Approval Process
To the Honourable Minister for Environment, Local Government and Woman, Desley Boyle
We are writing to you as the chair of the Ministerial Council that will consider the construction of the Smithfield to Kuranda 4-Lane-Highway.
We feel obligated to alert you to the fact that the IAS and its addenda supporting the proposal lack objectivity are very biased and at times misleading
and even factually wrong. Moreover they fail to mention, ignore or marginalise negative impacts and ignore or brush over feasible alternatives. We
request that you do not base your decision on those DMR commissioned reports without truly independent assessments.
Furthermore the whole approval process for this project, which would end up costing at least 600-900 million dollars of our tax payer’s money,
favours the present option over all alternatives. It also fails to allow for significantly changed circumstances, particularly the effects of climate
change and peak oil.
We ask you, our elected representative, to please read this letter as it contains arguments which have not yet been considered and which we entrust
in you to consider before deciding on what would be FNQ's largest ever infrastructure expenditure.
Perceived Need for 4-Lane Highway
In the mid nineties the trucking industry wanted a way to get to Cairns with road-trains which the existing range road does not allow. It became
clear that the huge expenditure for widening and geometric improvements of the range road could not be justified with transport savings. (DMR's
own study showed that expenditure of only $20-30 million on the road could be justified by freight-savings.)
In the late nineties the 2010 plan called for urban development in Kuranda which then justified the perceived need for a 4-Lane-Highway.
However the 2010 plan never even considered the Mareeba area which already has much of the needed infrastructure and which is much less environmentally
sensitive than the Kuranda environs abutting WHA, a significant shortcoming of the planning process. Nor did the 2010 plan consider encouraging development
in Innisfail and on the southern tablelands by upgrading the roads between the Palmerston highway and Mareeba.
None of the rail options which were considered in the 2000 transport study featured regenerative braking (which minimises or eliminates the need
for ventilation shafts) or drive on/off carriages (which would allow vehicles and even B-doubles to go by train and free the range road from trucks)
- rail tunnel options were discarded because trucks would still have to use the range and because of ventilation problems. They were also discarded
because of the wrong and very biased costing done at the time. Rail was costed at around one billion (a longer rail tunnel in Switzerland was constructed
and fitted for 750 million Australian dollars) while the freeway was costed at 249 million (which has already blown out to nearly 600 million and
that is unlikely to be final nor does it include the cost of required feeder roads).
Positive and Negative Impacts
The IAS wrongly or misleadingly claims the following impacts to be positive:
- Wildlife connectivity would be better - VERY LIMITED and not 'highly beneficial' as claimed.
Much higher and more constant air, noise and light pollution would discourage animals from even approaching the road corridor - this is a very
significant effect which has not been sufficiently considered. Any canopy connectivity under bridges would be very close to underneath of noisy
roadway. Connectivity for many species (eg frogs, insects etc) would be significantly worse because of higher traffic and wider road surface
to cross. It would be easier for most animals to get onto the road than off it.
During the 10-20 years of construction connectivity would be significantly worse.
- Views from the road would be better - THE OPPOSITE IS TRUE.
The continuous concrete barriers would bar almost all distant views for most users and close views would be of concrete, cuttings and road rather
than the present greenery. Overall views from the road for all cars would be much poorer.
- Scenic drive - THE OPPOSITE IS TRUE.
The IAS claims that the present road is not considered scenic while the new one would. This is wrong and misleading. The present road is widely
seen as a scenic route and as such is a valuable tourist asset (just do a Google search for 'Kuranda range road'). The proposed road would be
like a concrete walled racing track and most users would not see any scenery due to the over 1.7 meter high barriers.
- Water quality would be improved - THE OPPOSITE IS TRUE.
The positive assessment is based on the fact that some road run-off will be treated to remove up to 50% of pollutants. It ignores the 6-8 fold
increase of pollutants due to more traffic which would more than cancel out any improvement. It also assumes water collection systems which even
the IAS admits to be "greater than practical". It ignores the leaching of poisonous concrete additives. It ignores construction run-off
which is likely to kill amphibians and fish for two decades.
- Stabilisation - MISLEADING.
The IAS blames land slides along the existing road on poor design and fails to admit that the inherently unstable geology combined with heavy freight
impacts are significant factors.
Combine the inherently unstable geology of weathered rock with the high tropical rainfall (up to 500mm/day over four days) and it is only a question
of when a large landslide will tear down parts of the proposed freeway, not if. This very real possibility has been ignored.
