The Kirby Reports: Volume I - Report

I THE PROBLEM

A container on the back of a semi-trailer stands
out from the traffic stream. It does so because
of its very size and because it is a distinctive
form of transportation. The container box is 8
feet wide. The distance from the top of the
container to the ground will be approximately
13-14 feet. The length of the vehicle may be as
much as 57 feet. The vehicle unladen is likely
to weigh approximately 13 tonnes. Loaded with a
container its weight may exceed 30 tonnes. On
any view a container truck is a large vehicle.

Certain facts relating to the transportation and
distribution of containers have been placed before
the Inquiry and are said to call for action. Reducing
the argument to its bare bones three matters are
important: -

First, the opening of Port Botany
will alter the balance between
containers carried by road and
containers carried by rail. Each
of the Port Botany terminals is
primarily directed towards a road
delivery system. Fewer containers
will be carried by rail than was
the case when trade was confined
to Port Jackson. There will, in
consequence, be many more containers
on the road.

Secondly, the move to Port Botany
will change the direction of travel
of the vehicles carrying containers.
Container vehicles will be making
their way towards Port Botany
rather than Port Jackson and thus
using a different road network.
Suburbs not previously exposed to
containers will suddenly be confronted
by them in increasing numbers.
Thirdly, the Kyeemagh/Chullora
road proposals do not provide an
immediate solution to an immediate
problem. Even if the decision
were taken tomorrow to construct
the Kyeemagh/Chullora Road it is
likely that it would not be
completed for a significant period,
probably ten years.

In these circumstances a number of submissions have
been made to the Inquiry outlining various options.
They provide, so it is said, an immediate solution
to the 'container problem'. It is the task of this
Inquiry to examine these suggestions and to assess
their feasibility and their worth.

We would like to emphasise that this Report makes
no statement one way or the other concerning the
Kyeemagh/Chullora Road proposals. Those proposals
(as well as the suggested rail link) will be the
subject of a separate report.

We will begin by sketching the history of
containerisation in Sydney and the environmental
impact of this unique form of transportation.

We will then examine various options. The options
suggest either:-

There should be no interference
with an importer's or exporter’s
right to choose the mode of
transport which best suits his
needs (the 'Free Market Case')

or

The environment will be spared
if containers can be diverted from
road transportation to rail
transportation for part of the
journey (the State Rail Authority
Option and the Western SuburbsOption).

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II HISTORICAL PERSPECTIVE

1. THE CONCEPT OF CONTAINERISATION

1.1 Introduction

The present chapter will examine the
following: -

First, the concept of containerisation
and why it has dominated cargo handling
in the space of a decade.
The container handling facilities at
Port Jackson.
The inadequacies of Port Jackson
creating the need to establish
supplementary facilities at Port
Botany

1.2 The Container Revolution

A promotional film for the Glebe Island Terminals
suggests that containerisation has brought about
as great a revolution in the shipping industry as
the conversion from sail to steam. Whilst that
may be pitching the case too high, there is no
doubt that containerisation has effected a
remarkable change in the sea carriage of goods.

Containerisation is but an example of the more
general concept of unitisation. The concept
itself is simple. It is easier, cheaper and
more efficient to transport and handle goods
in parcels than as individual items. Unitisation
involves the use of standardized 'parcels' such
as pallets, or cargoes which have been consolidated
and strapped (e.g., timber and steel) or
containers, which are simply steel boxes with
particular dimensions and particular features.

Before unitisation it was necessary to
individually transport each item to the wharves
where it would be taken aboard the ship and
carefully stowed. This was a painstaking and
time consuming process and was labour intensive.

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The irregular shapes of goods and their
varying weights created difficulties both in
handling and stowing.

Containerisation was an overwhelming success
because it significantly improved cargo handling and
because it offered advantages over other forms of
unitisation. First, the consolidation of cargo
into standardized boxes or 'containers’ meant that
ships could be loaded or unloaded in far less time.
Ship 'turn-around time' improved. The improvements
moreover, were dramatic. Whereas conventional
vessels with conventional cargo handling methods
spent approximately 75% of their time in port being
loaded or unloaded, a container ship was able to
spend a mere 25% of its time in port and therefore
75% of its time at sea. ₍₁₎ Within a given year
vessels could make more trips between one port and
another. Less vessels, therefore, were required
to carry the same cargo. Since vessels are hugely
expensive there was a significant saving for the
shipping companies in the adoption of containerisation.
It did, however, require a corresponding investment
in vessels of a particular type.

Secondly, containerisation offered a more efficient
use of ship space. It was superior in this respect
to other forms of unitisation. Containers could
be packed tightly into the vessel hold in specially
designed cells. They could, in addition, be
stowed on deck since the cargo is protected by the
steel casing.

Thirdly, the introduction of containerisation
effected a switch from a labour intensive method of
handling to one which was capital intensive.

1. Urban Transport Study Group "Port Jackson
Container Movements", page 2.

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Since labour costs were a significant proportion of
sea freight costs ₍₂₎ the savings were significant.
The extent of the revolution in terms of labour is
demonstrated by the reduction in membership of the
waterfront union, the Waterside Workers' Federation,
during the period in which unitisation was being
introduced. The Australia-wide figures are: ₍₃₎

Date Number of Waterside Workers

June 30th, 1956              26,426
June 30th, 1967              20,140
June 30th, 1978              9,846

This represents a reduction of 16, 580 waterside
workers in 22 years or 62.7%. Yet at the same time
the cargo handled by various ports throughout Australia
more than doubled (from 24,911,513 tonnes to 51,858,200
tonnes per annum). The figures for Port Jackson are
as follows:- ₍₄₎

TABLE 1

ANNUAL REVIEW OF GENERAL CARGO, CONTAINER
MOVEMENTS AND WATERSIDE WORKERS EMPLOYED

2. Rendel and Partners "Study of Sea Ports/Land Use
Interaction" February, 1976, page 42.
3. "Freight" August 23^rd, 1979, page 4.
4. Exhibit 133 (Maritime Services Board).

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Fourthly, there were a number of incidental benefits
for those shipping or receiving goods. Goods could
be packed to the satisfaction and specification of
the exporter at his own premises. The goods were
not manhandled a number of times and the risk of
loss or damage was therefore minimised. The
availability of heavy duty fork-lift trucks to load
or remove containers ensured that road transportation
(where that was used) was not delayed unnecessarily.
Since the trucks are larger and the goods more closely
packed, less trucks were required to perform the
transport task. Pilfering of cargoes was all but
eradicated first, by locking containers and affixing
a seal and secondly, by the very anonymity of a
container where one container box looks very much
like another and may just as readily contain bulk
metals as transistor radios.

There were further advantages for the Port Authority.
The Port of Sydney imports and exports a certain
number of tonnes each year. Different wharves are
able to handle a different number of tonnes per day.
Conventional cargo is handled at the rate of
approximately 300 to 400 tonnes per day ₍₅₎. Container
terminals in Sydney are able to handle 4,000 tonnes
per day and the expectation is that Port Botany will be
able to handle 10,000 tonnes per day ₍₅₎. Without
containerisation Sydney would simply not have had the
wharf space available to handle the tonnage which
passes across the wharf.

The price for these advantages was high. The container
vessels and the terminal infrastructure both required
massive capital investment.

1.3 Classification of Containers

There are two broad groups of containers:-

Full container load (FCL)
which is a container where
the cargo is destined

5. Submission S 145 by A.N.L. entitled "Comments
   on Proposals for Decentralised Container Sub-
   Terminals” made to the Botany Bay Port and
   Environment Inquiry (the Simblist Inquiry) 1976.

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for one consignee (an import FCL) or
originates from one consignor (an
export FCL).

Less than container load (LCL) where
the container is loaded with a number
of items of cargo.

Each destined for different
consignees (in the case of an
import LCL)

Or originating from a number of
consignors (in the case of an export
LCL)

The distinction is important for a number of reasons.
First, the procedure adopted to unpack an FCL is
different from that adopted for an LCL. An import
FCL is taken to the premises of the consignee and
unpacked (usually whilst it is sitting on the back of
the semi-trailer). Conversly an export FCL is packed
at the premises of the consignor and thereafter taken
to the port. An import LCL, on the other hand, must
first be unpacked before individual consignees can be
identified and the goods distributed. The LCL import
container is unpacked (the term used is 'unstuffed')
at a depot. Similarly, exporters with cargo which will
not require a full container, are directed by the
shipping lines to particular depots where the goods are
consolidated with other goods bound for the same
destination (an export LCL). They are thereafter
transported to the port by the depot.

The distinction is important for a second reason.
The transport requirements for an FCL are different to
the requirements for an LCL. In the case of an FCL
the movement is from the port to the importer’s premises
(or the reverse in the case of an export). An LCL gives
rise to a number of truck movements each descending upon
a depot to deposit or collect the smaller items which
together make up one container. The trucks are likely
to be smaller.

1.4 Types of Containers

The International Standards Organisation (I.S.O.) has
settled upon a standard box container. It is a 20 foot
unit 8 feet high by 8 feet wide. Indeed it is referred

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to by the letters 'TEU' being an acronym for
‘twenty foot equivalent unit’.

There are a number of variations upon the standard.
A common variation is the 40 foot container box.
In statistics it is referred to as ‘2 TEU’. There
are in addition a number of specialised containers
including 'over-heights' (being slightly more than
8 feet in height), 'over-widths (being more than
8 feet in width), containers with collapsible sides
or canvas sides (for transporting horses etc) and
a number of other particular variations designed to
suit the needs of a particular trade.

The most common form of specialised container is the
'reefer' which is a container specifically designed
for refrigerated cargo. The vessels themselves in
some cases (especially on the European trades) are
fitted with refrigeration units which are connected
to these containers to ensure that their contents are
chilled for the entire sea journey. In other cases
the chilling mechanism is affixed to one end (an
integrated unit) and travels with the container
(common on the Japanese trades).

1.5 The System for Handling Containers

A number of different systems have been developed to
handle containers. Vessels have been specifically
designed to complement the unloading and loading
facilities available at particular ports. In broad
terms there are two systems of importance in the Port
of Sydney. They are:-

The Lift-on/Lift-off system (LO.LO)

The Roll-on/Roll-off system (RO.RO)

Under the lift-on/lift-off system containers are lifted
onto a vessel or removed from a vessel by means of a
large overhead crane. In some cases the ships have
been converted to carry containers in their holds.
Ships (known as cellular vessels) have been specifically
developed to complement this loading and unloading
system by the provision of cells into which containers
are slotted.

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Under the roll-on/roll-off system heavy duty
fork lift trucks or trailers enter the vessel to
either deposit or remove the containers. The vessel
either carries its own ramp which then rests upon
the wharf (e.g., quarter ramp vessels) or a ramp
is provided as part of the wharf facility (roll-on/
roll-off).

It would appear that the roll-on/roll-off system
is something of a minority taste in containerisation,
but one of specific relevance to Australia, since it
is favoured by the Australian National Line and by
certain other overseas carriers using facilities
at Darling Harbour.

This is far from an exhaustive statement on the
systems available. There are, for instance, a number
of vessels in the service of the Australian National
Line which are truly hybrid incorporating both
lift-on/lift-off and roll-on/roll-off facilities.

2. CONTAINERISATION AT PORT JACKSON

2.1 Container Facilities

A distinction is drawn between ‘container terminals'
on the one hand, and, conventional wharves on the
other. A container terminal is a facility which is
devoted substantially to the handling of containers
though it may handle small quantities of conventional
cargo. A conventional wharf may be compatible with
the handling of containers but it is designed to
handle conventional vessels stowed with non-
containerised cargo.

The container terminals at port Jackson are:-

The White Bay facility leased
by Seatainer Terminals Limited.
The Glebe Island facility leased
by Glebe Island Terminals Pty.
Limited.

Until April this year there was a further facility
at Mort Bay, Balmain leased by the Australian National
Line. On the 17th April, 1980 the Australian National
Line transferred its operations to Port Botany.

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There are a number of conventional wharves which
lack the massive overhead crane necessary for the
cellular container vessels. In some cases these
wharves have been specifically adapted to handle
containers by the alternative roll-on/roll-off
system. The conventional wharves capable of handling
containers are:-

Various wharves in Darling
Harbour
Woolloomooloo No. 11 wharf
which is immediately adjacent
to Mrs Macquarie's Chair and
primarily used for bulk cargoes.

Figure 1 identifies the location of these facilities.
Tabre 2 sets out the container movements through
Port Jackson between 1969/70 and 1978/79.

In the nature of things it is not possible for all
cargo to be containerised. Most timber, for instance,
is not suited to handling within containers and many
bulk cargoes are better handled by other means.
Approximately 69% of the cargo passing through Port
Jackson (whether as imports or exports) is containerised.
The Maritime Services Board has expressed the view
that the scope for the introduction of further
containerisation is not great. Table 3 sets out the
various trading areas and the extent to which
containerisation has been introduced.

2.2 The Decentralised Container Depots

Port Jackson is a sunken river valley. It is surrounded
by hills and there is little flat land close to the
harbour’s edge. Container handling requires space.
The marshalling of containers for export, or the
despatch of import containers by road or rail, demands
a considerable area. The stuffing and unstuffing of
LCL containers requires a shed and further space.
In Port Jackson that space was simply not available.
Alternatives had to be found.

TABLE 2.

CONTAINER MOVEMENTS THROUGH PORT JACKSON

1969/70 - 1978/79

Twenty Ft. Equivalent Container Units TEUs

TABLE 3.

CONTAINERISED GENERAL CARGO TRADE

IN VARIOUS GEOGRAPHICAL AREAS

1978-79

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The White Bay terminal endeavoured to overcome space
limitations by stacking containers five-high. The
method has obvious limitations. To get at the
container on the bottom, four other containers have
to be moved. That is a costly and time consuming
process. The number of containers handled by the
terminal each day will be less, because equipment
and men are occupied shuffling containers rather than
attending to their receipt and delivery. If the
containers are spread out, two-high, there is at
least a 50% chance that no container has to be moved
when gaining access to a particular box.
Productivity for men and equipment is thereby improved.
The two-high stacking system has been adopted at
Botany Bay.

