I realise it might seem like fairly late notice however if you intend to make a submission about Puhoi to Warkworth then you only have a few days left as submissions close at 5pm on Friday. The details for how to make a submission are on the Environmental Protection Authority (EPA) website while the detailed documents from the NZTA to support the proposal can be found here.
This video shows the route being proposed.
I haven’t yet put together my submission (that will be a task for the next few days) however with this post I’m going to highlight some of the areas I will be focussing on.
Like so many other projects that are going on at the moment, I do agree that some improvements need to be made to the route between Puhoi and Warkworth however I disagree with the scale of the solution. There seems to be a prevailing attitude from the government and transport agencies that if we’re going to build something, then instead of small and targeted upgrades we should just bite the bullet and build the long term solution that we might not 30 years. It may sound like a good idea to effectively “build once” but the downside is it sucks up transport funding for other projects that might provide a better return on investment, even if just in the short term.
There is some evidence of this when we compare some of the information in the executive summary with some older reports/studies of the project. This part is from the executive summary although I have cut out a section between the two paragraphs:
Over the decade to 2012, the NZTA carried out a series of studies on the State highway network connecting the Auckland and Northland regions. These studies considered the role of the State highway network in relation to the wider transport system between Auckland and Northland.
The studies concluded that an off-line four-lane motorway alternative to the existing SH1 will achieve the strategic objectives of supporting economic development in northland, will address transport constraints imposed by the existing alignment of SH1, and will address traffic congestion and safety issues on SH1 .
While it is true that the previous studies had recommended an offline motorway as the best long term option, they also said that the only part worth doing was a bypass around Warkworth. Other sections of the road from Puhoi to Warkworth were expensive and provided little economic benefit as it was considered that there was little opportunity for substantial economic growth in Northland. In other words while a motorway might be the ideal situation, it doesn’t make sense. Of course that all changed after the current government were elected in 2008 and quickly declared the route a road of national significance.
Some people may think that this part is not that important – at least for the consenting process which is mainly about how to mitigate the negative impacts caused by the construction and operation of this road. However I think it is critically important. If we don’t need to build the road at all then we can not only save ourselves a huge amount of money that can go towards upgrades to the existing route and other projects, but we can avoid completely damaging the environment where the new road will go through.
And those environmental impacts are going to be huge with massive amounts of earthworks needed to get the route to motorway standard. To give you an idea of the amount of change to the landscape that is proposed, there will be some embankments up to 46.5m high and some cuts into hills up to 45.8m deep. In total over 8 million m³ of fill will be needed, that’s 6-7 times what is being taken out of Waterview. In addition there are 7 major viaducts, 5 bridges with the highest being 46m high – that’s similar in height to driving over the Harbour Bridge.
Now it might be possible to mitigate the impacts of building and operating the road however the big issue is the cost of doing so. As a result of what is already proposed the project is expected to cost $760 million which means the road needs to deliver a lot of benefits to be viable and that is where things start to get shaky. As mentioned previous economic assessment ranked everything but a bypass of Warkworth uneconomic. There isn’t a whole lot of information about the current business case with the only economic information talking about the high level economic effects of the project. The NZTA should be releasing the full business case for this project, not just an 8 page letter.
Of course many of the economic benefits are meant to accrue to the users of the road through travels savings along with safety improvements. The traffic assessment report provides information about this but the thing that catches me is that all through the report it comments that the project is primarily an issue during holiday times while that at other times of the year the road is relatively free.
And shortly after
To sum all of that up, the problems on the road that cause congestion happen during the summer months when heaps of people are going away on holiday to the beaches primarily to the east of Warkworth. The rest of the time it handles less traffic than many single lane arterials in Auckland. Spending hundreds of millions (latest estimate I saw was $760m) just so that some people going on holiday can get to their baches a few minutes quicker hardly seems like a good use our money.
I think a really useful outcome from this process would be to get a fully independent assessment of the transport and economic reports, much like we saw come out recently about the Basin Bridge. If you are going to submit then perhaps consider adding that to your submission.
