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Feb 05...No Port Enfield Community Group (NoPE) submission to 2nd hearings of Commission of Inquiry

No Port Enfield Community Group (NoPE)

Submission to the Commission of Inquiry
Session in Reply:

Proposed Construction and Operation of a
New Container Terminal at Port Botany,
Botany Bay City

February 2005

No Port EnfieldCommunity Group (NoPE)P.O. Box 81, Enfield NSW 2136Email: Contact:Jenny Maddocks Ph 0425 207 279 Gary Blaschke Ph 9759 0997

No Port Enfield group submission to the Commission of Inquiry into the Proposed expansion of Port Botany Session in reply, February 2005

The No Port Enfield group is here today, at the session in reply, to address the areas of concern to us, to talk about the issues raised during the question and answer process, and to talk about other matters that have arisen since the first hearings of this Commission of Inquiry.

Of course, we remain thoroughly opposed to the Port Botany expansion proposal, because we believe that not only is the Port expansion unnecessary and monstrous, but of course because we believe that this is only one part of Sydney Ports Corporation plan to handle predicted freight growth in Sydney. The other part of their plan is a major intermodal terminal at Enfield.

Even though a separate DA is being prepared for the new Enfield intermodal logistics centre, the existence of Enfield and / or other intermodal terminals to which some significant percentage of this freight will be sent by rail (40% of 3.2 Million) is an integral part, a basic assumption of this development proposal.

The basic premise upon which this proposed development is based is that infrastructure including rail lines and intermodal terminals, not to mention a massively enhanced road system, will exist to move the containers from and to the Port.

We maintain therefore that Enfield is part of the Botany proposal, the entire 20 plus kilometres of freight rail corridor in metropolitan Sydney is part of the proposal, and that the offsite impacts of those components must therefore be assessed and addressed in the EIS for this Development proposal. We do not believe that those impacts have been addressed in this EIS.

Our questions to four organisations, Sydney Ports, DEC, RailCorp, and DIPNR covered the following
general areas:

Capacity at Port Botany and the capacity of the rail / intermodal network. I don’t intend to speak on the capacity issue as it has and will be well canvassed by others.

Air quality issues relating to train emissions.

Noise / vibration from rail.

It is sufficient to re-iterate our concern that capacity is the most crucial issue to be considered because it goes to all other aspects and impacts of the proposal, indeed to the need and justification of the proposal.

In our view these issues arise from the Port Botany expansion proposal and the consequent modal shift to rail. In our view these are not adequately dealt with in the EIS and have therefore been subject of our submissions, and our questions to the parties. In putting these questions to the various organisations we sought to ask each organisation the same question in order to be able to compare answers. We got some answers, we got some "refer to" s and Mr Commissioner, as you are aware, then there was RailCorp. RailCorp is the "state-owned corporation that has as its main focus the provision of a safe, clean and reliable passenger rail network throughout NSW."

RailCorp is the organisation that provided us with a fabulous "Rail Inspection Tour" on the 27th January organised by Sydney Ports Corporation. Our thanks to all involved for a good job, especially to the very knowledgeable RailCorp freight operations people.

NoPE as part of the questions process, asked RailCorp 40 specific questions in writing, following established Commission of Inquiry procedures, on issues relating to air quality and rail noise and vibration, and we received, as you are already aware, a three line response, referring us to RailCorp "extensive submission" to the COI, which I think panned out to a total of three pages.

Clearly then the questions we raised on these issues have not been answered or addressed by RailCorp, who would reasonably be expected to know, or have access to, this information as it goes to their provision of a "safe, clean and reliable" network.

I've outlined some of the issues that to us, remain unresolved, unanswered, or not adequately assessed or addressed. In asking the questions I've also provided some potential answers, when I could find answers, but we would like to emphasise the point that it shouldn't be left to the community to raise and answer many of these points.

That's why we have government agencies, and departments. That's why we have environmental agencies and planning departments. How can we have confidence that this process of " the most rigorous environmental assessment" is actual rigorous when parties to this Commission of Inquiry don't know, or won't supply, answers to what seems to be fairly straight forward questions, sought as part of the well established process.

