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Submission on Regional Land Transport Plan & Regional Fuel Tax

Wednesday 9 May 2018

9 May 2018

By email:

Thank you for the opportunity to submit to the Draft Regional Land Transport Plan 2018-2028 (RLTP) and Regional Fuel Tax proposal. 

Heart of the City is the business association for the city centre, which includes more than 4000 commercially rated properties and 12,000+ businesses. We are committed to the growth and success of the city centre as a thriving place to do business, and as an accessible, safe and welcoming urban community. 

The City Centre is the centre of the region’s economy. It is growing at pace, with more than 120,000 people working, 45,000 residents and 60,000 students studying in the city centre, as well as buoyant growth in national and international visitors. 

We have a strong interest in getting Auckland’s Transport right to ensure we unlock the city’s potential and meet the access needs for a growing city centre.

We recognise that the shape and form of the city centre is changing and the way in which people access it will continue to change over time. We support ongoing improvements to public transport and recognise that innovation is required to optimise results. We have limited space in our road reserve, so a holistic approach to delivering high quality transport and place-making is required.  Access needs for business must continue to be met through this period of significant change.

We support the overall direction of the plan, with some key provisos outlined below. Where appropriate our comments are shown under the relevant headings of the RLTP ‘Have your say’ feedback form.


It is vital to support and deliver on an affordable and accessible public transport system across Auckland to support population, employment and visitor growth in the city centre, and critically to ensure that we can create priority for freight and delivery movements across Auckland, and into and out of the city centre.

We also acknowledge the need for road corridor improvements as well as network capacity and performance improvements to address road congestion.  

Our preference is to introduce initiatives that both manage demand and raise funding equitably as soon as possible, balanced with investment into affordable and more frequent public transport in order to effect sustainable behavioural change. 

We also note our view that the overall funding model requires a complete review.  Auckland is operating within the limits of a dated funding system that is continually being patched with targeted rates and interim steps to try and address growth and longstanding lags in infrastructure development. 

Urgent attention must be given to overhaul the funding model, which will require action from central government and a joined up approach with Auckland Council, with input from key stakeholders.  We note our concern that a joined-up approach was not demonstrated when the Government announced planned increases to the fuel excise duty (to be brought in over the next three years) shortly after Auckland Council announced its long-signalled intent to introduce a regional fuel tax.

Furthermore, we reiterate comments expressed in our long-term plan submission that Council must continue to seek cost savings and efficiencies and not merely look to raise more money through taxes and rates.  We welcome the reviews currently underway.


For the reasons outlined above, our support for a regional fuel tax of 10 cents per litre (plus GST) is interim only, up to a maximum of three years to ensure urgent action on the above issues. We note that a regional fuel tax spreads the cost of funding transport infrastructure across a wide base of users of the transport system and has a closer connection with those who benefit from the investment than rates.  It may also have some impact on travel behaviour and moves to new technology such as electric vehicles and hybrids.  However, we need to ensure the knock-on impact on the economy of multi-pronged increases signalled in the price of fuel over this time is minimised.  

We support the interim regional fuel tax being hypothecated to spending on specific transport projects and services, and its expenditure must be reported on with complete transparency.  We note that the proposal identifies the specific transport projects and services it is proposed to be spent on, but note that ongoing transparency as projects are planned in more detail and co-ordination of timing is important to avoid detrimental impacts on business and the economy.   

We support that the legislation allows for the GST portion to also be hypothecated to Auckland’s transport projects/services and that non-road fuel not be subject to the tax

We support the proposed use of the fuel tax for projects that will improve access to and enjoyment of the city-centre, particularly (in no particular order):

  • Bus priority improvements along central isthmus arterial road corridors
  • City Centre bus infrastructure
  • Downtown Ferry redevelopment
  • Network Capacity and Performance improvements
  • AMETI Eastern Busway
  • Park and Rides
  • Active transport

While we understand that the Government is expected to pass the legislation in time for the tax to apply from July 2018, if for some reason that does not occur and the ITL must remain in place for another year, we support it remaining set at current levels for residential and farm/lifestyle ratepayers and business ratepayers.  However, alternative provision for the shortfall in funding over a regional fuel tax (approx. $70m - $90m) would need to be found if key projects are to be funded.

FUNDING – refer earlier comments

We note that infrastructure to support implementation of congestion charging is not provided for in the draft RLTP ($58m unfunded).  We have expressed support for the council’s regional fuel tax proposal as an interim mechanism on the basis that a congestion charging mechanism would be more efficient and equitable.  As work on congestion charging options is underway, we expect that funding for support infrastructure will be addressed in the next RLTP 2021-31 at the latest.

PRIORITY AREA: Public transport
Extending the rapid transit network; buses; ferries; Park and Ride; walking and cycling


We have been advocates for the development of enhanced public transport options and support the principle to improve the city’s transport infrastructure to allow for increased capacity, improved access and also reduce the environmental impact.  We wish to ensure that the most cost effective and efficient option for rapid transit between the city centre and Auckland Airport and from the north-west is chosen based on a full business case tested in a public environment.

