The final decision from the Board of Inquiry confirming the Puhoi to Warkworth toll road was published on 12th September but, what with one thing and another, I’m only now getting round to writing about it. The final report is largely unchanged from the draft version.

Here’s a reminder of the route, which runs from Puhoi to a point 2km north of Warkworth:

Puhoi to Warkworth toll road
Puhoi to Warkworth toll road

The toll road will be just 700m shorter than the existing SH1 and reduce travel time to the north of Warkworth by just three minutes compared to the current journey time.  Most Warkworth residents will find the new toll road won’t be quicker (and in some cases slower) than the existing SH1.

Probably the most perplexing thing about the BOI Report is the complete absence of any consideration of the economic impacts on the community.

Section 8.5 of the report is headed “Economics” and starts off promisingly, but it is only three paragraphs and really just sets the scene for the Board’s consideration of economic impacts:

[200] It is necessary to consider the economic impacts of the Project in the context of the Act. These impacts are particularly relevant to the Part 2 assessment that the Board conducts later in this Report.

[201] The purpose of the Act is to promote the sustainable management of natural and physical resources in a manner which enables people and communities to provide for their social, economic and cultural wellbeing (s 5). Under s 7 of the Act it is necessary to have particular regard to certain matters
including the efficient use and development of natural and physical resources.

[202] A number of representations and submissions questioned the adequacy of NZTA’s consideration of alternatives. Also questioned were the wisdom of the use of public monies on the motorway Project and whether or not there had been an adequate cost-benefit analysis. These issues are dealt with in another section of this Report.

Regular readers will recall that the toll road hasn’t been subject to any economic analysis (even the standard Economic Evaluation Manual), however the Board discusses this in section 10.5, para 374:

[374] One of the difficulties with which these submissions posed the Board is that no expert evidence was called to challenge the economic and cost benefit assumptions on which NZTA’s applications were based. Nonetheless, the submissions generally, and the statutory status of “alternatives” in particular, require the Board to deal briefly with these issues.

In comments to the Board, CBT responded by pointing out that “no economic evidence in chief was supplied by the applicant in support of the project, so there was no evidence to challenge.”  CBT sought an amendment to the report, asking for some commentary from the Board as to why it considers an economic analysis of the Project’s impact on the community is not necessary, but none was forthcoming in the final version of the report.

Further on, the Board states in paragraph 379:

…Section 7 “alternatives” in the AEE sets out in detail the process whereby NZTA considered the various options and alternatives open to it.The Board is satisfied that the consideration of alternatives to the proposed route and designations by NZTA was conscientious and comprehensive. Many evaluation criteria were deployed, including a “value for money” criterion.

Again, in comments to the Board, the CBT pointed out the “value for money” criterion on p.144 of the AEE refers to the “ability of the option to be tolled”.  In this context, “value for money” refers to value for money for the applicant, and not to the value to the community.  Value to the community, alongside possible negative economic impacts to the community should be the primary consideration of the Board.

Neither of these and other comments resulted in any changes to the draft report. Instead, in a separate document, the Board notes the following with regard to the CBT and Generation Zero’s comments on the draft report in section 1.6

[18] There may, in respect of any proposal, be positive or adverse economic effects. These positive or negative economic effects may impact on entire communities or on individuals. It is also clear law that the financial viability of a proposal is not an appropriate matter for a consent authority to consider.

[19] It was against that background that the Board’s Draft Decision contained the various passages which the Campaign for Better Transport and Generation Zero seek to be further justified. But it is not for the Board to scrutinise the economic viability of the Project (regardless of whether the proposed highway is a toll highway or not).

[20] There were many representations from territorial authorities in Northland and transport groups that the Project would bring significant regional economic benefits and cost savings.

[21] Consent authorities and Boards established under the Act are required to make planning judgments which inevitably (as is the case with all decision makers) engage the common sense and life-experience of Board members. The effects of a heavy truck and trailer unit moving slowly up a steep hill, with other traffic stretching out behind it, on fuel consumption and journey times is self evident and need not be a matter for direct evidence.

[22] Whether or not improved highways designed for vehicular transport of goods and private motorists, with the resulting consumption of fuel, is desirable (economically, socially, or otherwise), or whether motor vehicle use should be discouraged and public transport enhanced, are indeed “high policy” matters and cannot properly be dictated or influenced by this Board.

[23] The Board accepts that Mr Pitches’ cross-examination of NZTA’s Traffic Report as it related to traffic flows in and around Warkworth5 indeed challenged some of the information provided by NZTA. But it was not, in the circumstances, necessary for the Board to make further factual findings beyond those which it did relating to Warkworth traffic generally and the Hill Street intersection in particular.

[24] As stated, the Board has noted the comments of the Campaign for Better Transport and Generation Zero. It is unnecessary, however, for the Board to do anything further. The economic concerns of both organisations were, to the extent that they can be, carefully considered. Those concerns certainly cannot be described as minor or technical.

And that’s it. So the Board hasn’t considered any evidence about the economic impacts on the community at all, as they set out to do in section 8.5.  Instead they conflate the economic viability of the project (which they don’t have to consider) with the economic impact on the community (which they do). It is also worth pointing out that the representations referred to in para 20 didn’t contain any economic evidence either. The Northland territorial authorities simply asserted that the toll road would be good for Northland’s economy.