Director General Requirements Port Versus Roads

Recently I have obtained a copy of the Director General's requirements in relation to the M4 East extension / tunnel proposal.

The Director General in the letter of 25.6.2004 to the RTA giving requirements for preparation of an EIS for the M4 East extension : lists , amongst others, the following key issues to be addressed in preparation of the EIS;

Quote Attachment1

Pg 1.13 Strategic Landuse / Infrastructure Integration Issues
6. Justification with respect to addressing existing and future freight issues with construction of the M4 East extension against other alternatives (in full or staged), including extension of the tunnel to Port Botany, sequencing from Port Botany and expanding of the M5 East etc.

Pg 1.14: Strategic Transport Issues:

8. Strategic traffic/transport (including freight task) context and priority of the proposal with respect the city and broader metropolitan road network.

11. Assess the cumulative impacts of the proposed M4 East Motorway including the implications for key impact issues (such as traffic management, air quality, and noise) during both the construction an operational phases of the sensitive aspects of existing/ approved transport projects particularly the Lane Cove Tunnel, Western Sydney Orbital, Cross City Tunnel, M5 East, King Georges Rd City West Link Port Botany Freight Rail Line and major transport changes associated with the proposed Port Botany expansion, increases at Sydney Airport, and the south Sydney Growth Centre.

Pg 1.14 Freight

14. Impacts on major existing and potential future (taking into account Port Botany expansion predictions) freight movements particularly between Port Botany and the inner west / west (ie Villawood, Yennora, Chullora, Enfield), including changes to routes, impacts on roads (including existing/ approved tunnels such as the M5 East, Cross City and Eastern Distributor). Particularly growth on routes such as Marrickville, Sydneyham, Addison and Edgeware Roads, Railway Terrace and West Street. Potential for redistribution of freight traffic from the M5 East to the inner west such as through the Marrickville and Leichhardt local government areas.

15. Travel times on key freight corridors between the port and freight centres with and without the proposal on opening, 2016 and if available (with reasonable confidence) 2021.

So, the Director General / DIPNR recognises that the expansion of Port Botany and its associated transport and traffic impacts of extra freight movements on many roads in Sydney are key issues to be addressed in the preparation of the EIS for the M4 East.

The question that arises is why where the same issues and impacts not required to be assessed in the EIS for the actual PORT, the development that will produce these impacts ?

Air Quality Issues -

The issues arising from the proposal and in our view not adequately addressed in the EIS are:

How will a 220% increase in trains and a 100% increase in road traffic actually result in air quality improvements?

Is the general contention that shifting freight to rail results in a reduction in greenhouse gas emissions valid?

This contention warrants just two pages in the EIS - App B to App P and is, once again based on the magic number of 3.2 Million TEU's. Their approach compared the expansion proposal to the "do nothing" scenario apparently without allowing for growth in container trade through Port Botany without the physical expansion, when clearly TEU numbers will continue to rise even if this physical expansion doesn't proceed.

Is the general contention that shifting freight to rail results in a reduction in air emissions (all types) valid?

What off site impacts in terms of diesel exhaust emissions from both trucks and trains will this development have, in the local Botany region, the M5 airshed, along freight rail corridors, in the whole Sydney airshed?. Have these impacts been adequately addressed. In our view certainly not. Diesel exhaust fumes are generally recognised as having serious human health impacts and a wealth of literature exists.

What particular pollutants do diesel locomotives produce? As listed in the NPI Emissions inventory:

Antimony and compounds
Arsenic and compounds Benzene
Cadmium and compounds
Carbon monoxide
Chromium (III) compounds
Chromium (VI) compounds
Cobalt and compounds
Copper and compounds
Lead and compounds Zinc and compounds
Manganese and compounds
Mercury and compounds
Nickel and compounds
Oxides of nitrogen
Particulate matter 10 mm (PM10)
Polycyclic aromatic hydrocarbons
Selenium and compounds
Sulphur dioxide
Total volatile organic compounds (VOCs)
Zinc and compounds

With the majors being CO, Particulate matter, Nox

What air emissions standards exist internationally for locomotives and trucks? Because we know that there are no emission standards that apply to diesel locomotives in Australia. In 1997, the US EPA established emissions standards for NOx, HC, CO, PM and smoke, for new and re-manufactured diesel-powered locos and loco engines and these standards are being progressively tightened, as are emission standards for diesel trucks.