We understand that the government is proceeding with a tender process for the light rail project and recognise that it is included in the wider Auckland Transport Alignment Programme and RLTP as a NZTA-led project; and that no council funding contribution to light rail is being consulted on as part of the RLTP or the council’s Fuel Tax Proposal. 

Whilst the proposals appear attractive as a new mode to provide access through the central isthmus and north-west, to cater for projected population and employment growth, and act as a catalyst for development, it also appears to be the most ‘at-risk’ project within ATAP in terms of the adequacy of funding.  This creates risk for ratepayers of future pressure on rates (e.g. general rates rises, targeted rates) as well as development contributions and the regional fuel tax.

We ask that:

  • Auckland Transport confirms that NZTA plans for light rail are fully integrated into the wider transport plan for the city. For light rail to be considered as a better option for Auckland than alternative options (i.e. rapid bus, heavy rail) for connecting growing populations of the south and the north west of the city centre, a full and complete business case should be developed.
  • The RLTP should provide an indication of the cost of light rail.  The government’s initial contribution to light rail is set at $1.8billion and while media reports have referred to figures of up to $6 billion (almost double the CRL budget), there is no estimate in the RLTP of the cost of building (nor operating) the proposed light network[1]. The initial government funding may be sufficient for building the city centre to Mt. Roskill link, but significant additional funding is clearly needed to complete the proposed links to the airport and the northwest. This is a significant omission from the RLTP and implies that light rail is significantly underfunded (at a similar magnitude to the previous ATAP 2017 programme, albeit for different reasons).
  • The business case development needs to address the risk of a substantial reliance on third party funding to complete the network, as this could cause delays in completion or partial completion, and cause excessive disruption to road users and surrounding residents and businesses.  While staging could allow segments of light rail to be built as funding permits, it could also mean that planned extensions do not occur, and the first stage ‘Wynyard to Mt. Roskill’ route could be stranded for several years.
  • The RLTP needs to provide transparency of funding.  As the 2018 ATAP states that the $1.8billion seed funding will be used to leverage funding and financing to progress both corridors over the next decade, the RLTP should indicate whether or not potential funding options will include contributions from property owners through general or targeted rates or application of a value-capture mechanism.  If a cost-sharing approach with the council (via rates or development contributions) is to be explored as part of the light rail business case, it should be clear in the RLTP at the outset.
  • The RLTP should be clear about alternative options.  We also request that the RLTP should indicate a ‘Plan B’ for both light rail corridors as in, what transport and accessibility improvements would be given priority in the next 2-5 years, while either a light rail system is designed and implemented or if it does not make it past business case[2].  On that note, we support the intention of Auckland Transport to undertake further investigation on how best to develop the northwest corridor. 
  • Consideration of place is paramount. There is great potential for infrastructure projects like this to bring considerable enhancement to the city, and to support and encourage pedestrian activity and business growth along the corridors. We wish to see that this project delivers quality place outcomes for Auckland.  
  • That the project is coordinated and integrated with other activity, with high quality development response. The timing for the implementation of the project has to take into consideration what else is happening around it, including the City Rail Link. We need assurance that there will be adequate time to plan for a significant and disruptive project like this, and that it will be coordinated to avoid unplanned and unnecessary cumulative impacts.   The city must learn from the lessons of the CRL and commit to development response by assigning an appropriate budget as part of the overall project plan. A comprehensive strategic development response plan must be developed to ensure strong stakeholder engagement, communication and initiatives implemented to mitigate the impact of construction. 
  • We are directly engaged on the further development of the light rail business case including funding and financing options, and place considerations, given its direct and significant impact on the city centre, particularly in the Queen Street and the Wynyard precincts.


We recognise that buses are the most heavily used mode of public transport in the city, currently accounting for around 70% of public transport trips and delivering around 80,000 commuters into the city centre each morning.  We agree with the RLTP statement that extending public transport coverage and service frequency will play a key part in improving accessibility and increasing public transport mode share. We also support the intent to deliver a new fleet of electric buses to reduce the overall environmental and health impact on our community.

We support the priority being given to the bus improvements in Downtown (Quay St. East and Lower Albert St.) and Midtown (Albert and Vincent Sts., Wellesley St. and the Learning Quarter interchange), and for investment in electric buses and associated infrastructure.

We also support implementation of the ‘Whole of Bus Route Priority Phase 1’ along the Frequent Service Network on Sandringham Road, New North Road, Mt Eden Road, Remuera Road, and Manukau Road (with a budget of $215m) which will improve bus passenger accessibility to the city centre.

