Well I got to tell ARTA what I think about their draft 2009 Auckland Tranport Plan today. It was quite interesting and I think they were quite impressed. My submission is here, and what I told ARTA today is shown below:
My submission was in relation to the Auckland Transport Plan 2009. It supported the idea of a flagship transport plan and generally considered the ATP to be a small step in the right direction. However, my submission also considered there to be significant flaws to the proposed ATP, particularly the under-investment in public transport and the way in which peak oil has been ignored by the plan.
I do support parts of the ATP; although for the sake of brevity I will focus on the parts of it that I consider need altering, and the reasons for why I think such alteration is necessary. My submission also raised some minor issues, particularly with relation to Figure 6 (on page 15), Map 1 (on page 21) and Map 2 (on page 25). These more minor issues relate to what may appear to be typographical or methodological errors in the formulation of the ATP rather than points where I fundamentally believe that change is necessary. I trust that my submission with regards to these points has been considered and, if necessary, the appropriate changes or clarification will be made.
Therefore, I consider that there are four major areas of concern that I have with the proposed ATP, these are outlined below:
1) I have concern that the ATP is based on implementing the 2005 Regional Land Transport Strategy (RLTS), a policy document that is now in the process of being significantly overhauled.
2) I have concern that peak oil has not been mentioned at all in the ATP, particularly as it is likely to have a major impact upon travel patterns in the next decade.
3) I consider that the CBD rail loop should be included in the ATP as it is a critical project for Auckland’s future.
4) I have significant concerns relating to the decrease in funding for passenger transport infrastructure and rail infrastructure in the latter part of the 10 year period.
I am aware that since I made my submission a lot has changed regarding transportation funding and the future of local government in Auckland. I consider the establishment of a single Regional Transportation Agency for Auckland will be a great step forwards for the city, but at the same time I am disappointed by the changes made to the Government Policy Statement that relates to transport funding. The removal of the regional petrol tax has also been disappointing in my opinion.
Submission One – Alignment with Regional Land Transport Strategy
As my submission stated, the ATP ‘gives effect to’ the policies and strategies of the RLTS. I have concerns that the 2005 RLTS, which is the document the ATP is based around, is now ‘out of date’ with more recent transportation trends. The RLTS is currently being reviewed by the Auckland Regional Council and – from what I have read of the new document – there are to be some significant changes.
While the 2005 RLTS “called for a substantial improvement in public transport services, the completion of key elements of the strategic road network and placed new emphasis on alternatives to car travel, like walking and cycling” , it effectively still proposed the vast majority of transportation funds in Auckland be spent on roads.
The 2005 RLTS, upon which the ATP is based, has been criticised for its roads-centric funding allocation. Mees and Dodson’s analysis is included below:
All six of the options involved spending more money on roads than on public transport: even the ‘high public transport’ options (5 and 6) involved spending twice as much on roads as on transit. Only a further ‘extreme public transport option’, which was developed and tested privately, involved spending comparable amounts on roads and public transport (Technical Paper 24, p. 4; table 4). The idea of spending more on public transport than roads – bipartisan policy in cities such as Perth, Vancouver and Portland – was so radical that it could not be evaluated even as an unpublished “extreme” scenario!
The 2008 RLTS is in a fairly early stage of development, but appears to offer a more sensible long-term approach to transport. Page 3 of the Background Document outlines the change that is necessary:
“A ‘business as usual’ approach cannot continue. Climate change, the unsustainable consumption of natural resources, global economic change, population pressures, demographic change and social disadvantage are fundamental challenges for the region. Our transport strategy must respond.”
My concern is that the 2009 ATP is based upon the very same ‘business as usual’ approach that the 2008 RTLS specifically states “cannot continue”.
As my submission stated, I do understand that the RLTS is in an early stage of development, and delaying the implementation of the ATP until it is finished would be very problematic. However, as the ATP will guide the expenditure of billions of dollars of funds this inconvenience appears relatively minor compared to the potential for such large amounts of money to be misallocated.
Therefore, I strongly advise the ATP to either be put on hold until the 2008 RLTS is completed, or that the ATP be altered so that it is not the ‘business as usual’ approach that is so strongly criticised by the 2008 RLTS.
Submission 2 – Peak Oil has not been mentioned in the 2009 ATP
As this part of my submission stated, I find it extraordinary that peak oil has not been mentioned at all within the ATP. The exact time when peak oil will happen is debatable and not necessarily relevant to the ATP, but it is clear that when oil supply can no longer meet demand we will see a significant increase in petrol prices. The effect of that increase in prices will itself have a significant effect on transportation – as seen last year when high petrol prices led to large increases in the number of people using public transport.
