Introduction

The Campaign for Better Transport (CBT) is a non-politically aligned group that advocates for sustainable transport policies and projects throughout Auckland and the rest of New Zealand. The CBT regularly advocates for better alignment between land-use planning and its effects on the transport network, better public transport and better walking and cycling facilities.

Summary of Submission

The CBT generally opposes the Puhoi to Warkworth section of Ara Tuhono (“the Project”). This is for a number of reasons that are detailed further in this submission.

• There is a high probability the project will not realise the project objectives and benefits sought by the NZTA
• The justification for the Project on the grounds of route security is based on a very low number of incidents on the existing SH1
• Safety issues on the existing SH1 should be addressed. Should the Project be confirmed, traffic volumes on the existing SH1 will be similar to present day levels. Users of the existing SH1 in 2026 are three to four times more likely to be involved in injury accidents than users of the Project route
• Likely traffic volumes for the Project have been overstated. The Transportation and Traffic Assessment Report lacks the necessary detail required to conclude support for the Project
• Reports to back up claimed economic benefits are not based on any empirical data or studies
• Alternative options which will achieve NZTA’s objectives have been not been considered

Legal Framework

Section 171(1) of the Resource Management Act outlines the process by which a notice of requirement is considered by a territorial authority (or the BOI in this case). A variety of matters must be taken into consideration. Of particular relevance to this application and the CBT’s submission are the following:

• Part 2 5 (2) – enabling people and communities to provide for their social, economic and cultural well-being and for their health and safety
• 171 (1) (b) – whether adequate consideration has been given to alternative sites, routes, or methods of undertaking the work
• 171 (1) (c) – whether the work and designation are reasonably necessary for achieving the objectives of the requiring authority for which the designation is sought

 Project Objectives and Benefits May Not Be Met

The AEE summarises the benefits of the project as:

• Improved route security and resilience of the State highway network north of Auckland through reducing the reliance on one main route (the current SH1);
• Improved safety performance compared to the existing SH1 between Puhoi and Warkworth with the indicative alignment designed to RoNS standards;
• Reduced travel times and improved travel time reliability along the State highway network north of Auckland increasing accessibility across many parts of the Region’s road network; and
• Potential for economic development as a result of travel time savings, improved trip time reliability and improved inter-regional accessibility between Auckland and Northland.

The following sections discuss each of these claimed benefits.

 Improved Route Security

From p.45 of the Transportation and Traffic Assessment Report:

 The existing SH1 route is currently closed a number of times a year as a result of events such as crashes, flooding or slips blocking the road. By way of an example, information provided by the NZTA’s network contractor indicates that in the 10 years from 2003 – 2012, SH1 between Puhoi and Warkworth was closed for a total of approximately 64 hours due to 21 crashes.

So, on average, the existing SH1 has been closed twice a year due to accidents for three hours at a time.

We submit that this is a very low number of incidents in which to justify building a further alternative route to the existing SH1 and the existing SH16. The risk of closure should be mitigated not by building an alternative route, but by addressing safety issues on the existing SH1.

Improved Safety

The Transportation and Traffic Assessment Report contains the following table in relation to serious crashes on the existing SH 1.

Fatal and serious crashes 2008 – 2012

It is obvious that there are a number of “black spots” on the existing SH1 route, however the Project will not address these areas despite the statistics providing a compelling reason to do so.

From p.45 of the Transportation and Traffic Assessment Report:

 The average annual number of injury crashes in the corridor is forecast to decrease by five (23%) in the year 2026 in comparison to the future traffic volumes on the existing SH1 route.

We assume that the traffic modelling has produced this result because traffic volumes on the existing SH1 will be similar to the volumes experienced today. Consequently accident rates can be expected to be unchanged on the existing SH1.

The unchanged traffic volumes are borne out in the following two snapshots taken from the Transportation and Traffic Assessment Report, showing traffic volumes at Hungry Creek Road will be similar to 2009 levels, disregarding the infrequent Holiday Start (HS) and Holiday End (HE) periods.