There was not the wharf space available at the Port
Jackson terminals (White Bay, Glebe Island Terminal
and Mort Bay) to establish depots for the stuffing
and unstuffing of LCL containers. Decentralised
depots were established at the following locations:-

At Alexandria operated by Liner
Services Pty. Limited.

At Chullora operated by Seatainer
Terminals Limited.

At Villawood operated by Freightbases
Pty. Limited.

At Rozelle operated by Consolidated
Cargo Services Pty. Limited.

These are the main depots. There are other smaller
depots servicing particular shipping interests.

In 1974 the Federal Government revalued the currency
and removed certain import restrictions. The combined
effect was a massive increase in trade. Congestion
at the Port, already evident before that increase,
became significantly worse. Ship queueing was
commonplace and exporters and importers alike suffered
considerable delay in despatching or obtaining their
goods.

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Seatainer Terminals Limited, the operators of
White Bay, found they were not able to efficiently
process the number of containers passing through
that facility (either as imports or exports).
They changed the operation. Before that change
import FCLs were made available by the Terminal
at White Bay itself. After, they were despatched
by rail to the decentralised container park at
Chullora where they were then made available to
importers.

3. THE MOVE TO PORT BOTANY

3.1 The Inadequacy and Unsuitability of Port Jackson

The move to Port Botany was inevitable. It came
about, first, by the sheer weight of numbers where
Port Jackson was simply not able to efficiently
handle the expected container throughput in the
1980s, and secondly, by the unsuitability of the
Port Jackson facilities and the undesirability of
further expanding those facilities.

It was plain by 1974 that the Port could barely
cope with the number of containers reaching these
shores, and would not cope at all with the increase
in trade which could be anticipated in the years to
come. Trade was increasing at the rate of approximately
6% each year ₍₆₎. The Maritime Services Board
estimated the container throughput for the financial
year 1984/85 to be 418,000 TEU. At the time that
estimate was made the Port of Sydney was having
great difficulty handling 280,000 TEU. It was
apparent that some alternative had to be found.

There were those who suggested that the Port Jackson
facilities should be expanded to avoid the necessity
of developing Botany Bay. Clearly that was not a
real alternative. First, the existing facilities at
white Bay and Grebe Island could not realistically be

6. Submission M.S.B. to the Botany Bay Port and
Environment Inquiry (The Simblist Inquiry),
page 84.

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given more space. Glebe Island was on a peninsula
and White Bay was hard up against a rock face.
Darling Harbour was almost at saturation. It was
adjacent to the city area so that expansion was
difficult if not impossible. The expansion of
Mort Bay was out of the question because of the
severe environmental impact of existing operations.

The particular demands of the container trade made
Port Jackson unsuitable in other respects. Larger
cellular container vessels were being developed.
Their draft and length made their handling difficult
at existing facilities in Port Jackson. They can
be accommodated at Port Botany.

3.2 The Port Botany Terminals

In March 1969 the New South Wales Government approved
in principle the construction of a Port at Botany.
The construction involved the reclamation of part
of Botany Bay. Within the reclaimed area a dock,
known as the Brotherson Dock, was to be constructed
and container terminals alloted space on either side.

The Maritime Services Board invited tenders to develop
the container terminals. At that stage one terminal
was to consist of three berths (the northern terminal)
and the other of two berths (the southern terminal).
The Board received applications from the Australian
National Line and from Seatainer Terminals Limited
(which operated the White Bay facility). Both
applicants wished to develop the northern (three berth)
facility.

It was later decided that there should be two three
berth terminals:

the northern terminal consisting of
some 42.18 hectares which has been
leased to the Australian National Line
for a period of 25 years from 12 April,
1979 with a further-option for 5 years
a consortium of shipping companies known
as Container Terminals Australia Limited
(CTAL) replaced (by agreement) Seatainer

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Terminals Limited in negotiations
with the Board for the right to
develop the second (southern)
terminal. An agreement for lease
was signed by this company on 9th
February, 1978.

The Premier, Mr. Neville Wran, opened the Australian
National Line Terminal on 10th December, 1979. An
industrial dispute delayed the commencement of
operations until 10th March, 1980. The terminal is
now operating and the Australian National Line has
shifted its entire operation from Mort Bay to Botany.

The CTAL facility is still in the course of
construction and is expected to be completed by the
middle of 1981.

III THE ENVIRONMENTAL IMPACT OF
CONTAINER TRANSPORTATION

1. THE ENVIRONMENTAL IMPACT OF CONTAINERS

1.1 The Sheer Size of Containers

More than once in the public hearings those
concerned with the carriage of containers asked
why it was that the community had singled out
containers from other forms of transportation.
The answer is not difficult to find. It appears,
for instance, in the following passage taken
from the Environmental Impact Statement
submitted by the Australian National Line ₍₇₎:

"..The movement of container trucks has
given considerable cause for concern to
people who are affected by them. Some
of the environmental impacts of container
vehicles, or indeed of any similar large
vehicles, can be discussed in objective
or even quantitative terms - fumes,
safety, traffic congestion, pedestrian
delays, noise and vibration.

Others are less tangible and possibly
emotive. It would seem that these factors
are linked with the sheer size of the
container on its truck.

A standard I.S.O. container measures
20 feet x 8 feet x 8 feet and weighs
up to 20 tonne. Where a 40 foot container
or two 20 foot containers are carried
on a single vehicle or trailer unit the
length is up to 17.4 m (57 feet)."
(emphasis added).

Containers by their size intimidate other road
users and pedestrians. The submissions to the
Inquiry echo this theme time without number.

We are not suggesting, for one moment, that
container trucks are a menace which ought to be
banished from our road network. Containerisation
has effected a remarkable revolution to the sea
carriage of goods. By the more efficient use of

7. Australian National Line Environmental Impact
Statement, March, 1976, page 87.

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larger vehicles it has reduced the number of trucks
needed to perform the transport task. We are simply
saying that the public reaction to the size of these
vehicles is entirely understandable and certainly
not irrational.

There are two important statistics disclosed by the
State Transport Study Group (STSG) in their port
and depot surveys:

69% of containers are carried by
semi-trailers ₍₈₎
the trucks used in connection with
the distribution and delivery of
LCL cargo (once it has been unstuffed
at depots) are significantly smaller.
Some 77% are rigid trucks and only
10% are semi-trailers ₍₉₎

We will return to this difference in vehicle size
when we come to consider (later in this Report)
the question of whether a depot should be established
at Port Botany.

1.2 The Impact is Not Denied by Transport Operators

It can hardly be denied that container trucks have
an impact upon the environment and that the impact
is significant. A close reading of the various
submissions made by those concerned with the
transportation of containers does not suggest
otherwise. The submission from the Transport
Workers’ Union is typical and in part reads as
follows ₍₁₀₎:

"Failure to construct this road (the Kyeemagh/
Chullora Road) will see Rockdale, Kogarah and
surrounding suburbs saturated by heavy truck
movements..To over-work the existing road
system adds not only to pollution levels and
causes inconvenience with traffic density,
but indeed the very safety of future
generations will be put at risk unless
action is taken now to construct a road

8. Edgerton, James & Jordan "Container Movements
    in Sydney", Forum Papers, page 76.
9. UTSG (now STSG) "Documentation of UTSG 1979
    Depot Survey", page 25.
10. S.K/C 1290 Transport Workers' Union of Australia
    (N.S.W. Branch) letter 7.8.79, pages 1 and 2.

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link..The need for early action to be
taken to reduce the environmental and
transport costs of trucks filtering
through residential streets and disrupting
shopping centres and inconveniencing
the community in general must be
considered in costing the proposed road."

1.3 The Noise Caused by Containers

Empty containers rattle. Full containers are heavy
and require large vehicles. These matters aside,
it is not suggested that container transportation
gives rise to noise problems not shared by other
forms of heavy transportation.

Heavy vehicles contribute to highway noise in two
distinct ways. First, their presence in the traffic
stream can operate to slow traffic. The noise
generated by all vehicles at slower speeds is likely
to be higher than at higher speeds. Secondly, and more
importantly, the vehicles themselves operate at high
noise levels so that even a small percentage of
heavy vehicles has a disproportionate effect upon
the traffic noise levels.

Associate Professor A.B. Lawrence and Mrs. Burgess
conducted a survey on behalf of the Commission of
Enquiry into the New South Wales Road Freight Industry ₍₁₁₎.
The survey was designed to indicate the relative
contribution of cars and trucks to maximum traffic
noise levels. The results were:

At the Wollongong by-pass trucks
constituted 14.5% of the vehicle
flow over an 18 hour period. yet
they contributed 52% of the noise
which could be regarded as
unacceptable.

11. Commission of Enquiry into the New South Wales
Road Freight Industry Volume VI, Supplementary
Paper 6.0, pages 10-11.

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At the Princes Highway, Fairy Meadow
medium and heavy trucks constituted
8% of the 18 hour traffic flow and
yet they contributed 46% of the noise
which could be considered unacceptable.

The Commission in its Report stated ₍₁₂₎:

"Community dissatisfaction has some
correlation with the percentage of
heavy vehicles in the traffic stream,
rather than with some general measure
(e.9. L10) of noise level, probably
because their noise is more intrusive."

(emphasis in the original)

1.4 Air Pollution

The semi-trailer used to haul a container is powered
by a diesel engine. Diesel fuel is less volatile
than petrol and the diesel engine allows for a more
complete combustion. In consequence the level of
hydrocarbon and carbon monoxide emission is relatively
low, and certainly lower than for ordinary cars.

The diesel engine, however, emits far greater
quantities of nitrogen oxide. Once emitted this
gas changes slowly to nitrogen dioxide in the
atmosphere. Nitrogen dioxide is itself a pollutant.
It has, moreover, an important role (in combination
with hydrocarbons) in producing photochemical smog.

Diesel engines can emit ten times or more smoke and
particulate pollution than emitted by a motor car,
especially if not properly maintained, and more
especially when operating under high load condi-
tions. These are the black fumes which give trucks
a bad name in the community. Certainly they are
highly visible, and certainly they are obnoxious.
Surprisingly, they may be the least harmful of all
pollutants.

12. Commission of Enquiry into the N.S.W. Road
Freight Industry, Volume IV, page 5-33.

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The Inquiry cannot imagine that container trucks
will significantly add to air pollution problems
whether regional or local. That is not to say that
the fumes and smoke can be safely ignored. The
fumes and the smoke will be accompanied by significant
noise, by vibration and by the sheer bulk of the
vehicle. They may, in these circumstances, assume
an importance in the community mind, as an index of
environmental degradation, even though scientifically
it would be quite impossible to prove any impairment
to health.

1.5 Vibration Caused by Container Vehicles

Traffic-induced vibration may be either ground-borne
or air-borne. Air-borne vibration is sometimes
called infra-sound. A good deal is known about
ground-borne vibrations. Relatively little is known
about air-borne vibrations or infra-sound. Yet the
latter, in the context of traffic, and specifically
heavy vehicle traffic, may be the more important.

The literature dealing with vibrations is replete
with references to the "extreme sensitivity of human
beings to vibration". Indeed, it has been suggested
that it is this sensitivity which causes people to
over-estimate the degree of movement which is actually
taking place.

Residents of Balmain complained of the vibrations
caused by container vehicles going to or coming
from Mort Bay. The Residents' Action Group responsible
for the publication "The Balmain Residents' Case Against
Cargo Trucking From Mort_Bay" retained consultants,
Louis A. Challis and Associates Pty. Limited, to
measure the vibrations. The consultants concluded
in the following terms ₍₁₃₎:

13. "The Balmain Residents' Case Against Cargo Trucking
from Mort_Bay", Appendix 8, page 7.

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“The current complaints of building
damage due to container truck move-
ments in the residential area of
Balmain could not be substantiated
by the results measured during our
inspection. It is also unlikely that
the actual building vibration, as
measured, would result in significant
annoyance to residents in the area."

Essentially the measurements taken were ground-borne
vibrations. The streets in the Southern and Western
Metropolitan Area are generally wider than Balmain
and the houses set further back. It seems unlikely,
therefore, that container trucks will give rise to
significant ground-borne vibrations.

Can the same be said of air-borne vibrations? It
appears that there are two distinct sources of
air-borne vibrations, one more important than the
other. First, the very passage of the motor vehicle
"through the air" ₍₁₄₎ produces air-borne vibrations.
The more significant source, however, is thought to
be the low-frequency sound waves which come from the
vehicle engine and in particular the diesel engine.
Diesel engines have a much higher proportion of
low-sound frequencies than engines fuelled by
petrol ₍₁₅₎.

The relative importance of air-borne and ground-borne
vibrations can be appreciated from certain experiments
conducted in the United Kingdom. A comparison was
made between ground-borne vibrations detected at the
base of a building and the vibration of window panes.
Care was taken to exclude the possibility of the window
panes vibrating because of the amplifying effect which
a structure gives to vibrations felt in its foundation.
In one case the average vibration detected in the window
pane was fifty times greater than that measured at founda-
tion level. The vibrations could only have been caused

14. "Effects of Traffic on Roads and the Environment
in Urban Areas" O.E.C.D., page 33.
15. Report on Urban Motorways Project Team, page 66.

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by air-borne vibration.

After construction of an elevated section of
roadway in London, known as the Westway, measure-
ments were taken in a three storey end terrace
whose top windows faced the road and were
approximately ten metres from the carriageway.
The results of the experiment are described in
the following passage ₍₁₆₎:

"Simultaneous measurements were made
of vibration levels at foundation,
top floor windows and adjacent walls;
and of low-frequency sound inside
the room. A heavy lorry known to
generate infra-sound was used as a
source. At the foot of the columns
supporting the road, structural
vibration was barely measurable and
well below the limits of perception
and the same was true at the house
foundation: which strongly suggests
the absence of ground-path effects
at this site. Horizontal vibrations
of window panes could, however, be
felt, and were several orders of
magnitude greater than those at the
foundations: to an extent that ruled
out the possibility of their being
caused by amplification of foundation
vibration.. This appears to establish
transmission mainly through the air
during these measurements.”