My submission pointed towards an NZTA report commissioned last year, entitled “Managing Transport Challenges when Oil Prices rise”. Of particular note is the likelihood that traffic levels will not continue to increase in the future as they have done so in the past, but rather level off and potentially even decline (if the report’s recommendations are implemented).
With population levels continuing to increase, it is clear that many more people will be using public transport due to higher oil prices in the future. Furthermore, if traffic levels on roads are not increasing then a significant amount of money that is proposed to be spent upon those roads could be avoided, and directed to places it will actually be required in the future.
The 2008 RLTS recognises peak oil as a significant factor in future transportation requirements, stating the following (on page 2 of the background document):
In the next 10 years, oil prices are expected to be volatile, with petrol and diesel prices potentially stabilising at around $3 per litre. Beyond this, oil prices are expected to increase sharply as world oil supplies diminish.
As my submission stated, by not taking into account peak oil and rising fuel costs in the longer-term, the proposed ATP is a reckless approach to transportation funding. It appears highly like that billions of dollars are set to be misallocated to roads unlikely to be required; instead of walking, cycling and public transportation infrastructure that will be critical as petrol prices increase dramatically.
Submission 3 – The CBD Rail Tunnel should be included in the ATP
This aspect of my submission noted that the CBD Rail Tunnel should be included as an essential project for Auckland, and therefore must be included in the 10 year funding plan of the ATP, rather than just a ‘possible future’ project.
While the CBD Rail Tunnel has a number of benefits, what is most critical is the way that it will increase the capacity of the Britomart railway station. It is my understanding that even with recent upgrades to Quay Park Junction and the signaling of the Britomart tunnel, the station is still fairly close to capacity and likely to reach capacity in the next few years.
Furthermore, it has also been proposed that the future Onehunga train line will have to terminate at Newmarket rather than Britomart – due to the capacity constraints of the Britomart tunnel. This means that effectively Auckland’s railway system is already being compromised by the lack of a CBD tunnel. It makes one wonder how rail patronage will be able to be increased in the future, if the approach to the main downtown station is already at capacity.
Clearly, the CBD Rail Tunnel is a very expensive and complicated project. It will take many years to design and construct. Therefore, it is critical that work on this project commences as soon as possible. Otherwise Auckland’s rail system will hit a capacity ceiling and will suffer from over-crowding and delays in the future – potentially wasting the benefits of electrification. For these reasons the CBD Rail Tunnel must be fully included in the ATP.
Submission 4 – Concerns about the decreasing funding for passenger transport infrastructure and rail infrastructure later in the ATP period
This part of my submission pointed out how funding for public transport projects (including rail) declines dramatically towards the end of the 10 year period. In the 2009-2012 period the amount of money invested in new public transport infrastructure ($1.598 billion) almost matches that invested in roading infrastructure ($1.854 billion). However, by 2015-2019 the amount invested in public transport infrastructure ($147 million) pales into insignificance compared with the amount spent on roading infrastructure ($1.7 billion).
This funding is completely at odds with what the 2008 RLTS is saying will be necessary in the longer-term, and clearly looks like a return to ‘business at usual’ with regards to the bulk of transport funds going to roads. The proposed funding allocation is also completely at odds with the NZTA research document above, which estimates that the demand for roading will remain steady or potentially decline over the next 10 years and beyond.
It appears absolutely extraordinary that the 2008 RLTS background document can state that the ‘business as usual’ option cannot continue, while the funding arrangements proposed in the ATP, particularly for the 2015-2019 time period are exactly that: business as usual. Furthermore, while the 2008 RLTS (and NZTA research) are predicting rapidly increasing petrol prices in the future, particularly later in the 10 year period covered by the ATP, transport funding throughout that same time period is proposing to spend over ten times more on roading infrastructure than on public transport infrastructure.
The proposed changes to Auckland’s local government structure present a great opportunity for similarly significant changes to Auckland’s transportation. It appears as though ARTA will effectively be significantly enlarged and empowered to operate Auckland’s entire transportation infrastructure – besides the state highways and the rail network. This is an enormous opportunity to draw a line in the sand and put Auckland’s automobile dependency behind us, to become a truly 21st century city with a sustainable transport system that is flexible enough to withstand the effects of peak oil and climate change.
However, unfortunately I do not believe that the ATP will achieve this goal. By giving effect to an outdated RLTS, ignoring the issue of peak oil, excluding Auckland’s most critical transportation project and continuing to spend far more on roads than on public transport, Auckland will continue to be what it is – one of the most automobile dependent cities in the world.
The ATP therefore must be significantly altered, as I have detailed above. Most particularly, it must give effect to the 2008 RLTS and the need to not conduct ‘business as usual’ and provide the vast bulk of transport funds to roading projects. Auckland’s transport system must look forwards to a more sustainable future, not backwards to a 1960s era of automobile-centric planning.