GCLR4

To: Hon Mark Bailey MP, Minister for Transport and Main  Roads
Re: Submission to TMR Gold Coast Light Rail Stage 4  community consultation
Please accept this as my formal submission to the TMR Gold  Coast Light Rail Stage 4 (GCLR4) community consultation.
I am a Gold Coast resident and I have substantial concerns  with the GCLR4 and do not wish to see it implemented. 
The proposal affects me personally in the following ways:

  1.

  2.

  3.
In this submission, I highlight my specific concerns,  including how the gigantic costs of light rail extensions will deprive the  broader Gold Coast community of a better, more widespread, modern,  high-frequency public transport network. I draw these concerns to your  attention and offer alternative solutions for your evaluation. 
POOR VALUE FOR MONEY

  The expected costs of Gold Coast Light Rail (GCLR) Stage 3  now exceed $1billion.  
Current estimates of Stage 3 costs per built kilometre are: 

  • 2.4 times those of Stage 1

  • 2.8 times Stage 2 per km costs and 

  • 1.6 times the $709m proposed in the 2019 Stage 3 business  case.
$716m in additional operating and maintenance costs over 30  years are also proposed without a justification presented. 
Despite community requests, no review of project financial  feasibility has been undertaken. Nor have alternative transport options been  reviewed. Nor have falsities in “urban consolidation” arguments been  recognised. Instead, the push is on to waste much more public money by forcing  Stage 4.  Poor revenue potential  imprudently raises risks, rates and debt servicing needs.
I am concerned that a lack of due diligence along with undue  political and commercial considerations is leading to lock-in and a “commitment  to failure” outcome. ‘There Is No Alternative’ claims surround the GCLR,  despite this being manifestly untrue. 
I consider the authoritative warning from PWC Australia that  “lack of flexibility can leave the government vulnerable to private-sector  profiteering on the commercial terms of significant [light rail] extensions”  must be heeded. 
GCLR Stages 1 and 2 actually make some sense and have  further promise (as might Carrara-Nerang). Stages 3 and 4 don’t and won’t stack  up, no matter how hard some might pretend.  
It’s time to accept this and work together on real solutions  that do not squander billions needlessly. 
Subsides and poor performance
Recently released Gold Coast Light Rail passenger data  indicate that Stage 1 and 2 financial performance is poor (Passenger figures  from TMR’s online RTI disclosure log, RTI-1550.

  Tram revenues are failing to cover even the interest  payments due on government borrowings for the first two stages according to  initial estimates by a retired academic from QUT’s School of Economics and  Finance.
Gold Coast Light Rail patronage averages 30% of total  capacity (apparently except for the Commonwealth games when the reported 36%  peak was reached). Bus and Light Rail annual average revenue is estimated to be  around $22m. 

  

  To achieve this return, $1.3 billion has been directly  invested in GCLR Stages 1 and 2 by tax and ratepayers. It appears at least  another $600m has been invested by private parties as part of a Public-Private  Partnership agreement.
Investing $1.9 billion to earn $22m extra annual transport  income to service over $100m in annual interest, operation, maintenance, and  other costs looks decidedly diabolical.
Based on these figures it seems that the Queensland taxpayer  is providing a subsidy of around $8 for every $2 of the fare paid by a  passenger, just to meet the annual interest payment on the borrows for Light  Rail Stages 1 and 2, with no provision for paying down the capital cost over  time.
I ask: How much is it costing bus and other road users along  with rate and taxpayers to subsidise the costs of 21 km of underused tramway?

  Clearly, a proper, transparent performance review is needed  before any more extensions of Light Rail are signed off.
This is especially relevant given the emergence of far  cheaper mass transit options, such as 150 passenger Brisbane Metro  battery-electric buses.
The Stage 3 extension to Burleigh will double down on the  loss position. Infrastructure Australia’s 2019 evaluation of the Stage 3  Business Case reported no new passengers were expected (there would simply be a  switch from bus). A new unexplained 30-year payment stream of $24m each year  also arises with Stage 3. All this for another $1.1 billion of public money.
Going to the Airport and Coolangatta appears even more  financially horrendous, with an estimated cost of $2.5 billion for Light Rail  Stage 4, excluding property resumptions.

