The Wellington Civic Trust has told the Wellington Regional Council to think again. It has asked the council to withdraw its support for the flyover alongside the Basin Reserve, and the other roading plans being pushed on to Wellington by the NZ Transport Agency.

The Trust says the roading issue is of great significance to the city and the region. It challenges the council’s belief that the subject lacks sufficient “significance.”

Read the rest of the story on Scoop.co.nz

1. The draft before you is about the July 2011 NZTA “Public engagement” scheme. They’ve made available the public feedback about it to inform Council’s submission. We’re heartened by that, it’s what your press statement of July 4th committed to; it’s worth noting in the submission itself.
2. One of those 2000+ giving feedback was us, the Civic Trust. We said then that NZTA billed its scheme as “an improvement for a successful capital city” and our stance then and now is made in this light. 
3. The scheme is presented as “all-or-nothing, take-it-or-leave-it, no-cost-to-council”. Your draft prefers option A, what the Dominion Post editorial last Saturday 1 October 2011 called “the cheapest option”.
4. We all know the realpolitik – NZTA will just press on regardless of Council’s view. Or the scheme might be scrapped in wider cost-cutting, or to switch funds to Christchurch, and blamed on you as an excuse. So Council might just as well take the long-term view and not be framed just by cheapest option factors. So:
5. The environmental factors are covered by your Climate Change item you are dealing with later on in this meeting. You’ll ensure that both are in synch with each other – no silo thinking here?
6. Starting from the airport end: for Ruahine St and Wellington Rd, the 2008 Ngauranga to Airport Corridor Plan agrees on four lanes. Your draft #8.6 seems also to prefer this over NZTA’s planned 6-8 lanes, but its wording is too coy –worth strengthening. Likewise #10.2.2 about the Pedestrian and cycle lane – again your wording is too coy. These uses needed to be differentiated. Work on this part of the scheme is not intended to start until Transmission Gully is completed, in say 2021. The Council officers’ report #5.12 recommends against seeking to speed this up. By then totally new trends in road use may be clear, and these eastern works may not need this scale.  So we urge taihoa on any “interim improvements” due to start in 2014/5 (see #4 5th para of the officers’ report) because of the risk of these morphing by scope creep– you know, the way these “interim works” tend to do.
7. On Buckle St factors: the War Memorial park is considered solely as a highway cost. NZTA tell us they can’t spend on anything which does not have a transport benefit. So the Memorial Park is reduced to roadside landscaping. The Parks’ functions are well described in #4 of your draft submission, where #4.3. is at odds with the cheapest option. The Architectural Centre’s Option X deserves at least a mention – you can’t just pretend it isn’t on the table. Your officers’ report #5.3 last 2 paras says that such tunnel options are “unaffordable in the context of the current land transport programme”. A big plus is the Memorial Park which obviously isn’t a transport function – but responsibility for it has been passed to the transport agency! That itself is worth challenge by council. Instead of a memorial worthy of its deep values, we get a park divided by a multi-lane highway. Here’s what we said to NZTA in our July submission: “Both State Highway One and the National War Memorial are Crown assets; it is a reasonable citizen expectation that decisions about a matter affecting both would be made in a “joined-up” way, and not as implied here by expecting some transport benefit, whatever benefit cost numbers are used. The War Memorial Park is a policy decision in its own right.  It would also have transport benefits if it were made by a tunnel for SH 1. The Civic Trust believes that the decision to transfer responsibility for creating it to the state’s roading agency is both insulting to the war dead and unrealistic for NZTA to achieve”. Now you might say “that’s nothing to do with us”. Yes it is. You as civic leaders will be standing there on April 25th 2015 and will want to feel proud of what the city’s achieved over those 100 years since ANZAC. And the Memorial Park is not just a Gallipoli thing. It commemorates the dead of all wars past, present and future. It could be achieved for a small fraction of the cost of all wars since the Carillon was built.
8. On Vivian St factors: #5.6. in your draft notes “once the 2nd tunnel is built there will be no future opportunity to increase capacity from Hataitai to City”. There is no comment about the continuation of half the route west of Mt Victoria continuing to run along a CBD street laid out in the 1840s (Vivian St). Is this really what council wants? It hardly sounds like a real road of national significance.
9. On Flyover factors: The Dominion Post Editorial on Saturday October 1st said: “NZTA will also fund the $11m grandstand.” Your draft supports Option A with “significant mitigation”. You should specify Grandstand if that is what you mean. The new road would be a 380m long curved bridge – it’s an elevated highway really, so any mitigation would need to be around 15m higher still to block out the cricket ground. It might be cheapest, but it sounds like ugliest too.
10. This isn’t just about transport – it’s about what you want the shape of our city to be. So, based on you draft submission, the Scenario in 2040 would be:

• SH1 via Karo Drive and Vivian St. with traffic lights etc as now.
• 380m long bridge of boring design over Kent/Cambridge.
• No War Memorial Park beyond a bit of roadside landscaping.
• Wide 60 k/h highway through Hataitai reducing Town Belt size.

