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.


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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  1. “This would align the RLTP with the GPS, ATAP and the Auckland Plan.” – that’s a lot of high level fuzzy meaningless plans to ignore. Maybe they should spend some time and money actually doing something.

    1. There are some excellent and hard-hitting points in the City Centre Residents’ Group submission that are valid for residents of the entire city. Eg: “Every road project built today is going to be a temporary and expensive ‘fix’ that will be just as congested in 10 years as current roads are today, solving nothing and just delaying the provision of a real solution until crisis point is once again reached.”

      That’s correct. Thus, this NLTP will not enable AT to meet the goals of the GPS. Every road proposed is taking both taking funding from and undermining the projects that could work to meet the goals of the GPS.

      I understand that it’s difficult politically to make wholesale changes quickly. But with so much money still being spent on roads, with the resulting traffic that will be induced from that, the public will not see the benefit of the shift that is happening. Mill Rd and the SH1 and SH20 ‘improvements’ will, with the traffic they induce, ruin Auckland’s chance at a safe, accessible city at least as quickly as the CRL and LR can help to fix it.

      Your stuff about greenfields developments is to the point, too. Well done. I hope you will all submit it individually, as well as together, as numbers seem to count in this game.

      1. Thanks GA, great work (again!). And thanks Heidi for the extract from the City Centre Residents’ Group submission – it hits the nail on the head.

        I encourage people to submit on NZTA’s draft Investment Assessment Framework (IAF), this will be the basis for how all land transport projects are evaluated. I suggest submitters ask NZTA to stop ignoring induced traffic generated by increased road capacity.

        Consultation close on Fri 18 May; details at:

        1. Yes, I’d encourage everyone to submit on the IAF that NZTA stops ignoring induced traffic generated by increased road capacity. To use the terminology that they can’t weasel out of, it is “newly generated trips” that they won’t include. That’s “induced traffic” to you and me, but they argue they do include “induced traffic” because their models show that people will shift from one road to another, or from one mode to another, or from one destination to another (without land-use changes). None of those are anything like as significant as the actual “newly generated trips” that they ignore.

          Not including the “newly generated trips” is one of the bigger reasons their travel time estimates are so very wrong, and why their business cases produce fanciful BCRs. As pointed out by the Productivity Commission in its draft Low-Emissions Economy Report, the complexity of land use and transport planning “poses a challenge to conventional economic assessment methods that focus on short-run impacts and put heavy emphasis on travel time savings”. – Another goodie to quote if you’re submitting on the IAF. Please do!

        2. And further to the issue of NZTA ignoring the newly generated trips caused by increasing road capacity, we must also query the true value of NZTA’s forecast time savings for motorists.

          The vast majority of the forecast travel time savings are due to peak hour travel time by commuters who work routine hours, eg: 8:30am to 5:30pm. If their journey time is reduced by 15 minutes then what do they do with that extra time in the morning?

          Given their hours are fixed, I suggest that most people will sleep in for an extra 15 minutes. NZTA values that extra sleeping time in its BCR calculation to validate the need for a new/wider roading project.

        3. BTW, unlike the RLTP, the submission deadline for the AIF is at 5 pm on Friday. Tricky when it’s sometimes 5, sometimes 8, sometimes midnight…

  2. Great submission, thanks GA. I hope others pick up on your points about priorities in the first three years, and on the need for more money for cycling funding, as the RLTP doesn’t align with ATAP.

    I wish you would point out more strongly how much the new roads will undermine the goals of the GPS.

    Auckland is like a hospital linen storeroom that has been stocked for decades with fancy tablecloths, and a few teatowels. It needs to spend at least 20 years buying sheets and towels, and a few more teatowels, but it needs to go cold turkey on the fancy tablecloths, even if it has a nice relationship with the supplier.

    We won’t achieve a balanced set of transport modes if we keep building roads. The current ones need to be fixed for safety, with much reallocation to the other modes.

  3. Anyone else noticed on p 42 that “Street sweeping practices prevented six thousands tonnes of material entering waterways and harbours in the year to June 2017”.

    Wow. That’s over 2 kg each. Who is putting it there?

    1. A lot of it would also be loose chips from roads since NZ seems to be quite partial to loose chip seal rather than hot mix seal (more expensive but lasts longer). If 1km of road was sealed about a month ago and you swept it with those trucks you’d probably get about a ton of chips from it.

      Of course none of that excuses the disgusting behaviour of the few who just litter anywhere they like. Seems to be especially common amongst recent arrivals from certain countries (at least from what I’ve seen. Then again look at how polluted their countries are).

    1. I wonder if there’s any discernment being shown by the street sweepers as to whether it’s mainly organic matter (eg from a street lined with large deciduous trees in autumn), which could be composted, mainly loose chip as pointed out by Akldude, and should be returned to the road construction crew, or mainly rubbish. For 6000 tonnes a year, I’d have thought it was worth it…

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