How can we make a comparison between diesel trains (locomotives) and diesel trucks? What questions do we need to ask to make an accurate comparison ? Perhaps the following?

Have actual Australian locomotive emissions been tested.? In order to establish a baseline it would be essential to have valid independent information on what is emissions are produced, data to compare types, ages, maintenance records etc. Have dispersion models been developed for locomotive emissions?

What is the age of the locomotive fleet operating in NSW / Australia ? -Raising maintenance issues. Remanufactured up to 10 times in 40 yr life. In the US 47% of operational locos are 20- 50 years old!

Land Transport Environment Committee " Scoping Rail Environment issues Discussion document Sep 2004"

"Modern locomotives have a design life of about 30 years. Most can undergo a process
termed ‘remanufacture’ a few times during the lifespan of the machine. The changes can vary from overhauls, to improvements to complete engine replacements, but the cab and usually the under-frame remain. There is a very slow turnover of the fleet and a long lead-in time for new designs. However, ‘remanufactures’ may incorporate changes and improvements.

In addition, at 5.4,

"NSW raised concerns that many old locomotives are coming out of retirement, with no retro fit requirements in relation to either air or noise emissions."

What is the fuel consumption of a diesel locomotive doing line haul work, and yard work. Is there a difference between consumption on long haul routes and short intra city or shuttle work. Accurate figures representing actual consumption under actual operating conditions should be sourced.

What diesel fuels are being used by locomotives and what standards apply to those fuels?

How many trucks equal one loco, in terms of emissions? Can we generalise? Should we compare different emission pollutants? Which one or ones?

At a workshop organised by the Land Transport Environment Committee , National Transport Commission, in November 2004, Mr Ian Loy, Caterpillar, (the engine company) presented a very interesting comparison. In his view, when comparing Nox and PM diesel truck engine emissions with diesel line haul locomotives, EPA 2010 v EPA Loco regs, posing the question how many trucks equal one loco in terms of those emissions, his answers were startling.

One unregulated loco equals 6000 trucks
One Tier 0 loco equals 3000 trucks
One Tier 1 loco equals 1750 trucks
One Tier 2 loco equals 600 trucks

Mr Loy also presented two other very interesting pieces of information.
1. "Diesel emission characteristic; reduce NOx increases PM, reduce PM increases NOx"

2. Emission Regulations, (in Australia):
"Apply to all trucks
- Urban, rural, application do not matter
Have created little if any discomfort
- Up to and including ADR 80/00
Will create significant issues
- ADR 80/01 & ADR 80/02
Ports are SIGNIFICANT point source
- Ships, Rail, Trucks "

Have any studies been done in Australia that test the above questions?

Most work done on the subject of diesel locomotive emissions in Australia, has considered greenhouse gas emissions only and thus restricted their work to CO2 emissions.

Comparisons have been made between actual road and rail modes on long distance corridors, but only energy efficiency and CO2 emissions have been considered. ( Affleck 2002 for QR)

There have been no comparative studies that we could find where short haul (intra city) routes are compared, or where Nox, PM, HC or other emissions have been studied.

The NPI Emissions Estimation Technique Manual for Aggregrated Emissions from Railways 1999, currently used to determine railway emissions on Australia for the National Pollution Inventory, uses methods based on a national locomotive fleet mix and average fuel consumption figures developed by the USEPA (1992).

However, at 4.3 Recommendations for further work, it states;

To improve the accuracy of these techniques it would be necessary to measure emissions from diesel locomotives operating in Australia. Research is also required for determining an accurate speciation profile of volatile organic compounds and particulate emissions.