Air-borne vibrations obey the usual laws of sound.
Because they involve low-sound frequencies with
long-wave lengths, they attenuate relatively
little with distance, insulation or screening.

Vibrations caused by container trucks are unlikely,
of themselves, to significantly effect the environ-
ment. As with air pollution, they do not occur “by
themselves". The passage of a container vehicle,
expecially under load, is accompanied by fumes, noise,
and vibration. The combination operates to accentuate
each of the ingredients of which it is comprised.

16. Report of the Urban Motorways Project Team, page 66.

-28-

1.6 Accidents Involving Heavy Vehicles

1.6.1 The Involvement of Trucks in Accidents

It is sometimes said that the motor vehicle is a
lethal weapon. Yet there is a degree of complacency
about cars which does not extend to trucks. People
rarely fear cars (though perhaps they ought). They
do fear trucks. The fear grows with the size of the
truck.

It was apparent from the many submissions made to the
Inquiry that the public does perceive trucks as
threatening its safety. Nor is it wrong in that
perception. Trucks, and especially articulated
vehicles, make a disproportionate contribution to
fatal accidents. The statistics emerge from the
Commission of Enquiry into the New South Wales Road
Freight Industry ₍₁₇₎. Articulated vehicle represent
only 0.6% of the vehicles registered in New South
Wales. Yet their involvement in accidents is as
follows:

5.3% of vehicles involved in
fatal crashes
1.5% of vehicles involved in
injury crashes
1.4% of vehicles involved in
tow-away crashes.

Perhaps it is fairer to look at the number of accidents
per kilometre? The Freight Enquiry ₍₁₈₎ demonstrated
that even where the measure is the number of accidents
per kilometre travelled, articulated vehicles are
involved in over twice as many fatal crashes as other
vehicles. In this respect the figures are not
different to those in the United Kingdom and elsewhere
around the world.

17. Volume IV, page 5/18 and Supplementary Paper
    No. 4, page 3.
18. Volume VI The Commission of Enquiry into the New
    South Wales Road Freight Industry, Supplementary
    Paper No. 4, page 5.

-29-

It is, moreover, the other road users who bear the
brunt of truck accidents. The position is summarised
in the following passage ₍₁₉₎:

"It has been found in a British Study
(by Farr and Neilson 1968) that in a
collision, other road users are four
times more likely to suffer injury
than the driver of an articulated
vehicler and the ratio is 10:1 for
serious or fatal injuries."

1.6.2 Truck Characteristics Affecting Safety

Trucks are usually much larger than cars and much
less manoeuverable. Container trucks are amongst
the largest of all trucks. They do not have,
therefore, the same ability to avoid accidents.
They suffer, moreover, from a number of design
features which make accidents the more likely. The
matter was investigated in some depth by the commission
of Enquiry into the New South Wales Road Freight
Industry. It is sufficient in this context to
mention but one feature; braking performance.

Trucks, especially when laden, may require twice
(or more than four times) the stopping distance
required by cars travelling at the same speed. There
are a number of reasons for this ₍₂₀₎:

(i)         Truck tyres do not grip the road
as well as car tyres.

(ii)       Truck brakes have inferior ratio
of brake area to axle loads when
compared to car brakes, and the
ability to dissipate heat is
inferior.

(iii)     Air brakes take up to one second
to be fully applied after the brake
pedal has been depressed.

(iv)       Truck brakes require frequent
maintenance which is not always
carried out at the correct frequency
(a matter upon which further comment
will be made below).

19. Trucks in Suburbs, page 12.
20. Enquiry into the New South Wales Road Freight
Industry, Volume VI, Supplementary Paper No. 4,
page 20.

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It is hardly surprising that cars come off rather
worse in collisions when they take place. The
obvious explanation is the relative difference
between the weight of the truck, on the one hand,
and the weight of the car, on the other. There
is a frightening statistic ₍₂₁₎ that when one
vehicle which is involved in a head-on collision
with another is twice the weight of the other
vehicle, the percentage of deaths in the lighter
vehicle is approximately seven times that of the
heavier vehicle.

The severity of the accidents involving trucks is
also partly the result of the relatively high
stiffness of trucks. On impact most of the energy
loss is dissipated in the collapse of the car
instead of being shared between vehicles. There
is also the difference in height between the
bumper-bar of the truck and those of the car which
accentuates the damage to the latter.

1.6.3 Maintenance of Trucks

Because of the relative shortcomings of the truck
braking system, meticulous and regular maintenance
is of the utmost importance. After the horrifying
accident in 1979 at Mount Ousley, where a loaded
coal truck collided with four other vehicles, killing
five people from the one family, the Department of
Motor Transport made an inspection of 492 of the 551
coal trucks operating. The Road Freight Enquiry ₍₂₂₎
describes the results of that inspection as 'startling'.
There is no other word. The alarming statistics were:

167 (i.e.33%) were found to have
major defects prejudicial to their
safe operation.

98 (i.e. a further 20%) had defects
which demonstrated a lack of
attention to maintenance even
though they may not have compromised
the vehicles safe operation.

21. Volume IV Enquiry into New South Wales Road
Freight Industry, page 5/8.
22. Volume IV, page 5/3.

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only 46% of the vehicles inspected
passed muster.

61% of the major defects detected
were defects in the braking system.

Curiously a similar spot-check in the United
States revealed a high proportion of trucks (47%)
with ‘safety violations and hazards' ₍₂₃₎.

Although the Freight Enquiry urges caution before
drawing general conclusions from this one sample,
and whilst it must be acknowledged that there are
truck drivers who do demonstrate care and consider-
ation in the maintenance and management of their
vehicles, it is inescapable that the public view of
trucks as threatening their safety is not mistaken.

It is not surprising in these circumstances that
the public should especially fear one of the
largest species of trucks, the articulated
vehicle carrying a container.

1.7 Container Trucks and Congestion

1.7.1 The Concept of Passenger Car Units

Each road has a certain traffic capacity which can
be calculated. A straight road between point A and
point B has a capacity which will depend upon the
number of lanes, the width of each lane, the nature
of the carriageway and so on. If the road is crossed
by another road (creating an intersection) the
capacity will be reduced because allowance must be
made for the time it will take cross traffic to get
from one side of the intersection to the other. If
there are a number of intersections the capacity of
the road will be determined by the capacity of the
intersection which is the most constricted.

Calculations of capacity pre-suppose certain vehicle
characteristics. The capacity of a road which is
required to service nothing but trucks will be
different from, and less than, the capacity of a
road which only handles cars. A road which handles

23. N.S.W. Road Freight Enquiry, Volume VI,
Supplementary Paper No. 4, page 25.

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a mixture of cars and trucks will be different again.

The 'passenger car unit' is a unit of measurement
originally developed in the United States in what
is known as the 'Highway Capacity Manual'. An
ordinary car is one PCU. A truck does not have
the accelerating, braking nor manoeuvring capacity
of the average car. It will represent more than
one PCU; how many more will depend upon the size of
the truck.

There is no universal standard to which all traffic
engineers subscribe. The Simblist Inquiry made the
following statement in the course of its investigation ₍₂₄₎:

"The D.M.R. was reluctant to formulate
a multiple, stating that there were
variations over a very wide range
from as low as one to as high as ten.
This Department said that the approp-
riate figure for Botany was toward
the lower end of this range.

The M.S.B. adopted a figure of two pcu
for the port-oriented road truck
vehicles. Any figure chosen must be
arbitrary to some extent, but three
pcu appeared a more appropriate figure
to this Inquiry."

The State Rail Authority in its submission to this
Inquiry had this to say ₍₂₅₎:

"The Simblist Report chose a value of
three PCU per container truck. This is
based mainly on the effect the trucks
would have on traffic flows. After
discussions held between offices of
the P.T.C. and Traffic Management
experts it was considered that a figure
of six PCU's would be more appropriate
when considering the environmental impact
of container trucks."

24, The Botany Bay Port & Environment Inquiry, 1976
paragraph 10.4.1.
25. Submission S.K/C 208 Public Transport Commission
(now State Rail Authority), July 1979, page 7.

-33-

The Inquiry is inclined to the view that the concept
of passenger car units is not especially helpful
when considering either traffic capacity or the
environmental impact of containers. The variations
in any given situation are vast. Leaving aside the
environmental impact of containers, and concentrating
simply upon traffic capacity, the traffic effect of
a container truck on the Foreshore Road at Botany
may be little more than the effect of an ordinary
car. In Bay Street, Rockdale it may be considerably
more. A container vehicle struggling to negotiate
the hill leading from the Bardwell Creek Valley to
the Bexley Shopping Centre may substantially exceed
the six PCU selected by the State Rail Authority.
In the Inquiry's view it is easier in the end to
consider the problem in terms of container trucks
simpliciter rather than passenger car units.

1.7.2 The Myth of Low Numbers

The terminal operators suggest that the number of
container trucks is insignificant when compared to
the total number of vehicles using the Metropolitan
road network. They are not wrong. The number is
insignificant. The impression which that number
makes upon the public mind, however, is far from
insignificant and this because the vehicles stand
out from the traffic stream.

The impact made by trucks upon the public mind can
be appreciated by considering two things. First,
less than 1% of the vehicles registered in New South
Wales are articulated vehicles. Yet they seem
to be everywhere. They appear to be everywhere
because they dominate the landscape wherever they
go. Pedestrians notice them. Other road users
also notice them.

Secondly, the importance of trucks can be appreciated
from a document tendered by the Department of Main
Roads in its submission to the Inquiry ₍₂₆₎. The

26. Exhibit 66.

-34-

document discloses the number of trips made by cars
and by trucks in the two hour a.m. peak (between
7 a.m. and 9 a.m.). According to the computer
calculations for the year 1976 there were 609,965
car trips ₍₂₇₎. Trucks, on the other hand, consti-
tuted only 36,414 vehicle trips. They made up less
than 6% of the total vehicle trips. The percentage
rises in the off-peak when there are rather less
cars and more trucks. In relative terms the
percentage is still low. Yet the impression upon
the public mind is far greater than the numbers
would suggest.

2. ENVIRONMENTAL PROBLEMS EXPERIENCED AT PORT JACKSON

2.1 The Experience at Mort Bay, Balmain

History has its own fascination but it may also
offer an insight into the mistakes made in the
past. There can be no doubt that the Australian
National Line Terminal at Balmain was, environ-
mentally, a mistake. The Maritime Services Board
in evidence before the Inquiry described it, in
this way ₍₂₈₎:

"One’s only got to drive down the street
to Mort Bay to see that it is a situation
that is clearly unacceptable...possibly
a thing that should never have happened."

The Australian National Line does not contend
otherwise. Indeed it gave as one of its reasons
for wishing to develop Port Botany, a desire to
quit the ‘environmentally unsatisfactory' situation
in which it found itself. It said ₍₂₉₎:

"(The Australian National Line) has already
experienced a back-lash of inadequate
transportation facilities in its present
operation. In fact, one of the prime
reasons for the establishment of the
Botany Terminal is to withdraw from the

27. In fact the document speaks of non-trucks which
are somewhat wider than cars, but for simplicity
we will refer to non-trucks as cars.
28. Transcript 16th April, 1980, page 64.
29. A.N.L. Environmental Impact Statement, page 57.

-35-

congested site and unsatisfactory road
network of the Balmain area with the
prospect of improved operational and
environmental conditions at Botany."

The wrath of Balmain residents has been preserved
in a document entitled "Balmain Residents’ Case
Against Cargo Trucking from Mort Bay" published in
June 1975. The publication is accompanied by a
video tape which dramatically records the hostility
of residents to container transportation and the
area's unsuitability to that form of truck movement.

2.2 The White Bay Terminal

The White Bay terminal is immediately adjacent
to the Balmain residential area though separated
from that area by a substantial sandstone cliff.
Access to the terminal is via Robert Street, which
leads into Victoria Road, Rozelle.

Three factors combined to create environmental
problems for the terminal in the period 1973-74.
That was the period of extensive congestion at
the terminal before the decision was taken to
establish the decentralised park at Chullora and
rail FCL import containers to that park. First,
the terminal was within ear-shot of a residential
area. Secondly, the means of access to the
terminal (namely Robert Street, Rozelle) was
hardly adequate having regard to the number of
heavy vehicles entering and leaving the terminal.
Thirdly, the sudden surge of trade 1973-74
exacerbated the congestion which the terminal
was already experiencing, so that trucks began
to queue beyond Robert Street, Rozelle into
Victoria Road. Victoria Road is, of course, a
main artery.

Seatainer Terminals Limited in its submission to
the Inquiry ₍₃₀₎ does not disguise that pressure
from local residents in Balmain was, in part,

30. S.K/C 953, page 1.

-36-

responsible for its decision to alter its
operation so that FCL import containers would be
delivered at Chullora rather than at the White
Bay Terminal itself. At a stroke, the number of
vehicles congregating at White Bay was dramatically
reduced and the environmental problems substantially
abated.

2.3 The Glebe Island Terminal

The Glebe Island Terminal was designed and
constructed by the Maritime Services Board of
New South Wales. It began operations under
the control of the Maritime Services Board in
February 1973. Commercially it was not a success.
There were a number of operational difficulties.
Tenders from the private sector were invited, and
the facility was then leased to a company, Glebe
Island Terminals Pty. Limited, being a consortium
of various companies with shipping and port interests.
Control was passed from the Maritime Services Board
to Glebe Island Terminals Pty. Limited in November,
1974.

