CEN Eddington report submission

Monash freeway traffic June 2008
Monash freeway traffic June 2008


The Climate Emergency Network (CEN) represents 12 groups around Victoria who in turn represent thousands of people who believe more urgent and profound action needs to be taken to prevent the economic, social and ecological collapses being caused by climate change.

The CEN welcomes the opportunity to comment on the East-West Links Needs Assessment (EWLNA), as transport is an essential feature of the liveability of Melbourne and one of the main areas that require urgent action as part of a response to climate change.

The CEN believes that while the EWLNA has some proposals with merit, such as improvements to public transport and cross city cycle links, it overwhelmingly fails to tackle the massive and urgent problems of greenhouse gas emissions from transport and peak oil. While the focus on public transport is welcome, and the CEN strongly supports increased investment in public transport, the EWLNA is a business as usual document, based on outdated ideas, at a time where business as usual means climate catastrophe and remaining unprepared for continual increases in oil prices.

The EWLNA has no vision for a sustainable transport future for Melbourne and it therefore fails as a document that the State Government can use to guide its actions.

Transport policy cannot assume a business as usual case. All transport policy development must lead to a drastic reduction in reliance on oil, and a massive, rapid reduction in greenhouse gas emissions. In fact, it should be one of the major aims of transport policy to achieve these outcomes – and with these outcomes improvements in the amenity of our suburbs will be created. This is the best way to ensure prosperity and liveability into the future.

In this submission, we look at the broad big picture issues that we feel the EWLNA has not adequately tackled, and then comment on some of the particular recommendations that are of interest.

Melbourne railway network, 2008
Melbourne railway network, 2008

Key Points

The key points of the CEN submission are listed below, see separate sections for more detail.

  • The EWLNA’s business as usual approach to transport planning is deeply flawed, and does not take climate change or peak oil into account. Melbourne needs a visionary transport plan that will tackle the urgent problems that we face.
  • The CEN supports a massive, order of magnitude increase in public transport funding from the State and Federal governments, and thereby broadly supports the EWLNA recommendations that achieve this. The CEN however, does not support a road tunnel or any new freeways.
  • The assumptions made to make up the EWLNA reference case with regard to oil prices, carbon pricing and road pricing are incorrect, and greatly exaggerate the case for supporting private car use and the road tunnel.
  • The EWLNA ignores the climate emergency and ignores the pressing need for us to reduce our greenhouse gas emissions from transport. Any new transport infrastructure or plan needs to have emissions reductions as a central aim.
  • The propensity for people to shift to public transport when high quality services are available is underestimated and the recommendations are consequently poorly targeted.
  • Past transport studies and experience have shown that building freeways does not solve congestion, and they will in fact increase congestion in the long term.
  • The recommendations in the EWLNA will result in a 1% modal shift from cars to public transport by 2031, in contradiction with the Brumby Government’s 11% shift (by 2020). We need a much more profound shift if we are to retain Melbourne’s liveability and reduce our emissions.

Flawed Assumptions

The EWLNA reference case makes the following assumptions:

  • No real increase in fuel prices beyond 2006
  • No carbon price on transport emissions
  • No road pricing before 2031

Under the assumptions made in the EWLNA, fuel prices would currently be around $1.25/litre. This is obviously much lower than the current petrol prices in Melbourne. World oil prices are driving up petrol prices at a rate much higher than CPI. Some of the world’s major banks, such as Goldman Sachs and Deutsch Bank predict that oil prices will continue to rise due to increasing demand and restricted supply.

It is also unrealistic to assume that there will be no carbon price on transport emissions, when transport is a key sector currently being considered for an emissions trading scheme. Road pricing is also likely to be introduced well before 2031 and motoring organisations such as the RACV are already advocating for the introduction of road user pricing as part of broader reforms.

All of these assumptions have meant that the EWLNA’s projections are flawed and have falsely exaggerated the case for supporting private car use and the road tunnel.

What about Climate Change?

Any government committed to tackling climate change should not be building new freeways or accepting studies that forecast an increase in transport emissions.

