE REASONS INLAND RAIL SHOULD UTILIZE EXISTING CONNECTION TO COONAMBLE

 We need to be directly on the route, so our freight is competitive with other areas in the State and Coonamble can be a hub for this area. We need competitive freight prices and growth to survive.  Gulargambone, Coonamble, Baradine, Walgett, Lightning Ridge, Brewarrina and Pilliga towns and areas are currently excluded from access to Inland Rail (9.5 million acres of farmland and produce).  If freight is cheaper, and accessibility greater, there would be opportunity to buy and sell goods on the route from Melbourne to Brisbane, encouraging new business, and growth in existing business which would potentially create more jobs to encourage younger people to stay in the district.  We could value add to our produce. For example, an abattoir and meat packing plant, and send product straight to port. Our product is clean and green.  New business needs to be serviced. Plumbers, electricians, builders, hardware, clothes shops, cafes and other associated enterprises would benefit.  Business could easily access latest products and be more competitive. Prices could be kept in line with bigger centres. People wouldn’t have to shop out of town.  We have the Warrumbungle National Park a Dark Sky Park, Coonamble Rodeo, Lightening Ridge (opals), Macquarie Marshes (birds), Pillage bore (caravans), and so much more. Coonamble is the gateway to Hebel, St. George and outback NSW/ QLD. The potential for passenger trains in the future on this line is something we can't miss.

See Submission to ARTC to have the line to Coonamble.12We believe the route options outlined in the 201013 have been discarded without giving sufficient consideration to the towns and districts of Coonamble, Warrumbungle, Gilgandra and Walgett. These Shires have a right to be included in the biggest project of the century.

Currently, the planned alignment shows no terminals for this area of 50,000 square kilometres with a population of 25,000 and a reputation as one of the largest grain, cattle and sheep production areas of the State.

The other routes put forward in the 2010 Report should be more closely investigated. I have 670 signatures on a Petition from Coonamble people asking for a Hub/Terminal at Coonamble (which is halfway between Brisbane and Melbourne) which would be a huge benefit to the area.

When asked at the CCC meeting in July 2019 what will be the benefit for the four Shires on the investigation corridor of the Inland Rail, ARTCs Mike Clancy, Manager Business Development replied that ‘’he couldn’t see a benefit for our area.’’

The proposed Greenfield route is going to drain and devalue our farming businesses, our communities, our towns, and add high financial cost forever on Shire Councils and be an ongoing cost to all rate payers with no benefit.

When a simple cost-effective alternative is available.

If inland rail is a white elephant. If Coonamble, Gilgandra, Gulargambone with silos and hubs were directly on Inland Rail we would still have a freight advantage because we have so much export product. Access to Melbourne,

12 https://coonambleshirecouncil.worldsecuresystems.com/AboutCouncil/mediareleases.html

13 www.artc.com.au/library/IRAS Appendix E.pdf Brisbane, Dubbo, , Newcastle, Badgery’s Creek Airport, Port Kembla and Botany with a high performance rail line would be a game changer for this area.

ARTC and Regional Australia Institute reports presented at Baradine on 4th October 2019. The sentiment of the report supported Coonamble, Gilgandra, and Warrumbungle Shires to be on alignment of the Inland Rail,” it would indicate a strong potential for additional freight capacity to contribute to the region’s future economic competitiveness.’14

Competitiveness for Ag freight is highly questionable in areas away from an intermodal.

Even with Inland Rail every kilo of agriculture freight comes off the farms on a truck.

E. Collaboration between governments;

I have seen no signs of involvement at the regional level (N2N section) by the NSW Government in the process to date.

F. Interaction with National Freight and Supply Chain Strategy; There is no interaction for Coonamble on the N2N section. Our produce has to travel by truck to the closest hub. 240kms or 173 km if the hubs get built, so our freight will stay on the truck to end destination and our region won’t get the chance it deserves to go ahead, all for the sake of a few minutes of travel time. This few minutes will be costing $16billion Plus.

Is it true that bulk grain for export must go directly to a port to be cost effective?

G. Any other related matters

The environmental damage from Greenfield to this beautiful productive country will be a crime. Recycle and use the existing railway line in the N2N section. ARTC have said they will use 2-3 gigs of water a day. This could well be unsustainable in this area.

There does not appear to have been conducted a social impact assessment of the impact of the proposed route as compared to the impact of upgrading the existing line.

Coonamble Shire has applied through the Inland Rail interface improvement program to have a business case study into the town ship of Coonamble’s inclusion on the inland rail route.

Inland rail is like Chinese whispers. Every year there’s a report - 2006, 2008, 2010, 2014, 2015, 2016, 2017, and 2018. The same old information is enhanced to make the whisper more exciting and 80% of the whisper is not true because it is based on inaccurate assumptions, desk top studies and a complete failure to understand the business case for this region.

14 ’ https://inlandrail.artc.com.au/documents