BEFORE THE UNITARY PLAN INDEPENDENT HEARING PANEL

IN THE MATTER of the Resource Management Act 1991 and the Local Government (Auckland Transitional Provisions) Act 2010 AND IN THE MATTER of Topic 017 RUB South AND IN THE MATTER of the submissions set out in the Parties and Issues Report

______JOINT STATEMENT OF EVIDENCE OF COLIN EDWARD GEARY MACARTHUR AND DAVID JOHN ROBERT SMITH ON BEHALF OF BOB DEMLER 16 NOVEMBER 2015 ______

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1 SUMMARY

1.1 This is a joint statement of evidence prepared by Colin MacArthur and Dave Smith of Abley Transportation Consultants Limited (Abley) who have been asked to evaluate the development and consequences of selecting the Southern RUB for inclusion in the Preliminary Auckland Unitary Plan, specifically to determine at a high level, if these processes are sufficiently robust enough to demonstrate the outcome represents an efficient and effective use of land.

1.2 Our analysis identifies a number of short comings in terms of thoroughness of the evaluation process and consideration of alternative RUB areas that may offer more efficient land use than the current proposed Southern RUB. The analysis demonstrates that greenfield development particularly in the vicinity of will result in greater adverse impacts across the Auckland transport network than alternative sites, resulting in less than optimal land use and transportation integration.

1.3 These greater effects will necessitate significant transportation infrastructure investment to accommodate the likely growth in traffic associated with Pukekohe. At present, these investments are not planned or funded.

1.4 We conclude that there remains an inadequate demonstration of a comprehensive assessment of all viable areas or total construction and servicing costs, either through the application of transportation modelling or derived from a first principles approach. This is supported by the ‘Cost of Residential Servicing’ Study which reinforces the challenges in validating the Council’s assumptions and recommends further analysis.

1.5 Consequently the lack of a region-wide technical analysis suggests the PAUP does not optimise land use and transportation integration.

2 INTRODUCTION

2.1 Our full names are Colin Edward Geary MacArthur and David John Robert Smith. We have been asked by Russell Bartlett QC to provide

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transport planning evidence on the Southern RUB provisions of the Proposed Auckland Unitary Plan (PAUP).

2.2 Colin MacArthur holds the position of Associate Director at Abley. He holds a B.Eng. Civil Engineering degree from Kingston University, United Kingdom, is a member of the Institution of Civil Engineers and Institution of Professional Engineers , and is a Charters Civil Engineer registers through both organisations; and has 23 years’ experience in civil engineering, with a particular focus in transportation planning, design and project management.

2.3 Colin currently manages the Auckland office which he established in April 2014, building on his past Auckland experience of 10 years, managing transportation planning and engineering consultancy teams. He has also held design and project management roles in the development of key transportation infrastructure improvements around Auckland including the SH16/18 Western Ring Route (Hobsonville Section), the Hill Road to 4 Laning and the Papakura Transportation Plan.

2.4 David holds the position of Associate with Abley. He is a Chartered Member of the Institute of Logistics and Transport, an affiliate member of the Institute of Professional Engineers New Zealand (IPENZ) and a member of the NZMUGS transportation modelling subgroup of IPENZ.

2.5 His technical qualifications are Bachelor of Technology (with Honours) in Industrial Operations Research and Master of Philosophy in Operations Research from Massey University. He has 15 years of transportation planning and modelling experience and has managed high profile transport modelling projects including modelling to support the Franklin District Growth Strategy. He has developed, maintained and applied transportation models throughout New Zealand, Australia and Malaysia and was appointed by the Environmental Protection Authority to provide independent transport planning and modelling expert advice and evidence in the Basin Bridge Proposal hearings.

2.6 Full details of their qualifications and relevant past experience are included at Attachments A and B.

3 CODE OF CONDUCT

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3.1 We confirm that we have read the Code of Conduct for Expert Witnesses contained in the Environment Court Practice Note 2014 and that we agree to comply with it. We confirm that we have considered all the material facts that we are aware of that might alter or detract from options that we express, and that this evidence is within out areas of expertise, except where we state that we are relying on the evidence of another person.

4 SCOPE

4.1 This submission reports on the transport effects of further greenfield development in the vicinity of Pukekohe that would form part of the Southern Rural Urban Boundary (RUB) under the Proposed Auckland Unitary Plan (PAUP), including analysis based upon 2013 Statistics New Zealand census data.

4.2 We are concerned that the selection of the RUB areas originates from the ‘Greenfield Areas for Investigation’ document identified in the Auckland Plan. The subsequent Transport in Greenfield Areas (TIGA) Report, if completed, was never formally released (though some of its contents were referred to in the Section 32 Report for the PAUP) so this work which is referenced numerous times in PAUP submissions and related reports, cannot be challenged. References to it does, however, imply that it eliminated further options for consideration. As subsequent analysis has simply taken the areas identified in the TIGA as the only area to be assessed, a holistic methodical approach has not been demonstrated that assesses all locations to determine the most effective and efficient land use.