The most recent science, as outlined in the book Climate Code Red (2008), which is more up-to-date than the 2007 IPCC report that is generally used by government, shows that the situation is much worse than previously thought. As Lord Nicholas Stern pointed out in April this year:

‘I underestimated the threat of global warming in my report in Nov 2006. Emissions are growing faster than we thought. The planet’s capacity to absorb is less than we thought. The risks of greenhouse gases are worse and are potentially bigger than more cautious estimates.And the speed of climate change is faster’. (Reuters, 16 April 2008)

According to the most recent science describe in the Climate Code Red report (2008), we are already, with the current level of greenhouse gases in the atmosphere and our current rate of emissions, locked in to a warming of 2 degrees by 2030. With a warming on average of two degrees, we are likely to get the melting of the arctic ice sheet, the extinction of 15-40% of all plant and animal species, the acidification of the oceans leading to marine ecosystem collapse and coral bleaching, more frequent extreme weather events and widespread drought and desertification across the globe, especially in Australia. All of these impacts will have a profoundly negative effect on Victoria’s economy and liveability.

The fact is, we need to stop emitting greenhouse gases, and start to remove greenhouse gases from the atmosphere, down to the level they were in the 1970s, which means a temperature rise of 0.5 degrees.

It is unacceptable and irresponsible to play dice with our future and lock us in to an expensive transport plan that will not greatly reduce emissions.

The infrastructure recommendations in the EWLNA fail the greenhouse emissions test, as they will have practically no effect on transport mode share or greenhouse gas emissions, as compared to a business as usual case. This goes against the State and Federal Government target of a 60% reduction on 2000 levels by 2050, goes against our obligations under the Kyoto protocol and any other subsequent global agreement, goes against the target of 20% of journeys on public transport by 2020, and goes against what the science is telling us about climate change.

The EWLNA also puts most of its faith in terms of reducing greenhouse gas emissions (or at last keeping them from skyrocketing) on increasing the fuel efficiency of cars. While increasing the fuel efficiency of cars is a worthwhile aim, it is not going to achieve anywhere near the kind of emissions reductions we need. Modelling by the Bus Association of Victoria in its submission to the Garnaut Review shows that achieving a 20% reduction in transport emissions by 2030 on 2000 levels would require the doubling of fuel efficiency of every single car and truck currently on the road. Their modeling also shows that even if the efficiency of vehicle quadrupled by 2050, they could still only make up 11% of the urban transport modal share (as opposed to 77% in 2007) if we were aiming to cut transport emissions by 80% based on 2000 levels. Clearly, even if we are able to make cars more efficient, we still need a massive modal shift away from the private vehicle.

Peak Oil

Peak oil is the point in time when the maximum rate of global petroleum production is reached, after which the rate of production enters terminal decline. If global consumption is not mitigated before the peak, a world energy crisis may develop because the availability of conventional oil will drop and prices will rise, perhaps dramatically.

While there is some contention on when oil production will peak, with estimates varying from 2005 to right now (2008) to 2020, significant and sustained petrol and diesel price rises during 2008, up to a record $1.65 per litre in June 2008, indicate that static supply combined with increasing global demand for oil, mainly from China and India, is putting great pressure on oil-dependant western economies such as Australia.

High fuel prices are contributing to financial stress on low income households and some unrest globally with protests across Asia and by truck drivers and fishers in Europe. What is also being witnessed however is that motorists are more willing and able to shift to public transport and thereby reduce petrol consumption where good quality public transport is available . Australian transport policy should recognise this and ensure high quality public transport is made available to more people to reduce the financial impact of rising fuel costs and enable greater mode shift.

Major investments in sustainable transport alternatives are required to avert a looming financial crisis and obviate the need for major changes in the lifestyle of developed nations.

Alternative fuels will not make any meaningful contribution to solving the problem if transport-related energy consumption is not reduced. The substitutes to conventional petroleum with the highest probability of supplying significant quantities of transport fuel may actually result in much higher emissions as is the case with shale oil, tar sands and coal-to-liquids. Significant improvements in the energy efficiency of transport are required. For example, routine single occupant vehicle trips should be shifted to lower energy transport modes such as train or bicycle.

The EWLNA doesn’t reduce our reliance on petrol, and doesn’t take into account the price rises in oil potentially being caused by peak oil now and into the future. It is ignoring the reality of petrol prices and its recommendations, particularly those advocating for construction of major roads are deeply flawed due to this.