So, all in all, a disappointing decision that doesn’t really address economic impacts on the community, other than accepting the assertions of the applicant which aren’t based on any hard economic studies.  I’m not an RMA lawyer, but potentially I see this as setting a precedent for all future infrastructure projects whereby economic benefit cost studies need not be supplied at all.

The decision is also in stark contrast to the Basin Bridge decision, which declined the Basin Reserve flyover. In that decision, the Board carefully discusses economic effects in the context of a cost benefit framework.  In the consideration of alternatives, the Board appointed its own peer reviewer and found that consideration had been inadequate.

NB: Any appeal would need to be lodged by the 3rd October, however the CBT decided at its last Committee meeting that we will not be pursing this option. The cost and effort would be prohibitive and the result of an appeal would simply direct the Board to reconsider their decision.

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12 comments

  1. It’s a stupid project and a complete waste of money. However, if I have to watch National wasting large sums of money (and it seems no amount of logic will make them see differently), I’d rather see this happening on rural roads rather than new ones being bulldozed through existing urban areas in the city. In fact, the longer the NTLF is tied up building these sorts of projects, the longer (I hope) it will be before National starts focusing (or having the money to spend) on really damaging projects like the AWHC. Regardless, the fact that Nikki Kaye specifically mentioned accelerating the AWHC in her election debates does make me quite concerned about that particular project actually being progressed quite significantly under this new term.

    1. I actually have no problem with the government spending money on most of the RONs (this one is debatable though). I can’t see there ever being a decent non-road based PT alternative intercity, and the current roads are dangerous, slow, and congested with trucks. However within Auckland it is quite obvious that the better bang for buck is PT.

          1. Well things are improving in Melb for both trams and trains, although overcrowding is serious. The tram right of way issue is being sorted in the centre by making more and more streets car free, and there are new trains. Major investment in the rail network is coming and may just be closer as the massive East-West road boondoggle may well die with the Napthine State Gov:

            http://blogs.crikey.com.au/theurbanist/2014/09/21/is-melbournes-east-west-link-dead-in-the-water/

            Anyway the centre of Melbourne is an urban paradise compared to any NZ city, and affordable too if you are happy to live in an apartment. If you insist on some 1/4 acre detached house fantasy you’ll need a fortune however.

            But remember Melb is in Australia; give me the centrist John Key over the quite frankly unhinged and extremist Tony Abbott any day.

  2. Has the three minute saving time been revised assuming that the new road will have a 110km/hr speed limit? Considering the average speed on the existing road is probably about 80km/hr and on this road you will be able to travel at 110km/hr that must save much more than 3 minutes!

    1. Here’s an extract from an article I wrote in the Herald in April 2011, admittedly at the time the scheme was due to go Puhoi to Wellsford, but the principle still applies.

      “The NZ Transport Agency document that champions the cause for this project claims there will be savings in journey times of eight minutes from Puhoi to Warkworth and seven minutes from Warkworth to Wellsford, a saving of 15 minutes on the whole journey.

      This is quite clearly ridiculous as the present journey (according to the AA) of 35km takes just 31 minutes at an average speed of 67km/h. To achieve a journey time of 16 minutes over the proposed 38km motorway, the average speed would need to be 142km/h – not only illegal, but highly dangerous and unlikely to do very much for safety.”

      From Puhoi to Warkworth, the AA currently claims a journey time of 15 minutes, so to save 3 minutes, the road would have to have a speed limit of at least 120 Km/hr.

      1. NZTA discussed the predicted travel time of just over 10 minutes on page 8 of their evidence. They assumed travel speeds of 99km/h:

        http://www.epa.govt.nz/resource-management/NSP000033/NSP000033_NZTA_EIC_1.04_Bell_Operational_Traffic.pdf

        “However, CBT’s example assumes the travel times in my Report were taken over the full 18.5 km length of the Project. As noted in my Report (and shown in Figure 15 of that), the travel time routes are taken from Puhoi to immediately north of the Project’s northern tie-in, not from the physical extent of the Project at the Johnstone’s Hill Tunnels. I chose the southern extent of the route immediately south of Puhoi Road because the Project and the existing SH1 are very close to each other at this point and it provided a useful location to make a comparison. The distance between Puhoi and the northern tie-in is approximately 16.6 km and the average travel speed over this length of the Project is forecast to be 99 km/h in the interpeak. This travel speed is for vehicles in uncongested conditions. In the PM peak period the speed is 98 km/h over the same route.”

        The current journey time between the same two points is 13 minutes, via google maps. If the speed limit increases to 110 kph then, yes, the travel time would reduce from 10 minutes to 9 minutes or so.

        It is worth noting that NZTA model much higher travel time savings because in the base case scenario they assume (unrealistic) traffic growth of 4.6% per annum between 2009 and 2026, so by 2026 travel times would be slower on SH1. For instance, by 2026 NZTA reckon the north to south trip would be 6 – 11 minutes longer than currently,These travel times are shown in the tables here:

        http://greaterakl.wpengine.com/2014/04/24/no-economic-rationale-for-760m-warkworth-toll-road/

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