We make the point that PM is presently considered the most dangerous of the emissions to human health, and an accurate determination of all sizes of PM emitted by locomotives in Australia is essential.

Whilst it appears that fuel consumption per tonne kilometre is reduced by a modal shift to rail, it also appears that actual total emissions are higher on rail than road.

"Calculations indicate that rail uses 49% less fuel per tonne carried than road-freighting, but that total emissions (per tonne) are higher than road transport.
BTCE (1996) Transport and Greenhouse: Costs and options for reducing emissions No 94 Ch 12. Emphasis addded.

Included as an Appendix to this document is a recent literature survey by Prof. Philip Laird on studies relating to fuel / emissions / rail transport in Australia.

Is any overseas data relevant here? Can we use USEPA data that is based on a overseas locomotive fleet mix, overseas conditions, and overseas fuel. These are the questions to be asked and addressed if we are to achieve a truly relevant outcome.

Again, we make the point that when discussing air quality impacts, the EIS uses a figure of 3.2 Mill TEU's to model air impacts, and as we have heard, the actual capacity figure or the number that may ultimately be handled may be hugely higher than that.

Noise issues

In our submission to this COI NoPE raised concerns about rail noise impacts on the many people living and working along the freight lines in Sydney. Freight rail noise is of course very different from the noise made by passenger trains, and passenger trains are not of concern to us here.

Freight rail noise, in our opinion and based on first hand experience, raises the following issues:

Timing - out of peak hours and at night. No curfews operating to protect residents.

Very different forms of noise, often together - low frequency locomotive noise, and high pitched wheel noise. A third category for wagon bunching / clanging is appropriate. Each type of noise and the interaction between the types varies in impact depending on the physical location and variable conditions.

Much longer passing times - two minutes plus is normal.

Vibration is much more than rattling crockery. Sensitive receivers include laboratories, optometry or optical services and other precision industries, operating theatres or surgeries, cinemas. Western Australian experience shows that predictive modelling of vibration is not completely reliable. (Neil Hammer, New Western Rail presentation to LTEC workshop, November 2004)

In our questioning of other parties to the COI we asked specifically about the current and future noise complaint mechanisms.

NoPE questions to DEC.

Q5. What is the present mechanism for people living along freight rail lines wanting to make complaints about freight noise?

DEC response: RailCorp's environment protection licence requires that it operate a telephone complaints line (131500) that is available at all times for members of the community to make complaints. Reports about pollution incidents can also be made to DEC's Pollution Line (131555)

Q6. How are these complaints handled /resolved and by whom?

DEC response: See question 5 above.

In asking that question about the complaints handling and resolution mechanism, we were seeking specific and detailed information on the policies and procedures in place (if any) and a blow by blow description of just what is supposed to happen when a noise complaint arises.

For example,
what action is taken on receiving a complaint,
how many complaints about the same incident / area are required before action is taken,
how is a complaint investigated (for establishing whether a problem exists and its extent and by whom,
how is a complaint handled - by whom - that is, what position in what department or ageny is responsible for handling those complaints.
How /when/where are complaints logged and collated, and
where are the numbers / nature of complaints reported to the public.

The phone number given, 131500 - is the transport infoline. Press 5 for complaints, compliments. Press 6 for pollution issues. You get transferred to an "information agent".

Now the reason for asking a specific question about the present and future mechanism for complaints arises from experience with those complaint mechanisms, and definite cynicism about the future when it comes to handling complaints about freight rail noise and emissions.