Freeways do not solve congestion

“The past 20 years have seen billions invested in freeways. Each augmentation has come with a promise that congestion would be cured, ignoring the tendency of new freeways to attract traffic and undermine public transport. As the greenhouse clock ticks, do we really want to commit another $10 billion to this illusion?”– Professor Bill Russell, deputy director of the Centre for the Governance and Management of Urban Transport at the University of Melbourne

Countless transport studies have shown that building freeways does not solve congestion. That in fact, in the medium and long term, new freeways attract more cars onto the roads and increase congestion. CityLink, for example, was also said to be there to solve congestion, and now we’re building extra lanes on the Monash Freeway to deal with the extra traffic that CityLink has caused (again, leading to more traffic!). The East-West Road Tunnel proposed by the EWLNA would be no different. Not only will building more freeways increase greenhouse gas emissions, increase our reliance on depleting oil resources and show the State Government’s rhetoric on climate change to be completely false, it won’t even do the job it is supposed to, that is, reduce congestion on Melbourne’s roads.

It is economically, socially and environmentally irresponsible to build a single new freeway. The CEN recommends that the Victorian State Government commit to the stopping of construction of new freeways as a first step towards a sensible transport policy for Victoria. It’s time to break the vicious cycle of freeway construction and increasing congestion.

Public Transport Patronage

During 2005 to 2006 patronage of Melbourne’s trains increased over 18 per cent, which caught the Victorian Government by surprise. This increase was partly attributed to increased petrol prices prompting commuters to travel by train rather than by car.

The Government’s $10.5 billion 10-year major transport plan announced in May 2006 had significantly underestimated the usage of public transport. This was followed by an announcement in April 2008 of the introduction of more than 200 new weekly train services, described as the biggest overhaul of Melbourne’s rail timetable since the City Loop opened in 1981. The new services will be introduced to tackle overcrowding on the city’s busiest train lines, attributed to a lack of trains and falling reliability. Melbourne’s train system has reached crisis point.

The EWLNA recommendations contain many public transport proposals, but manifestly fail to address low public transport mode share beyond inner Melbourne. There is an urgent need to deliver new and extended train lines servicing growth corridors such as Whittlesea and Casey, and more established areas such as Doncaster and Rowville.

The government target for public transport patronage from the Melbourne 2030 Strategy, is a more-than doubling of the proportion of motorised transport trips taken on public transport from 9 per cent to 20 percent by 2020 Melbourne 2030 stated that: “The public transport system in and around metropolitan Melbourne must be expanded, resourced and promoted accordingly.”

This 20 percent by 2020 public transport target cannot be achieved by investment in road infrastructure that the EWLNA recommends. In fact, the EWLNA itself models a modal shift of merely 1% from cars to public transport by 2031 with its recommendations in place – in direct contradiction with Brumby Government policy.

EWLNA Recommendations

The CEN believes that the EWLNA is fundamentally flawed in its approach to transport planning, however, below are comments on some of the individual recommendations from the report. Please note that the CEN supports a massive increase in investment in public transport infrastructure and services, and therefore we believe that some of the EWLNA recommendations have merit. However, we strongly urge the State Government to institute a plan for transport in Melbourne that prioritises mitigating the climate change and peak oil emergencies.

Recommendation 1 – Melbourne Metro Rail Tunnel West to South-East

The CEN strongly supports the principle of a large investment in public transport, and we encourage the Government to invest more in public transport.

The recommendation for a new 17 kilometre rail tunnel linking Melbourne’s fast growing western and south-eastern suburbs is described in the report as: “a generational ‘step-up’ in the city’s rail capacity and Melbourne’s first ‘metro’ style passenger line”.

This tunnel would service a transport route where there is existing above ground rail services. By contrast, large regions of Melbourne are not well serviced by existing railway lines, including suburbs where rail lines have been planned but not constructed, such as Doncaster, Rowville and Aurora, and entirely new suburbs in Melbourne’s north and south east.

Melbourne also lacks any metro style passenger lines that connect hubs close to the central business district such as South Yarra, South Melbourne, Carlton, Brunswick and Richmond.

These are all public transport projects that also need urgent funding.

Recommendation 2 – Rail Link Werribee to Sunshine (Tarneit link)

As mentioned above, the CEN welcomes an increase in funding for public transport infrastructure. Melbourne’s west in particular requires greatly improved public transport services. The construction of the Tarneit link is an important first step, and the extension of the metropolitan rail network further to the west needs to be undertaken as soon as possible. However, a number of issues need to be resolved, particularly the impact on Geelong passengers.

Recommendation 3 – Electrification to Sunbury and Sydenham Boost

The CEN welcomes this recommendation and believes the government should initiate works on Sunbury electrification as soon as possible. Other measures to enhance capacity should also be expedited such as duplicating lines that are currently only single track, updating signalling systems and ensuring more efficient loading and unloading of trains at stations.