  Imprudent investments impoverish all citizens. They also  mean that far less public transport is provided from the same available budget.  Disclosure and accountability are needed. 
I consider it is imperative that Federal and State Auditors  General commence urgent investigations into GCLR Stages 3 and 4 as these  megaprojects seem to represent extraordinarily poor value for taxpayer funds. I  make this recommendation in view of the damning findings from the NSW  Auditor-General into the Circular Quay to Randwick light rail project.
To summarise concerns around poor value (with a Churchillian  twist) my view is that “Never has so much been spent to transport so few and  congest so many.” 
SUBSTANTIAL LOST OPPORTUNITY COSTS

  We don’t have a bottomless bucket of money to fund critical  infrastructure. The pie chart of TMR funding at Wayne Purcell for Better  Planning Gold Coast (https://bit.ly/3keGP65) summarises the issue well, with  three megaprojects accounting for 84% of the TMR major Gold Coast project funds  from 2021 to 2025 (noting 28% to GCLR Stage 3). The Grattan Institute also  warns megaprojects should be the last, not the first resort for addressing traffic  congestion problems.
In terms of Gold Coast population distribution, I note that  there are 362,160 persons living in the northern GC (north from Main beach);  216,227 from Main Beach to Burleigh including western suburbs; and only 66,804  from Tallebudgera Creek to Coolangatta. The greatest need for new public  transport is in the growth corridor at the northern end of the Gold Coast. 
Furthermore: 

  • Robina Town Centre is a major shopping centre with over  320 specialty stores, first-class movie theatres, and 7,000 car parks, but  again is not serviced by high-frequency bus services that would encourage a  mode shift away from cars.

  • Robina Hospital has 407 beds and provides health care to a  large portion of the population, but Robina health precinct and many other  health providers in the area are not serviced by high-frequency bus services.
So Robina also stands out as a location in desperate need of  better, high-frequency public transport. Yet we have before us a flawed  proposal to spend at least $2.5 billion dollars providing light rail to service  a catchment of only 66,804 citizens from Tallebudgera Creek to Coolangatta. And  I contend the future growth potential of this catchment is far less than that  of the northern Gold Coast and Robina. In the context of best allocation of  finite resources GCLR4 does not make sense and looks wasteful to me.
Although simplistic it seems appropriate to contemplate that  the $2.5 billion cost of GCLR4 would purchase 2500 Zero-Emission Buses  identical to those being built by BusTech (Burleigh Heads) for Hornibrook Bus  Line at North Lakes, the state’s first 100 per cent electric bus depot.

  The $190K per metre cost for GCLR4 is astonishing and needs  to be seen in comparison with other alternatives with far greater or more  positive impact such as: 

  • Urban beautification - Tree-lined roads, not overhead tram  wire and more pavement

  • Public amenity - Better all-weather bus stops with  dedicated lanes

  • Road bottleneck reduction (not six additional level tram  crossings and traffic lane reductions)

  • Improved bus services - Fuel cell buses with GPS app  tracking (the Singapore model) and a free Hop on / Hop off 777 bus route from  the Airport.  That’s the hallmark of a  true tourist city. 
I note that the Transport Infrastructure Act 1994 requires  that the Minister must publicly document the “investment criteria for deciding  priorities for government-supported transport infrastructure between and within  the different transport modes and options for financing the priorities”.
Given this legislative provision I consider it reasonable to  ask:

  •Where is the evaluation of the alternative congestion  reduction and safety improvements that $2.5 billion could purchase for the Gold  Coast region? This would reach and benefit more people than replacing a bus  service with a tram ever will.

  • Where is the data supporting tram over faster rail with  Park & Ride which was to be completed by 2015?

  • Where is the evaluation of east/west interconnection and  transport hubbing? 

  • Where is the data that supports replacing the 777 and  other buses with a tram costing $2.5 billion?
Gold Coast public interest advocates share these concerns.  For example, the well-researched posts at Wayne Purcell for Better Planning  Gold Coast (https://bit.ly/3nHnz2W) state (inter alia): “Instead of looking at  rationalising the whole public transport network in a way that offers benefits  to a majority of the coast, we’re prioritising the replacement of buses with  light rail down the GC Hwy.” and “This singular focus on the GC Hwy and light  rail means the vast majority of Gold Coasters are going to continue missing out  on frequent and reliable public transport services. It’s not fair, it’s not  equitable and it’s not good for the future of the Gold Coast (in our  opinion!).”
My concerns with lost opportunities include loss of heavy  rail to the Airport. I fear that the huge cost of GCLR4 will mean the crucial  extension of heavy rail will not occur for decades to come, even with the  impetus of the 2032 Olympic Games.
I am dismayed with the Government’s fixation on the $2.5  billion GCLR4 project and its refusal to evaluate alternative options. I  consider GCLR4 will result in huge opportunity costs for the residents of the  northern Gold Coast, Robina and other areas. They are being denied access to  better, urgently needed public transport because GCLR4 will consume the finite  funds available for the foreseeable future. I consider that a strategic  re-think coupled with a reallocation of available transport funds will produce  a far better outcome for both the northern and southern Gold Coast. Time,  costs, and better sustainable technologies have caught up with light rail. A  pause and a review of alternative options are overdue. 
I urge you to undertake this review and to do so with  transparency and genuine community involvement (as per the International  Association for Public Participation definition of involvement).
LIGHT RAIL FACILITATED OVERDEVELOPMENT