2009 Volumes

Volumes 2026 Base Case and Project

We submit that the modelled figures for reductions in injury crashes are an unacceptably low de facto target for the Project. Should the Project be confirmed, we submit that safety improvements to the following black spots are necessary to mitigate unnecessary injuries and loss of life:

• McKinney Road To Valerie Close South
• Perry Road to Conwan Bay Road
• Schedewys Hill
• Mahurangi West Road to Hungry Creek Road

We also note that there is a social equity issue in that motorists who cannot pay the toll, or cannot use the Project route because the Project does not serve their destination efficiently (for instance Puhoi – South Warkworth), will be subject to a substantially more dangerous road than the Project route. This is shown by the following chart taken from the Transportation and Traffic Assessment Report, which demonstrates that users of the existing SH1 in 2026 are three to four times more likely to be involved in injury accidents than users of the Project route.

It is conceivable that a higher toll will be introduced for trips between Puhoi and the northern point of the Project.  For instance, the existing NGTR toll could be increased, or an additional tolling gantry could be installed north of Puhoi so that users of the Project route are charged an additional fee.

Should this occur, then the social inequity will be more pronounced as more motorists will elect to take the free existing SH1 option rather than pay the toll, taking the risk of driving on a relatively unsafe road.

Projected Traffic Volumes

From p.13 of the AEE:

If no capacity improvements are provided on the State highway network between Puhoi and Warkworth, travel times in the corridor as a whole are forecast to increase significantly as traffic volumes on SH1 increase in the future. Traffic volumes on the existing section of SH1 between Puhoi and Warkworth are anticipated to grow by approximately 4% per annum to the year 2026 and be in the order of approximately 25,000vpd

We submit that the projected traffic volumes have been overstated in order to support the Project. From p.14 of the Transportation and Traffic Assessment Report:

Drivers generally only use SH16 as an alternative to SH1 during holiday periods when SH1 becomes heavily congested. This congestion will be largely eliminated by the Project. With the Project in place, many of the long distance trips will actually take place in the SH1 / Project corridor rather than SH16. To reflect this, we made some manual adjustments to the model in the Holiday Start and Holiday End periods. 75% of trips that used SH16 but did not have a destination along SH16 (and were travelling further north to Wellsford) were forced to enter the model network on SH1 at the southern extent of the model rather than using SH16.

We submit there is no valid reason for assuming 75% of SH16 users (many of whom presumably reside in West Auckland) will use the Project route during holiday periods. This is because congestion will not be largely eliminated by the Project during holiday periods.

The following chart from p.55 of the Transportation and Traffic Assessment report identifies congestion will occur on the existing SH1 between Warkworth and Wellsford.

We assume that this is because at the northern interchange where the existing SH1 and the Project routes merge, congestion will occur as three lanes merge into one.

Knowing that congestion will continue to occur during holiday periods once the Project route is completed, making a manual adjustment to the model so that 75% of existing SH16 users are forced into the Project model needs to be further justified.

It is worth noting that the Transportation and Traffic Assessment Report dismisses the increased travel times during the holiday period, stating:

This is a minor adverse effect for relatively few holiday periods each year.

Yet a considerable amount of modelling contained within the report, and hence justification for the project, is based around trips within the “holiday start” and “holiday end” periods.

Since the report acknowledges the holiday periods only occur a few times a year, we submit that inclusion of holiday peak travel figures in the Transportation and Traffic Assessment Report are irrelevant and should not be part of any justification for the project.

Because of the obvious shortcomings of the Transportation and Traffic Assesment Report, we submit that the Board of Inquiry should commission its own review of the report. There is a precedent for this with the BOI for the Basin Reserve flyover project in Wellington commissioning a similar review of the NZTA commissioned traffic assessment report.

Unless NZTA can guarantee that there will be no extra toll levied, any peer review of the Transportation and Traffic Assessment Report should also test scenarios of an additional toll being charged for trips between Puhoi and Warkworth. The imposition of an additional toll would cause considerable diversion of traffic to the existing SH1,and thus have a material affect on expected traffic flows.

Reduced Travel Times

From p.60 of the Transportation and Traffic Assessment Report:

Ignoring the relatively few holiday periods each year, we submit that the Project is not justifiable on the grounds of reduced travel times.