Recommendation 4 – Cross City Road Tunnel

The proposed tunnel is fundamentally flawed and would be a gross misallocation of resources. The proposal is to construct an 18km tunnel from the city end of the Eastern Freeway to the western suburbs at a cost of around $10 billion. This is supposed to cater for a demand that does not at the moment exist and for personal travel that would be better served by trains, trams and buses. It is also a moot point whether travellers would be prepared to enter such a tunnel given the real risk of an accident in the tunnel that trapped them some kilometres from an exit, especially in light of the recent accidents in the Burnley tunnel.

As mentioned previously, it is also a well known fact that the provision of more and wider roads just serves to increase the traffic on the roads, so annulling the hoped for benefits. The M25 motorway around London is a good example of this effect.

It is true that some people need to travel from east to west or vice versa but it is also true that people would like to travel from one suburb to another in a convenient form via integrated bus, tram and train services. The disjointed and somewhat unreliable bus services are in desperate need of more effective planning and upgraded service levels complemented with priority measures such as traffic light priority. The money to be spent on the grand design of a large tunnel would go a long way in effecting such a scheme.

It seems that the projected usage of the tunnel is predicated on an increase in vehicle traffic just when the appreciation of the effects of global warming are becoming frighteningly clear and the cost of fuel is escalating. The movement of freight by road should have been dampened many years ago by the provision of a modern integrated rail network that coexisted with passenger traffic. In an age where computer, mobile communication and GPS systems are readily available it should be possible to upgrade, and extend, the rail system to cope with far more traffic. The removal of level crossings at selected spots (particularly major tram and bus routes) would ensure a faster and more efficient transport of people and freight especially if coupled with a modernised signalling system.

The current state of the rolling stock and peak hour overcrowding, as more people take to public transport, could also be addressed at little cost, compared with the cost of a tunnel with the extra hidden costs of maintenance and the upgrading of roads near the exits.

There is currently a transport crisis in Melbourne. Rather than build the proposed road links, a cheaper, more effective alternative to the issues identified in the EWLNA is to upgrade and extend the public transport system, take freight off the road and move it onto rail, institute more efficient freight handling practices and introduce incentives for people to reduce car use.

Recommendation 5 – Truck Action Plan in the West

The CEN welcomes the thrust of this recommendation as a way to improve amenity in Melbourne’s west, however we do not support the expansion of Ballarat Road or additional road links to Ballarat Road that would actually harm amenity in the vicinity. These measures should be complemented with a shift of freight from road to rail.

Recommendation 6 – DART bus service to Doncaster

The major opportunity to reduce congestion on this arterial route, is to construct the long awaited Doncaster rail line. Planned as part of the 1969 Melbourne Transportation Study, construction commenced in the 1970s with a cutting dug 400 metres north of Victoria Park Station to connect to the Freeway. Freeway road overpasses were also constructed to meet the requirements of a rail line in the central median. Although the project lapsed, commuter transit demands on this corridor are clear. While the DART bus service would be an improvement to the current situation, a rail line is a more effective outcome.

Recommendation 7 – Improve Cross City Cycle Connection

The cross-city cycle connections recommended would greatly facilitate bicycle travel and make it safer within inner Melbourne. However, to be effective, these routes need to link with equivalent high quality and safe bicycle paths transecting adjacent suburbs. For example, there is currently no safe and efficient bicycle route through Hawthorn and Camberwell towards Box Hill.

Cycling is the most carbon-efficient form of medium distance personal transport. However, low safety and convenience factors are major barriers preventing people from cycling in urban areas.

The current Principal Bicycle Network needs to have routes added to connect with the proposed cross-city cycle connections. Integrated planning for cycle paths and routes is essential to get the best outcome. Improved safety at a local level is also crucial to enable safe access to the Principal Bicycle Network and to activity centres and public transport.

Recommendation 8 – Priority Measures for Trams and Buses

To make sure that we are getting the most efficient road based public transport (buses and trams) we need to ensure that these forms of transport are given priority over the motor car through traffic light priority measures and strict enforcement of fairways.

Recommendation 9 – Improving Park and Ride Facilities

Park and Ride schemes are an adjunct to integrated and modernised bus services. In their absence station car parks are often full by 8am which prevents many willing train passengers from using trains whether for commuting to work or for other reasons. Park and Ride car parks away from the station combined with a regular local and express bus service to the station or other suburbs can boost the capacity of park and ride schemes. These are not uncommon overseas and with planning can be very effective.