The following statement appears in the submission
by Glebe Island Terminals Pty. Limited to the
Inquiry (31):

"..Even at peak container throughput in
which road transportation has accounted
for 80% of all traffic, the company has
received no complaint or objection on
environmental grounds. This is due to
the astute planning of the terminal's
designers, who enabled all road traffic
to be wisely diffused at a very short
distance from the terminal. A basic,
and very costly, factor in achieving
rapid vehicle dispersal was the
construction of an underpass beneath
Victoria Road to minimise traffic
through residential areas."
(emphasis added)

31. S.K/C 1427, page 3.

-37-

Two things can be said about the Glebe Island
Terminal which do distinguish it in some respects
from other terminals. First, it is located on a
peninsula between Johnstons Bay and White Bay and
is remote from any residential area. Secondly,
as the submission suggests, there is a long access
road which passes underneath Victoria Road (being
the nearest major arterial road) and proceeds past
the Consolidated Cargo Services depot to a road
known as The Crescent, Glebe (which then gives
access to Victoria Road). The Inquiry accepts
that its design and location combine to ameliorate
environmental problems.

That is not to say that container trucks servicing
the Glebe Island Terminal may not give rise to
environmental problems. They may. It is not
possible to infer the absence of such problems from
the fact that no complaints have been made.
Ordinarily a person who felt aggrieved by the
presence of a container truck would direct his or
her complaint to the trucking company rather than
the container terminal. The container terminal
does not itself maintain a trucking fleet and it
would be impossible for a resident of Glebe who
felt minded to make a complaint to know whether
the Glebe Island Terminal was responsible for that
truck rather than the White Bay Terminal, Mort
Bay or Darling Harbour.

The evidence before the Inquiry would suggest that
container trucks have created certain problems in
Glebe and Leichhardt, and have been the subject
of complaint, even though the complaints may have
been directed to parliamentarians or Local Councils
or to the trucking companies.

The real test is not whether there has been a
complaint to the terminal; rather, whether
disturbance is probable having regard to the routes
which container truck drivers can be expected to

-38-

take to effect delivery. There is no direct
route from Port Jackson to the West. It is
probable that at some stager and to a greater
or lesser degree depending upon the particular
driver, the container truck will thread its
way through residential streets.

2.4 Darling Harbour and Woolloomooloo

The Darling Harbour wharves do not have access
to rail. All containers must at some stage be
transported by road. Access is difficult and
heavy vehicles regularly use indirect routes
through the central city area. Congestion is
serious throughout most of the day.

IV THE OPTIONS

1. THE OPTIONS DESCRIBED

In broad terms three options were considered by
the Inquiry. They were:

1. The so-called ‘free market case'
in which it was said that there
should be no regulation of the
Port and no attempt to divert
containers from road transporta-
tion to rail transportation.

2. The scheme advocated by the State
Rail Authority. The scheme
envisages the establishment of
four decentralised depots at
the following locations:

Cooks River goods yard

Rozelle goods yard

Chullora (the existing depot)

Villawood (also an existing depot)

Import containers would be carried by
rail to the depot nearest their final
destination. Export containers would
be taken to the depot closest to their
origin.

3. The Western Suburbs Scheme strenuously
advocated by the Planning and Environment
Commission amongst others. This scheme
envisages the creation of an Eastern
zone and a Western zone. Import
containers destined for the Western
zone would be carried by rail to the
decentralised depots at Villawood or
Chullora. Export containers coming from
the Western Suburbs would be delivered
to the decentralised depots rather than
to Port Botany or Port Jackson as the
case may be.

-41-

2. RAIL SHARE

The State Transport Study Group has conducted
a painstaking analysis of the likely rail share
under the various schemes ₍₃₂₎. Their analysis
must be considered against the background of
these facts:

Before the opening of Botany the
State Rail Authority carried 39%
of the container throughput of
the Port of Sydney ₍₃₃₎.

The container trade transferring to
Botany has a higher rail component
than the rest of Port Jackson because,
in large measure, it is trade from
White Bay and White Bay has forced
rail to Chullora at the present time.
Accordingly 53% of the trade which
is likely to transfer to Port Botany
presently goes by rail.

Based upon 1985 predictions the share
between the various facilities at Port
Jackson and those at Port Botany will
be approximately:

65% Port Botany

35% Port Jackson

According to the State Transport Study Group the
schemes will produce the following rail shares:

The Free Market Case will result in a
26% rail share for Port Botany.
The State Rail Authority scheme would
result in 70% of containers being
carried at some stage by rail.
The Western Suburbs scheme would result
in approximately 47% of containers
being carried by rail.

32. Exhibit 139.
33. 137,000 TEU from approximately 350,000 TEU.
(Letter State Rail Authority, dated 19.8.80).

-42-

It is difficult to predict rail's overall share
because the future of Port Jackson is uncertain
once Port Botany is fully operational. The
various wharves at Port Jackson have demonstrated
(though with difficulty) a combined capacity to
handle in excess of 300,000 TEU each year. Yet,
if the figures given above are right, they will
have only 145,000 containers to share between
them. How they will be divided between the various
facilities is a matter upon which no one has been
willing to express a view. That division, however,
is of the utmost importance to the State Rail
Authority because some only of the facilities at
Port Jackson are connected to rail (i.e. White Bay
and Glebe Island Terminal). The Darling Harbour
wharves and Woolloomooloo Wharf No. 11 have no rail
connection.

3. VARIOUS SUB-OPTIONS CONSIDERED

Apart from the options outlined, a number of
variations upon these themes were discussed in
submissions and in the public hearings.

(i) A suggestion that the industry
should be left to its own devices
for the time being. It would
demonstrate (so it was said) that
it can effectively organise its
own affairs so as to increase the
rail share, and therefore reduce
the environmental damage occasioned
by the carriage of containers by
road.

(ii) It was suggested that if regulation
were introduced, it should be
confined to imports or alternatively
to exports, but should not be
extended to both.

-43-

(iii) If a scheme were to be introduced
it should apply equally to Port
Jackson and Port Botany. The
Maritime Services Board, it was
said, has pursued a 'twin port’
policy for some time in which it
was even-handed in its treatment
of the two ports. The extension
of any scheme to include Port
Jackson would be consistent with
that policy and would serve the
environment at the same time.

(iv) It is suggested that the real
environmental problem was not
trucks, as such, but rather the
very large container trucks
described in the introduction to
this Report. Port Botany offers
an opportunity to establish a
depot for the unstuffing of LCL
containers. For sound environmental
reasons, so the argument runs, that
option ought to be taken up and
endorsed by this Inquiry.

The three broad options will be considered and in
the course of that consideration, where appropriate,
the various sub-options will be dealt with and
recommendations will be made.

4. THE KYEEMAGH/CHULLORA ROAD PROPOSALS DO NOT
PROVIDE AN IMMEDIATE SOLUTION

We stressed in the introduction to this Report
that there are two distinct issues:

the extent to which it is desirable
to divert containers to rail
transportation when they would
otherwise go by road
the various road proposals being
examined by this Inquiry

-44-

If it is thought desirable to build a major
road from Port Botany to the Western or South-
Western Suburbs (a matter upon which we will
separately report) it is apparent that such a
road would take at least ten years to build.
The following is an extract from the Simblist
Report ₍₃₄₎:

"This Report (referring to a Report by
URTAC ₍₃₅₎ recommending the Cooks River
route) was dated 4th March, 1976, and
gave a recommended time schedule which
envisaged the construction of this road
commencing in the 1979/80 financial year
and being completed in the 1985/86 year..
From evidence given by officers of the
D.M.R., the Inquiry doubted that such a
formidable task could be completed within
that time, given its present stage of
planning."

It is evident from the material placed before the
present Inquiry that planning has not materially
advanced since these words were written in November,
1976. The Inquiry, in that respect, makes no
criticism of the Department of Main Roads. First,
the concept of the Cooks River Route has changed in
the meantime from a freeway to a major arterial
road. Secondly, there has been considerable
uncertainty (culminating in the present Inquiry)
concerning the acceptability of the Cooks River
proposal.

There are grounds for believing the ten year estimate
may be conservative. There are issues of a fundamental
kind which have not been resolved and which signal
further delay. There are a number of examples. It
is sufficient in the context of this Report to give
one illustration. The others will be dealt with in
the Report evaluating the various road options.

34. The Botany Bay port and Environment Inquiry,
paragraph 10.6.3.
35. Now referred to as Transport Strategy Advisory
Committee.

-45-

The Kingsford Smith Airport occupies a
substantial area. In terms of road planning,
it is difficult to know whether a major road
coming from the West or South-West should
circumnavigate the airport on the southern side
(terminating at General Holmes Drive) or to the
North (terminating somewhere in the Central
Industrial Area and giving easy access to the
Port). The proposal put before the public for
its scrutiny and comment suggested a southern
alignment, following the Cooks River, terminating
at the junction of Tancred Avenue and General
Holmes Drive, Kyeemagh.

The Department of Main Roads, for its part, evinced
little enthusiasm for that alignment. First, the
corridor terminating at General Holmes Drive had
been established by the County of Cumberland Scheme
in 1951. In 1951 the Airport had not been extended
into Botany Bay. There was not then, as there is
now, the problem of a tunnel under the airport.
That tunnel is already over-worked. Suggestions
have been made that the capacity of the tunnel can
be increased by adding a further lane and making
the other lanes more narrow. A container truck on
a wide road is not an engaging companion. In a
tunnel with narrow lanes it is liable to intimidate
other road users to an unacceptable degree.

Secondly, it was found on examination that traffic
loadings (according to the computer model) on
the section terminating in General Holmes Drive
were fairly light. Traffic seemed to desert the
Cooks River route or the South Western route in
the vicinity of Marrickville. Drivers either
wanted to go to Marrickville itself or to the
north of the airport rather than the south. To
spare the southern residential area of Marrickville
that traffic, and to accommodate the motorists who
would use either the South-Western or the Cooks

-46-

River routes, it seemed to the Department of
Main Roads that a northern orientation may be
preferable.

Is it feasible to terminate the road to the
north of the airport rather than the south?
That was an issue raised on almost the first
day of the public hearings in September, 1979.
It was raised again from time to time in the
ensuing months. It was discussed at some length
on the final day upon which the Department gave
its evidence, the 18th March, 1980 ₍₃₆₎. It
was never resolved. It could not be resolved
because the Department of Main Roads, at this
time, simply does not know the answer. The
answer may only emerge after an extended study,
estimated to take at least six months. It may
not even emerge after such a study because it
may depend, in part, upon the resolution of an
issue between the New South Wales State
Government and the Commonwealth Government
concerning the extension of the airport.

In short, whatever view one takes about the
Kyeemagh/Chullora Road proposals, it is plain
that they do not offer a solution available to
the community in less than ten years. Indeed
it may take considerably more than that span of
time before they furnish any relief from the
passage of containers.

5. OPTIONS WHICH HAVE LAPSED

The Botany Bay development will take a decade to
complete. The issues we are presently considering
have been on the horizon for some time. They were
issues which demanded a considered response. Oppor-
tunities presented themselves from time to time for
the implementation of that response with a minimum of
fuss. To what extent has the present confrontation

36. Transcript l8th March, 1980, pages 87-95.

(the Free Market Case versus the case for
regulation) been brought about by permitting
various options to lapse?

The Inquiry will examine those options one by
one. It will endeavour to conduct that examina-
tion by drawing upon evidence available when
decisions were made rather than upon the wisdom
which comes with hindsight.

The following will be examined:

1. The Maritime Services Board is the
statutory owner of the reclaimed land
at Botany Bay. It has leased land to
the terminal operators, ANL and CTAL.
The leasing agreements contain a
number of conditions. Would it have
been possible to impose a condition
requiring the terminal operators to
carry out their operations in a
particular way? Would it have been
possible, far instance, to require
them to divert a certain proportion
of containers (for instance those
destined for certain areas) to rail?
Is it reasonable to suppose that the
Maritime Services Board ought to have
anticipated that a problem would arise
unless steps were taken to divert
containers from road to rail?

2. After the Simblist Inquiry in November,
1976 the terminal operators were
required to seek planning permission.
That permission was given subject to
certain conditions. Did the planning
Inquiries present an opportunity to
impose conditions upon terminal
operators in respect of the rail share?

-48-

3. The terminals have been designed for
a road delivery system. Each terminal
operator anticipated that the lion's
share of deliveries would be by
road (80% in the case of ANL and 64%
in the case of CTAL). Two questions
arise:

First, whether rail has been
disadvantaged in the location
of the rail sidings (at the
edge of each terminal)

Secondly, even if it has not
been disadvantaged, whether
it was open to those who gave
planning permission to insist
that it was so located that it
would be positively advantaged
to ensure the maximum use of
rail.

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V THE CLAMOUR FOR RAIL

1. MANIFESTATIONS OF PUBLIC OPINION

1.1 Introduction

The Botany Bay Port development is a vast project.
It has involved the physical transformation of
Botany Bay by the construction of a breakwater
and the reclamation of a large area.

This has not occurred overnight. It has taken
many years of planning, discussion and hard
labour. It has not occurred by stealth. The
local community has all the while been nervously
looking on. The community has, at the same time,
witnessed the confrontation between the Australian
National Line and the residents of Balmain. It
has observed the passage of containers through its
own locality. It has come to fear that environmental
changes will take place once Port Botany is fully
operational. It has had time to formulate a
response.

There have been a number of manifestations of that
response. They are examined briefly in this
chapter.

1.2 The Botany Bay ,Port and Environment Inquiry
(The Simblist Inquiry) 1976

The Simblist Inquiry reported in November, 1976.
It recommended approval for the establishment of
two container terminals at Port Botany subject
to certain conditions. The conditions are just
as important as the approval. The recommendation
in paragraph 5.4.1 was in the following terms:

"(a) that there be an increase in
the percentage of containers
moved by rail..”

In the same Report the following appears:

"The advantages of rail haulage of
containers are obvious. It is a

-51-

safer, relatively pollution-free
system and reduces road congestion.