  I am concerned the City Plan will be amended to achieve  greater building height and density along the GCLR4 corridor allowing  potentially no height restrictions (HX area) for new developments along the  light rail corridor. The claim by TMR that this is solely a Council issue  cannot be sustained as a significant component of the cost/benefit  justification for light rail in TMR’s own Business Case is the economic  benefits of “urban uplift”. It is entirely inappropriate for TMR to attempt to  unbundle these two issues that are so clearly intertwined.
The current City Plan Strategic Framework provides for  retention of diversity in the built form of our growing city along the coastal  strip. Locations with unrestricted height limits and high densities such as  Surfers Paradise and Broadbeach are balanced with retention of lower heights  and densities in areas such as Mermaid Beach, Nobby Beach, Miami, Palm Beach,  Currumbin and Tugun.
I contend most residents south of Tallebudgera Creek are  dismayed at the prospect of City Plan changes that will provide greater height  and density. These residents wish to sustain for the long-term the more  natural, relaxed, less developed character and values of their coastal strip.  They do not wish to see a light rail facilitated replication of the Surfers  Paradise/Broadbeach concrete canyon. Most are not opposed to responsible  renewal or good public transport, but they see light rail as a Trojan horse for  overdevelopment. I consider this fear to be well-founded. The current Council  has demonstrated a propensity to grant excessive relaxations in development  approvals, the cumulative effect of which is development intensity that  undermines the City Plan’s Strategic Framework. The introduction of the Light  Rail Urban Renewal Overlay Area (LRUROA) into the City Plan following Light  Rail Stage 1 has facilitated grossly over-scaled development in Main Beach and  generated substantial distress for local residents. These residents are now  actively lobbying Council for the removal of the LRUROA from Main Beach.
The Southern Gold Coast is proud of its pristine beaches,  world-class surf, scenic headlands and wonderful coastal creeks. These features  attract 90% of tourists that visit the city(4). This stretch of the coast is  home to the 8th World Surfing Reserve, established in 2016 and endorsed by the  Queensland State Government and the City of Gold Coast. The fact that the  Queensland Government is now developing legislation to provide statutory  protection to the World Surfing Reserve is a further affirmation of the  outstanding tourism, recreational and amenity values of the Southern Gold  Coast. Residents of the Southern Gold Coast do not wish to see these important values  destroyed by light rail facilitated overdevelopment.
TRAFFIC AND PARKING IN PALM BEACH

  The proposed design narrows the Highway, the City’s number  two arterial road, from four to two lanes in places. This is a huge call. Many  residents are concerned that two lanes will simply not work, particularly as  multi-unit development is accelerating and generally each unit has at least one  vehicle, but usually two. I am concerned this will generate dire traffic  congestion and “rat-running” problems for residents. TMR claims its traffic  modelling on improvements to the M1 shows these problems will not occur, but  that crucial modelling has not been released publicly, nor subject to  independent, expert peer review.
The implementation of the proposed GCLR4 design will remove  many car park spaces along the Gold Coast Highway where four traffic lanes are  retained through Palm Beach. On-street parking is already under pressure in  Palm Beach and this loss of spaces will amplify the problems, especially on  weekends when many families from the inland suburbs head to the beach. Noting  that 36% of the population of the Gold Coast has more than two cars, I am  concerned that with growth in Palm Beach (under the current City Plan)  hundreds, if not thousands of cars owned by new Palm Beach residents will be  seeking parking space on the streets. 
No car parking stations are provided in proximity to light  rail stations in the design.  I am  concerned this will result in many side streets in Palm Beach between the Gold  Coast Highway and Townson Avenue being converted to one-way, single lanes with  angle parking on one side. This is a huge impact for the residents of those  streets, especially those streets close to light rail stations that can expect  to have commuters’ cars coming and going at all times of the day and night. 
I also note, with disappointment, that the claims of  creating a tree-lined boulevard through Palm Beach are deceptive. My  understanding is that such an outcome is not allowed under the provisions of  TMR’s own Road Landscape Manual  https://www.tmr.qld.gov.au/business-industry/Technical-standards-publications/Road-landscape-manual.aspx.,  which seems to prohibit the tall shade trees depicted in video graphics for  traffic safety reasons.
ENVIRONMENTAL & CULTURAL HERITAGE

