23rd October 2006

Attn The Hon Mr Eric Roozendaal
Minister for Roads
Level 30, Governor Macquarie Tower
1 Farrer Place
NSW 2000

Dear Mr Roozendaal

Pacific Highway Upgrade Wells Crossing to Iluka Road
An assessment of the 'Preferred Route Report' (27.9.2006)


Following the release of route options for the above section of Pacific Highway upgrade in 2005, and modified options in 2006, the RTA took time to assess the merits of an inland option (Summerland Way). In September 2006, the RTA rejected the inland option in its entirety, and presented plans for the preferred route option for the Wells Crossing to Iluka Road section of the upgraded Pacific Highway.

The Clarence Environment Centre has previously made its position clear by opposing all four options presented, because of the massive environmental and social impacts that simply cannot be avoided, claiming instead that an upgrade of the rail systems should take priority. This view is justified in light of:

  • Peak oil, and the acknowledged fact that oil shortages and price rises are inevitable, and that rail transport is a logical alternative that could help conserve dwindling world supplies.

  • CO2 emissions are acknowledged as being a major contributor to global warming and irreversible climate change. Again, the use of rail systems has the potential to reduce these emissions.

  • The high level of destruction of the natural environment through highway construction which requires the clearing of a 100m wide corridor, as opposed to a 30m corridor for rail infrastructure.

  • The high level of destruction of prime agricultural land along the Clarence flood plain. With half the world's population currently starving or suffering from malnutrition, there can be no moral or ethical justification for placing this vital resource under concrete.

The 'Technical review of alternative inland corridor' - September 2006.

The above document accompanies the 'Preferred Route Report', and cannot avoid criticism. If a road corridor is seen as imperative, on which we would not agree, an inland option could only ever be justified if it followed the logical straight line from Wells Crossing (or even further south at Macksville) to Brisbane. That straight line passes approximately through Casino, Kyogle, Woodenbong, and Beaudesert, along the current Summerland Way and Mt Lindsay Highway.

This inland route would;

  • generally avoid prime agricultural land,

  • avoid coastal estuaries and reduce potential pollution of those waterways, and remove the need for expensive bridge construction,

  • avoid coastal floodplain and major problems with highway foundations, and floodway construction,

  • avoid biodiversity hotspots such as Tweed Valley; Byron Bay hinterland; The Clarence Valley, and potentially the Coffs Harbour - Woolgoolga hinterland,

  • avoid the need to acquire some of the most expensive real estate in NSW,

  • result in a reduction of possibly an hour's travelling time, and save billions of dollars in construction costs.

The RTA has placed two white arrows on the Locality Map (page 4) with a caption announcing the, "longer term potential option to upgrade Summerland Way and Mt Lindsay Highway into South East Queensland". It then completely ignores this potential, with the proposed inland alternative taking a 45 degree turn at Casino to rejoin the current Pacific Highway 80km away near Byron Bay.

The distance from Casino to Brisbane via the Mt Lindsay Highway is approximately 190km. From Byron Bay to Brisbane, approximately 160km. Therefore, the decision to align the route back to the coast from Casino, makes that option about 50km longer than the more direct Mt Lindsay route.

The assessed section from Casino to Byron Bay would also impact on some of the highest quality agricultural land in NSW, and the difficult hilly terrain would result in the need to construct up to 3km of tunnels. Both these arguments have been used by the above review to prove the unsuitability of the inland option.

The Technical Review also indulges in some not so very creative accounting, concluding that the cost to construct the inland option is unacceptably high, claiming that cost to be between $3 Billion and $3.2 Billion. We know that the current 80km Wells Crossing to Iluka Road preferred option has been costed at approximately $0.9 Billion, but nowhere in the pamphlet is there any figure given for the cost to construct the remaining 100km section from Iluka Road to Byron Bay, which would give a true comparison. This high cost can again be attributed to the decision to assess the Casino to Byron Bay option rather than the Mt Lindsay route.

The Review highlights the fact that the assessed inland option would have high impacts on agricultural land between Casino and Ewingsdale, and that serious engineering issues exist for the same section. It would appear therefore, that the Casino to Byron Bay section has been deliberately adopted to give weight to the argument in favour of the preferred route.