4.3 In an attempt to establish whether the outcomes of the TIGA report are flawed, we have undertaken a number of pieces of technical analysis towards advancing our assessment of the Southern RUB.

4.4 Our analysis focuses on five specific tasks: • Forecasting the likely traffic growth due to Southern RUB development including reference to the Franklin District Growth Strategy;

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• Analysis of the growth in commuter travel patterns between Pukekohe and Auckland between 2001 and 2013; • Comparison of greenfield development in and Pukekohe against other alternative areas outside of the Southern RUB; • Consideration of the consequential cost effectiveness of the proposed RUB locations; and • Consideration of the inclusion of Pukekohe in the proposed RUB against the objectives of the Unitary Plan.

5 TRAFFIC ANALYSIS IN THE SOUTHERN RUB

5.1 A high-level analysis of the growth in traffic volumes and development between 2006 and 2013 has been undertaken to understand the relationship between land use growth and the increase in the use of SH1 and SH22 to travel between Auckland and Pukekohe (and the surrounding areas).

5.2 Census data has been sourced from Statistics New Zealand for 2006 and 2013 and is shown in Table 1, where Pukekohe is defined as the urban area and the immediate surrounds (combining Pukekohe North, Pukekohe West, Paerata-Cape Hill, Buckland and Eden Road-Hill Top Census Areas Units) and ‘Wider Catchment is the area bordered by the River in the south, SH1 in the east and the coast on the west as far north as Linwood Road. Both areas are shown in Figure 2.

Table 1 2006 and 2013 Census Data Totals Area Land use 2006 2013 Growth

Pukekohe Households 6,060 7,182 +922 Population 17,349 20,511 +3,162 Jobs 6,258 7,116 +858 ‘Wider Households 16,365 18,555 +2,190 Catchment’ Population 47,157 52,134 +4,977 Jobs 13,123 15,171 +2,048

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5.3 The NZ Transport Agency (NZTA) publish average annual daily traffic (AADT) volumes every year for the State Highway network. This data has been used to determine the growth in traffic over the period 2006 and 2013, in respect of aggregating the major entry points between Pukekohe and Auckland (approximating a screenline). These entry points relate to the traffic volumes on the north facing ramps at the SH1 Mill Road and SH1 Ramarama (Ararimu Road) interchanges, together with the SH22 count site to the east of Great South Road to quantify the total traffic movements between the ‘Wider Catchment’ and the remainder of Auckland City. The published AADT volumes are presented in Table 2.

Table 2 AADT Traffic Volumes on Key Links between Pukekohe and Auckland Location 2006 2013 2006-2013 Daily Daily Traffic Growth Traffic SH1 (Mill Rd) NB on ramp 4,932 5,734 +802 SH1 (Mill Rd) SB off ramp 4,801 5,379 +578 SH1 (Ramarama) NB onramp 1,661 1,767 +106 SH1 (Ramarama) SB off 1,594 1,802 +208 ramp SH22 (N of Great South 20,824 23,492 +2,668 Road) (Two Way Volume) TOTAL Daily Volume 33,812 38,174 +4,362

5.4 In 2006, there were 16,365 households (occupied dwellings) in the Wider Catchment and 33,812 trips between this area and the remainder of Auckland, corresponding to approximately two trips per household per day.

5.5 Between 2006 and 2013 the Wider Catchment has experienced growth of 2,190 households, which corresponds to approximately 310 households per annum. Over the same period the two-way traffic volume between this catchment and Auckland has increased by 4,362

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vehicles per day which corresponds to an approximate increase of 620 vehicles per day for each year since 2006.

5.6 Subsequently the relationship between traffic interaction with Auckland and development in Pukekohe and the wider catchment area is approximately 2.0 trips per household every day and is consistent with the 2006 trip rate.

5.7 Between 2006 and 2013, the number of jobs per household within this catchment area has increased marginally from 0.80 to 0.82 jobs per household indicating that there is a slight trend towards greater provision of employment within the study area over the past 7 years.

5.8 The draft Future Urban Land Supply Strategy specifies that the proposed capacity of the Southern RUB is 27,800 to 38,900 households with 11,600 to 14,100 households on the outskirts of Pukekohe.

5.9 Using the relationship established from the earlier technical analysis (two trips per day to/from Auckland for every household developed in Wider Catchment), the existing roading corridors between Pukekohe and Auckland are likely to need to accommodate an additional 23,000 to 28,000 vehicles per day. In simplistic terms based on standard roadway capacities1 this corresponds to a requirement for two additional lanes (one in each direction) between Pukekohe and Papakura.

5.10 Based on this high-level analysis, it is concluded that the likely extent of Southern RUB development in the vicinity of Pukekohe is likely to necessitate the addition of two lanes of capacity. This is in addition to the proposed widening of the Southern Motorway between Hill Road and Papakura.

5.11 This conclusion is explored further in the following section, which revisits transport modelling analysis, commissioned by the former Franklin District Council in 2010.