Alan Smith, Chairman

The Trust agrees with the main finding of the report — that the framework is fit for purpose. The Trust has never understood why the Council would wish to disturb a set of objectives and principles which were the product of a consultative and collaborative process and which had successfully established benchmarks for evaluating specific proposals. 

However, we are pleased that the opportunity was taken to go beyond a simple answer to a simple question about the utility of the Framework and find out what the general public, through the use of focus groups, and the special interest groups, through interviews, thought about the health of the project. The Trust was also pleased to be invited to participate.Unfortunately our pleasure was short-lived. The views of Waterfront Watch, Architectural Centre and the Wellington Civic Trust have been condensed into five lines of typed comment in the feedback report. Those interviews would have involved some three hours of detailed questions to, and comments from, the three organisations. All you are told is that their views largely mirror “those of the public focus groups.”

Anyone who knows the views of the three interest groups selected for interview will be aware they are not as one on, for instance, the balance between new construction and open space.

The only way in which the disparate views of those organisations can be said to accord with the views of the focus groups is if the latter’s views are so imprecisely expressed as to be made to fit any interpretation. The report achieves that dubious purpose.

In the third paragraph of section 6 of the report the focus groups were said to:

like the current balance of built form and open space and would like this to continue to the northern part of the waterfront which desperately needs improving

‘Desperately’ is a strange word to use in that context and what is meant by ‘the current balance of built form’? As you will know the current balance of built form does not involve the three buildings proposed for North Kumutoto, the construction of which is dependent both on the approval of Variation 11 and finding developers. Neither does the current balance include the three buildings which were proposed for Waitangi Park.

If the focus groups are saying ‘we like the waterfront as it is — do no more new building’ – then Waterfront Watch will be well pleased. But the organisation I represent would not. We believe that building on sites 9 and 10 at North Kumutoto is justified and, irrespective of design considerations, probably necessary to avoid the ratepayer being presented with a very large bill.

But we do not really know what the public thinks. Maybe they would rather pay than lose public open space to more buildings. This exercise had the opportunity to help clarify that issue – on the basis of the feedback report it has served only to confuse it.

I quote from my notes which I used for the meeting with Litmus (a copy of which I left with them):

The issue is not no new buildings, but rather the balance between buildings and open space and the height and mass of new buildings. Framework is still sound on this, but WWL and Council need a better indication of how the public want those principles interpreted especially at Kumutoto and Waitangi.

We are particularly concerned about the Waitangi Park sites. We know that neither of the two public-use buildings, the UN Studio and Wardle Architects designs, will now go ahead. So what is proposed for those sites? What process is proposed for reconsidering future use? How will the public be involved?

The Trust believes that the Council should make constructive use of the current market conditions to thoroughly review its options for Waitangi. There should be a public discussion.

In contrast to the sparse and inadequate feedback from the public, the report devotes a full page to the views of TAG. We endorse much of what TAG has to say. We especially welcome the comments on public access to ground floors. In our discussions with Litmus we suggested that somebody, the waterfront company and/or the building owners, had misread the market in terms of appropriate rentals, particularly in respect of the Chaffers Dock ground floor. We assume that any waterfront space would be rentable at a price.

If the Council determines to build another seven or so new buildings on the waterfront, it will need to find a way to deal with this problem. We think you will be disappointed if you pin your hopes on better access from the CBD. A test will be provided by the rebuilt Overseas Passenger Terminal. Ground floor space on a long finger wharf, well away from established foot traffic, is not a formula for the designers’ much-beloved active edges.

