IN THE MATTER of the Resource Management Act 1991 AND IN THE MATTER of a Board of Inquiry appointed under section 149J of the Resource Management Act 1991 to consider the East West Link Proposal by the New Zealand Transport Agency. STATEMENT OF EVIDENCE OF DAVID GORDON FOR KIWIRAIL HOLDINGS LIMITED 10 MAY 2017 CONTENTS 1. EXECUTIVE SUMMARY ........................................................................................ 2 2. INTRODUCTION .................................................................................................... 2 3. KIWIRAIL – CONTEXT .......................................................................................... 3 4. ROLE OF RAIL IN METROPOLITAN AUCKLAND ................................................ 4 5. KIWIRAIL'S RELATIONSHIP WITH AUCKLAND TRANSPORT, THE TRANSPORT AGENCY AND AUCKLAND COUNCIL .................................. 5 6. KEY RAIL INFRASTRUCTURE WITHIN AUCKLAND RELEVANT TO THE EWL .......................................................................................................... 6 7. KIWIRAIL'S MAIN CONCERNS FROM A CORPORATE PERSPECTIVE ....................................................................................................... 9 2 STATEMENT OF EVIDENCE OF DAVID GORDON ON BEHALF OF KIWIRAIL HOLDINGS LIMITED 1. EXECUTIVE SUMMARY 1.1 This statement outlines the role that KiwiRail plays as the provider of a nationally and regionally significant piece of infrastructure within the Auckland region, and the interface between that infrastructure and the proposed East West Link ("EWL"). 1.2 The Auckland rail network serves two functions, both as public transport routes and as freight routes. Both these uses result in large numbers of train movements throughout the region. As such, it is imperative that KiwiRail is able to continue to operate, maintain and upgrade its network within its existing footprint, to ensure the safe and efficient movement of freight and passengers around Auckland. It is important that the design and methods proposed to construct the EWL reflect this paramount concern. 1.3 KiwiRail remains supportive of the proposal as notified. However, we seek amendments to the conditions on the relevant approvals required to ensure adverse effects on KiwiRail's infrastructure are avoided, or mitigated to the greatest extent possible. 2. INTRODUCTION Qualifications and experience 2.1 My full name is David Stuart Gordon. 2.2 I am the Group General Manager Asset Management and Investment for KiwiRail Holdings Limited (“KiwiRail”), and am authorised to present this evidence on behalf of KiwiRail. The specific accountabilities within my portfolio relevant to this evidence are: (a) Network Planning and Capital Budgeting; (b) Access Rights and Network Control Services; (c) Asset Management Planning; and (d) Resource Management Act Planning. 3 2.3 I have been involved in the rail business either as a contractor or employee for 15 years. 2.4 I have a BA and Diploma of Town Planning, although I have never practised as a planner and make no claims to be an expert in that discipline. 2.5 I am not an independent expert, given my employment by KiwiRail. However, I have expertise in rail matters by virtue of my long experience in the rail industry and provide this evidence to assist the Board on matters within my expertise, as well as to confirm to the Board the views of KiwiRail as an organisation. Scope of evidence 2.6 My evidence will address: (a) KiwiRail, and its role within the Auckland region; (b) the role of rail in metropolitan Auckland (c) KiwiRail's relationships with key stakeholders; (d) how the East West Link ("EWL") aligns with the national rail network; and (e) KiwiRail's recommended relief to give effect to the matters raised in its submission. 2.7 Separate evidence will be presented on specific details within the submission and the New Zealand Transport Agency's ("Transport Agency") evidence on planning matters. 3. KIWIRAIL – CONTEXT 3.1 The rail network in New Zealand, and particularly in the greater Auckland region, is regionally and nationally significant infrastructure. Rail is used throughout the country, not only for freight services between major metropolitan areas, but also for passenger services between and within those areas. The rail network (in certain areas) has been in place for well over 100 years, and is crucially important to the economic and social development of the areas it services. 