Predicted travel times appear to be exaggerated. The Project route measures 18.5 km in length. The fastest travel time of 10.1 minutes for inter-peak travel equates to an average speed of 109.9 kph, or 10 kph above the legal speed limit. While NZTA have indicated that the Project route will have a design speed of 110 kph, there is no indication that the law will be changed to allow these speeds for cars and trucks.

(In any case, allowing higher speeds of up to 110 kph negates claims of operating cost savings, as fuel consumption is dispropotionately higher at higher speeds.)

We submit that a more realistic assumption of the average speed of trucks and vehicles should be made to determine predicted travel times. This information should be readily available from the nearby NGTR, which is of a similar standard to the Project.

Without the Project, travel times from South to North are expected to increase by only 2.6 minutes inter-peak and 3.1 minutes during the pm peak. We submit that these increases do not warrant and intervention of the scale of the Project.

We note that travel time savings with the Project for journeys other than South to North are substantially smaller – less than 3 minutes at best, ignoring holiday periods. We assume that his is because the “fastest route” for these projects is in fact the existing SH1 road.

We submit that the NZTA should conduct further assessment work focussing on improvements that can be made to the existing SH1 to achieve travel time savings for all motorists travelling between Puhoi and Warkworth, not just the proportion of traffic able to use the Project route.

 Travel Time Reliability

We note from the Transportation and Traffic Assessment Report that currently 66% of all trips between Puhoi and Warkworth vary by only +/- 1.4 minutes. 95% of all journeys north are between 12.2 and 17.8 minutes. We submit that the Project cannot be justified on the basis of improving travel time variability, given the variability is already extremely low in terms of absolute minutes.

Projected variability in the 2026 base case scenario is also questionable, given that traffic volumes are unlikely to grow by the amounts claimed for reasons already stated.

From the p.13 of the AEE:

Congestion resulting in increased travel times and reduced travel time reliability is already a problem along the SH1 corridor north of Auckland, particularly at Warkworth where congestion regularly occurs during weekday evening commuter peak periods. More severe congestion is experienced when incidents such as crashes or slips occur, or during weekends or holiday periods, the latter due to an increase in both long distance through trips and local traffic travelling within and through Warkworth resulting in in higher traffic volumes. If no capacity improvements are provided on the State highway network between Puhoi and Warkworth, travel times in the corridor as a whole are forecast to increase significantly as traffic volumes on SH1 increase in the future.

We note that a bypass of Warkworth is already planned (the Warkworth Western Collector route). We submit that travel time reliability will be improved, particularly in and around Warkworth, with the addition of this route.

For freight movements, we note that less than half of all HCV movements in the Puhoi to Warkworth corridor will use the Project route, as shown in the figure taken from p. 68 of the Transportation and Traffic Assessment Report.

This being the case, we question the value of the Project to the freight industry, and again submit that NZTA should conduct further assessment work focussing on improvements that can be made to the existing SH1 to achieve travel time savings for all freight movements in the corridor, not just those movements on the Project route.

Claimed Economic Benefits

The AEE Executive Summary provides the following chart:

The sole basis for this summary appears to be Appendix C of the AEE – Letter from M Copeland. This document contains generalised economic assertions but little in the way of empirical evidence.

Increase in economic activity in Auckland and Northland during construction

The letter does not explain by how much economic activity will increase, or exactly how Northland’s economy will benefit. Assuming “Northland” is meant to be the area encompassed by the Northland Regional Council, then the boundary for this lies some distance north of Wellsford.

It is difficult to see how this translates into the summary assessment shown.

No mention is made either of the current skill shortage in the construction sector. This will mean construction costs for the Project could be significantly higher as a premium will have to be paid to attract suitably qualified workers.

Reductions in vehicle operating costs

For many users travel time savings are likely to be less than three minutes and furthermore less than half of all truck movements will be using the Project route.

It is also foreseeable that an additional toll could be levied on users of the Project route, which would add significantly to vehicle operation costs, yet this is not mentioned in the letter.