The RTA presents the following arguments to support the current preferred route over the inland option (page 1, Technical Review). Most are questionable at best, as is demonstrated below:

  • The claim that the current Pacific Highway would still require a safety upgrade if the inland route was chosen, thus requiring additional funding, is correct. However, with the preferred route, the existing highway will remain, and retain 70% of current traffic. It will still receive the safety upgrade and require the additional funding. To suggest safety upgrades on the existing highway will add costs, only if an inland route is adopted, is patently untrue and deliberately misleading.

  • In choosing to back-track the inland option from Casino to Byron Bay, we are told a tunnel, or tunnels, would be required, possibly resulting in dangerous goods and inflammable materials being transported along the existing Pacific Highway. The same information sheet highlights the fact the the coastal population is expanding rapidly. Again, to suggest that a road tunnel would force dangerous goods to be rerouted through highly populated areas with inferior road conditions, is quite literally unbelievable.

  • The inland option would lead to longer travel times and steeper grades, therefore trucks would opt to remain on the existing (inferior) Pacific Highway. This dubious claim that truck drivers would opt for a 190km route with with 60 and 80kph limits, not to mention possible 40kph in school zones, just to save 10km in distance, when the longer route can be travelled at 110kpm has to be disregarded.

  • The RTA claims that an inland route would result in two noisy routes instead of one. That is exactly what residents of Tucabia have argued all along. The entire preferred route from Glenugie to Tyndale will be an additional noisy road through areas where population levels are generally far higher than the inland alternative.

  • The inland route "could have flooding consequences" according to the RTA. This is another inclusion designed to mislead. By only assessing a bypass on flood prone land east of Grafton, the RTA can make this flood problem claim, while flood free options west of Grafton remain ignored. What isn't immediately explained is that numerous sections of the preferred route are to be designed only to a 1 in 20 year flood level (Figures 6.7 and 6.8, 'Preferred Route Report'), suggesting the preferred option will also have flooding consequences.

  • The inland route will impact on up to 50km of prime agricultural land. The RTA has listed this as a negative. However they fail to mention that the preferred route between Grafton and Byron Bay, the alternative to their inland option, will destroy a far greater amount of prime agricultural land. In the Clarence valley alone, it is estimated that 200ha of prime land will be destroyed.

    In lauding the merits of the preferred route, the RTA notes that:

  • It runs, "where the populations are growing a high standard transport corridor is badly needed." In designing the Pacific Highway upgrade through the Clarence Valley in a way that precludes locals from using the road to gain access to Grafton, the RTA makes a complete mockery of this claim. The RTA has long acknowledged that local traffic will not use the new upgraded highway resulting in 70% of the traffic remaining on the existing route in the short term, while in the longer term, traffic will continue to increase along with the rapidly increasing local population (33% in 25 years, according to the RTA's figures).

  • "Investing in the Pacific Highway is the most cost- effective way to address safety and traffic flow." On page iii of the Executive Summary of the 'Preferred Route Report', the 1989 Cowper bus crash is identified to illustrate what the RTA describes as a primary objective of the Pacific Highway upgrade road safety.

    There is no current plan to change or upgrade the section of highway where the crash occurred, and it should be recognised that 70% of current traffic is expected to remain on that road, a number that is currently as great, if not greater, than the volume experienced in 1989. As a result it is difficult to see how the RTA can justify the claim that the chances of another bus crash is in any way diminished by the planned upgrade.

  • Finally there is the ludicrous claim that the "Upgrading meets the needs of 289,000 people by 2031." As has already been pointed out, the RTA acknowledges that residents of the Clarence valley will be unable to use the motorway for their every day local travel needs. Very few stand to benefit from the proposed preferred route.

  • There is also an RTA argument that an inland option would still leave heavy transport delivering goods to businesses in centres along the current highway. There is no credible evidence to support the high percentages of trucks the RTA claims will remain on the existing highway, nevertheless, because no interchange is planned for Grafton, trucks delivering locally will still use the current highway for 45km from Maclean when the preferred route is completed. Again the argument is flawed, and misleading.

To meet the needs of the local community, residents need better, safer roads to access facilities such as shops; sporting venues; medical facilities; public transport terminals; beaches, parks, and reserves. The preferred option fails to deliver this primary need, in fact, there is a likelihood that travel times and distances may be increased in some cases.

To cap it all, rate-payers will now be expected to meet the maintenance costs of the existing Pacific Highway to achieve the safety levels that the RTA falsely professes are provided by the proposed upgrade.

Yours sincerely

John Edwards Hon Secretary