The Rivermouth Action Group Inc
P.O. Box 268
Morningside  Qld  4170

 

19 October 2004

Mr Bruce Wilson
Director General
Queensland Transport
PO Box 1549
Brisbane QLD 4001

Dear Sir

The proposed North South Bypass Tunnel (NSBT) will not deliver a sustainable solution to Brisbane’s congestion problem.

Concerned residents have, through their own investigations, established that there are serious public health risks and that the so-called ‘benefits’ of such a proposal are questionable. The results of these investigations are progressively being posted on the website www.rag.org.au/tunnels and I invite you and your staff to take your time and read through the pages.

Air Quality and Public Health Implications

There is a plume of pollution that pours out of untreated/unfiltered road tunnel exhaust stacks. In Brisbane’s case that may well be at both ends of the NSBT 4.5 kilometre tunnel which will have long-term health impacts on residents within the fall out zone. Depending on the wind direction and velocity the people living in Spring Hill, The Valley, Herston, Bowen Hills, Lutwyche, Wilston, Wooloowin, Albion, and Clayfield and beyond on the north side and the suburbs of Woolloongabba, East Brisbane, Kangaroo Point, Buranda, Stones Corner, Dutton Park, Highgate Hill and South Brisbane on the south side will be affected.

If untreated emissions are allowed out of these stacks they will also deposit pollution over nearby Downey Park, Gabba Cricket Grounds, a large number of schools, busy sport fields and a large range of community facilities depending on wind direction and velocity. The two proposed stacks, to be located at either end of the tunnel, will be immensely large structures and up to a minimum of 30 metres high. Both will be very close to multi-discipline public hospitals.

Recent media information highlights that a new Sydney exhaust stack should be increased from 60 to 80 meters high, on advice from the New South Wales Health Department, to ensure (untreated) ‘adequate pollutant dispersion.’ Are residents of Brisbane being short changed at 30 - 35 metres?

World wide there is a growing body of research that indicates ultra fine particulants (PM 2.5 and below which will increase in percentage when low ((and eventually ultra low)) sulphur diesel fuels appear at the service stations) have serious health implications for particularly the elderly and the very young. This should at least alert you to the fact that the precautionary principle must be applied to any Brisbane tunnel project.

Look what’s happened in Sydney and Melbourne! Parliamentary debates continually mention the fact that there has been a significant underestimation of the out-of-tunnel congestion impacts. As a result of traffic being delayed in the tunnel for significant periods occupants of the vehicles experience considerable distress. In fact the Sydney tunnels have been so bad some days that motorcycles and open air cars have been banned.

In Melbourne the Burnley Tunnel has had to be closed over 60 times in a 12 month period due to poor in-tunnel air quality. The same situation could easily be repeated here.

The worst traffic emissions come from diesel vehicles. In Sydney the traffic analysis significantly understated these heavy vehicles. The health impacts of diesel emissions are much more deadly and very well documented.

Congestion on roads will get worse

The traffic and transport analysis we have seen, is in our opinion, seriously flawed. Assumptions have been made that lanes will be ‘closed’ and that traffic will be ‘forced’ to use the tunnel.

There will be an increase in the congestion on the roads leading into and out of the portals, especially Lutwyche Road. Does this mean that the NSBT Stages 2 (ICB to Kedron Brook Road) and Stage 3 (Gympie Road to the Gateway Motorway) will be brought forward? If this is the case then everyone needs to be aware of this, especially the residents whose health problems will, as a consequence, be compromised.

At each road portal along this route there will need to be another exhaust stack. This will mean a series of large stacks (30 plus meters) will ‘march’ across the landscape of Windsor, Wooloowin and beyond. We do not think this is the vision residents have for a ‘liveable’ Brisbane.

Recently Brisbane City Council (BCC) staff advised us that the geological investigation for stages 2 and 3 indicates that the stage 2 tunnel will not be able to directly connect to stage 1. Does this mean that in another 10 years the area north of Enoggera Creek will be turned into a wasteland of flyovers and interchanges like what is proposed for Bowen Hills? Why are communities being wiped out and replaced by asphalt in prime inner city areas where there is the greatest opportunity to promote a higher usage of public transport and a higher rate of active transport?

Despite the words being printed by BCC no real commitment is being made to improve the public transport, cycling and walking facilities. Yet Windsor, Bowen Hills, Herston, Woolloongabba and Kangaroo Point are all within a 5km radius of the city – just the right distance to promote active transport options. And both areas have major trip attractors such as hospitals and schools – it costs a lot less money to improve these sorts of connections than to dig large black holes down which more and more money has to be poured.

Bus lanes along Lutwyche Road have already been closed and any congestion on tunnel feeder routes will inevitably delay commuter buses in the priority lanes. What will this do for the patronage levels of public transport especially at a time when so much is being invested into the TransLink operation?

Words are being written about this project bringing many benefits for public transport cycling and walking options, the reality falls far short.

The True Cost

No doubt there has been a lot of effort put into establishing the business case to justify why and how this tunnel should be built.

Whether this project is a delivered through a public sector financing, public private partnership or private sector financing there is one conclusion: the tunnel cannot pay for itself. Yet the Council appears to be determined to enter into a high-risk financial investment.

All the signs are there alerting us to be cautious and prudent – construction costs are continuing to increase, at first it was $900 million (end 2003) now it is $1.3 billion (August 2004). If adequate filtration (in the form of electrostatic precipitators or other types of pollution extractors) is added the figure could be around $1.7 billion and if safety features are improved the sum would then exceed $2 billion.

Brisbane motorists will not be immune to rising petrol prices and yet the assumptions for the tunnel’s viability have continually downgraded the fact that it is very toll sensitive.

We believe the ratepayers of Brisbane deserve better.

Outdated safety features are being proposed

While we all need to ‘be alert not alarmed’ we also need to be pragmatic and recognise that to build a 4.7 km tunnel using outdated safety features no longer acceptable in Europe is to show a lack of care and concern to Brisbane road users.

And what about members of the community who are not agile enough to be able to get to safety doors 120m apart. What happens to them? Will the tunnel “safety” features go the same way as the access to lifts in the South Brisbane Convention Centre - An Anti-Discrimination Case?.

There is a Better Solution

The NSBT will not be a value for money investment. We cannot build our way out of congestion. Plenty of cities have tried that and have found it does not work. To continue down this path will result in the destruction of what makes Brisbane a liveable city.

In Australia and overseas there are good examples of how transport issues can be resolved without requiring massive capital and recurrent expenditure.

We are not denying the region’s transport system needs to be improved if we are to reduce our reliance on private transport. The right network structure needs to be put in place that will deliver the right system performance. Not something which only benefits the ‘big business’ end of town and wrecks local communities leaving the future ratepayers of Brisbane with a financial millstone.

Let’s move from the ‘can do’ mentality of yesterday.

As Director General of Queensland Transport - the agency responsible for advising the State Government - you have duty of care to ensure the transport solutions are the right ones. Not ones that will leave long term public health impacts and result in financial loss.

What are you doing to ensure that the right decision will be made?

Please acknowledge receipt of our letter within 7 days and respond to its contents within 14 days

Yours sincerely

signed

Barry Wilson
Chairperson