6 FRANKLIN DISTRICT GROWTH STRATEGY

1 Austroads Guide to Traffic Management Part 3: Traffic Studies and Analysis (2nd Edition 2013)

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6.1 Prior to the amalgamation of the Local Authorities that now make up Auckland City, Franklin District Council commissioned the development of a transportation model for the District that was subsequently used to understand the impacts of the then Franklin District Growth Strategy. Auckland Transport (AT) have provided Abley Transportation Consultants with a copy of the Growth Strategy Modelling Report dated May 2010 and the transportation model on the understanding that AT have not had the opportunity to interrogate the model and therefore accept no responsibility for the model outputs.

6.2 Regardless, the transport model has been developed using New Zealand best practice and is in our opinion developed to an appropriate standard for the Growth Strategy assessment. Our understanding is the model represents the most thorough forecast assessment of the impact of development near Pukekohe. The model uses data inputs from the Auckland Regional Transport model (ART2) that provides synergy with the higher-level modelling tools used by the Auckland Regional Council at that time.

6.3 The model includes a base assessment year of 2006 and future years of 2021 and 2051 that forecast demand on the transport network. The model uses residential and commercial land use input assumptions that were developed by the then Franklin District Council.

6.4 Between 2006 and the 2051 forecast year the model indicates growth of 20,460 households (from 16,722 in 2006 to 37,182 households in 2051) in the wider catchment. The resultant growth in traffic between the ‘Wider Catchment’ and Auckland to the north is from 30,432 vehicles per day to 68,795 vehicles per day, an increase of approximately 38,000 vehicles per day. The Franklin District modelling analysis aligns with our technical analysis wherein approximately 20,000 households is expected to generate approximately 38,000 additional vehicle trips per day to Auckland. This approximates to 2 trips per household.

6.5 The Franklin District Growth Strategy Traffic Study modelling report published by Gabites Porter in May 2010 considers three scenarios based on different levels of provision and locations for employment growth in the District. These are: • No greenfield industrial development;

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• Develop Paerata zone immediately to the north of Pukekohe; and • Do not develop Paerata but include greenfield development elsewhere in the District.

6.6 With respect to the PAUP, the Paerata development area depicted in the report corresponds to the proposed Southern RUB boundary and therefore is considered to provide the best indication with regard to the impact of the proposed Southern RUB. Based on the modelling assessment the report concluded that of the three options considered, the Paerata option resulted in the highest Road User Costs across the network and required the largest number of intersection upgrades and additional roadway capacity. The report specifies the following road network upgrades would be required out to 2051 (at which point the Paerata area is fully developed): • Pukekohe East Arterial; • SH1 six-lanes extending from south of Mill Road to Papakura with Mill Rd interchange upgrade; • Pukekohe East Road and Mill Road four lanes along portions of this corridor; and • SH22 four lanes from Pukekohe to Great South Rd including numerous intersection upgrades. 6.7 The Auckland Integrated Transport Programme 2012-2041 specifies that the Pukekohe East Arterial and SH1 widening to the north of Papakura is planned (refer Figure 4.4. of ITP) as well as a major upgrade project to the east of Drury and Papakura to bypass those townships. However, there is no consideration of investment in SH1 south of Drury, SH22 or the Pukekohe East Road/Mill Road corridor to the east of Pukekohe.

6.8 Whilst the existing transport modelling assessment pre-dates the PAUP it clearly signals that extensive investment in the transport network is necessary to accommodate traffic growth in Pukekohe and surrounds including the Paerata business zone, which is included in the PAUP.

6.9 The infrastructure investment is not contemplated in the Auckland ITP and therefore it is considered that the inclusion of Pukekohe in the Southern RUB does not demonstrate a high level of integration between the land use development, resultant traffic impacts and planned infrastructure provision.

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6.10 It is therefore concluded that the inclusion of Pukekohe in the proposed Southern RUB will lead to adverse and most likely unplanned transport impacts. The following section of analysis considers a number of alternative areas that are not considered within the PAUP, which in our opinion, results in a more integrated transportation outcome.

7 ANALYSIS OF COMMUTER TRAVEL PATTERNS

7.1 Statistics New Zealand publish commuter travel data from each census and this is commonly referred to as ‘Journey-to-Work’ (JTW) analysis. Census respondents are asked to specify their workplace and the main mode of travel to work on census day, enabling the patterns of trips from households to work to be understood for vehicle drivers as well as other modes of transport. The JTW data has been sourced at Census Area Unit level from the 2001, 2006 and 2013 census results and compared to understand the merging trends in commuter travel patterns between Pukekohe and wider Auckland.

7.2 The analysis compares the quantum of growth in household and employment for four geographic areas to understand the JTW trends between Pukekohe and other parts of Auckland. The growth in population, households and jobs in each of the four geographic areas between 2001 and 2013 is depicted in Figure 2. The corresponding growth in JTW trips between each of these geographic areas is shown in Figure 3.

Figure 2 Growth in Population, Household and Jobs 2001-13

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7.3 Over the 12-year period approximately 2300 additional households and 2100 additional jobs were established in Pukekohe. An additional 1500 households and 1500 jobs were established in the catchment area surrounding Pukekohe and extending to the western coastline.