In a presentation to Land Transport Environment Committee workshop in November 2004, South Australian EPA's Jason Turner noted the following on the South Australian Experience:

EPA investigation began in 1999 due to growing community concern
Locomotive noise, vibration and wheel squeal identified as issues - wheel squeal being significant
Monitoring indicated extreme levels of noise
Unsuccessful friction modification trial undertaken in 2001
Barrier installation investigated
World first monitoring program initiated in 2004 Industry preparing monitoring and environment improvement programs
Department of Health indicate wheel squeal may result in an increased risk of cardiovascular disease in vulnerable people
Complex issue with high level legislative and technical requirements
He characterised the following issues:
International and State guidelines based on annoyance and regularly exceeded
Growing nexus between rail noise and health impacts -
interference with speech
sleep disturbance
possible increased risk cardiovascular disease
Guidelines adopted in some States - NSW EPA Rail Noise Policy development
difficult and lengthy
Actions to reduce impacts often impractical, complex and require specialist research
Limited control on expansion of the issue - planning and new locomotives
Europe provides some direction, but still work in progress

Noise related questions: NoPe's questions to SPC:

1. What was SPC's justification for the rail noise assessment contained in the EIS:
In terms of the area assessed;
In terms of the methodology;
In terms of potential future noise impacts on residential and other receivers along the
entire freight rail corridor?
SPC response:
….An assessment of impacts along the line from Marrickville to beyond Enfield is also included in the EIS…Refer Chapter 22.4.4 And Appendix Q (Section 6.2)

Our comment is that it appears that in fact no assessment of noise impacts along the line from Marrickville to Enfield or beyond has been undertaken :

Appendix Q (Section 6.2) …. There has been no noise assessment undertaken for assessing the future use of the freight rail line between Marrickville and Enfield as this section of the freight line has been duplicated for some time. …….

Six paragraphs, two thirds of one page of 6000 plus the additional 1200 are devoted to an "assessment of impacts" on the Marrickville to Enfield section of the line and concludes:

The difference in noise due to train movements with and without the new terminal is calculated to be up to 1dB, using the method outlined above, which is considered to be barely perceptible to the human ear.

Beyond Enfield, that is the rest of Sydney, warrants just one paragraph in a 6000 plus 1200 additional page EIS:

Beyond Enfield the freight rail line joins and shares the track with passenger trains. Assuming that all 18 trains from the new terminal travel beyond Enfield (which is conservative as trains also could go to White Bay or travel on the Illawarra line to the South Coast), and considering the predicted breakdown of destinations from Enfield, approximately 50% of the 18 trains would travel on the western line, 25% on the northern line and 25% on the south-western line. It is considered that the impact of the additional 18 trains from the new terminal, spread over the western, northern and southwestern
lines, and entering into the passenger network, would be sufficiently 'diluted' within the system such that the effects would not be considered significant.

Whilst there are no guidelines for the assessment of increased rail movements,
equivalent guidelines for the assessment of road traffic……

What about AS 2377- 2002 Methods for measurement of rail bound vehicle noise ?

Questions to DEC

Q30. Will ARTC as the track access provider have ultimate responsibility for pollution impacts of freight rail operations on the freight rail lines within Sydney and metropolitan areas? If not ARTC, who has, or will have this responsibility?

DEC response: The licensed network manager, whoever it is has this responsibility.

Well, it seems DEC is not too sure of the answer to this question, so we'll help them out a little here.

In its submission to the National Transport Commission's LTEC ARTC wrote:

ARTC is working with operators in other states as well as NSW, to address the problem of locomotive noises. NSW EPA (and other States are considering similar provisions) has place noise target limits on ARTC through conditions on its licence. Limits relate primarily to locomotive noise and ARTC is obliged to enforce them as a condition of its licence. ARTC also finds itself in the role of ‘enforcing’ and ‘policing’ the requirements for rail operators using its track, which it believes this is contrary to its core business of providing access as it creates a conflict of interest.

What should be done about rail noise?

In a presentation to Land Transport Environment Committee workshop in November 2004, South Australian EPA's Jason Turner suggested:

Standards developed within a national framework for ADR's, in-service operation, planning criteria, remediation actions.

National research into common problems such as wheel squeal and low frequency noise and vibration.

Regulatory role for States? ( could be problems with national operators)

Planning framework for buildings in the vicinity of railways developed at a national level and applied by Local Govt (Development of a Standard for building siting and construction underway)

Possible future regulatory action is all well and good, but by no means guaranteed in terms of time frame or extent. With a locomotive fleet that is well and truly aged, any change for the better is not going to happen for a long time. Wheel / track noise is also an international problem and an effective solution is not imminent. Better technologies do exist but will generally be resisted by industry as being not cost effective as they generally provide no operational benefit, just benefit to the community.