The greatest possible use of rail for
the carriage of containers is highly
desirable.

ANL proposes a total rail/road split
of the order of 20/80%. The CTAL
estimate varies slightly from this.
The Terminal Operators should be
compelled to accept a much higher
rail usage." (emphasis added)

Commissioner Simblist suggested a scheme not
dissimilar to the Western Suburbs option which
will be examined later in this Report.

1.3 The Botany Bay Sub-Region Community Advisory
Committee

The Simblist Inquiry identified the need for
public participation from the community. The
Botany Bay Sub-Region Community advisory Committee
has been established to advise the New South
Wales Government on planning and environmental
matters. The Committee on 7th November, 1977
passed a resolution in these terms:

"That this Committee request the
appropriate authority to provide
for all cargoes to be carried by
rail where practicable or pipe to
depots north, south or west."

The resolution does not differ materially from
statements of Government policy which have
appeared from time to time. The Rockdale Council
tendered in evidence a letter from the Premier,
Mr. Neville Wran, to the Local Member for Rockdale,
Mr. B.J. Bannon in which the following appears:

"In reply I would advise that it is
the Government's firm view that rail
should be used to the maximum extent
practicable for the carriage of
containers from Port Botany."

1.4 Submissions to the Kyeemagh/Chullora Road Inquiry

Certain facts should be stated in relation to the

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present Inquiry. They are:

almost 1500 written submissions
were received from interested
parties.
public hearings commenced on 23rd,
September, 1979 and did not conclude
until the end of May, 1980. Over
180 appearances have been made
before the Inquiry.

This is an overwhelming public response. Only
133 persons or organisations made submissions to
the Simblist Inquiry in 1976 and we are led to
believe that even the Drug Inquiry, which received
extensive publicity and excited a good deal of
public interest, received less than 500
submissions. Other inquiries received many less
submissions than that.

The view put to the Inquiry has been almost
unanimous. There is a clamour for the movement
of containers by rail which is all but deafening.
That public response is not lightly put to one
side.

Sydney is not unique in that response. The
position in the United Kingdom is described in
the following passage ₍₃₇₎:

"The concern of people throughout the
industrial world with considerations of
the environment has almost everywhere
embraced a desire to see freight
transferred from road to rail. Amenity
societies and action groups have
continued to fight motorways and in the
United Kingdom public spending limits
also have forced a reduction in road
building. British Governments have
recognised also the need for action and
in some instances legislated to reduce
noise levels and pollution and encourage
conservation."

37. Containers – Their Handling & Transport, page 331.

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2. UNANIMOUS SUPPORT FOR THE RAILING OF CONTAINERS BY
LOCAL COUNCILS

2.1 The Botany Municipal Council

In its submission to the Inquiry the Botany Council
made the following statement ₍₃₈₎:

"the Council reaffirms:

* a need to expand the use of other
modes of transport principally
(i) the railway; and
(ii) the pipelines."

They conclude their submission with the following
words:

"..The best method of achieving
Council's objective (is) the
greatest use of the railway and
the least use of the road."
(emphasis added).

2.2 The South Sydney Council

The South Sydney Council passed a resolution
to be placed before the present Inquiry. The
resolution, in part, reads as follows:

"That it should be made compulsory
that all containers having a
destination north-west of
Canterbury Road or outside the
Metropolitan Area should be
transported from Botany to a
sub-terminal by rail.”

(emphasis added).

2.3 The Marrickville Council

The submission (both written and oral) made by
the Marrickville Council is in similar terms.
The following passage appears in their letter
to the Inquiry on 3rd August, 1979 ₍₃₉₎:

38. S.K/C 687, Attachment A, 30/10/79.
39. Submission S.K/C 1297.

-54-

"The movement of vehicular traffic to
the Port and airport sites is such
that the industrial movement could be
more effectively handled by the rail
system than the construction of a
major county road through the Cooks
River Valley." (emphasis added)

2.4 The Rockdale Council

The resolution of the Rockdale Council passed at
a meeting on 10th October, 1979 and placed before
the Inquiry was as follows:

"All containers with origins and destina-
tions west of the inner city suburbs
should be transported by rail as concluded
by the Simblist Inquiry. If no legislation
exists whereby this could be made mandatory,
then it is incumbent upon the New South
Wales Government to create such legislation.”

(emphasis added)

2.5 The Canterbury Council

The relevant part of the Canterbury Council's
lengthy submission is ₍₄₀₎:

“..Given the high environmental and social
costs associated with heavy truck movement
the Council believes the State Government
should consider instituting a policy to
ensure that rail carries at least 50% of
container traffic this being recommended
as a feasible figure by the Simblist
Inquiry, 1976.” (emphasis added)

2.6 The Kogarah Council

The view expressed by the Kogarah Council on this
issue was as follows ₍₄₁₎:

"Council has also resolved that the
Commission be advised of Council's
concern at the likely impact of container
and other freight traffic from the Port
Botany development on the road system
within the Botany Bay Sub-Region.
Council considers that as much container

40. S.K/C 341, page 21.
41. S.K/C l258, submission, page 2.

-55-

and freight traffic as possible
should be moved from the Port Botany
development by electrified rail.
Council’s support for the new road
link is a result of the existing and
predicted future traffic movements and
should not be regarded as an endorse-
ment for the use of road transport for
the movement of container traffic from
the Port Botany development."

(emphasis added)

2.7 Hurstville Municipal Council

The Hurstville Municipal Council, significantly,
appreciated the analogy with Mort Bay. It said ₍₄₂₎:

"Consideration was based on the experience
already gained at the Balmain terminal and
the well documented evidence of noise and
air pollution that the residents of the
areas have had to endure for too long a
period. Council is therefore anxious that
a situation such as this is not repeated
through this area.

Council also considered the use of rail
transport and agrees that this should be
the principal method of transporting the
containers. However, if left to the
Operators to resolve the proportion of
rail against road transport, Council
realises that the figures quoted of
approximately 25-30% by rail would result.
Council considered this too low a percen-
tage and therefore believes that transport
by-rail should be compulsory to produce a
much higher percentage.” (emphasis added)

3. IS THE CLAMOUR FOR RAIL BY THE PUBLIC MISGUIDED?

We have established ₍₄₃₎ that the transportation of
containers by road can have an environmental impact.
But is that impact likely to be severe once Port
Botany is fully operational? Is the public
response misconceived? Is there panic in the
public mind which can be allayed by disclosure
of the true facts?

42. S.K/C 1086, submission, page 1.
43. Chapter III.

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Those who advocate the Free Market Case believe
there will be no significant environmental
problem created by Port Botany. We will now
examine that belief.

VI THE FREE MARKET CASE

1. THE PORT WITHOUT REGULATION

1.1 Advocates of the Free Market Case

The line-up of parties who oppose regulation is
formidable indeed. First, the Maritime Services
Board in its final submission to the Inquiry
concluded with these words:- ₍₄₄₎

“.. In conclusion (I) must emphasise that
the Board believes no restrictions
should be placed on the transport of
containers either at Port Botany or
Port Jackson”.

The operators at Botany Bay, ANL and CTAL, each
take the same view and oppose regulation. Glebe
Island Terminals Pty. Limited opposes regulation
more especially if it is extended from Port Botany
(where it may or may not be appropriate) to Port
Jackson (where it is said to be wholly inappropriate).
Liner Services Pty. Limited, which operates a major
depot at Alexandria, and is one of four partners in
the Glebe Island facility, also characterises the
various regulatory options as "undesirable". The
Australian Chamber of Shipping strenuously advocates
what it terms a ‘free market case', as does the New
South Wales Road Transport Association.

1.2 The Overseas and Interstate Experience

The Inquiry was concerned to know whether an attempt
had been made to introduce regulatory schemes
overseas or interstate. There were vague references
to an attempt by the New Zealand Government to
implement a scheme favouring rail for non-metropolitan
containers and a scheme in south Africa which is
dependent upon certain features peculiar to that
country and where the port Authority and the Rail
Authority are one and the same. It would appear
that neither in Europe nor in other states of
Australia has any attempt been made to in any way

44. S.K/C 1424, letter dated 9/6/80, page 3.

-59-

circumscribe the choice of mode made by importers
and exporters and to divert containers to rail
where they would otherwise go by road.

Inevitably this causes one to pause before embracing
any scheme involving regulation. It should not, in
the Inquiry’s view, cause the immediate rejection of
the suggested schemes for a number of reasons. First,
containerisation is itself a relatively recent
phenomenon. It is hardly more than a decade old so
that new ground is being broken all the time.
Secondly, each metropolis, and each port, has its own
peculiar problems which must be solved in its own
idiosyncratic way. Matters of physical geography
and quirks of history will often determine the
location of the port in relation to the metropolitan
area. So it is with Sydney, where both port Botany
and Port Jackson are surrounded by closely settled
residential and industrial areas. The contrast with
other ports around Australia is drawn in the
following passage:- ₍₄₅₎

"The new general cargo port areas planned
for Brisbane and Freemantle are
decentralised with respect to their
metropolitan areas, whereas those of
Melbourne and Sydney will remain within
the urban hearts of their respective
cities."

1.3 Inability of the Terminal Operators to Interfere
with the Choice of Mode

The basic premise of the Terminal Operators' argument
is that they are unable to interfere with the choice
of mode made by the importer or exporter. This is
said a number of times in the various Environmental
Impact Statements submitted by the terminals when
seeking planning permission. It was said by CTAL in
its submission to the Inquiry in the following passage ₍₄₆₎:-

45. Rendel & Partners "Study of Sea Ports/Land Use
   Interaction" Report prepared in February, 1976
    for the Department of Environment, Housing and
    Community Development, page 58.

46. S.K/C 1421, page 12.

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"The Terminal Operator has the
responsibility to handle containers
moving from land to sea or sea to land;
however, the Terminal Operator does not
have control of containers moved during
the land transport sections of their
journey either to the terminal or from it.”
(emphasis in the original)

The following also appears:-

"It cannot be emphasised too strongly
that the choice of how goods move is
governed by a number of factors that
are outside the Terminal Operator’s
control."

An Inquiry was conducted by the S.P.C.C. It is
clear that the S.P.C.C. accepted this basic
premise. In its report it said: ₍₄₇₎

"..The Commission considers it has received
insufficient evidence to establish that
adequate safeguards will be provided in
time to ensure that all traffic associated
with the operation of the container
terminals at Port Botany will have an
acceptable impact on the metropolitan
environment. However, the Commission
considers that development approval of the
company's proposals should not be deferred
or withheld for this reason because it is
outside the control of the Terminal
Operators.” (emphasis added)

This Inquiry rejects that premise. The Terminal
Operators can arrogate to themselves by the fine print
in the contract the choice of mode. Indeed they
already do so at Port Jackson and they are likely
to continue to do so at Port Botany in some cases.
Two examples will suffice. First, the White Bay
facility is operated by Seatainer Terminals Limited.
In 1974 it found it could not handle the number of
containers passing across the wharf. It altered its
operation. Thenceforth import FCL containers were
railed to Chullora. The importer had no say. The
Terminal Operator simply decided that was the way
in which the operation would be performed.

47. S.P.C.C. Report into the CTAL Terminal, July, 1979,
page 2.

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A second illustration can be given. In the case
of LCL containers (less than container loads with
multiple consignees or consignors) the individual
consignee who may have a trunk within a container
has no say over which depot the container is taken
to or how it gets there. The shipping line makes
that decision.

In all cases the importer or exporter can switch
shipping lines so that his containers will be
handled in one way (which may suit him better)
rather than another. But that is not the point.
The point is that shipping lines and Terminal
Operators can, when they choose, determine the
choice of mode. They have chosen not to do so and
they are not to be criticized for that. Hitherto,
except in the case of white Bay, there has not been
an occasion which demanded that they determine the
choice of mode.

2. IS THERE AN ENVIRONMENTAL PROBLEM?

2.1 The Issues which Arise for Consideration

It would be unfair to simply assume that Port Botany
will give rise to an environmental problem. If there
is a problem it should be demonstrated by reference
to the evidence.

An analysis of the evidence will be assisted by
approaching the question in two stages:-

First, what are the effects of Port
Botany likely to be? How many vehicles
can be expected in the surrounding
suburbs and what routes will they use?

Secondly, having regard to the numbers
of vehicles and where they will go, does
history suggest an adverse public reaction
similar to that experienced by the

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Australian National Line at Mort
Bay, Balmain? Is there, in other
words, an analogy to be drawn
between Mort Bay and Botany Bay?

We will address each question in turn.

The first question, concerning the future of Port
Botany and its effects upon the Metropolitan Area,
is rather like the first in a series of Chinese
boxes. Concealed within that question is a further
question which gives rise to yet another question and
so it goes on. The questions are:-

i. What is the future container trade
through the Port of Sydney like1y
to be?

ii.     How will that trade be shared between
Port Jackson and Port Botany?

iii.     What will be the division (referred
to as the mode split) between road
and rail at Port Jackson?

iv.     What will be the split between road
and rail at Port Botany?

v.     How many truck movements will be
generated by Port Botany?

vi.     What types of vehicle can be expected
to carry containers from Port Botany?

vii.     At what time of day will those
containers be carried?

viii.     Where will the export containers be
coming from and where the import
containers be carried to?

ix.     Having regard to the origins and destin-
ations of containers, what routes can the
container truck drivers be expected to use?

-63-

Once this evidence has been assembled, an estimate
can be made of the number of container trucks
upon various roads in the southern and south-western
Metropolitan Area. The basis has then been laid
for an examination of the second question: Whether
there is an analogy to be drawn between the
unfortunate experience at Mort Bay, and Botany
Bay.