7.4 Despite the strong growth in employment to complement the residential growth an additional 900 JTW trips were recorded between 2001-2013 from Pukekohe to Auckland and 600 JTW trips between the wider catchment and Auckland, equating to 1500 vehicle driver trips travelling northbound from households to workplaces and a corresponding 1500 trips southbound trips returning back home to Pukekohe and the wider catchment later in the day.

7.5 The growth in the total number of vehicle driver trips between these areas is likely to be far greater due to private and commercial vehicle trips for non-work travel purposes.

Figure 3 Growth in Vehicle Driver Journey to Work Trips

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7.6 The analysis indicates there is a significant risk that even with additional employment growth to complement the residential growth, travel demand between Pukekohe and Auckland will continue to grow as it has done in the past 12 years. This will be sensitive to the extent to which new employment opportunities arise in a range of industry sectors.

8 A COMPARISON OF PUKEKOHE DEVELOPMENT TO OTHER ALTERNATIVE AREAS

8.1 An investigation has been carried out to identify alternative ‘candidate’ sites that could be considered for inclusion within the Auckland RUB in preference to Pukekohe from a traffic and transportation perspective.

Description of RUB Alternatives

8.2 Five candidate RUB alternative areas are proposed as follows:

• Area A relates to the approximate region between Ardmore and Clevedon serviced off the Papakura-Clevedon Road. The Unitary Plan map zones the area as ‘mixed rural’ and has relatively flat topography. This is located east of, though not adjacent to, the proposed Southern RUB area at Alfriston.

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• Area B is located west of Massey and between two new RUB areas already proposed in the Unitary Plan. It is zoned as ‘Mixed Rural’ and close to various roads of significance including SH16 and Fred Taylor Drive, which is a bus route. • Area C is in the vicinity of Redvale and Okura. The Unitary Plan zones the area as ‘Countryside Living’ and covers part of the gap between the existing RUB and the proposed Silverdale RUB areas. It already has road infrastructure nearby and connects with the East Coast Road (Highway 25), which is a major route. • Area D is immediately west of the RUB south of Swanson and west of Henderson. It has rolling topography, is zoned as rural countryside living and serviced by various road connections. • Area E is located south west of Henderson in the vicinity of Henderson Valley. This area is mainly zoned as Rural Countryside Living and immediately west of the existing RUB at Henderson. Consideration of ‘Edge Requests’

8.3 Each of the areas identified are of a similar size or greater in comparison to the area identified near Pukekohe. Some of the sites identified were amongst the 12 locations that were considered as part of the ‘Assessment of Edge Requests’2 where landowners located outside the RUB put forward areas for inclusion in the RUB through the feedback process. The location of all the edge requests is shown in Figure 4.

Figure 4 Location of AUP Edge Requests

2 http://www.aucklandcouncil.govt.nz/EN/planspoliciesprojects/plansstrategies/unitaryplan/Documents/Section32report/2.2%20 RUB%20Location%20v3%202013-09-16.pdf (p135-7)

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8.4 Edge requests were classified as simple or complex by ; the latter requiring a large-scale assessment of technical information required to resolve identified issues and/or constraints. Sites 5 (Massey/Birdwood), 6 (Swanson) and 7 (Henderson Valley) partly correspond with candidate Areas B, D and E of this assessment and are considered ‘simple’. Site 3 (Okura) partly corresponds with Area C and is regarded as ‘complex’. The outcome of this assessment was that simple requests were assessed against the Addendum3 criteria and decisions made by Council. Complex sites were deferred by Auckland Council until further investigation was undertaken and may be presented as part of the Unitary Plan hearing process.

Accessibility Analysis

8.5 The relative accessibility of each area has been evaluated using distance isochrones indicating increments of 5km on the road network from the Auckland CBD along with the RUB alternative locations in Figure 5.

Figure 5 Private Vehicle Travel Distances to CBD

3 http://unitaryplan.aucklandcouncil.govt.nz/Images/RUB%20addendum.pdf

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8.6 Pukekohe is approximately 50 km from the Britomart which is twice the distance of most of the RUB alternatives wherein:

• Area A is 30 to 35 km; • Area B is 25 to 30 km; and • Area C, D and E are 20 to 25 km. 8.7 The travel times from each area to key destinations including Britomart, the nearest rapid transport station (whether it be rail or busway) and the nearest main Hospital from each of the Southern RUB areas and potential RUB alternatives were also evaluated.

8.8 A summary of travel times by car or public transport (PT) are shown in Table 3. The travel times by private vehicle and public transport modes

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were sourced using the estimates provided by Google Maps, which are in turn informed by commercial GPS data sources.

Table 3 RUB Area Travel Time Comparison Table (minutes) Area Car to PT to Car to Rapid Car to PT to CBD CBD Transit Hospital Hospital Southern RUB 56 99 7 30 67 avg RUB Alternative A 45 82 18 18 56 RUB Alternative B 62 64 6 18 54 RUB Alternative C 45 65 1 12 23 RUB Alternative D 38 69 4 10 24 RUB Alternative E 48 78 7 26 46

8.9 Table 3 demonstrates that three of the five RUB alternative areas provide better accessibility using all of the accessibility metrics applied. The remaining two areas provide better outcomes in four out of five instances. This demonstrates that the RUB alternative areas which are more conveniently located in proximity to the Central Business District, Hospital and provision of rapid transit within the City.