Likewise any planning improvements in terms of building siting and construction will be a very long term proposition given that housing stock in residential areas along freight rail affected corridors is likely to be existing. In addition, strategies to produce higher residential densities along transport corridors have been in place for some time, with some outstanding examples of how not to do it now existing, including units in Station St Homebush.

Any future air emissions standards are not yet "in the pipeline", and the LTEC discussion paper "Scoping Rail Environment Issues" did raise the question of whether air emissions might more properly be addressed at a local level, although NoPE seriously questions how that approach could work to actually reduce emissions in corridors.

We are of course dealing here with the both the here and now, and the medium to long term, in respect of these impacts.

It is our view that the EIS for this development has failed to adequately consider off-site impacts arising out of this development in respect of rail noise impacts on residents and workers along freight rail corridors, air quality impacts from rail emissions both localised along rail corridors, and the entire Sydney airshed.

Jenny Maddocks


Affleck Consulting (2002) Comparison of Greenhouse Gas Emissions by Australian Intermodal Rail and Road Transport (see via track access publications)

Bureau of Transport (and Communications/Regional) Economics
- (1980) Consumption of transport energy in Australia 1975-76
- (1981) Freight Transport Energy Consumption
- (1991) Greenhouse Gas Emissions in Australian Transport
- (1996) Transport and Greenhouse: Costs and options for reducing emissions No 94
- (1999) Competitive neutrality between road and rail, Working Paper No 40
- (2002) Greenhouse policy options for transport
- (2003) Greenhouse emissions from transport - Australian trends to 2020 Report 107,

Department Environment and Heritage, Urban air pollution in Australia An Inquiry by the Australian Academy of Technological Sciences and Engineering, 1997 Report of Task Group 4: Transport Vehicles Ch 7.

Lilley, W.E. Quantification and Dispersion Modelling of Diesel Locomotive Emissions. Unpublished BSc Thesis 1996, Department of Geography, University of Newcastle, NSW.

National Transport Commission, Land Transport Environment Committee Scoping Rail Environment Issues Discussion Document September 2004.

National Transport Commission, Land Transport Environment Committee Rail Environment Discussion Document Submissions - Dec 2004

National Transport Commission, Land Transport Environment Committee Workshop Presentations 2004



Philip Laird, University of Wollongong and CRC for Railway Engineering and Technologies Project 24 – Rail Transport Energy Efficiency and Sustainability

The subject of fuel use in transport operations in Australia has received limited attention from a number of writers over the last 25 years. This includes the Australian Transport Advisory Council (1979), Bureau of Transport (and Communications/Regional) Economics (BTE - 1980, 1981, 1991, 1996, 1999), Railways of Australia (1980), Gentle (1983), Senate Standing Committees (on Industry Science and Technology - 1990 and Environment, Communications, Information Technology and the Arts - 2000), Laird (1990, 1995, 1996, 1998, 2003), the Industry Commission (1991a, 1991b), Laird and Adorni-Braccesi (1993), Moon (1994), Bureau of Industry Economics (1996), Australian Bureau of Statistics (1997), the Australian Bureau of Agricultural and Resource Economics (ABARE - 2001), and, the Apelbaum Consulting Group (ACG-1991, 1993, 1997, 2001). Overseas interest in Australian transport energy use includes that of the International Energy Agency (2001).
A common theme of much of this work, when touching on freight transport, is that sea and rail transport are generally more energy efficient than road transport. More attention has been given to freight than passenger transport in the above references. Further discussion on land freight is given in Section 2 of this report.
More recent publications on energy use in transport include Affleck (2002) and Laird (2003). In addition, attention has been given to the related topic of greenhouse gas emissions transport, including the BTE (1991, 1996, 2002, 2003) and the Australian Greenhouse Office (AGO - see "

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