We ask that:

  • Priority be given to the currently unfunded Quay St. streetscapes and Victoria St. linear park streetscapes ($66m and $23m respectively) in the city centre.  These projects are centre-pieces of the City Centre and Waterfront Masterplans adopted by the council several years ago.   We note that the detail around the Quay Street project needs to be worked through to ensure that it works well in the environment and for the stakeholders in the surrounding area.  
  • Council and AT to commit to taking a joined up place-making role to enhance the pedestrian environment in these two locations to support (already funded) bus improvements and equip the streets to perform as strategic ‘above-ground’ pedestrian links to the CRL.  Specifically they must deliver a quality public realm experience and enhance the adjacent businesses areas. These projects relate to significant city real estate adjacent to the waterfront, the arts quarter and the learning quarter.
  • Priority be given to the currently unfunded Dominion Rd. Bus Lane improvements ($12m budget) on the basis that it will encourage continued use of public transport on this corridor while a light rail option is being investigated, and may be several years away before it is operational.
  • Consideration be given to re-prioritising projects from the ‘Whole of Bus Route Priority Phase 2’ project to bring them into the funded RLTP programme within the next decade (requiring reallocation of up to $423m). This will allow greater progress to be made on improving the capacity and speed of the existing Frequent Service Network by adding to the gains made through the Phase 1 projects.


As a waterfront city, ferries are an obvious transport mode to invest in and grow. We support the completion of the Future Ferry Strategy for Auckland as proposed in the plan. We support the priority being given to the Downtown Ferry basin redevelopment as it will cater for expected growth (40% in the next 10 years) in ferry patronage from the gulf islands and coastal suburbs, as well as visitors to the city centre.  As well as addressing congestion in the ferry basin through improved berthing facilities, an upgraded ferry terminal will contribute to a higher amenity environment and improved customer experience.


The 5,500 Park and Ride spaces currently available are being utilised to full capacity, and lack of capacity is causing spillover issues for many neighbouring residential areas and town centres (including increased road traffic and competition for on-road parking).  The Regional Fuel Tax Proposal indicates a total budget of $63m for new Park and Ride facilities, which would add 1,900 new spaces. The Draft RLTP suggests that the funded budget is $51m (i.e. there appears to be a discrepancy between the two documents) and also indicates that an Enhanced Park and Ride programme of $119 million is currently unfunded.

We ask that consideration be given to re-prioritising currently unfunded Park and Ride projects to significantly increase capacity in the next decade, and encourage take-up of increases in public transport capacity, particularly from areas that have significant distances to travel to access such services and can’t be expected to rely on feeder buses or walking and cycling.  


We support the focus on improving city centre cycleways, which connect key parts of Auckland’s city centre, including Quay Street and the waterfront, Karangahape Road and Upper Queen Street, and a number of east-west connections. The cycleways will also connect with the city’s other key cycling corridors that are largely separated from traffic and pedestrians, and better link workplaces, shops, schools and tertiary institutes that are within the city centre.

We are supportive of the priority given to achieving ‘maximum impact for short trips to the city centre’. We are pleased to see that the Skypath and Seapath projects are funded in the plan. These projects will enhance the Auckland’s tourism offering as well as enable better commuter connections.

The city needs great cycling facilities (along with great end of trip facilities) as they are valued by workers and recreational cyclists, assist businesses with talent attraction and retention, and contribute to positive perceptions of the city centre.

As with other projects, integrated planning and strong development response is vital to ensure the needs of business are taken into account with such projects.


In order to ensure business can remain successful, we support the priority given to reducing travel delays and improving reliability along key freight routes (particularly state highways, motorways and arterial roads).  The regional freight network will benefit from greater use of public transport and active transport over both peak commuter periods and in the inter-peak period.

We recognise the way in which loading and servicing is carried out in the city centre will need to change in the future as road space is re-allocated for people. Attention to the first and last ‘leg’ of freight journeys is important.  To ensure businesses in the city centre can effectively be served, it is vital to ensure that both the design and implementation of projects (e.g. construction of new public transport facilities or works in road corridors) takes into consideration the needs of freight delivery as well as business servicing and that access and the ability to service businesses is maintained. We support developing an innovative loading and servicing strategy for the city centre to enable the ongoing servicing of businesses and we seek to work with Auckland Transport and others to do this.  

PRIORITY AREA: Network Capacity and Performance Improvements

With regard to network capacity and performance improvements, we agree that Auckland needs to make better use of its existing transport system to increase the number of people who can travel through key routes and corridors.  We support the programme to take advantage of emerging technologies to manage congestion, improve safety and influence travel demand.  Changes such as improving the efficiency and coordination of traffic signals and the use of dynamic traffic lanes will enhance peak traffic flows and give priority to freight movements on key freight connections.

[1] Previous reports released by Auckland Transport provide some estimates of capex costs e.g. $930-1,205m for 6.4km of light rail from CBD to Mt. Roskill; $1,240-$1,780m for 14.8km from Mt Roskill to the Auckland airport. The estimates are subject to several qualifications. Refer ‘AT Airport to City Light Rail Transit Acceleration Strategy’ Oct. 2017, and AT ‘Briefing Note Light Rail Transit for Auckland’.

[2] For example, if the viability of light rail is found to depend heavily on securing funding from a high level of ‘transit-oriented’ development along the corridors, it could be prudent to pursue ‘development-oriented’ transit instead i.e. consider the current zoning potential and projected rates of development along the corridor, and then connect the main destinations with a lower level of viable rapid bus transit.