Recommendation 10 – Review of 30/2010 rail target

The CEN does not agree with this recommendation, and urges the State Government to remain committed to its 30/2010 rail freight target, and to meet this target through increased investment in rail freight.

Recommendation 11 – Increase Rail’s Share of Freight

The Port of Melbourne Corporation, in its submission to the VCEC Congestion Inquiry 2005) has acknowledged that there are significant opportunities to improve the efficiency of road transport trips to and from the Port, given that trucks on average are loaded at only 50% capacity.

Smart Freight policies must be implemented to promote greater efficiency in the freight industry through better use of freight logistics, based on full cost externalities. In Germany and Sweden, partnerships between logistics contractors and the freight industry, are substantially reducing truck journey times and truck numbers. In Freiburg, truck operations were able to be reduced by 33%. A Swedish example cited in Forseback’s Case Studies on the Information Society and Sustainable Development (2000), demonstrated that through efficiencies in carrying, freight kms were reduced by 39%, truck numbers by 42%, and truck journeys by 58%.

It is also imperative to implement actions that will result in increased rail freight capacity to meet the State target of 30% of port land freight carried by rail by 2010.

Recommendation 13 – Introduction of High Productivity Freight Vehicles

It is unfortunate that the present government is following a path of increasing the port handling facilities near the centre of Melbourne. If we are to lessen our ecological footprint we should be dampening this demand rather than encouraging it. However, given that there is to be a significant increase in freight traffic it seems sensible to build infrastructure that maximises efficiency of movement and at the same time reduces the need for road cartage. Technology has come a long way in the past decade and it should be possible to build systems that make a maximum use of rail without reducing, or in fact increasing, efficiency of movement of containers. The mere expansion of the road system seems to be an unimaginative last century solution and does little credit to transport planners. As a minimum there needs to be a number of automated or semi-automated container hubs so that containers, or the rail truck carrying them, can be shunted and shifted to the appropriate engine and line. Smaller rail engines pulling a lesser number of container rail trucks may be the answer.

Recommendation 14 – Implementation of Melbourne 2030

The CEN agrees with this recommendation. Melbourne 2030 is a plan that can help reduce the demand for travel, by creating activity centres in Melbourne’s suburbs, based around adequate public transport facilities. The CEN urges the State Government to strengthen its implementation of Melbourne 2030 and to commit to keeping the urban growth boundary where it is. The farmland around Melbourne should not be developed into residential estates, not just because of the transport difficulties the outer suburbs face, but also because we need this farmland to ensure food security as climate change induced drought continues in our food growing areas.

Recommendation 15 – European CO2 Emission Standards for Vehicles

It is clear that all motor traffic needs to use as little fuel as possible and the European CO2 Emission Standards for Vehicles is a start. The Rudd Government’s proposed initiative in supporting the building of electric, and electric assisted vehicles, is a welcome initiative. However, the real reduction of emissions must eventually come by reducing the number of vehicles on the road and the EWLNA does not address this adequately.

Recommendation 16 – Increasing Low Emission Vehicles in Melbourne

It is vital for Australians to reduce their emissions of carbon, in its various forms, into the atmosphere if we are to meet the targets being set nationally and internationally to combat global warming. Our emissions per head of population are amongst the highest in the world. CEN would prefer that this recommendation advocate for reducing the amount of high emission vehicles in Melbourne, rather than increase low emission vehicles. That being said, there are several mechanisms which will induce drivers to move over to more efficient and low emission vehicles:

  • the rise in the price of fuel induced by demand outstripping supply (Peak Oil);
  • tax incentives either by a lowering of tax on low emission vehicles and/or by increasing taxes on high emission vehicles;
  • congestion charges on a sliding scale disfavouring large fuel inefficient vehicles;


Thank you for your time. We hope that the State Government uses this opportunity to change course and starts creating a transport system that will help us meet the challenges of climate change and peak oil, while also improving the amenity of our suburbs. Our business as usual transport planning and construction of freeways will cause us more pain in the near future and it is a decision we will come to regret. A sustainable future involves cutting emissions and creating a massive and permanent modal shift from cars to public transport, walking and cycling.

Submission endorsements

See also

External links

  • Eddington Transport Report, Victoria – Wikipedia