Lastly if you are an expert in any of the fields that want to help with a submission then please let me know.
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Section 5 of the RMA effectively requires a balancing of benefits to society against environmental impact. If the benefits are small that’s very relevant as they’re likely to be outweighed by the impacts and the proposal is fundamentally in conflict with the RMA’s core purpose.
Not sure of the detail but aren’t the government re-writing the RMA even down to removing the definition of the act, (a glaring omission that can and will cause all sorts of problems) so I can guess that such protections will vanish to suit their many non environmental agendas.
Actually, it did occur to me that maybe we should be supporting the proposed changes to give more equal weight in the RMA to considering “economic development” on a similar footing to the environment… because then we can more clearly point out the LACK OF economic benefit of many of the RoNS projects… (something currently outside the scope of these Inquiry Boards)
You are correct in the case that both the RMA and the BOI weigh up the benefits with the social and environmental costs of the project, but you need to be careful to not confuse this with the construction costs.
When it comes to construction costs this is NZTA’s money and in this process how much they choose to spend is irrelivant.
I tried to read a copy of the report yesterday at the Warkworth Service Centre of Auckland Council, but unfortunately Volume 1 which covers the resource consent applications and the notices of requirement have “gone missing”. This despite the fact that the copies are not supposed to be removed from the centre.
Nevertheless, I have submitted and really urge everyone else to do so before the Friday deadline.
Some words of advice for anyone intending to do a submission.
The Board of Inquiry’s brief is to consider the project in terms of its effects on the environment. While some of the Board may be concerned about the colossal waste of money or the dodgy modelling or even the future of motor vehicles, these are issues that a peripheral to their consideration. It’s even dobtful wheteher potential global warming effects can be taken into account.
The NZTA sets the project objectives and there is little a submitter, or the Board, can do about those.
A successful submission will be one that argues that the project objectives are (largely) met through a more modest upgrading alternative, which will have significantly lesser environmental effects than the current proposal, and will have additional environmental benefits of providing for an immediate level of safety improvement and retaining connections to communities. It will also have the additional incidental benefit of costing a whole lot less.
Be aware that the process from here on in is a high-speed juggernaut and you will be having to prepare evidence very soon. Unless you can get expert assistance you could be a lay witness opposing a highly paid “expert” – those fights are very one-sided.
…. a more modest upgrading alternative etc. etc. – AKA – Project Lifesaver
From the advice I have had, the BOI has yet to be appointed and it is the BOI that determines the rules around expert witnesses, cross examinations etc, so there is still plenty of time.
Duncan what scope does the BOI have for considering social impacts? For instance one of the supposed reasons for the project is that it will be safer than the current SH1, yet for people travelling to Warkworth itself the existing SH1 from Puhoi will likely be the quicker alternative, and this won’t have any safety improvements.
Also note:
-There is a project underway already to build a “Western Collector” around Warkworth township itself. This will be completed before the Holiday Highway. (Nope, I’m not going to apologise for calling it that, because holidays are about the only period when congestion occurs). This is included in the project modelling.
-The traffic assessment report states that if the project proceeds, then travel times will actually be slower between Warkworth and Wellsford (p. 55 of the Traffic Assessment Report), but this is dismissed with “This is a minor adverse effect for relatively few holiday periods each year.” Then the rest of the document talks about how bad the travel times are during the holiday periods, so there is an obvious logical contradiction here.
-The modelling for the traffic assessment report is based on the assumption that the existing toll “on the Northern Gateway Toll Road is assumed to remain constant in real terms, however people with destinations in Warkworth and further north will enjoy a significantly larger travel time saving using
the NGTR and the Project alignment.” So the new road is provided free to users for modelling purposes, and there is no sensitivity analysis for tolled scenarios.
Make your submission here:
http://www.epa.govt.nz/Resource-management/Puhoi/Pages/default.aspx
The purpose of the Puhoi-Warkworth motorway is to improve the passage of trucks. Auckland-Whangarei is one of the busiest truck routes in the country, and it’s important to remember NZTA’s freight strategy, which essentially prioritises state highway spending on where it will benefit the cartage of freight by road. Population and private car use are no longer significant factors in determining where roading money is to be spent.