Additionally the IAS either fails to mention, mentions but fails to correctly evaluate, or minimises the following negative impacts - many of which
are outside of WTMA's narrow terms of reference and consequently have never been independently considered:
- the extremely long construction period has many very negative impacts on WHA as well as on the local economy and community eg significant delays
and total closures for long periods and one-lane traffic for probably month or even years, noise, visual impacts, water run-off, connectivity,
loss of rare or endangered fauna and/or flora
- extra traffic through Cairns, especially long-haul trucks and road-trains, causing more noise, air pollution and congestion
- congestion on feeder roads in Kuranda area, Smithfield/Freshwater/Earlville and Smithfield/Cairns roads until they are upgraded
- the costs for upgrading these feeder roads need to be accounted for in any objective costing of the 4-Lane-Highway
- maintenance is likely to be very expensive and should be publicly quantified before irreversibly committing tax payer’s money for decades
to come
- marginalisation of Aboriginal people in the Kuranda area from about 25% of population to less than 3% - a highly adverse social impact
- the resulting loss of the famed "Village in the Rainforest" would most likely significantly diminish Kuranda's tourism income
- views from the coast and Skyrail - loss of Cairns famous backdrop of uninterrupted green hills
- pictures of the destruction by tourists and their word of mouth affecting FNQ's standing as an eco-tourism area
- the lack of development controls in Speewah has the potential to negate any possible connectivity gains in Myola. Speewah's proximity to WHA
makes such controls even more important than in Myola.
- the lack of development controls and domestic animals along Black Mountain road and Top of the Range are likely to thin the main north-south
wildlife corridor and affect adjoining WHA
- thousands of domestic dogs and cats close to WHA would kill wildlife near and inside of WHA, negatively impacting on WH integrity - cats and
dogs are known to roam for kilometres
- significant but avoidable additional pressure on fauna and flora of wet tropic rainforests at a time when climate change threatens many species
in what are already only remnant areas
- the heat created by about 75 acres of road surface, which in contrast to the present road would be almost entirely unshaded, could cause significant
local environmental changes.
- the effect of construction noise for 10-20 years on wild life - especially low frequency noise from blasting and heavy machinery affecting cassowaries
- at night glare and reflections from moving headlights would light up large areas of World Heritage and be visible from large areas on the coastal
plain
- the proposed 4-lane highway promotes increased CO2 output
- the proposal facilitates car dependent suburbs despite petrol very likely to be unaffordable for most people before the project is completed.
(in Penrith residents are already forced to move because of unaffordable commuting costs and here the main reason for the 4-lane highway is to
create suburbia with very significant commuting distance to jobs in Cairns or Mareeba)
- the proposed 4-lane highway is very poor value for money. A limited upgrade can provide much of the traffic and connectivity gains for a fraction
of the cost and the single rail tunnel to Mareeba option can shift many more people for comparable money while at the same time providing an effective
evacuation route for Cairns with minimal negative impacts
- DMR has no experience of building such a road in an area of such inherently unstable geology and high rainfall. Its poor track record of road
building is well known and contains significant failures in much less challenging circumstances.
Contrasting the many negatives and considering its very large budget the positive impacts of this proposed freeway are very limited:
- economic benefits due to larger traffic capacity - significant improvements can be achieved with much less money and larger capacity can be achieved
for similar sums with the single rail tunnel
- allowing road trains down that range - upgrading Mareeba to Palmerston Highway or a rail tunnel with drive on/off carriages would provide that
positive impact as well
- possibly in the very long term of some wild life connectivity improvements - significant improvements can be achieved in a limited upgrade with
much less money; also see limitations discussed above
Prudent and Feasible Alternatives
- Limited Upgrade
This option was never properly investigated or costed. It was ruled out because DMR and WTMA considered many incremental upgrades without any connectivity
improvements as worse than the 4-lane highway option. This is correct but totally misleading. Limited upgrades, when properly planned can provide
very significant gains in connectivity, a fact totally ignored in the analysis. In fact a well-planned limited upgrade can provide much of the
traffic and most of the connectivity improvements of the 4-lane highway for a fraction of its cost and without the many significant negative
impacts
- Development in Mareeba with single rail tunnel featuring drive on/off carriages
This option has many significant advantages over the 4-lane highway which are spelled out in attached document, but the most important ones are
that it would provide Cairns with an effective evacuation route in case of a major cyclone and it would be a good hybrid transport option for
both private and public transport, which is very valuable at a time when private transport is likely to diminish due to peak oil escalating fuel
prices.
