Everyone knows more than 350 mature kauri will be felled or topped to make way for the Puhoi Warkworth toll road, eh?

— Better Transport NZ (@bettertransport) March 8, 2015

If you are looking for some background, you’ll find it on page 47 of the final report of the Board of Inquiry

“NZTA’s Terrestrial Ecology Assessment Report envisages that up to approximately 375 kauri trees, many young, would need to be felled or topped to accommodate the eco-viaduct. Additionally it was proposed that the Mahurangi River be diverted for approximately 200m through a new open channel.”

“The Board’s initial reaction during a site visit, expressed by the Chairman during an exchange with a witness, was that it was indeed a bold move in this day and age to destroy kauri trees to accommodate a viaduct carrying a motorway. The effects on both the river and the forest stand would largely be avoided if the designation was shifted approximately 150m to the east…”

“The Board is satisfied that, as a matter of jurisdiction, it has no power to move the designation to the east in the manner tentatively contemplated.”

The “many young” comment is arguable. Later on in the document they say “It is thought that these trees range in age between 75 – 100 years.”

The Campaign for Better Transport submitted against the toll road through the Board of Inquiry process last year. This is documented in a series of posts over at TransportBlog.

Probably most concerning is that the toll road has not been the subject of a business case, which until now has been standard procedure on any project of this scale.  NZTA had a budget of $600,000 for expert advice in relation to their application, but none of this was spent on conducting a cost benefit analysis in accordance with their own Economic Evaluation Manual.  This is covered in a bit more detail in this post at TransportBlog.

The economics behind the project are likely to be poor.  The new toll road route, between Puhoi and a point 2km north of Warkworth is just 700m shorter than the existing route, with a predicted travel time of ten minutes, just three minutes faster than today.  Also, because the junction is to the north of Warkworth, few Warkworth residents are likely to use the road.  The Government is yet to provide any indication of how much the toll charge will be for using the road either.  The map below shows the designated route (with north to the right, click to enlarge).

It should be noted that a further extension of the toll road from Warkworth to Wellsford is unlikely due to the difficultly in finding a cost-effective route brought about by the the geographical challenges of the area.

The CBT was disappointed that the Board chose to approve NZTA’s application, and we believe that the decision sets a bad precedent for future RMA related decisions as effectively the economic impacts of the community can be ignored, let alone the impacts on the environment. You can read our closing submission, which covers all of these points and more, here.

Like many, I suspect, correspondent Nick Cottle believes that economic benefits will flow from the NZ Transport Agency’s proposed toll road from Puhoi to the north of Warkworth.

In reality, NZTA have not provided any economic evidence in support of the toll road to the Board of Inquiry which is considering the project.

Projected travel time savings to Warkworth, Omaha and other Eastern Beaches are forecast to be only one or two minutes faster on completion of the toll road, outside of holiday periods. This is because the fastest route to these destinations will be the existing State Highway 1, rather than the toll road itself which has a northern junction almost two kilometres to the north of Warkworth.

Trips between Puhoi and north of Warkworth will only achieve travel time savings four minutes faster than currently, for those willing to pay the as yet unspecified toll. During holiday periods a bottleneck is likely to occur at the Northern junction of the project where three lanes merge into one.

With these sorts of miniscule travel time savings, it is little wonder that the NZTA have not been able to produce an economic business case for the $760m project.

I’ve posted more detail on this over at TransportBlog.

The Campaign for Better Transport today labelled the proposed Warkworth toll road as “fundamentally flawed”.

The organisation today took its concerns to the Board of Inquiry set up to look at the environmental impacts of the $750m extension of the existing Northern Gateway Toll Road from Puhoi to north of Warkworth.

Spokesperson Cameron Pitches says that without improvements to the notorious Hill Street intersection, or the inclusion of a new link road to Matakana, the $750m project will not meet one of its key objectives of reducing congestion at Warkworth.

In a report to the Board, project backers the NZ Transport Agency concede that unless changes are made, “delays at the Hill Street intersection were forecast to increase significantly” as a result of construction of the new toll road.

The report goes on to say that changing the layout “seems entirely reasonable, as the traffic patterns will change significantly in this area.”

Last month NZTA announced they intend to hold off on any potential upgrades of the intersection until at least 2021, after the toll road is complete.

The same report cites travel time savings of only one or two minutes for trips to Warkworth and the Matakana region at most times of the day after the toll road is complete.

“This is because the fastest route will still be the existing State Highway one,” said Mr Pitches.

“The travel time savings for this project are microscopic, outside of the relatively infrequent holiday periods.

Mr Pitches says because the toll road won’t achieve the objective of reducing congestion at Warkworth, the Board needs to consider declining the application.

“It is pretty clear the toll road solution won’t achieve NZTA’s objectives,” said Mr Pitches. “It is fundamentally flawed in a number of areas.”

