Our Submission on the 2018 draft Regional Land Transport Plan

The council and Auckland Transport are currently consulting on the proposed Regional Fuel Tax (RFT) and the draft Regional Land Transport Plan (RLTP). The RLTP is the 10-year transport programme for Auckland. The draft RLTP represents a significant improvement from the version that emerged in February and now is more reflective of council and government policy, as well as ATAP.

Submissions on the RFT and RLTP close tonight at 8pm. Here’s our submission on the RLTP.

Summary:

Greater Auckland supports the Regional Fuel Tax and generally supports the 2018 draft Regional Land Transport Plan (the RLTP). The RLTP reflects the Auckland Transport Alignment Project, which we consider is an excellent 10 year transport programme for Auckland.

While we generally support the RLTP, we request the following amendments:

• Highlighting “poor travel choice” as a key challenge facing Auckland. This would align the RLTP with the GPS, ATAP and the Auckland Plan.
• A clearer explanation of the RLTP’s objectives, policies and land transport priorities (as distinct from the particular projects in the document’s appendices). As well as ensuring the RLTP meets its statutory requirements, this would make the document’s “strategy” much easier for the public to understand.
• Clarity on what the priorities will be for the first three years and an assurance that these will address the most critical transport issues (e.g. Auckland’s road safety crisis).
• Updating funding and expenditure information to align with ATAP and the GPS (e.g. rail funding now generally comes through the National Land Transport Fund rather than from the Government directly).
• Additional funding for cycling to reflect the excellent value for money from this investment and its broad range of benefits. The RLTP appears to be misaligned with ATAP by not including additional cycling funding as a priority for additional funding.

These changes will help ensure the RLTP is an easier and clearer document to read and follow and properly reflects ATAP, the Government Policy Statement (GPS) and the Auckland Plan.
The remainder of this submission provides more detail on our suggested changes to the draft document.

Section 3 – Challenges

While the main transport challenges facing Auckland are described in this section, we generally consider it could be structured in a way that is much easier to follow and is more logical and connected to the GPS, ATAP and the Auckland Plan.

In particular, we request the following changes:

• The key challenges should be listed at the start of the section. This would make the whole section easier to follow and ensure the RLTP aligns with the GPS and ATAP. We suggest the following challenges (in order):
  • Fixing Auckland’s road safety crisis
  • Improving travel choice
  • Improving access and addressing congestion
  • Reducing environmental impacts
  • Supporting Auckland’s growth
  • Achieving value for money
• Remove the graph and text relating to car registrations. Most vehicles entering New Zealand are registered in Auckland and therefore this data does not really provide an insight into Auckland’s transport challenges. Furthermore, new car registrations appear to be only a small proportion of total vehicle imports making this data even more misleading.
• The text at the bottom of page 14 appears out of place and could be read as “the vehicle growth provides opportunities to improve prosperity…”. This is incorrect as growth in private vehicle travel only creates congestion, emissions and a variety of other problems.
• The safety section should cut to the chase and call out that Auckland faces a road safety crisis. It also needs to provide some further information about where the high-risk areas are, what parts of Auckland are seeing the most significant problems, how Auckland is comparing against other cities. This section really needs to “set up” where the focus of effort is going to be to address Auckland’s road safety crisis.
• The accessibility, congestion and freight sections are incredibly long and disjointed with repetitious information (two sub-sections on access?) These should be significantly shortened and be much more focused on the key direction given by the GPS and ATAP.
• There should be a new transport challenge that focuses on improving travel choice. This is discussed at length in the GPS, ATAP and the Auckland Plan. Much of the text relating to public transport, walking and cycling on pages 24-26 would better fit under this heading.

Section 4 – Addressing Auckland’s Challenges

Like the previous section, this would also benefit from a clearer summary at its start and a key list of the key components of the strategic approach to addressing Auckland’s challenges. This should be structured around the legislative requirements that the RLTP identify objectives, policies and land transport priorities.

In general, there is quite a bit of repetition between sections 3 and 4 that should be removed. Section four should really be much more about detailing the actions that will be undertaken to address the challenges, rather than simply restating why a particular issue is important. The current sub-sections within section 4 feel like arbitrary distinctions (e.g. why is rail not part of rapid transit, why is rapid transit discussed in access rather than rapid transit etc.) and need to be changed to make sense and to align with the GPS and ATAP.

We suggest the “policies/priorities” that this section should be structured around should be based on ATAP, using the following headings:

• Expanding Auckland’s rapid transit network
• Making targeted improvements to the road network
• Enabling greenfield growth
• Delivering dedicated safety programmes
• Building safe and attractive walking and cycling facilities
• Continuing to improve bus and ferry networks
• Maximising the benefits of technology and optimising existing networks
• Looking after existing assets

Much of the current text could be reworking into these sub-sections. Other requested changes are:

• The safety section needs to be clear that safety is not a negotiable transport outcome and cannot be traded off against other outcomes or compromised through public consultation processes.
• The text on cycling should draw from the Cycling Programme Business Case more and describe the approach to cycling investment (area focused rather than scattered improvements) and the priority areas.
• The “meeting the needs of visitors to Auckland” section appears very out of place and would probably better sit in section 3.
• Sections 5 and 6 should be integrated into section 4 as these both form critical parts of the overall strategy for addressing transport challenges.

Section 8 – Funding and Expenditure

Some changes to this section are required to ensure it reflects the GPS, in particular rail funding is proposed to come from the National Land Transport Fund through its Transitional Rail activity class.

This section also needs to detail what the key investment priorities in the first three years will be. It is important that the direction of ATAP and the GPS is given effect to in the first three years and there is not “business as usual” during this time. There needs to be a particularly strong focus on safety (including safe infrastructure for vulnerable road users like those walking or cycling) in the first three years to end Auckland’s road safety crisis.

Appendices – Details of Funded and Unfunded Investments

We request the following changes to the appendices that detail the proposed investments at a project or programme level.

• Reallocate the $62m “Regional Improvement Projects” line item elsewhere (a larger funded cycling programme) or provide greater clarity around what this will be used for. It appears to be a “slush fund” for projects that may not give effect to the overall strategy.
• Review the “Carrington Road improvements” project to ensure it responds to the latest government housing plans, which are much more significant than 1,400 homes.
• Add further investment to the “walking and cycling programme” to give effect to the emphasis ATAP places on investing in cycling and to Auckland Transports recently adopted 10-year Programme Business Case (PBC) for cycling. The PBC calls for over $600 million in investment however it appears only $338 million is allocated towards it in the RLTP and nothing in the unfunded project list. If this is not possible within the funded levels, then the list of unfunded projects needs to include a larger cycling programme to align with the PBC and ATAP, which recommends “…as further funding becomes available, stronger consideration be given to increasing the cycling programme”.

Make sure you get your submissions in before 8pm tonight by clicking here. Also make sure you remember to say you support the proposed Regional Fuel Tax as otherwise a huge part of this programme will simply not happen.

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