TAG’s final comment is a lament that whereas lucky Auckland does not have to bother about what its citizens want on their waterfront, in Wellington consents have to be notified and people may derail a developer’s best laid plans by objecting and then appealing. The Trust opposed Variation 11, because we thought it provocative and unnecessary – the same certainty for developers could have been achieved if sites were marketed with consents already attached. Indeed that approach had been recommended to this committee by officers in December 2008. On the other hand the Variation process achieves much the same opportunity to object and appeal and Waterfront Watch and others have done so. What surprises the Trust about Variation 11, is that what was seen as a matter of great urgency in 2009, now ambles along the hidden paths of mediation.

I draw the committee’s attention to a comment in the third paragraph of section 6 of your report:

Whatever decisions are made must be taken with extreme caution and very careful consideration as we have got it wrong a few times, for example Queens Wharf.

That is a perceptive comment. If we have now a project which largely meets the expectations of the public (and we all deserve some credit for that), we did not get there by rushing into building 31 storey towers, or hotels with problems of access, or by shifting heritage buildings around the wharf as if they were chess pieces. We did it by allowing for second thoughts, by acknowledging that a place for people can only be created by listening to people. That might not be the way they do it in Auckland, but so far at least we in Wellington are not encumbered by a local government structure that inhibits public engagement. Our disappointment with the Litmus exercise, as reported, is that this opportunity to engage was not as productive as it should have been.

Peter Brooks
Peter.brooks@xtra.co.nz / Ph: 479 6812
Convenor Waterfront Issues
Wellington Civic Trust

This is our submission on the Town Belt Guiding Principles (public consultation closing 9 September 2011). It is of enduring interest to us, and we wish to be heard in any oral submissions process on this consultation.

Overriding paramount principles

1. Firstly, the Wellington Civic Trust (the Trust) recommends to Council that there be overriding paramount principles.  The foremost of these would be that the Town Belt is to be accorded a mana and a sanctity that place it supremely above all other public reserve and recreation areas.  The other overriding principle would be that each generation of Wellington Councillors and citizens honour the responsibility of protecting and enhancing the Town Belt as open recreational space for future generations in perpetuity. This is not just another park. 

 Legislative review

2. Curiously, the explanatory booklet lacks any context or commentary for the legislative part of the proposed review.
3. The Trust believes that it would be more enlightening for the public of Wellington to have from Council an outline of the legislative changes that will be sought. Preferably timing for such disclosure would be before the guiding principles are adopted and before the review of the management plan.  This will enable all participants to comprehend the end game before detailed consultations commence.
4. Of primary importance is for the amending legislation to establish a legal process for returning original Town Belt land back to Town Belt status enjoying statutory protection as well as the protections bestowed by the 1873 Trust Deed.  Rather than requiring amending legislation as at present, provision could be made for returning land to be mandated by an Order in Council on the joint recommendation of the Mayor and City Councillors as Trustees and of the Minister of Conservation.  Removal of Town Belt land on the other hand  should require amending legislation.
5. The broad intent of the 1873 Trust Deed needs to be upheld: that it is a public recreation ground available as open space to all, at all times, in perpetuity. The legislation should make reference to the original ideals enunciated when the Town Belt was established in 1839.
6. The temptation to expand the definition of ‘recreation’ needs to be resisted.  Instead, consideration could be given to spelling out those activities that are not compatible with the ideal of universal accessibility.  For example, these could include educational institutions, commercial ventures, and allotment gardens.  It is the Trust’s view that any widening of the interpretation of ‘recreation’ has the potential to seriously and perhaps permanently undermine the integrity of the Town Belt.
7. Another feature that the Trust would like to see in the amending legislation is formal status being accorded to the position of Town Belt Curator.  The statute could require the Mayor and Councillors as Trustees to appoint a senior officer with experience in the management of parks and reserves.  This would help ensure that the Town Belt is perceived by Council officers and by the public as having a status unique from other reserve lands.  It would also assist in establishing clear lines of responsibility.
8. Submissions for improvements to the wording of the proposed Principles, plus some explanatory comment, follow.

Principle 1

Proposed wording in Council’s brochure

There will always be a Town Belt in Wellington

Suggested changes

The Trust recommends that the wording of this guiding principle be changed to read as follows:

There will always be the Town Belt in Wellington, held in trust for the citizens of Wellington in perpetuity.

It needs to be emphasised that there will always be the Town Belt, not ‘a Town Belt’ and that the boundaries be defined as those established in 1840 by William Mein-Smith. Confining the term ‘Town Belt’ to the original intention gives that part of the city an historic and legal identity that sets it apart from all else and gives it a unique status.  It also acknowledges that over time areas have been alienated and that every opportunity should be taken to restore those areas to the Town Belt.