Traffic Congestion Analysis

8.10 A screenshot of the Google Maps traffic page for Auckland was recorded every 15 minutes for the week from 23rd to 30th of October 2015. The intention of this analysis was to document the extent to which the Southern Motorway and other key arterials servicing the Southern RUB and RUB alternative areas are experiencing congestion during peak and off-peak periods of the day.

8.11 Congestion is represented by colour based on Google commercial GPS data feeds, wherein red and orange represents the extent of corridors which are heavily congested and moderately congested through to green and yellow representing lightly congested and/or free flowing traffic conditions.

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8.12 Figure 6 was captured at 7:04am on 29 October and is typical of the weekday morning peak traffic based on the five weekdays of data collected. It is noted that there is heavy traffic congestion travelling towards the Auckland CBD on the Southern Motorway (near Drury, Manukau and Mount Wellington), the North-Western Motorway (near Whenuapai) and the Northern Motorway (from Albany to Takapuna).

8.13 In terms of the scale of the congestion, the Southern Motorway has the greatest length of moderate and heavy congestion (denoted by orange and red) followed by the Northern Motorway and the North-Western Motorway has the least of the three.

Figure 6 Typical Peak Morning Congestion

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Figure 7 Typical Evening Peak Congestion

8.14 Figure 7 was captured at 4:44pm on 29 October and is typical of the weekday evening peak traffic based on five days of weekday congestion data. Significant traffic congestion is experienced by vehicles leaving the Auckland CBD by the Southern Motorway (from Auckland City to Takanini), North-Western Motorway (from Auckland City to Te Atatu) and Northern Motorway (Auckland City to SH18 interchange). The Southern motorway exhibits the most congestion in terms of the length of the corridor affected, followed by the Northern Motorway and the North-western Motorway has the shortest length of congestion.

8.15 Considering the location of the Southern RUB and proposed RUB alternative sites it is evident that the Southern Motorway currently is experiencing heavy congestion over a greater length of the journey from Drury to the City Centre compared to the North-western Motorway journey from the current urban boundary to the City Centre.

8.16 If the RUB alternative areas in the west of the City were to be developed today in preference to the Southern RUB areas, the implications in terms of traffic congestion on the Motorway and by inference the transport infrastructure requirements are likely to be significantly less.

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8.17 The Waterview Connection4 and City Rail Link5 which are both currently under construction will provide more congestion relief and resilience to the Western suburbs throughout improving the capacity and efficiency of the road and rail networks.

8.18 The longer sections of the Southern Motorway which are presently experiencing congestion indicate that the Southern Motorway is less likely to accommodate growth and by inference would require a greater level of investment in transport infrastructure to provide capacity for Southern RUB growth. There are initiatives to add lane capacity to the Southern Motorway, specifically the Southern Corridor Improvements project6 between SH1/20 interchange and Papakura. There are no imminent, committed projects intended to add capacity to the already congested sections of the Southern Motorway to the north of the SH1/20 interchange.

8.19 This high-level assessment of the current congestion on the Auckland Motorways network and consideration of the committed infrastructure improvements provides guidance that the level of investment required in future transport infrastructure is more likely to be higher arising from Southern RUB traffic as opposed to the proposed RUB alternative areas to the west of the City.

8.20 The significant level of investment in road and rail and shorter lengths of congestion to the west are likely to create a more resilient network where the effects of development are less likely to trigger widespread future investment in transport infrastructure.

9 COST EFFECTIVENESS AND EFFICIENCY

9.1 The Cost of Residential Servicing 7Report states its purpose as providing empirical evidence of the true cost of servicing different types of development and assessing the impacts of location and typology. The empirical approach is supported by identifying the likely quantitative and qualitative costs, consideration of impacts of ‘similar’ developments

4 https://www.nzta.govt.nz/projects/the-western-ring-route/waterview-connection/ 5 https://at.govt.nz/projects-roadworks/city-rail-link/city-rail-link-route/ 6 http://www.nzta.govt.nz/projects/southern-corridor-improvements/ 7 http://infocouncil.aucklandcouncil.govt.nz/Open/2015/02/AUC_20150212_ATT_5683_EXCLUDED.htm

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and using that information when analysing the infrastructure developed costs and associated impacts.

9.2 The report also states that due to a lack of consistent and comparable historical information on the cost of transport infrastructure, the residential servicing costs cannot be readily generated for a review and/or comparison. Its analysis does not extend to a comparison of alternative locations, rather to inform the reader of potential ranges of cost for the identified RUB locations.

9.3 It predictably concluded that costs per dwelling reduce as density and scale increases and that outlying developments incur higher costs per dwelling that in the isthmus. Helpfully it does recognise that costs vary considerably between cases of similar location /density and that the Council should examine the specific proposed developments sites to ratify its conclusions regarding higher relative cost of greenfield development.