  The Jacobs Gold Coast Highway (Burleigh Heads to Tugun)  Multi-Modal Corridor Study(1) allocates only two pages (point 3.5) to  Environmental and Cultural Heritage, mostly taken up by an unreferenced Figure  3.10 on ecological values and Figure 3.11 on heritage significance.
National Park and fauna bridges

  I fully support the provision of a fauna bridge at Burleigh  Hill to reconnect it with Burleigh Ridge Park and the greenbelt conservation  corridor extending west to David Fleay Wildlife Park and beyond. I consider  this fauna bridge should be a commitment of the Queensland Government  regardless of whether GCLR4 is implemented or not. I also strongly advocate for  a similar fauna bridge at the Currumbin Hill cutting regardless of whether  GCLR4 is implemented or not.

  

  Cultural heritage and stone fish traps

  Burleigh Hill (or Jellurgal) is of enormous cultural  heritage significance to local first nations people. On the east and west side  of the Tallebudgera bridge, there are three ancient aboriginal stone fish traps.  Towards the entrance of the national park, there are massive shell middens.
The proposed construction of a new LR bridge poses a huge  threat to the aboriginal stone fish trap located on the eastern side of the  existing Tallebudgera Ck bridge. This fish trap is one of the best remaining,  tangible artefacts of first nations peoples’ traditional use of Gold Coast  waterways. Most of these physical artefacts have been obliterated by coastal  development. We live in an age where we know better how to value and conserve  this heritage, not clear it away. Its loss will greatly diminish the remaining  cultural integrity of the Jellurgal precinct. Such loss is no longer acceptable  on our watch.
Environmental and cultural heritage impact assessment 

  I understand that detailed environmental and cultural  heritage impact assessment processes under both State and Federal legislation  are yet to commence.  I expect the EPBC  Act assessment will trigger matters of national environmental and cultural  heritage significance requiring detailed investigation.
I will be following these assessments closely. My grave  concern is the proposed GCLR4 route via the GC Highway will entail unacceptable  impacts to Tallebudgera and Currumbin Creek waterways, Burleigh and Currumbin  Hills and their associated unique flora, fauna and cultural heritage.
ALTERNATIVE SOLUTIONS

  My view is Gold Coast City would be far better served by  redirecting GCLR4 funding into an improved, distributed transport network that  establishes a number of well-located, efficient interchange hubs, rather than  an expensive light rail spine with no hubs that services only a small fraction  of its growing population.
I am particularly concerned by the question “How far will  people walk to use a tram?” My view is that distance is very limited,  especially during our hot, humid summer months. The long separation between  light rail stations, therefore, becomes problematic. A distributed network of  more closely spaced bus stops will help overcome this barrier to public  transport uptake.
New bus technology is emerging around the world, including  more comfortable, stable, low-floor models such as Brisbane Metro Vehicles.  Electric Vehicles (EVs) powered from renewable sources produce very low  emissions (from 6 gCO2/km). There is a great opportunity to use the enormous  GCLR4 budget on solar farms, battery technology and EV charging stations as  well as supporting the government’s policy direction, in conjunction with the  Minister for Hydrogen Mick de Brenni and the Premier, for green  hydrogen-powered vehicles. TMR can innovate and contribute to this sustainable  future by partnering with local companies such as BusTech from Burleigh Heads  that is already building 16 battery-electric buses for Hornibrook’s North Lakes  depot(22), creating local jobs and supporting the industry. 
Shenzhen, China, converted 16,000 buses in a short period of  time. Sydney and Perth are having electric bus trials and according to the 2020  UITP Zero Emissions Bus Forum, “The Department of Transport and Main Roads in  Queensland has announced all buses purchased by 2030 will be zero emissions. Several  electric bus trials have been announced including 10 new electric buses to be  operated in South-East Queensland in 2021.” 
I would like the Southern Gold Coast to be included in this  plan to promote our city as the “Jewel in the crown of Queensland tourism” in  alignment with our environment, the future and our lifestyle. Brisbane City  Council already has a complete, publicly available business case substantiating  its prudent choice of the modern, far less costly Brisbane Metro Vehicle for  the city’s public transport spine. The zero-emission vehicle is future proof  and an Australian pioneer with a capacity for over 150 passengers. 
I consider the best practice, most cost-effective,  efficient, adaptive and sustainable solution suitable for the Gold Coast is  Hydrogen fuel cell buses operating routes along with a combination of clearly  marked shared roadway and dedicated peak time bus lanes. I suggest that  evaluation of alternative modes will also identify that expensive new bridges  across creeks will not be required.
I am also aware that the City of Sterling in WA has a  current application with Infrastructure Australia for a 7 km Trackless Tram  system connecting the Perth CBD to Scarborough Beach through the Sterling CBD.  I understand this project will be delivered for one fifth of the cost per  kilometre as the GCLR4. This is an amazing price differential. A potential cost  saving of 80% cannot be ignored. Trackless Tram must also be evaluated as an  alternative to GCLR4.
HEAVY RAIL