For these reasons we submit that classifying reductions in vehicle operating costs as highly significant and positive is overstating the case.

Opportunties for economic growth in northen Auckland and Northland Regions

Since 1984, the Northen motorway has been extended by 30 km to from Sunset Road to Puhoi. No analysis has been supplied by NZTA on whether this led to significant economic growth in Northland.

There is no evidence supplied that the 18.5 km Project will bring opportunities for growth in Northland, in comparison with spending on other alternatives.

Summary

In summary the economic assessment appears to be high level, generic and could in fact be applied to any NZTA project. As the letter points out, if funds are not utilised for the Project, then other projects are likely to be funded instead.

Given the scale of the Project, the potential for the misallocation of capital is large. We submit that a far more rigourous, independently reviewed economic assessement should be supplied by the NZTA in support of their application.

Consideration of Alternatives

NZTA have considered a number of roading options in their applicaiton, but all involve the construction of a four lane expressway or motorway. No evidence is given as to why this configuration is necessary, especially given the relatively low traffic volumes on the route when compared with other roads around New Zealand.

Indeed, the road between Warkworth and Wellsford will remain a single lane highway for the foreseeable future, so there is a strong argument that this project will simply move the bottleneck to the northern interchange for longer distance trips.

Potentially a far more cost effective solution, which will provide benefits to all users of the Puhoi to Warkworth corridor, could be achieved by simply fixing the “pinch points” of the current SH1. In particular:

• A by-pass of Warkworth township (already in scope in the Base Case)
• Schedewys Hill
• Pohuehue Viaduct
• Hill St intersection / Matakana turn-off

We submit that this alternative be costed and analysed as part of NZTA’s application.

We also note that upgrading the existing rail line does not feature in the study of alternatives. This is mentioned on p.14 of Justification for the Project:

The volumes moved by rail and coastal shipping being small at 3% and 11% respectively, and these are unlikely to increase significantly in the future…

Movement of freight north of Auckland by rail is constrained by the low standard system of the North Auckland Line (NAL). Rail lines north of Auckland must operate at low speed due to theconfiguration of the existing infrastructure, thus reducing the efficiency of transporting goods interregionally via rail. The proposed Marsden Point branch linking the NAL to Northport may increase the amount of freight transported by rail, though the use of this branch would still be constrained by the existing configuration of the NAL.

The main reason that volumes moved by rail are unlikely to increase in future is only because there no investment planned in the NAL. If investment was planned then it is likely growth would be achieved.

We accept that it is not within the scope of the NZTA to provision rail networks in New Zealand, however we submit that it would be reasonable to include indicative costs and impacts on SH1 traffic volumes if the NAL was upgraded as described, especially given the potential for rail’s lower environmental impacts.

Better Transport will be making a submission, pointing out that our own “Operation Lifesaver” project would be far cheaper and offer greater benefits for everybody, not just the motorists who can afford the toll.

A Herald article last month highlighted strong support for more Government spending on public transport improvements in Auckland. It included the following quote:

But a spokesman for Transport Minister Gerry Brownlee said that with $890 million budgeted for public transport in Auckland over three years “it would be grossly unfair to suggest the Government hasn’t given this mode of transport the priority it deserves”.

The story was analysed in a bit more detail in this post, but the question of where the $890m figure came from remained unresolved.

It is a figure that is repeated on the NZTA fact sheet, and in a press release from Transport Minister Gerry Brownlee’s office in relation to the opening of the Newmarket viaduct replacement:

A total of $3.4 billion is being invested in the Auckland region’s transport system between 2012/15 through the National Land Transport Programme alone, including $1.6 billion for state highways, $968 million for local roads and $890 million for public transport.

In the above context it looks like NZTA is investing $890m in public transport in Auckland, funded through fuel excise and road user charges. I sought clarification from Gerry Brownlee’s office on how the $890m figure was arrived at.  My request was referred to the NZTA, who responded earlier this week:

For clarification, the $890 million is the combined committed expenditure from the National Land Transport Fund (administered by the NZTA) and funding from Auckland Council for Auckland public transport services and infrastructure, between 1 July 2012 and 30 June 2015.