9.4 The limitations and assumptions made in the study only go to emphasise the need for the Council to develop a more robust detailed assessment of both providing and servicing new infrastructure across the entire taking account of site specific characteristics.

9.5 The report recognises that the Council has constrained budgets meaning infrastructure delivery must be carefully planned and prioritised, and comments that historically, transport infrastructure upgrades have been reactive to immediate issues, limiting investment in future developments, particularly greenfield areas.

9.6 Following a review of the Draft Future Urban Land Supply Strategy8, and the two statements by Auckland Council9 and Auckland Transport10, the subsequent analysis methodology of Sub-Regional Areas identifies the infrastructure costs and correlating dwelling capacity equate to a range of $129,735,- $167,073 per dwelling plus ongoing O&M costs. These costs exclude ongoing operational, maintenance and renewal costs;

8 http://www.shapeauckland.co.nz/media/1379/draftfuturelandsupplystrategy.pdf 9 https://hearings.aupihp.govt.nz/online- services/new/files/bhSvN0baXFDqMSkeEn9xpBwtsIj47XCKGxfPiuNgabhS 10 https://hearings.aupihp.govt.nz/online- services/new/files/GnU7BenI5rWY1JefdIgzNiqQo0g8aUEE8eubaX6oAiGn

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therefore transport infrastructure represents the single greatest investment at 49% of the overall costs. The funding for this infrastructure has not been identified.

9.7 The statement by Mr van Schalkwyk in his submission on behalf of Auckland Transport (Section 5.12) does identify that past development contributions have only accounted for 10% of overall infrastructure capital expenditure, suggesting that Development Contributions for RUB developments may be less than $20,000 per unit. This is implied rather than any firm commitment to future DCs. Whatever the level of DC’s, there is still a general acknowledgement that the funding stream is unknown.

9.8 If the infrastructure costs are unachievable, permitting changes to land use clearly is irresponsible and will ultimately damage the interrelation between affordable infrastructure implementation and land use. Promoting land development through the establishment of RUB areas that then require substantial funding of infrastructure improvements without first identifying viable funding streams.

9.9 The above assessment of the Southern RUB confirms our previous finding that the areas of Paerata and Pukekohe are likely to require substantial investment in transport infrastructure due to their remoteness from existing infrastructure coupled with existing congestion on the road network. It also reiterates the risk that RUB development areas may impact upon the function and operation of the Southern Motorway.

9.10 These matters however, appear to have been ignored when further evaluating the location and sequencing, preferring instead to reflect solely on the status of the planning stage. As such, the establishment of the Southern RUB does not appear to have been determined with due consideration for providing infrastructure efficiently and on a timely basis, as suggested in the Hearing Panel’s own Interim Guidance11.

9.11 The Strategy acknowledges that “adjustments” will have to consider the ability of infrastructure providers to bring funding programmes forward/push them out and the impact this has on getting the greatest

11 http://www.aupihp.govt.nz/documents/docs/aupihpintguidtxt013urbangrowthsecsb21andb23.pdf

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efficiency from their investment. The joint statement made by Auckland Transport also reiterates the challenge of identifying where funding is to come from. We agree with its stated approach of determining the RUB areas from a reciprocal viewpoint, recognising the need to integrate both land use and infrastructure investment, but note again this report jumps from confirming region-wide selection criteria, to an analysis of each of the Council’s predetermined Future Urban Zone (FUZ) clusters. Again no overall regional assessment has been presented.

9.12 Section 1.7 of Auckland Transport’s Statement states that their “evidence provides area-specific guidance for the small number of areas in which the Council’s planning evidence cites transport as a key reason for reaching the proposed RUB.” This suggests again that other areas have not been evaluated fully.

9.13 At a sub-regional level, Section 8.6 and 8.11 of their submission confirms that they have “not carried out detailed analysis … on the potential transport implications of further expansions of the RUB” for the northern and north-western areas. Specifically they identify Helensville, Waitakere, Puhinui, East Tamaki, Beachlands-Maraetai and Clevedon as being excluded from analysis. For the Southern RUB, Section 8.17 also raises our concern, that they too are “concerned at the effect further urbanisation will place on the already congested SH1 and its interchanges”. Whilst we might agree that transport should not “lead land use”, the selection of the RUB areas is fundamentally flawed if it does not evaluate all land areas with due regard for infrastructure costs or ongoing environmental or economic impact.

9.14 Based on our high-level analysis, the cost of upgrading transport infrastructure is more likely to be highest if development is initiated to the south of the city and development would be better suited to the northwest of the city or secondly to the north of the city.

9.15 The conclusion is there are at least five large potential greenfield development areas that would produce a more favourable transportation outcome relative to development in the vicinity of Pukekohe.

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10 REVIEW AGAINST THE AUCKLAND UNITARY PLAN TRANSPORT OBJECTIVES

10.1 In respect of Infrastructure (section 1.2), the PAUP12 includes a number of Transport Objectives. With regard to the inclusion of Pukekohe in the Southern RUB, an assessment has been undertaken to test if the current proposal achieves the expected objectives.

10.2 Objective 1: Land use and all modes of transport are integrated in a manner that enables the adverse effects of traffic generation on the transport network to be managed.