  Since 2009 the Queensland government has been undertaking a  review of the preserved Gold Coast Heavy Rail Corridor between Varsity Lakes  and Gold Coast Airport. Heavy rail will connect the Airport to the rest of  Queensland, including Brisbane (host city of the 2032 Olympic Games) and  potentially to Casino in NSW. It begs the question, why the urgent need to  spend billions on the light rail when there is the distinct possibility that  the heavy rail will be extended from Varsity Lakes to the Gold Coast Airport. 
Heavy rail is faster, can carry a lot more people including  freight and it is not far from where GCLR4 stations are proposed. Integrated  bus systems can work perfectly well with efficient interchanges at heavy rail  stations.
A survey of residents undertaken by the Federal Member for  McPherson Karen Andrews identified that of the 1400 respondents 80% wanted the  heavy rail connection from Varsity Lakes to the Airport completed in preference  to Light Rail Stage 4. Importantly, 81% responded “No” to the question “Do you  support the Light Rail continuing south along the Gold Coast Highway to the  Airport?”
I fully support the completion of the heavy rail to the  Airport as an urgent priority for the Queensland Government. My great concern  is that the Government’s indefensible fixation on the grossly expensive GCLR4  will mean there is no funding available for completing the heavy rail link to  the Southern Gold Coast for decades to come.
CONCLUSION

  Urban public transport technology has evolved rapidly in the  information era resulting in alternative, better, cheaper, sustainable options  now being available. Responsible governance demands that decisions made over 20  years ago regarding light rail as the preferred solution for the Gold Coast  must be critically re-evaluated against other viable options. It is deeply  concerning that the Terms of Reference for the Multi-Corridor Study (Burleigh  to Tugun) did not permit this to happen. 
I am dismayed that the Government’s fixation on the $2.5  billion GCLR4 will result in a huge opportunity cost for the residents of the  northern Gold Coast, Robina and other areas. They are being denied access to  better, urgently needed public transport because GCLR4 will consume the finite  funds available for the foreseeable future. I consider that a strategic  re-think coupled with a reallocation of available transport funds will produce  a far better outcome across the entire Gold Coast. Time, costs and better  sustainable technologies have caught up with light rail. A pause and a review  of alternative options is overdue. 
In summary, my message is:

  Stop the Light Rail at Burleigh Heads - Complete the Heavy  Rail from Varsity to the Airport - Integrate modern, comfortable Zero-Emission  Buses (ZEBs)
ACTION REQUESTED

  I respectfully request a commitment from you as Minister for  Transport and Main Roads to:

  • Fully evaluate all the concerns I have raised 

  • Undertake a transparent evaluation of my concerns  regarding poor value for money in cooperation with the independent Queensland  Auditor-General, with the report to be made publicly available

  • Undertake an evaluation of all alternative mode options,  including solar-powered ZEBs and green hydrogen-powered options

  • Pause all planning, business case and land acquisition  actions for GCLR4 until these reviews are completed

  • Ensure that the Terms of Reference for the Multi-Modal  Corridor Study (Tugun to Coolangatta) include a requirement to evaluate all  alternative mode options, such as modern ZEBs and Brisbane Metro  battery-electric buses

  • Release to the public the TMR Business Case documents for  GCLR Stages 1, 2 and 3 and the TMR Post-implementation review documents for  Stages 1 and 2

  • Release to the public the investment criteria for deciding  priorities for government-supported transport infrastructure between and within  the different transport modes and the specific evaluation that was undertaken  for the GCLR4 project

  • Provide to me a timely, written response to this  submission and a clear indication of your intentions regarding each of the  actions requested.
Thank you for your consideration of my submission.