CONTACT TMR AND POLICYMAKERS
Let them know your thoughts. We have prepared a letter for you to send them.
STEp-by-step HOW TO SEND
STEP 1 – Click “COPY” to copy the email recipients
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STEP 2 – Create a new email and “PASTE” the recipients (Ctrl+V) on “to”
Compose a new email in your email client and paste the recipients so that the email can be sent
STEP 3 – Add the subject
“GCLR4 response to community consultation” or what you think is best
STEP 4 – Copy and paste the SOSGC email template to Mark Bailey
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:
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.
• 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.
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.
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.
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)
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.
STEP 5 – Add 3 personal reasons so that the email can be counted as new feedback
This is important as they will receive it as a genuine email, not just the template.
STEP 6 – Sign the email with your name and address at the bottom and SEND IT
You legend! Now they hear you and they should respond to you! Well done!
Save Our Southern Gold Coast SOSGC has been raising concerns about the implementation of the Gold Coast Light Rail Stage 4 (GCLR4) on the southern end of the coast.
We believe TMR community consultation did not take the community feedback seriously. By signing this letter you will deliver a formal submission to firstname.lastname@example.org and request a response from policymakers to our concerns which include:
- POOR VALUE FOR MONEY
- SUBSTANTIAL LOST OPPORTUNITY COSTS
- LIGHT RAIL FACILITATED OVERDEVELOPMENT
- TRAFFIC AND PARKING
- ENVIRONMENTAL & CULTURAL HERITAGE
- ALTERNATIVE SOLUTIONS
- HEAVY RAIL
Financial, environmental and performance data do not stack up. We are looking at $2.5 billion dollars excluding resumptions for only 13Km for an archaic and disruptive transport system that will not be needed and will push a light rail facilitated overdevelopment on the SGC.
The letter will be sent to:
|Mayor Tom Tate||Mayor|
|Cr Mark Hammel||Division 1 Councillor|
|Cr William Owen-Jones||Division 2 Councillor|
|Cr Donna Gates||Division 3 Councillor|
|Cr Cameron Caldwell||Division 4 Councillor|
|Cr Peter Young||Division 5 Councillor|
|Cr Brooke Patterson||Division 6 Councillor|
|Cr Ryan Bayldon-Lumsden||Division 7 Councillor|
|Cr Robert La Castra||Division 8 Councillor|
|Cr Glenn Tozer||Division 9 Councillor|
|Cr Darren Taylor||Division 10 Councillor|
|Cr Hermann Vorster||Division 11 Councillor|
|Cr Pauline Young||Division 12 Councillor|
|Cr Daphne McDonald||Division 13 Councillor|
|Cr Gail O’Neill||Division 14 Councillor|
|Ms Rosslyn (Ros) Bates||Member for Mudgeeraba|
|Mr Michael Crandon||Member for Coomera (LNP)|
|Mrs Laura Gerber||Member for Currumbin (LNP)|
|Mr Michael Hart||Member for Burleigh (LNP)|
|Mr John-Paul Langbroek||Member for Surfers Paradise (LNP)|
|Mr Robert (Rob) Molhoek||Member for Southport (LNP)|
|Mr Raymond (Ray) Stevens||Member for Mermaid Beach (LNP)|
|TMR||Gold Coast Light Rail Stage 4|
|Mark Bailey||Minister of Transport|
|Felix Gibson||Caucus Liaison Officer|
|Hon Mick de Brenni||Minister for Energy, Renewables and Hydrogen|
|Hon Cameron Dick||Treasurer and Minister for Investment|
|Hon Dr Steven Miles||Minister for State Development, Infrastructure, Local Government and Planning|
|Hon Meaghan Scanlon||Minister for the Environment|
|Hon Annastacia Palaszczuk||Premier and Minister for Trade|
|Save Our Southern Gold Coast|
We expect our politicians to respond to our community and request a commitment from Transport and Main Roads to fully evaluate all the concerns including;
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 a timely, written response to this submission and a clear indication of your intentions regarding each of the actions requested.