10.3 Further urbanisation of Pukekohe is forecast to result in a significant proportion of travel, particularly commuting to Auckland CBD (equivalent to about 50km distance). Jobs are expected to be created in Pukekohe, although it is possible that the majority of professional jobs may be located outside the extended Pukekohe RUB, and particularly located in the Auckland CBD.

10.4 This increase in the need for travel is expected to result in adverse impacts over an extended part of the southern road network. Whilst it is possible to manage the adverse effects, the extent and cost of intervention increases as travel distance increases. It has previously been demonstrated that five RUB alternative greenfield locations exist that are between 20 to 30 km from the CBD or the equivalent of a 50% reduction in commute distance compared to the extended Pukekohe RUB. An increase in households is further expected to result in increased travel demand that will increase impacts upon the road network.

10.5 The proposed Southern RUB does not appear to achieve the objective to ‘integrate’ land uses with transport in a manner that enables management of the transport without significant and currently unplanned capital works.

10.6 Objective 2: An integrated public transport, walking and cycling network is provided for.

12 http://unitaryplan.aucklandcouncil.govt.nz/Images/Printable%20PDFs%20-%20September/Part%202%20- %20Obs%20and%20pols/Chapter%20C/1%20Infrastructure.pdf

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10.7 Provision for walking and cycling is likely to only be beneficial and available for trips within the Pukekohe Urban area and immediate surrounds. For wider travel, alternatives to the car to access destinations is limited other than public transport.

10.8 Current public transport options include a core rail service from Pukekohe Station to Britomart using the Southern Line and requiring a transfer in Papakura. These operate weekdays approximately every 20 minutes during peak periods and every 60 minutes in off peak periods. This service operates on an hourly basis during weekends and on public holidays. Scheduled bus services are available from Pukekohe to Auckland, but require a transfer in Papakura. Additional services enable travel between Pukekohe and , and . 10.9 Auckland Transport is moving towards a more integrated public transport network. This work includes the upgrade of Pukekohe station to improve connectivity between new network buses and rail at Pukekohe Station. This project is currently in the design and procurement stage for the temporary exchange, with construction due to commence in 2016.

10.10 The Auckland Regional Public Transport Plan 2013 has provision for a Pukekohe Rail line running at 15-minute peak and 30-minute off peak frequencies during weekdays. An evening and weekend service will operate at a 30 to 60 minute frequency. There is also a proposal to extend railway electrification to Pukekohe, however funding is not allocated in the Auckland Long Term Plan 2015-2025 therefore the level of commitment to this project is unclear.

10.11 The Papakura to Pukekohe Rail Electrification Scheme Assessment Report, board meeting minutes 20 November 201213, the cost of electrification including Drury and Paerata Stations is $102.3m indicating a very significant cost to improve public transport provision. The executive summary included in the published minutes specifies that:

10.12 “This project is not currently listed in the AT LTP [Auckland Transport Long Term Plan] and funding is not allocated for the $113.3m estimated total cost. Station upgrades do have

13 http://www.aucklandtransport.govt.nz/about-us/board-members/Board-Meetings- Minutes/Documents/Board%20reports%20November%202012/agenda-item-10i.pdf

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some LTP funding ($18.6m), and it has been assumed that funding will be available from KRG [Kiwi Rail Group] and NZTA [New Zealand Transport Agency] for improvements to infrastructure ($11.0m). The remaining $83.6m would be required to be funded by AC [Auckland Council] and although NZTA subsidy would be sought, it is unlikely to be provided… The implication of this is that either additional funding needs to be secured or lower priority projects will need to be reprogrammed out in time to ensure the fiscal envelope is not exceeded taking into account the business funding sources.”

10.13 To achieve this objective will require significant investment in public transport to access facilities outside the Pukekohe area itself and there is no clear commitment towards electrification of the rail line or funding. Consequently, there is no certainty around the provision for an integrated public transport network to support development in the vicinity of Pukekohe and mitigate the likely increase in private vehicular travel to Auckland.

10.14 With regards to walking and cycling, the AT LTP for 2015-2514 states the intention for upgrading walking and cycling facilities. There is a general commitment across the Auckland region to improve walking and cycling facilities, especially in relation to connecting to other public transport hubs to provide an integrated network.

10.15 Further reference in the AT LTP 2015-25 is given to “consolidating the existing walking and cycling networks and extending these to provide stronger connections” though there is no reference to any specific improvements planned for Pukekohe.

10.16 Objective 3: Development provides access between the road and activities by facilitating the effective, efficient and safe operation of the transport network

14 http://www.aucklandcouncil.govt.nz/SiteCollectionDocuments/aboutcouncil/planspoliciespublicatio ns/ltp2015volume2.pdf

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10.17 The comments in response to objective 1 also applies to objective 3 insofar as a RUB area such as Pukekohe is located further away from the CBD and would require more extensive ‘facilitating’ in comparison with alternatives that are a shorter distance from the CBD.

