23rd October 2006
Attn The Hon Mr Eric Roozendaal
Minister for Roads
Level 30, Governor Macquarie Tower
1 Farrer Place
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
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
- 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
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
- 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.