3.2 The land upon which the rail network operates is owned by the New Zealand Railways Corporation, and leased to KiwiRail under the provisions of the Core Lease. KiwiRail 4 owns rail infrastructure (including rails, sleepers, sidings, depots (including the major depot at Westfield in Auckland), and the inland port at Southdown) and is a railway operator for the purposes of the Railways Act 2005. It is also the licensed Access Provider under the Railways Act, which affords KiwiRail broad powers under the Act to control and restrict the use of railway assets and entry onto railway land. KiwiRail holds financial responsibility for public railway assets within New Zealand, and is a requiring authority for the purposes of the Resource Management Act 1991 ("RMA") for the crucial network utility operations it undertakes as the operator of the rail network in New Zealand. 3.3 The rail network within New Zealand, and particularly Auckland, is subject to significant engineering constraints. Unlike roads or other forms of transport, rail has very limited flexibility with regard to alignment, grade and curvature. Once a rail line is laid into a corridor, it cannot change these parameters without substantial engineering. As a result of historical increases in development near the rail corridor, KiwiRail is constrained in its ability to expand or identify alternative sites for its infrastructure, which is why its existing designations across the country are pivotal to its operations, and its ability to safely operate, maintain, and upgrade its network within its current footprint. Unlike roads, when a rail line is taken out of action, there is no alternative lane or bypass available to KiwiRail, and the end result is disruption to KiwiRail's core business. 3.4 Therefore, it is imperative to KiwiRail that development proposed near (or, as in the case of the EWL, over) its infrastructure is sensitive to those factors, and avoids (where possible) or mitigates any adverse effects on the safe and efficient operation of the rail network. Fundamentally, development proposals near the rail network need to work within the constraints that the rail network presents, as it is extremely difficult, costly, and disruptive to require KiwiRail to alter its operations to accommodate new activities. 4. ROLE OF RAIL IN METROPOLITAN AUCKLAND 4.1 Accelerated patterns of growth within the Auckland region are driving demand for both passenger and freight rail infrastructure, and increasing the load on the rail network significantly. KiwiRail has recently undertaken a number of measures to help deal with that additional demand including: 5 (a) double-tracking of the North Auckland Railway Line between Swanson and Newmarket between 2007 and 2010, to improve the reliability and frequency of services on that line; (b) the construction of the Manukau Rail Link between Davies Avenue in Manukau City to Onslow Avenue, Wiri and the North Island Main Trunk Line between 2008 and 2012; (c) upgrading the Onehunga Branch Railway Line in 2010; (d) most recently, the Auckland Electrification Project, which involved the installation of 560 kilometres of overhead lines carrying 25 kV AC to power Auckland Transport's new fleet of 57 three-car trains across 175 kilometres of track in the Auckland region completed in August 2015; and (e) the completion of an initial portion of the third main line between Otahuhu and Middlemore to provide additional capacity for freight rail services between 2012 and September 2015 4.2 Rail patronage data for the 12 months to 30 March 2017 showed that train services totalled close to 19,000,000 boardings, an increase of 19.4% on the 12 months to June 2017, and a 35% increase on June 2015 figures. The Ministry of Transport also predicts that rail freight traffic will grow by 70 percent over the next 20 years. However, most (if not all) of the upgrades identified above were limited to what KiwiRail could achieve within its existing footprint. The levels of growth identified above demonstrate the need for KiwiRail to carefully and closely manage its resources in the Auckland region to ensure that an efficient, profitable, and reliable service can be provided across both business operations. 5. KIWIRAIL'S RELATIONSHIP WITH AUCKLAND TRANSPORT, THE TRANSPORT AGENCY AND AUCKLAND COUNCIL 5.1 As part of its role and responsibilities in the Auckland region, KiwiRail maintains a close relationship with both Auckland Transport, the Transport Agency, and Auckland Council more generally, both as a stakeholder in the success of transport infrastructure in Auckland and as a major partner in projects such as the City Rail Link. 6 5.2 KiwiRail also has a Network Access Agreement with Auckland Transport ("Agreement"), where KiwiRail acts as both the Access Provider1 and Network Controller, and Auckland Transport provides funds for the portion of the costs of operating, maintaining, and renewing the Auckland network (in respect of passenger rail services).2 5.3 KiwiRail has a strong working relationship with those organisations, and is in regular contact with them regarding projects