11 RURAL URBAN BOUNDARY: DISCUSSION PAPER – TRANSPORT ISSUES

11.1 The Auckland Unitary Plan – Rural Urban Boundary (RUB) discussion paper, prepared by Auckland Council uses key transport principles to consider the setting of the RUB. The report considers the RUB in four distinct areas within three clusters: the north, the west and the south. The proposed northern and western RUB areas are not in dispute here, however, we would question how RUBs in each area are compared, to ensure the most effective use of land is achieved separately from geographical location. At present there appears to be an artificial geographical split.

11.2 The report details that the potential future development areas to the south were identified from previous consultation work carried out in 2012. These were ‘Karaka West,’ ‘Pukekohe West,’ ‘Pukekohe South East’ and ‘Ramarama South business.’ The report does not explain how this process considered quantitative or qualitative analysis of all viable options, including RUB alternatives identified in our evidence.

11.3 Critically, the report highlights that the maps presented identify a conceptual transport network and that further planning of land use and assessment of matters such as growth rates, staging of development, sequencing of projects, constructability issues and, most importantly, funding sources need to be determined before the final network arrangements are confirmed.

11.4 The RUB Principles state that the RUB should enable efficient and cost- effective provision of transport infrastructure, enabling modal shift away from private motor vehicles, the efficient movement of freight and place-making and good urban form outcomes. The development of a satellite RUB away from existing adequate transportation infrastructure does not align with these principles. The report goes into some detail about the application of these principles and without relisting them

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here, none of the applications are in our opinion supported by the proposed Southern RUB.

11.5 Later on in the report the evaluation of the Southern RUB highlights that there a number of potential future projects that may have some impact on the proposed area’s transport infrastructure, but it also acknowledges that many of these have no confirmed funding or even a defined timetable for delivery. It acknowledges the current and likely future congestion and that detailed network performance analysis has not yet been carried out.

11.6 Whilst the report highlights the benefit and alignment of the preferred RUB area to RUB principles, it does not provide a balanced comparative assessment of all viable RUB locations, and as such is incomplete. It does however, identify substantial infrastructure requirements required by the Southern RUB.

12 CONCLUSION

12.1 In identifying the preferred Southern RUB areas, in our view Auckland Council have not been able to demonstrate a robust analysis of all possibilities. Nor has Council provided evidence that the proposals once implemented will represent the best use of land and infrastructure when given due consideration of existing infrastructure capacity, travel time to key destinations or the ability to fund the consequential infrastructure improvement costs.

12.2 There is a significant risk that large-scale residential and commercial development in the vicinity of Pukekohe as highlighted in the Southern RUB, will generate unmanageable travel demand that cannot be accommodated by the existing transportation network or a network that can be funded and delivered to align with demand pressures.

12.3 We conclude that there remains an inadequate demonstration of a comprehensive assessment of all viable areas or total construction and servicing costs, either through the application of transportation modelling or derived from a first principles approach. This is supported by the ‘Cost of Residential Servicing’ Study which reinforces the challenges in validating the Council’s assumptions and recommends further analysis.

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12.4 Consequently the lack of a region-wide technical analysis suggests the PAUP does not optimise land use and transportation integration.

Colin MacArthur, Dave Smith 16 November 2015

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ATTACHMENT A

Curriculum Vitae of Colin Edward Geary MacArthur

Qualifications

B.Eng. (Civil), Kingston University, 1989-1993

Memberships and Affiliations

Chartered Professional Engineer in New Zealand (CPEng) No. 1009013.

Professional Member of the Institution of Professional Engineers New Zealand (MIPENZ) No. 1009013.

Chartered Civil Engineer in the United Kingdom (CEng) No. 48731927.

Corporate Member (MICE) of the Institution of Civil Engineers, United Kingdom, No. 48731927.

Career Summary

Associate Director, Abley Transportation, April 2014 – present

Auckland Transportation Unit Manager / Associate, AECOM, 2011 – 2014

Auckland Transportation Unit Manager, MWH New Zealand, 2008 – 2011

Group Manager (Highways), Opus International Ltd (NZ), 2005 – 2008

Route Manager / Project Sponsor, Highways Agency (UK), 2003 – 2005

Project Engineer, Surrey County Council (UK), 2001 – 2003

Assistant Development Control Engineer, Woking Borough Council (UK), 1995 – 2001

Site Engineer, Knights Civil Engineering (UK), 1993 – 1995

Assistant Engineer, Runnymede Borough Council (UK), 1991 - 1992

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ATTACHMENT B

Curriculum Vitae of David John Robert Smith

Qualifications

B.Tech (Hons), Massey University, 1994

M.Phil (Operations Research), Massey University, 2001

Memberships and Affiliations

Chartered Member of the Institute of Logistics and Transport (CMILT)

Affiliate member of the Institute of Professional Engineers New Zealand (IPENZ)

Member of the NZMUGS transportation modelling subgroup of IPENZ

Career Summary

Associate, Abley Transportation, 2014 – present

Principal Transportation Planner, Abley Transportation, 2012 - 2014

Senior Transportation Planner, Gabites Porter Consultants, 2004 - 2012

Transportation Planner, Gabites Porter Consultants, 2000 - 2003

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