The NZTA’s share of the $890 million is $488 million. This is made up of $449 million for public transport services and $39 million for public transport infrastructure.

So almost half of the $890m figure actually comes from Auckland Council ratepayers, and the remainder also includes public transport service operating costs as well. (From memory I think the transport services figure includes repayment of the EMU loan). Very few people would know that the National Land Transport Programme includes local council contributions.

This leaves an actual public transport infrastructure spend of $39m from fuel taxes and road user charges over the next three years in Auckland.  This really is a pitiful amount compared to the hundreds of millions being spent on new roading projects. It would seem more than fair to suggest that central Government hasn’t given public transport the priority it deserves.

 A reader writes: “If you live in Whangaparaoa instead of, say, Takapuna, you will spend around 30 minutes extra each way in your car at rush hour. Since in each eight-hour work day most people spend at least a couple of hours doing pretty much nothing (coffee, gossip etc), commuters work an extra day a week, equal to 20 per cent of their salary in lost time/money.”

To me it sounds like the reader might work at the NZTA economics department, as what they describe is the fundamental flaw in how benefit cost ratios are calculated. Anyhow, I responded:

A commuter in Whangaparaoa might spend a lot of time commuting by car, but this isn’t “equal” to 20% of their salary. People choose to commute in their own time, not their employer’s, and the value of this time is up to the individual.

A recent NZTA survey found that 40% of people actually enjoyed their commute – and only 3% specified zero minutes as the ideal commute. Few respondents said they would use the time saved to do work or study. Common responses identified any time savings would be spent on non-work/non-study activities such as sleeping, more time getting ready for work, eating breakfast, family time, household chores and reading.

For additional benefits they could also try the 0897x bus service – tweet and text as much as you like! (phone not included).

However, the Government isn’t saying what the alternative is. Auckland’s population is predicted to increase by a million people over the next four decades – seventy percent of New Zealand’s population growth overall.

Without the CBD rail tunnel, growth in public transport patronage will reach a capacity limit a few years from now.

No other transport option will be able to support the expected growth in CBD travel demand. We know this because the $5m business case in support of the CBD rail tunnel established that alternative scenarios of increased use of private vehicles or buses won’t be able to cope with this demand.

Even the New Zealand Transport Agency, in a recent board paper, acknowledges that “there is confidence by NZTA that the project offers a potential option for further transport investment in the Auckland CBD, that supports the stated aims of Auckland.”

The CBD rail tunnel will connect Mt Eden directly to downtown Auckland, with stations at Symonds St, K’Rd, and Midtown. It will not be operated as a loop or circular service, but as a more direct connection from Western line stations to the CBD. A trip from Morningside to Midtown will take just 8 minutes. Fast journey times such as this will be possible for trips from all stations on the Western line.

For the other lines on the network, the major benefit of the tunnel is that Britomart will become a through station, rather than a dead end. This will at least triple the capacity of the entire rail network during the morning peak.

Even with all this in mind, though, the financial constraints on the Government are very real, and a lot of money will need to be directed into rebuilding Christchurch’s infrastructure, particularly within the next five years.

It is clear that, as part of that, transport infrastructure projects will need to be reprioritised.

But, in the face of spiralling petrol prices and the pressure this will place on public transport, it would be a huge mistake to cancel CBD rail tunnel outright.

The CBD rail tunnel has a projected completion date of 2021, with construction not starting until 2015. The next four years are set aside for securing the project’s designation, acquiring the necessary resource consents and undertaking detailed design.

This preparatory work is relatively inexpensive compared to the construction work itself, and the Auckland Council needs to lead this work if it really wants the rail tunnel to progress.

Of course, by 2015, the Auckland Council will need to make a decision about whether to progress with the actual construction of the tunnel.

By then we are likely to have a far better understanding of Christchurch’s remaining infrastructure requirements compared with the rest of the country. And by then central Government will have realised that transport projects which reduce our reliance on fossil fuels should be a priority for the economy.

In opening a fourth motorway lane between Newmarket and Greenlane, the New Zealand Transport Agency claims benefits of over a million dollars week to the Auckland economy, brought about by peak hour journey time savings of up to five minutes.