2.2 The Future Container Trade Through Sydney

The Maritime Services Board provided the Simblist
Inquiry in 1976 with a forecast of container trade
through the Port of Sydney. They estimated 418,000
TEU in the financial year 1984/85. Some four years
later the Board provided this Inquiry with a further
estimate. It is content to adhere to the forecast
given in 1976. The following table (Table 4)
compares the 1976 forecast with the actual trade
figures:

TABLE 4.

FORECAST CONTAINER TRADE THROUGH SYDNEY PORTS

Year	Estimated Trade TEU/year	Actual Trade TEU/year
1974/75	-	262,000
1975/76	265,000	268,000
1976/77	281,000	311,000
1977/78	300,000	298,000
1978/79	318,000	347,337
1979/80	334,000	-
1980/81	347,000	-
1981/82	366,000	-
1982/83	382,000	-
1983/84	400,000	-
1984/85	418,000	-
1989/90	529,000	-

-64-

The forecast of 418,000 TEU for 1985 would appear
to be conservative. The 1978/79 estimate was exceeded
by over 30,000 TEU. The Board indicated in evidence
before the Inquiry that the most recent financial
year (ended 30th June, 1980) was a record year.

2.3 How Will the Trade be Shared Between Port Jackson
and Port Botany?

In the jargon of economics, the shipping and port
industries are characterised by vertical and
horizontal integration. Before containerisation,
in the days of tramp steamers, shipping lines were
largely concerned with shipping. That is no longer
the case. The shipping lines’ ability to maintain
schedules is dependent upon the service provided
by terminals. The shipping lines have formed
consortia to establish terminals. The terminals
service the vessels of each member.

The terminals at Botany Bay are examples of
vertical integration. The occupant of one, the
Australian National Line, is primarily a shipping
company. The occupant of the other, CTAL, is a
consortium of eight shipping lines;

To estimate the Port Botany throughput for 1985
the following information must be gathered:

Which shipping lines have an affiliation
with the Australian National Line terminal?
They can be expected to use that facility.
Which shipping lines are either members
of the CTAL consortium or have some
association with member companies?
What is the present market share of
each of these shipping lines?
What is the market share of each of these
companies likely to be in the forecast
year, 1985?

-65-

The State Transport Study Group (STSG) has
undertaken that analysis. They conclude as
follows:

65% Port Botany (273,000 TEU)

35% Port Jackson (145,000 TEU)
(assuming 418,000 TEU in 1985
as suggested by the M.S.B.)

The M.S.B. have independently estimated a likely
Botany throughput. They give a range of figures.
Their upper range coincides almost exactly with
the STSG figure. The range is:

256,000 TEU (lower estimate)

269,000 TEU (higher estimate) ₍₄₈₎

2.4 What Will be the Split Between Road and Rail
at Port Jackson?

It is difficult to predict the future of Port
Jackson once both terminals at Port Botany are
open. The following facilities will be available
to receive containers:

The White Bay Terminal
The Glebe Island Terminal
The various wharves in Darling Harbour

In the past both White Bay and the Glebe Island
Terminal have each demonstrated a capacity to handle
in excess of 100,000 TEU per annum. Darling Harbour
(and other minor wharves handling containers) handled
90,645 TEU in the financial year 1978/79 ₍₄₉₎. A
further wharf, Darling Harbour No. 3, is under
construction and will shortly be completed. It will
provide further container handling capacity. On this
basis it is safe to assume that the facilities within
Port Jackson have a combined capacity to handle
approximately 300,000 TEU per annum.

48. M.S.B. Submission S.K/C 1424, letter 19/12/79,
page 3.
49. See Table 2, Page 14.

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The Port Jackson share, as we have already
established, is likely to be rather less than
that (145,000 TEU). The rail 'slice' of this
Port Jackson 'cake' will broadly depend upon two
things:

(i) How the 145,000 TEU are divided
between the various facilities
within Port Jackson.

(ii) How the facilities organise their
operations once they have spare
capacity, and are operating on a
much reduced throughput.

The division between the facilities is important
because the Darling Harbour wharves are not connected
to rail. Only country and interstate containers
handled by these wharves are likely to be carried
by rail. The Glebe Island Terminal, on the other
hand, is connected to rail and can be expected to
take advantage of that connection where it is
appropriate. The White Bay facility is not only
connected to rail but the lessee of that facility,
Seatainer Terminals Limited, operates the Chullora
depot and may well encourage or induce importers or
exporters to use the depot facility.

STSG has conducted a Port Survey. It is possible
on the basis of that survey to say exactly what
proportion of containers from each of the facilities
went by rail in the past. It is somewhat dangerous
to extrapolate from past trends where the future for
Port Jackson is so dramatically different from the
past. The choice of mode in the past may have been
the result of exigencies created by Port Jackson
working beyond its capacity. The choice may be
very different when the facilities have spare
capacity.

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There are many imponderables. It is reasonable
to suppose that the Port Jackson trade will be
divided between the facilities as follows:

The various Darling Harbour
facilities (including the new
No. 3 wharf) 45,000 TEU
The Glebe Island Terminal 50,000 TEU
The White Bay Terminal 50,000 TEU

The distribution could be very different. There are
shipping lines which do not have an affiliation with
any terminal. A high proportion of these use the
common user facilities at Darling Harbour. We have
assumed that a significant proportion of uncommitted
lines will be attracted by the spare capacity of the
Glebe Island Terminal and White Bay and will
gravitate towards those facilities, deserting
Darling Harbour. They may not do so. The Glebe
Island Terminal share may be rather higher than the
50,000 TEU suggested since that facility is partly
owned (50%) by two shipping lines, the Columbus Line
and the Farrell Lines. Those two shipping lines had
a combined throughput exceeding 30,000 TEU in the
financial year ended June 1979. There is no
corresponding commitment within the shareholding of
Seatainer Terminals Limited, the lessee of White Bay.

Any division is arbitrary. For the purposes of
analysis we will adhere to the division we have
suggested. The result can be pushed and pulled in
various directions to make allowance for the
possibility that the division turns out to be
somewhat different.

Assuming that division, and assuming further that
past trends are maintained, the rail share for the
Port Jackson component of the trade is likely to
be as follows:

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22% or 311,859 TEU would go by rail

78% or 113,150 TEU would go by road

If the assumed division between the various
facilities is altered to give a greater share to
Darling Harbour, the result is not significantly
different. Assume the following division between
the various facilities:

Darling Harbour and other wharves
70,000 TEU

Glebe Island Terminal 37,500 TEU

the White Bay Terminal 37,500 TEU

For Port Jackson as a whole, on these assumptions,
the figures are as follows:

20% or 29,288 TEU would go by rail

80% or 115,712 TEU would go by road

On any view the number of container vehicles
descending upon Port Jackson, or coming from Port
Jackson, will be far less than in the past. That
is not to say that they will have an insignificant
impact upon the environment.

2.5 The Split Between Road and Rail at Port Botany

With the Port Botany terminals there are less
imponderables. Each of the Terminal Operators, in
its Environmental Impact Statement, has provided an
estimate of the likely rail share. In the case of
the Australian National Line the estimate was 20%.
In the case of CTAL the estimate was 36%. To the
latter estimate there is the following ominous
proviso ₍₅₀₎:-

"WhiLe CTAL estimate that 36% of their
movement will go by rail, CTAL has no
control over the mode or transport
that individual consignees/consignors
choose.” (emphasis added)

50. CTAL Environmental Impact Statement, page 45.

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The matter has been the subject of a painstaking
analysis by Messrs. Jordan and Stapleton of the
State Transport Study Group (51). The Group
concluded that 26% of the Botany throughput (a
total of approximately 70,359 TEU) would be
carried by rail.

The STSG estimate may require adjustment for two
reasons. First, the number of wool containers
being sent to the Port by rail is probably under-
stated. Secondly, and more importantly, a
significant part of the coastal trade of the
Australian National Line is non-containerised or
is container trade of a special sort with boxes
different in size to the International Standard.
The Australian National Line, when operating from
Port Jackson, split its trade between the Glebe
Island Terminal and Mort Bay. The following table
gives an indication of the importance of non-
containerised cargo.

TABLE 5.

NATURE OF CARGOES HANDLED

AT MAIN CONTAINER TERMINAL AREAS.

TERMINAL	TYPE OF CARGO	TONNES 1978/79
White Bay	Containerised Non-Containerised Total	1,969,737 22,555 --------- 1,992,289
Glebe Island	Containerised Non-Containerised Total	1,659,438 12,655 --------- 1,672,093
Mort Bay	Containerised Non-Containerised Total	790,563 141,169 -------- 931,732

51. Exhibit 90, letter 30/10/78, Page 1.

-70-

The Australian National Line suggested that the
coastal trade was almost exclusively a road trade
even where the goods were being carried in a
conventional 20 foot box container. If this is
right, the coastal component should be subtracted
before calculating the rail share in a free market.

Mr. Bryans from ANL Melbourne said in evidence ₍₅₂₎:

"In 1980-81 we expect to have a throughput
of about 135,000 TEU per annum. Of that
28,000 TEU is expected to be interstate
cargo or local domestic cargo. The
balance (will be) overseas trade."

The higher CTAL rail share (36%) is based, in part,
upon an assumption that empty LCL containers unstuffed
at Chullora or Villawood will be railed back to the
Port. CTAL estimate that 8,300 empty containers (in
1985) will be handled in this way ₍₅₃₎.

CTAL made a joint submission (with ANL) to the
Simblist Inquiry. It gave an indication of the
mode split and provided a basis for its calculation.
It did not include railing any empty containers from
Villawood or Chullora.

The port survey conducted by the State Transport
Study Group did not indicate a substantial traffic
in empty containers by rail. This, it may be said,
was because the Port Jackson terminals simply do not
have the space available to receive empty containers.
Provision has been made at Port Botany for their
storage.

The Inquiry is not convinced that empties will
go by rail. Empty container parks are
concentrated in the inner city suburbs and
especially South Sydney. They are not connected to
rail. They are very often insubstantial operations
with few overheads offering very attractive rates

52. Transcript ANL 14/4/80, page 2.
53. Environmental Impact Statement CTAL, March
1979, page 20 (figure 4).

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compared to the rates which the Terminal Operators,
with higher overheads, are able to offer. Unless a
container is required for immediate re-export (as
an empty) it seems unlikely that it would be
transported back to the Port and stored.

CTAL estimate that 48,700 TEU will be carried by
rail in 1985 ₍₅₄₎. If the 8,300 TEU empty
component is subtracted the percentage reduces
from 36% to 30%. To use an expression favoured
by experts in this field, such a reduction would
place the CTAL estimate and the STSG estimate "in
the same ball park" (30% and 26% respectively).

The Australian National Liners experience, since
the opening of its terminal (effectively from March,
1980) provides some corroboration of this assessment
The rail share has averaged 28% ₍₅₅₎.

2.6 The Number of Truck Movements Generated by
Port Botany

It is convenient to summarise the analysis thus far
in order to appreciate the questions which remain
outstanding:

The combined throughput of both
terminals at Botany will be approximately
273,000 TEU per annum by 1985.

Of these 26% to 28% will be carried
rail.

It follows that 72% (196,560 TEU) to
74% (202,020 TEU) will be carried by road.

Assuming a 250 day working year between
786 and 808 loaded containers will be
carried by road each day.

54. Environmental Impact Statement CTAL, March 1979,
page 20 (figure 4).
55. ANL transcript 14/4/80, page 23 (Mr. Peggram).

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That is not to say that there will be 786 or 808
road journeys with a container to or from Port
Botany each day. Unfortunately it is not that
simple. First, containers are to some extent
recycled or repositioned within the Metropolitan
Area. They are moved from this place to that so that
they are conveniently located to suit the
particular requirements of the shipping company
which owns them or has them under lease. It was
estimated by the Simblist Inquiry that reposition-
ing moves increased the number of road journeys by
a further 30%.

Secondly, it should be understood that each loaded
FCL container (whether import or export) gives rise
to an average of 3.5 truck movements. To take an
import FCL the truck movements are as follows:

1. Empty truck travels to the Port for
pick-up.

2. Loaded truck takes the FCL to the
importer.

3. The container having been unpacked at
the importer's premises, the truck
returns to an empty container park
or depot as directed by the shipping
company to drop off the container.

4. The truck then makes its way from the
empty container park or depot back to
its base, though on some occasions
(assumed to be 50% and hence 0.5 of a
movement) the truck driver is directed
to another job. That journey is counted
towards the next delivery.

An FCL export is the same in reverse. The transport
requirements of an LCL container are quite different.
They will be examined later in this Report ₍₅₆₎ when
depots are discussed.

56. Pages 274-284.

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Having estimated the number of containers being
transported by road, and having surveyed the
average number of road movements for each container,
it is possible to calculate the approximate number
of road journeys generated by the Port. That
calculation will not be a sufficient basis to draw
an inference concerning the environmental impact of
transporting containers by road. That impact will
depend upon the following factors which will now be
considered:

The types of vehicles which will
deliver the containers.

The time of day at which they will
be delivered.

Where they come from and where they
are going to.

What routes the truck drivers are
likely to take.

2.7 The Types of Vehicles Delivering Containers

It is clear from the survey carried out by the
State Transport Study Group that the vehicle
transporting the container will almost certainly
be a semi-trailer. The survey demonstrated that
69.2% of vehicles carrying containers were
semi-trailers ₍₅₇₎.

2.8 The Time of Container Movements

The same survey provides an insight into the times
at which containers are usually transported by road.
Messrs. Edgerton, James and Jordan, commenting upon
the survey, state ₍₅₈₎:

57. Edgerton, James and Jordan "Container Movements
in Sydney", Fifth ATRF Forum papers, page 76.
58. Edgerton, James and Jordan, ibid page 77.

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"An important finding (of the survey)
is the overall evenness of movements
throughout the day. There is little
peaking except for a decline in the
volume of movements in the hour ending
12.30 p.m. This presumably is a result
of the lunch break on the wharf..An
additional aspect is that the movement
tends to be compressed into the early
part of the day. After 2.30 p.m. there
is a rapid fall-off, and by the after-
noon commuter peak there are practically
no port containers on the road."