Our  areas of contention are:

• Whether projected traffic volumes for the Project route and existing SH1 are realistic
• Whether a supporting economic analysis consistent with the NZTA’s Economic Evaluation Manual should be supplied
• Whether alternatives have been adequately considered
• Whether unsafe sections of the existing SH1 require mitigation

Kiwirail’s announcement means that up to 200 truck movements a day of milk powder and logs will be added to the roading network north of Auckland.

“We need to bear in mind the line carries both dairy and forestry products and most road users are well aware of the dangers logging trucks pose. By adding an additional 200 or more trucks daily on Northland’s roads there is a higher risk of accidents causing death or severe injury to innocent road users,” campaign spokesperson Jon Reeves said.

The Campaign for Better Transport is concerned that the suspension of services could become permanent. However, Mr Reeves said that now would be the perfect opportunity to carry out needed maintenance of the line, in time for the resumption of freight services.

“We need to keep the Northland network open for the benefit of freight and road users. If central Government was not spending so much on the $800m Puhoi to Warkworth toll road, there would be money to do this,” said Mr Reeves.

The Campaign for Better Transport proposed “Operation Lifesaver” in 2010 as a more cost effective option to address safety issues between Puhoi and Wellsford.

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.

Unstable ground around Dome Valley north of Auckland threatens to rip the wheels off the Government’s “road of national significance” from Puhoi to Wellsford.

Transport Agency northern highways manager Tommy Parker has admitted concerns about the feasibility of completing the road as a four-lane expressway past Warkworth.

“There are alternatives outside the Dome, but you are still going the other side of the valley and we have a lot of ground movement,” he told the Herald.

“Every time you put a spade in the ground up there you’ve got to put in retaining structures, or tunnels or something.

“The level of ground movement is more than we had anticipated, which makes huge problems and huge costs.”

It looks like NZTA might finally be considering other options:

Asked how it could be completed within a $670 million estimate, when the shorter Puhoi-Warkworth leg would cost $980 million, Mr Parker said it depended to what standard it was built. That included whether it was built with four lanes or two.

Of a suggestion that the agency should settle for providing safety upgrades to the existing State Highway 1 through Dome Valley, he said: “That is an option that is being considered along with the others.”

Transport Minister Steven Joyce has this to say:

“I don’t have a strong view as to whether the road between Warkworth and Wellsford is built on the current route or a new alignment,” he said.

“But it is crucial for it to be built to roads of national significance standard – a four-lane divided expressway – and that remains the Government’s expectation.”

So it looks as if even Steven Joyce isn’t pushing for a new toll road all the way to Wellsford any more. Our “Operation Lifesaver” gets a mention as well:

The safety upgrade idea was raised last year by the Campaign for Better Transport, which suggested choosing between two sets of improvements to the Puhoi to Wellsford route costing $160 million and $320 million. Both included a $50 million bypass of Warkworth and safety upgrades including extensive median barriers for Dome Valley and other black spots on a route where 44 people have died since 2000.

The more expensive would include a realignment of the difficult Schedewys Hill north of Puhoi.

Campaign convener Cameron Pitches noted a cash-flow problem which the Transport Agency says has forced it to delay $15 million of improvements to Warkworth’s Hill St intersection with SHI, a traffic bottleneck, by at least 12 months.

“For us the obvious solution is instead of spending $1 billion on a new toll road to Warkworth, let’s just look at working with what we’ve got and making that safer,” he said.

Well yes, exactly!  In response Mr Joyce still clings to the fallacy of economic benefits for Northland:

It remained crucial for the economic development of Northland and the safety of one of the country’s busiest rural highways “that we have a clear strategic plan to upgrade it to a standard that befits the level of cars and freight that it carries”.

With the National Land Transport Fund about to go into deficit by $250m, you would think that the Minister would be looking at projects that offer the best value. A billion dollar toll road between Puhoi and Warkworth is not one of them.

A headline like “80 New Zealanders Sentenced to Death” would bring an outraged reaction if resulting from the actions of a Third World despot.

But the reality is, that’s not the case. Rather it’s what could happen if Transport Minister Steven Joyce gets his way with the ridiculous and hugely expensive scheme to classify the Puhoi to Wellsford motorway extension as a “Road of National Significance”. And to press on with its construction with a completion date of 2032…

He goes on to push for alternatives:

Among the schemes was one that was put forward by the Campaign for Better Transport. Known as “Operation Lifesaver”, it suggested urgent safety upgrades to the existing State Highway 1 at the known accident blackspots and bypasses for Warkworth and Wellsford to ease the congestion at these points.

The benefits of this scheme are many, including an estimated cost of between $160 million and $320 million. A fraction of what the Government is proposing to spend.

The chief benefit, however, is the work to improve the road could be started right now.

If the safety improvements were completed within the next three years, then saving lives would begin in 2014.

That alone could save at least 80 lives between now and 2032 that would otherwise be needlessly lost.

How can anyone possibly justify jeopardising so many lives on a piece of political ideology?

Incidentally, the only feedback we received on our proposal from central Government was that our figures were out of date.