It is difficult to understand how this claimed economic benefit is calculated. No commuter using this section of motorway at peak times is likely to arrive at work any earlier or leave work any later – workers travel on their own time, not their employers. For a while they may enjoy an extra five minutes in bed or an extra bowl of cornflakes, but this is unlikely to add up to a million a week for Auckland’s economy.

Courier and freight companies that utilise this section of road more frequently at peak times may enjoy some cost savings, but these would hardly add up to $1m a week either.

The NZTA’s reasoning appears seriously flawed, which is a concern given the billions currently being allocated by central Government to motorway projects, while petrol prices soar to record levels.

On the otherhand, if NZTA want to use this type of economic evaluation, then the CBD rail tunnel must be worth tens of millions a week, since a single railway line can carry 10x more than a single motorway lane in an hour at peak. The CBD rail tunnel will also save more than 5 minutes at peak for Western Line passengers, who can also be productive on their mobile phones at the same time, checking emails and texts.

Householders face being transported to and from their homes in a shuttle vehicle as contractors widen North Shore’s busy Onewa Rd during a nine-month project starting today.

Why not catch a bus?

The NZTA will take responsibility for the system, which could then be rolled out nationally. NZTA are interested in taking over integrated ticketing because a nationally integrated system could also be applied to toll roads, parking meters and car parking buildings, vastly simplifying the systems used for charging motorists as well.

The NZTA has been working on a draft farebox recovery policy for public transport services which sets out the NZTA’s proposed requirements relating to farebox recovery policy in the regions.  Once the policy is finalised it is to be implemented by regional councils and the Auckland Regional Transport Authority.

The farebox recovery policies that regional councils include in their regional public transport plans set out the contribution public transport users are expected to make to the cost of providing public transport services in their region.

A farebox recovery ratio, the proportion of the total costs of the services recovered from the users, measures the contribution fares make to the cost of providing public transport services, and is typically expressed as a percentage.

The NZTA believes the farebox recovery ratio is one way to measure the effectiveness and efficiency of public transport networks.  The NZTA is keen for regional councils to set and achieve a farebox recovery ratio target for public transport services in their region which sets a fair distribution of the costs between the users, the regional authority and the NZTA.  Farebox recovery ratios have been in decline in New Zealand for quite some time, and the NZTA is keen to arrest this decline.

It should be noted that changing fare structures or raising fares is not the only way to improve farebox recovery ratios, other measures include improving service and information quality, integrating fares and simplifying ticketing systems to encourage increased patronage together with  reducing costs by optimising schedules, frequencies and service times, increasing priority measures and so on.

Further rationale on why we are doing this work and the rationale for the NZTA’s draft farebox recovery policy can be found in the consultation document and associated Questions and Answers attached.  This information is also available via the NZTA’s website http://www.nzta.govt.nz/consultation/farebox-recovery-policy/index.html

We welcome any submission you would like to make.  Details on how to make a submission can be found in the consultation document.  I have also attached a word file with all of the consultation questions raised in the consultation document, which can be used to make a submission.  The closing date for submissions/feedback is 5pm Monday 30 November 2009.

Figures for the first five months of operation of the Northern Gateway Toll Road, to June 30, reveal that, on average, it cost $1.29 in transaction costs to collect each $2 car toll.

For those paying by phone, it would have been cheaper to have waved them through for free. Each $2 phone payment cost $2.70 to administer.

I wonder if Steven Joyce will now move to close down the toll operation, as clearly it isn’t making much of a profit, let alone a contribution to the Northern Gateway road.

As well they might, because under the legislation establishing the system, the Government agreed that $1.13 of the $2 collected was to go towards paying for the motorway, 65c was for transaction charges and 22c would go in GST.

In its operating report, the Transport Agency says: “This means we can claim only up $0.65 from each toll to cover our operational costs.”

To make up the difference between the 65c permitted transaction costs and the actual figure of $1.29, the agency has had to dig into its own pocket.

This must also mean the death knell for the ridiculous Puhoi to Wellsford road widening project.