Container truck drivers do not cease work at 2.30 p.m.
It takes approximately two hours to unpack a
container. The standard road costs make an
allowance of two hours for that task. There is no
point in taking delivery of a container much later
than 2.30 p.m. because there will be insufficient
time for the importer's staff to devote two hours
to unpacking and still finish by 5.00 p.m.

The time of day at which containers are delivered is
important for two reasons. First, if there was a
container peak which coincided with the commuter
peak (between 7.00 a.m. and 9.00 a.m.) it could be
argued that the overwhelming number of cars may
render the containers less visible. Because container
movements are relatively even throughout the day,
their presence is especially obvious once the number
of cars declines. Secondly, after the lunch time
lull, the outflow of containers may to some extent
coincide with the release of school children from
school (shortly after 3.00 p.m.) ₍₅₉₎.

2.9 Origins and Destinations of Containers

It is necessary to determine where containers are
coming from (in the case of exports) and where they
are going to (in the case of imports). This is a
matter of some complexity. Importers and exporters
are scattered throughout the Metropolitan Area (and
in the country as well). Their transportation

59. ANL an Environmental Impact Statement, page 67.

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requirements are satisfied by a large number of
organisations. In some cases their needs are met
by road transport companies or by freight forwarders
or by customs agents with a transport division.
There is no co-ordinating authority and no
statistics are kept on an industry-wide basis.
The experience of one transport organisation, even
a large organisation, may simply reflect the bias
of the sample he serves. It may not provide an
adequate basis from which a general conclusion can
be drawn.

The State Rail Authority in its submission to the
Inquiry ₍₆₀₎ performed an interesting exercise to
determine the distribution of import and export
containers. It calculated the relative sizes of
the industrial areas throughout the Metropolitan
Area and distributed the Port Botany throughput
according to the size of each industrial area (i.e.
industrially zoned land). The result was as follows:

TABLE 6.

DISTRIBUTION OF FCL ROAD MOVEMENTS
(Based Upon Size of Industrial Area)

Origin or Destination	Percentage Estimate
Inner Suburbs	22.1
Western Suburbs	58.5
Southern Suburbs	11.0
Eastern Suburbs	-
Northern Suburbs	8.4
TOTAL	100.0

The inner suburbs were defined as Municipalities
of Botany, Marrickville, Leichhardt, South Sydney and
the City of Sydney. The southern suburbs included
Hurstville, Kogarah, Rockdale and Sutherland. The
northern suburbs extended east from Hornsby. The
western suburbs made up the balance.

60. Formerly the Public Transport commission S.K/C 208,
(page 7).

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The State Rail Authority appreciated that this was a
less than adequate basis upon which to determine the
origins and destinations of containers. Industrial
areas obviously differ one from another. Some are
more intensively developed than others. Some of the
outer industrial- areas have yet to be developed at
all.

The table is reproduced in this Report because it may
offer an insight into the long-term distribution of
container movements. In the long term it seems
reasonable to suppose that a greater number of
containers will be concentrated in the west and
south-west. If there is, at this time, an unacceptable
environmental impact occasioned by the road transporta-
tion of containers west, it is likely to become the
more unacceptable as the decade wears on and the
century draws to its close.

Other organisations have attempted to monitor or
sample container movements to throw light upon their
origins and destinations. It is difficult to compare
one survey with another because they each adopt
different geographic zones. The Australian National
Line in its Environmental Impact Statement produced
a map which is reproduced in this Report (figure 2).
It is obvious from the map that there is a heavy
concentration of movement to and from the Central
Industrial Area ₍₆₁₎.

CTAL adopted a different procedure. It divided the
Metropolitan Area into zones. Reproduced in this
Report is a map which identifies the zones and the
percentage of containers which will either come from
or go to those zones (figure 3) ₍₆₂₎.

61. ANL Environmental Impact Statement, page 47.
62. CTAL Environmental Impact Statement, March 1979,
page 22.

FIGURE 2

AUSTRALIAN NATIONAL LINE – Environmental Impact

Statement Proposed Botany Bay Container Terminal

FIGURE 3

C.T.A.L. ENVIRONMENTAL

IMPACT STATEMENT.

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The CTAL map shows a rather greater concentration
of containers in the Western suburbs than the ANL
survey. Support for the CTAL analysis is to be
found in a survey by Seatainer Terminals Limited
made between December, 1978 and March, 1979.
During that period Seatainer Terminals despatched
substantially all import containers from White Bay
to its depot at Chullora regardless of their
ultimate destination. Some containers had then
to be transported back towards the inner city.
The survey revealed:

55.6% of FCL imports had destinations
west of Chullora;

5.4% had destinations east of
Chullora, but still closer to
Chullora than Botany Bay;

39% had destinations closer to
Botany Bay than to Chullora.

It may be suggested that the Seatainer figures are
not representative because the terminal tends to
attract importers located in the western suburbs
for whom the Chullora facility is convenient.

STSG has examined the question in depth. For two
weeks between the 12th June, 1978 and 23rd June,
1978 it conducted a Port survey. The survey
monitored almost 10,000 container truck movements
(representing 6,500 container movements by road),
and 4,500 movements by rail ₍₆₃₎.

Suggestions were made at the public hearings that
the survey may have been inaccurate. Three broad
criticisms were levelled. First, it was hinted
(though never said in terms) that the sample may
not have been large enough. That suggestion may
have had greater force if the number of containers

63. Edgerton, James and Jordan, ibid. page 66.

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involved in each of the other surveys was known.
With other surveys the conclusions are stated
without the accompanying documentation. It is
the Inquiry's view that a sample of almost 11,000
containers is substantial.

Secondly, the survey followed a period of extensive
industrial disputation. The survey was postponed
until the industrial problems had been sorted out.
There is no doubt that waterfront stoppages caused
exports and imports to accumulate at the wharf and
in the depots. That fact should not affect the
accuracy of the survey. It would simply serve to
enlarge the sample.

Thirdly, it was suggested the survey was in some
way tainted because a number of vessels had been
diverted to Melbourne where the containers were
off-loaded. The State Transport Study Group
specifically responded to this criticism in the
following terms ₍₆₄₎:

"An implicit corollary of the above
criticism, therefore, must presumably
be that any containers diverted to
Melbourne are distributed differently
from those that are not diverted (once
they are returned to Sydney for distribu-
tion) and are sufficiently large in
number to effect the overall distribution..
Only 283 overseas container TEU were
moved from Melbourne to Sydney during
this survey period."

This does not provide a complete answer because the
figure given STSG (283 TEU) represents the rail
movement. We do not know (and cannot in the nature
of things know) the number of road movements between
Melbourne and Sydney. Since rail is the cheaper
mode interstate, it seems probable that it was less
than the number mentioned by STSG. If that is
right, the diversion of ships to Melbourne is unlikely
to have made any difference at all.

64. Letter to the Inquiry dated 6th May, 1980.

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What, then, did the State Transport Study Group
survey reveal? It revealed the dominance of five
local government areas, namely South Sydney, Botany,
Marrickville (which essentially make up the
Central Industrial Area), the City of Sydney and
Leichhardt.

The figures were as follows:

51% of all loaded FCL movements (import
and export) originated in or were destined
for these five local government areas ₍₆₅₎

the remaining 49% of loaded FCL movements
were widely scattered throughout the
Metropolitan Area

if account is taken of all container
movements (FCL, LCL and empties) the
dominance of the inner suburbs is even
greater. Tt rises to 64% ₍₆₆₎

Although (Table 6 above) the western suburbs may
have 58.5% of the metropolitan industrial land, the
survey revealed the following:

32% of the loaded FCL imports were
destined for the western suburbs

13% of FCL export originated in
the western suburbs ₍₆₇₎

The Inquiry prefers the STSG survey to other surveys
carried out in the past. The STSG survey is the
most recent. It embraces a substantial sample of
containers. It has been painstakingly documented
and widely disseminated. In the Inquiry’s view it
furnishes the most reliable basis for determining
the origins and destinations of containers in the
Sydney Metropolitan Area.

65. Edgerton, James and Jordan ibid page 71.
66. Edgerton, James and Jordan ibid page 72.
67. STSG Calculations dated 12/8/80 relating
to the rail impact of extension of the
P.E.C. proposal to port Jackson, page 2.

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2.10 The Routes Used by Container Trucks

For those containers with origins or destinations
in the inner city suburbs, the switch from Port
Jackson to Port Botany is not likely to make a
great deal of difference. Substantial areas
of residential land, and mixed industrial and
residential land, must be crossed, whether by
trucks travelling south from Port Jackson, or
north from Port Botany.

We are not suggesting for a moment that such
trucks will not have an impact. They will. We
are simply asserting that there is no evidence
before the Inquiry to suggest that the impact will
be worse when trucks come from Port Botany than it
was when they came from Port Jackson. Insofar as
the balance of industry is closer to Port Botany
than Port Jackson, the position, environmentally,
may be marginally better.

For containers destined for the Western suburbs or
coming from the Western suburbs, the position is
quite different. Suburbs which had not previously
experienced containers in great numbers will
suddenly feel their presence. Port Botany will
bring about two important changes to which
reference has been made:

There will be a change in the direc-
tion of travel of container trucks.

There will be a dramatic change in
numbers because rail will cease to
carry the proportion of containers
it previously carried. The method
of operation at Port Botany is
primarily a road delivery system.

The Joint Submission by ANL and CTAL to the
Simblist Inquiry in 1976, estimated the

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combined effect of the CTAL and ANL operations
would be 11600 heavy vehicle movements per day
( 68) . Some only of these movements would be
destined for the western suburbs. The evidence
given by Mr. McCulloch (CTAL) was as follows ₍₆₉₎:

"MR. McCULLOCH: On the western corridor
which is the Bay Street, Frederick Street,
Watkins Street, Harrow Road route which
the carriers assure us (they use).

MR. BAUER: I am sorry..which route to
the western route?

MR. McCULLOCH: The Bay Street, Frederick
Street, leading from General-Holmes Drive
at Rockdale. There are 640 (heavy vehicle
movements) per day, which is 32 per hour
in each direction and one almost, just
under two minutes. We measured the flow
last Thursday at 11.30 in the morning.
Unfortunately the petrol strike was on so
car traffic may have been down a bit but
there were 1,076 vehicles in that hour
including 222 heavy vehicles. And I can
assure you that there is no restriction to
the flow of traffic, the street was
deserted. We are suggesting that we are
only putting in 64 per hour. Obviously
that street has a capacity well in excess
of this..Our contribution of 64 per hour
will be insignificant."

The throughput assumed for the purpose of calculating
1,600 heavy vehicle movements per day was 300,000
TEU in 1985 (compared to 270,000 TEU now estimated
by the M.S.B.).

The route nominated by Mr. McCulloch is (substantially)
the Bexley Road option under consideration by this
Inquiry. That option is the subject of a detailed
evaluation in a separate report. The words spoken
by Mr. McCulloch were apparently intended to
reassure Commissioner Simblist. One may doubt that
they had that effect. They certainly do not reassure
this Inquiry. The unsuitability of the Bexley Road
route for the transportation of containers by large

68. Transcript Botany Bay Port & Environmental
Inquiry (CTAL Submission) 7/10/76, page 9.
69. Transcript ibid. pages 14-15.

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semi-trailers is well documented. The Joint Study
Report prepared by the Department of Main Roads
and the Planning and Environment Commission for
this Inquiry describes that route in these terms ₍₇₀₎:

"The geometric standard..would be consistent
with the standard of the existing Bexley
Road, which is, along with many other existing
urban roads, below the recommended NAASRA
standards...Bexley Road has curves with
radii as low as 60 metres and grades up to
8%...Curves of (this radius) are below the
NAASRA standard for even 60 km per hour
design speed and it is therefore doubtful
whether they would provide a reasonable
level of safety for the traffic conditions
likely to prevail.”

2.11 How Many Vehicles Would Use Bay Street-Harrow Road-
Bexley Road Route

Calculations have been made by the Planning and
Environment Commission and by the State Transport
Study Group. They do not differ materially from
the evidence given by Mr. McCulloch to Commissioner
Simblist. The Planning and Environment Commission
conclude ₍₇₁₎:

Total container movements 82,029
TEU per annum.

Truck movements through Rockdale
128,062 per annum.

Assuming 250 working days per year
truck movements of 512 trucks per
day.

The maximum hourly movement through
Rockdale would be 89 container trucks.
Some of these trucks will be empty making their way to
Port Botany.

70. Joint Study Report, page 20.
71. Planning and Environment Commission Submission
S.K/C 947 documentation Appendix 9.

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The State Transport Study Group felt it had no
basis upon which it could estimate the empty
truck movements involved in picking up and
delivering containers. Some trucks will be
making their way to the Port from the Central
Industrial Area. Others will be coming from some
other direction. They did not feel they had
sufficient data to say what proportion would be
passing through Rockdale. Confining their
analysis to trucks actually carrying containers,
they estimate the number of containers passing
through Rockdale will lie somewhere between:

minimum 250 per day.

maximum 400 per day.

3. IS THERE AN ANALOGY BETWEEN MORT BAY AND BOTANY BAY?

3.1 Mort Bay Universally Condemned

We make no apology for repeating in this context
the words of the Maritime Services Board in its
submission to this Inquiry ₍₇₂₎:

"One has only got to drive down the streets
to Mort Bay to see that it is a situation
that is completely unacceptable. Possibly
a thing which should never have happened. "

It will be remembered that the Australian National
Line, which operated the Mort Bay Terminal, was
amongst those which most loudly proclaimed the
environmental unsuitability of that site.

Is there a lesson in the sorry history of Mort Bay
which has application to Botany Bay?