A small reminder of that in the media the other day: http://www.stuff.co.nz/marlborough-express/news/9497128/Truck-freight
If it was mostly about freight then they would just be bypassing the towns and major hills between Auckland and Whangarei. But they aren’t. You may have noticed that Wellsford, much less Warkworth, are not in Northland. Unless of course Warkworth has suddenly become a major freight hub 🙂
Rubbish. State Highway traffic volumes south of Warkworth are 17,500, of which 75% are heavy vehicles giving 1300.
North of Wellsford we have 12% of 8000 which is 950. Truck volumes equal or higher on SH1 from Auckland to Tokoroa, Wellington to Waiouru, Waipara to Timaru.
Everyone knows this road was decided by the current govt in opposition, based on not much more than hearsay.
Now I’m not one for conspiracy theories but on the other hand I do think it’s important to consider how like-minded people can form sub-groups within organisations with the unstated purpose of exerting an undue influence over policy.
In the case of Puhoi-Wellsford, I have heard that the momentum for the project originated internally within Transit’s Auckland regional office some years ago – well before this National Government came to power. It seems that over time the technocrats involved have subsequently leveraged political connections to get this project on the agenda, somewhat irrespective of its merits relative to other potential transport investments.
For this reason I actually don’t *blame* the National Government too much. While they obviously have ultimate responsibility for (poor) quality spending, it seems to me that they have been somewhat sucker-punched by an influential group of people into funding a project that does not scrub up very well. In saying that we should not necessarily presume that had Labour been in Government then the outcome would have been any different – they may have yielded to the same pressure.
The real thing that concerns me, however, is whether people with similar mindsets are still working in the transport-related public sector?
Now of course everyone is entitled to an opinion on transport priorities. In an ideal world these opinions would not influence decision-making beyond normal democratic processes. While this may sound naive, I think there is value in stating our expectations of what constitutes appropriate behaviour from our *public servants*. Just in case they’re reading this blog.
I guess what I am saying is that I am more concerned with the process that resulted in this project getting on the agenda than the project itself. This concern arises because once groups of like-minded people successfully exert (undue) political influence then it seems like they would try it again. And such pressure is that much easier to exert through opaque channels such as the RoNs. One has to wonder, for example, where the momentum for the East-West Link project emerged from?
None of this is to suggest that the people involved in getting these projects onto the agenda are inherently “bad” – I’m nearly 100% confident that they are good people that wholeheartedly believe these projects are worthwhile. It’s just that their opinions are based on their personal intuitions and are first expressed within a bureaucratic echo chamber to the like-minded people they work with. In this environment it’s not surprising they quickly gain traction …
What we do about it I’m not sure, except perhaps get rid of the RoNS funding category? The RoNS is just too tempting to groups of people who want to exert political influence.
Yes, this is where we can blame this government and Steven Joyce in particular, because the pompously named RoNS are his baby. So what is so wrong with this idea?
Well instead let’s imagine it was called IoNS; Infrastructure of National Significance. In other words if it began with the question about how to best invest significantly in our nation, not, as the RoNS do, with the assumption that the answer to that question is always a road, then it could be a valuable programme.
As it is it’s just a process to get low value highway projects built instead of better things or at best decades before they are needed. Any higher value highway schemes in the RoNS [VPT, Waterview] were in the process and would be built anyway.
It will die with this government. Not least because they will leave the cupboard less than bare, they will leave the NLTF over committed in a time of falling revenues. And the nation poorer for it.
Completely agree with you Patrick – Joyce and Brownlee have, ironically, perhaps overseen the largest socialist experiment in transport policy this country has seen since Vogel’s decision to debt-fund the North Island Main Trunk Line.
In comparison, the transport policy of the last Labour Government seems much more economically focused.
This herald article from 2008 provides some back-up to Stu’s story. http://www.nzherald.co.nz/nz/news/article.cfm?c_id=1&objectid=10528158