- Development in Innisfail and on southern and western tablelands combined with an upgrade of tablelands roads from Palmerton highway to Mareeba
This option has never been considered and we thought of it only after cyclone Larry and in conversations with Innisfail and southern tablelands
residents.
Why develop Kuranda which is already one of the most affluent areas on the tablelands and whose tourist trade is likely to be negatively affected
by the planned urbanisation when there are many other areas which would be much more welcoming to development, areas like Innisfail and the southern
tablelands which have been largely ignored in the 2010 plan. Upgrading the road from the top of the Palmerston highway to Mareeba would open up
some of those areas, would also give road trains from Cape York easy access to the coast and deep water ports and would encourage development in
the Innisfail area which seemingly can do with more development.
Changed Circumstances
- The actual population increases experienced over the last five years are significantly lower than even the lowest projections in the 2010 plan
and 2000 transport options study.
- Even more importantly the accelerating impacts of climate change and peak oil provide significantly changed conditions since the time when all
other alternatives were ruled out. Neither effects were as clearly important at that time as now and consequently need to be considered and addressed
in the context of this project.
These intensifying circumstances (and the fact that some available alternatives were not considered fairly or at all) postulate urgent reviews
of the 2010 plan and associated transport options. Since these documents led to the 4-lane highway becoming the 'preferred option' about five years
ago, a final decision on that project needs to be postponed until these reviews are completed.
- Very significant cost increases since the choice for the present 4-Lane-Highway option was made. That decision was made to a large degree on
costing, which has already more than doubled and will likely be more than three times the initially estimated 249 million dollars. This changed
circumstance alone justifies a reconsideration of alternatives
Closing
Please be aware that the Ministerial Council is the first body outside of DMR that has the right and obligation to consider most of these issues
(due to WTMA's very narrow terms of reference).
In closing we ask you to not approve the proposed 4-lane highway for the following reasons:
- The proposed highway is very expensive and has very few positive but many significant negative impacts on the areas ecology, economy and community
- the perceived demand for such a large project relied on population estimates which were severely overstated
- alternative areas for development were never properly investigated (eg Mareeba, southern tablelands and Innisfail) and seem to be better options
- some alternative transport options were either not considered at all, were not sufficiently investigated or were ruled out due to wrong and unproven
assumptions. By now some of those seem to be much better options than the 4-lane highway
- peak oil requires money to be put towards rail and public transport rather than fuel dependent highways. The findings of the Oil Vulnerability
Taskforce and the RRAT Senate Committee should be considered before you commit such massive expenditure to create suburbs depending on long distance
commuting.
- global warming demands low CO2 transport solutions eg nodal development along railways and avoidance of any additional pressure on threatened
eco-systems.
We ask for an immediate public review of the 2010 plan (as it should have been already) including consideration of developing Mareeba rather than
Kuranda in combination with a single rail tunnel (using drive on/off carriages and regenerative breaking) be independently investigated as an alternative
to the 4-lane highway.
This option has so many advantages over the freeway option that its detailed independent analysis is the least the Queensland government owes NQ
residents.
We also ask that a feasibility study be done into a limited upgrade option especially in regards to how much connectivity and traffic gains can be
achieved with a small fraction of what the freeway would cost as well as a study into the likely effects of peak oil on the local population growth
and distribution (due to increasingly higher fuel costs reducing tourism, commuting, truck transport and recreational car use).
And we ask that (prior to any final decision) a study is conducted into the effect on (eco-)tourism during building and after completion of the proposed
Freeway.
To allay concerns that traffic conditions and connectivity issues become worse in the meantime, we suggest that DMR construct 3-5 well-planned wildlife
underpasses and overtaking lanes as soon as possible.
For more information on most of the mentioned negative impacts and feasible alternatives please refer to submissions to WTMA and DMR made by 'The
Kuranda Range Defenders', 'Friends of the Earth Kuranda' and Svargo Freitag and/or please feel free to contact Svargo Freitag on 07-40937755 or by
email to management@didjshop.com.
Thank you very much for listening to and hopefully considering our concerns.
Yours sincerely
This letter was presented to Desley Boyle personally on 19th June with the names of those 66 signatories which were collected within one week. Desley
was asked for answers to those concers and for a meeting to discuss them. |