3.2 Submissions to the Present Inquiry

Mayne Nickless Limited in its submission to the
Inquiry stated: ₍₇₃₎

72. Transcript 16/4/80, page 64.
73. S.K/C 1321 page 1, made 15/8/79 when Mort Bay
was still operating.

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"Without adequate road systems to and
from Port Botany, a similar unacceptable
situation such as we have at Balmain,
will present itself."

In the corporate mind of one significant transport
operator there is an analogy to be drawn between
Mort Bay and Botany Bay.

The Hurstville Municipal Council, likewise, had
this to say: ₍₇₄₎

"Consideration was based on the experience
already gained at the Balmain Terminal and
the well documented evidence of noise and
air pollution that the residents of the
area have had to endure for too long a
period. Council is therefore anxious that
a situation such as this is not repeated
through this area."

The submissions from private residents repeatedly
echo this theme.

3.3 Are There Material Differences Between Mort Bay
and Botany Bay

There are four suggested differences between Mort
Bay and the route which container trucks are
likely to take when they are delivering containers
to the west (Bay Street, Harrow Road, Bexley Road
etc.). The differences are:-

(i) Mort Street and the other streets
in Balmain are narrower and the
houses are built immediately adjacent
to the footpath unlike the homes in
Rockdale, Bexley and Campsie. It is
suggested that the two situations are
not comparable.

(ii) It is suggested that Balmain is
hillier than the Bay Street/Bexley
Road route.

(iii) It is suggested that there were more
vehicles at Mort Bay than can be
expected at Rockdale, Bexley and Campsie.

(iv) Mort Street and other streets in
Balmain are residential streets. Bay
Street/Harrow Road/Bexley Road is a
secondary road carrying a significant
volume of traffic.

74. S.K/C 1086, submission page 1.

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The narrowness of the streets is relevant because
it affects noise, vibration and intimidation. Yet
Bexley Road, for instance, is approximately 12.8
metres wide with a 3.7 metre footway ₍₇₅₎ whereas
the carriageway in the relevant Balmain Streets
varied between 10 metres and 16 metres ₍₇₆₎.

Certainly the houses in Balmain are not set back
as they are to some extent in Rockdale, Bexley
and Campsie. Yet the differences are not great
and, in any event, noise and vibration do not
significantly attenuate over these distances.

The hilliness of the Balmain peninsula exacerbated
the noise and fumes created by trucks. The Bexley
Road is quite hilly as it descends into the Bardwell
Creek Valley and into the Wolli Creek Valley.

On the worst road (Mort Street, Balmain) the peak
flow was about 60 vehicles per hour ₍₇₇₎. The average
flow was described in the following terms: ₍₇₈₎

"..The number of trucks moving down the
street at an average frequency of one
truck every 3-4 minutes on the main routes,
represents an unacceptable frequency of
truck movement in an area where the
residential buildings are developed
close to the street alignment."

The daily average, in other words, was of the order
of 15-20 vehicles per hour down the main routes.
How does that compare with Botany? It will be
remembered that the Planning and Environment Commission
has submitted the following figures to the Inquiry ₍₇₉₎:

512 trucks per day (some of which
would be empty)

The maximum hourly movement through
Rockdale would be 89 container trucks.

75. Joint Study Report, page 20.
76. Balmain Residents’ Cage Against Cargo Trucking
    From Mort Bay, paragraph 5.2.
77. Appendix 4, page 2, Balmain Residents’ Case ibid.
78. Balmain Residents’ Case paragraph 5.3.
79. Planning & Environment Commission submission
    S.K/C 947 documentation of Appendix 9, page 5
    and see page 84 of this Report.

-88-

It will also be remembered that STSG made certain
calculations. It did not feel able to make any
estimate of the empty container trucks making
their way to the port. Excluding this element
their figures were:

approximately 250 per day minimum

approximately 400 per day maximum

The figures submitted by ANL and CTAL to Commissioner
Simblist in the Port and Environment Inquiry in 1976
did not differ materially from these estimates. They
estimated 64 containers per hour although they based
their estimate upon a Botany throughput of 300,000 TEU
(compared to the present M.S.B. estimate of 273,000).

It will be seen, therefore, that there will be
substantially more containers passing through
Rockdale than engendered the wrath of the public at
Mort Bay, Balmain.

The Inquiry regards these figures as conservative.
First, the calculations assume a throughput in 1985
of 418,000 TEU. That is the M.S.B. estimate made
in 1976. It is likely that this figure will be
exceeded. Secondly, even if it is not, the container
throughput is increasing at an annual rate of
approximately 6%. For the years beyond 1985 the
figure will certainly be exceeded. Thirdly, the
concentration of industry in the West and South-West
is likely to intensify in the future and this because
the industrial land available in the inner city areas
is restricted and prohibitively expensive. There are
large tracts of industrial land available in the
Western suburbs and the South-West. The dominance
of the five inner city local government areas,
detected by the STSG survey, is likely to be whittled
away as the years go by. Fourthly, Port Botany
represents the very latest in container terminal
technology. It offers a vast number of advantages
over the Port Jackson facilities. Its performance
is likely to be impressive indeed.

-89-

3.4 The Comparison is between a Residential Street
and a Secondary Road

We then come to the fourth suggested difference.
The Terminal Operators maintain that these containers
will be lost in the traffic stream because unlike
Balmain there are so many other vehicles. TABLE 7
provides the average daily (24 hour) traffic counts
for the year 1977 for the various roads which
container vehicles are likely to use in their
passage to the West or South-West.

TABLE 7.

AVERAGE DAILY TRAFFIC COUNTS 1977.

STREET	AVERAGE DAILY TRAFFIC
Bay Street, Rockdale (near junction Grand parade)	11,330
Bay Street, Rockdale (near Princes Highway)	16,230
Harrow Road, Bexley (near Forest Road, Bexley)	19,890
Bexley Road, west of the junction with Forest Road	14,640
Bexley Road (at Bexley North)	25,580
Bexley Road at Clempton Park north of William Street, Earlwood	19,810
Bexley Road near the junction of Canterbury Road (south)	24,260
Beamish Street, Campsie (north of Campsie Railway Station)	24,040

The Inquiry accepts that there is the suggested
difference between Mort Bay and Botany Bay. It
maintains however, that the analogy with Mort Bay
still holds. First, a container vehicle, even in
a sea of cars, stands out as an elephant would stand
out amidst a flock of pigeons.

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Secondly, the containers will pass through areas
which are sensitive to truck traffic and especially
container truck traffic. The following is an
extract from the Rockdale Council submission ₍₈₀₎:

"Within Rockdale container trucks will
pass through Brighton-Le-Sands, Rockdale,
Bexley and Bexley North shopping centres
and pass schools, churches and hospitals.
The route adjoins residential areas for the
greater portion of its length both within
Rockdale and the neighbouring municipality."

Thirdly, the passage of containers through Rockdale,
Bexley and Campsie will take place some ten years
after it began at Mort Bay. In 1969 when Mort Bay
began its operations no one quite knew what the
impact of containerisation would be. No one envisaged
that it would overwhelm the shipping industry within
the space of ten years. No one quite appreciated the
impact which container vehicles would make upon the
environment and upon the public mind. But those
lessons have been learned. The community is less
likely to be tolerant now, ten years on, than it
was when Mort Bay began.

Fourthly, it is obvious from the submissions made
to this Inquiry ₍₈₁₎ that the community senses that
the environmental degradation is unnecessary because
of the rail alternative which offers an immediate
solution. Even those who advocate the Kyeemagh/
Chullora Road, or some other road proposal, recognise
the long lead time required for the implementation
of that solution. It is to trespass unduly upon the
good-will and patience of a community to expect it to
wait a period of ten years if it be the case that
there is a solution which is available and can be
implemented immediately.

Finally, there is a great deal of evidence that the
areas through which containers would pass (Bay Street,

80. Rockdale Council S.K/C 343 “Transport of Containers
by Rail” 22nd April, 1979, paragraph 2.2.
81. See chapter V "The Clamour for Rail”, page 50.

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Rockdale, Harrow Road, Bexley and Bexley Road)
already suffer significantly from the effects
of noise and the other forms of environmental
degradation that follow in the wake of a heavy
traffic stream.

The noise suffered in this area furnishes an
illustration. The regional office for the Botany
sub-region of the Planning and Environment
Commission is, as it happens, in Bay Street,
Rockdale. The following passage describes
conditions in that office: ₍₈₂₎

"BOSS: In our office in Bay Street, the
P.E.C.'s office in Bay Street, the noise
levels measured at the open window on the
first floor were in the vicinity of 79
decibels. The noise measurement carried
out independently by the Council at the
Bexley shopping centre showed variations
between 79 and 83 decibels during the day.
So it can be appreciated that a 3 decibel
increase when you already have such a
large decibel reading, is very significant..
In the case of the office mentioned we have
partly solved this problem by double glazing.

CONROY: (before that) you couldn’t hear
people speaking to you on the telephone..
when there was traffic going past.”

At approximately 70 decibels it is difficult to
conduct a telephone conversation. Because the
decibel scale is a logarithmic scale, the addition
of 10 decibels (to 80 decibels) is effectively a
doubling of the noise level.

The Bexley shopping centre is especially troubled
by noise as the decibel readings suggest, and as the
following testimony graphically illustrates ₍₈₃₎:

"MRS JONES: ..The Bexley shopping centre,
it is absolutely ruined. There are trucks
going through there. You cannot talk if
you go there to shop. You park your car
in a little area they've got there, and
you try to walk through the main highway
you can't hear yourself speak to a friend

82. Transcript 26/3/80, pages 9-10.
83. Transcript 26/9/79, Mrs. Elizabeth Jones of
Harrow Road, Bexley.

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with the noise of the traffic.. It has
got worse. We went into a chemist shop
there, one day. This man's been in that
chemist shop for a number of years and he
said that he was broken hearted because
there was nothing he could do. Couldn’t
sell his shop. He just couldn't sell it,
because of the traffic. He couldn’t hear
what I was asking for in the chemist shop.
Bexley has been ruined for some time, I
would say."

It is against that background that the superimposition
of an additional load of container traffic must be
judged.

4. THE EFFECTS ON DECENTRALISED DEPOTS

4.1 Depots at Chullora

The Seatainer Terminal's Chullora depot is connected
by rail to Port Jackson. Its throughput has been:

FCL containers 35,700

LCL containers 11,750

Total throughput 47,450 ₍₈₄₎

Some 191 persons are employed at this establishment
including managerial and executive staff. Those
engaged in the handling of containers are either
members of the Federated Storemen and Packers Union
(Storemen and Packers) or members of the Federated
Clerks Union (referred to here as Clerks).

The State Transport Study Group and the PEC have
each considered the likely depot throughput once
Port Botany is fully operational. It will be
remembered that there is a need at the present time
for White Bay to rail containers to the Western
suburbs simply to handle the number of containers
passing across the wharf. It could not function
otherwise. The need will not exist at Botany.
Botany will cope handsomely. STSG and the PEC,
therefore, both assume that the FCL component (35,700
TEU) will disappear. STSG predicts that the Chullora
depot will have a throughput in 1985 of approximately
14,000 TEU if it is still ‘afloat'. ₍₈₅₎

84. Submission S.K/C 953 Seatainer Terminals Limited,
page 4.
85. Exhibit 139.

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Could the Chullora depot survive a reduction of
this order? The question was put to the National
Operations Manager of Seatainer Terminals Limited
at the public hearing ₍₈₆₎:

"COMMISSIONER: Is there in your mind a
distinct possibility.. that the Chullora
depot might be threatened unless something
were to occur to raise the throughput
which might otherwise disappear once Port
Botany opens?

McSPORRAN: I think it would be
unrealistic if one didn't assume that
that possibility existed."

The closure of Chullora would cost the jobs of 191
men and women. It will not be suggested by this
Report that the Government should interfere simply
to prevent unemployment of this order. Obviously
market forces close businesses every day of the
week. However, insofar as any scheme can manage
to preserve employment whilst serving some other
legitimate Government policy (such as the protection
of the environment) the preservation of employment
is obviously a bonus which cannot be ignored.

4.2 Depot at Villawood

Freightbases Pty. Limited has established a
decentralised container park at Villawood. It is
located near the Leightonfield railway station not
far from Woodville Road. That depot presently has
169 employees who likewise (depending upon their
particular classification) are either members of
the Federated Storemen and Packers Union or the
Federated Clerks Union. The precise throughput of
the depot does not appear from the evidence though
various estimates have been made. It is working at
something slightly less than capacity which is
stated to be:

11,000 LCL containers

4,000 FCL containers

86. Transcript 21/3/80, page 61.

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It would be able to increase its capacity without
great difficulty if it were necessary to do so₍₈₇₎.

It is difficult to predict the future for the
Villawood depot once Port Botany is in full swing.
It is generally conceded that the LCL component of
the container market is shrinking and certainly this
has been the experience of the Villawood depot. In
1976, for instance, the Villawood depot had 182
employees and this number has been trimmed to 169
as the market receded. It seems likely that this
trend will continue. It also seems likely that the
opening of Botany will remove the FCL component from
the Villawood throughput. Where this would leave the
Villawood depot is difficult to say. The distinct
impression was given at the public hearings that the
operation was already marginal. Its long term
viability, on this evidence, therefore, must be a
matter of doubt.

5. CONCLUSION

Those who advocate the free market case have two
strings to their bow. First they maintain that
there is no environmental problem. The public in
its response to this Inquiry has registered its
profound disagreement. The Local Councils, in a
rare show of unanimity, have also disagreed. This
Inquiry supports the view taken by the public and
the Local Councils and is firmly of the view that
there is a problem which will become increasingly
evident as Port Botany becomes fully operational.

But that is not the end of the free market case by
any means. There is the second string. It is said
that even if there is an environmental problem
the operational, practical and financial difficulties
which would accompany the alternatives make them even
less desirable. We will examine that contention in
the context of each option.

87. Transcript Freightbases Pty. Limited 14/3/80 page 63.

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The Kirby Reports

Sunday 24 May 2015

Volume I - Report - Chapter I