Principle 2

Proposed wording in Council’s brochure

The Council will work in partnership with mana whenua to manage the Town Belt

Suggested changes

The Trust recommends that the following wording be adopted for this principle:

The Council will work in partnership with mana whenua and will acknowledge the value of the Town Belt to Wellington by actively consulting with other guardian groups in the community that have maintained a long-lasting commitment to protecting and managing the Town Belt.

Principle 3

Proposed wording in Council’s brochure

 The Town Belt’s natural character will be protected and enhanced

Suggested changes

We suggest that the wording be changed to read:

The Town Belt’s natural character of open space and visual beauty will be protected and enhanced.

Principle 4

Proposed wording in Council’s brochure

The Town Belt is for all to enjoy

Suggested changes

The Trust suggests that this principle be more comprehensively defined, and read as follows:

The Town Belt is for all to enjoy and is to be freely accessible at all times.  To this end buildings and carparks will be kept to a minimum and over time be Council owned and operated as multi-purpose facilities available to a wide variety of recreational groups.

The Civic Trust favours a gradual change in the ownership and control of buildings on the Town Belt.  Exclusive use by individual clubs should over time be set aside and succeeded by multipurpose facilities that can be pre-booked by a wide variety of recreational groups.  The Council would then have more freedom to influence higher standards of building design and of maintenance.

Principle 5

Proposed wording in Council’s brochure

The Town Belt will be used for a wide range of recreational activities

Suggested changes

It is suggested that this principle be changed to read as follows: 

The Town Belt will be primarily used for casual and organised outdoor recreation activities, without compromising its natural character. 

The definition of ‘recreation activities’ is the linchpin to this whole exercise.  It is recommended that a very constrictive approach be taken to defining what constitutes recreation.

Definitely to be excluded are any educational facilities. These invariably involve either Government funding or commercial interests, and would inevitably lead to Town Belt land being sequestered by specific interests.

Another concern is the idea of creating recreational hubs.  There is the risk of these being regarded as areas for more buildings with sporting codes pressing for exclusive use.

Principle 6

Proposed wording in Council’s brochure

Management of the Town Belt will acknowledge historical and cultural links to the land

Suggested changes

We suggest the wording be as follows:

The Town Belt is to be celebrated for its longstanding historical cultural importance to Maori and to Pakeha alike.

The Civic Trust is wholly supportive of greater emphasis being given to pre- and post-European history and settlement and is keen to see greater balance in relating the history of both cultures.

Why the Wellington Civic Trust is making a submission

1. The Wellington Civic Trust has as its first object “to promote a civic environment whereby the City of Wellington, its surroundings, and its adjacent countryside and coastline become a resource for the use, benefit and enjoyment of all Wellington citizens.” (Constitution and rules, Objects, Clause 4 (a)) The NZTA proposals are billed as “improvements for a successful capital city.”  We have therefore approached this project in that light.  Would it promote that object set out in our constitution and in so doing would it make this capital city more successful?

 Public engagement

2. The Trust understands from NZTA workshops that this is not “consultation” on the Cobham Drive – Buckle St. SH 1 proposals in the statutory RMA sense, but “engagement” with the community on decisions already made.  SH 1 sections of the agreed 2008 Ngauranga-to-Airport Corridor Strategy (N2A) have been lifted out and given Roads of National Significance (RoNS) status because of their place in “a transport system that supports the growth of our country’s economy to deliver greater prosperity, security and opportunities for all New Zealanders”, and funded as a priority ahead of that agreed in N2A.
3. A basic tenet of the Trust’s work is that decisions affecting our city and our citizens must involve those affected. There have to be ways whereby they not only have their say, but have a real chance to affect outcomes.  These SH1 plans are presented as an “all or nothing, take it or leave it, no cost to the city” package.  If this is not the best solution then there is a cost to the city and in the absence of honest consultation it is very unlikely that the best solution will emerge.
4. The Trust convened a seminar on engineering projects in the Basin Reserve area (Round about the Basin, August 2009).  It brought together a wide range of experts, including those who had expert experience of living in the communities likely to be affected.  The major outcome was a request to the authorities “…to establish a joint working group, which would include community representatives , which would have access to all relevant information concerning options for the development of the transport spine.” (Round About the Basin, proceedings of the Wellington Civic Trust seminar, 8/8/09)
5. NZTA was asked following the seminar to establish structures and procedures to enable community representatives to have full access to options for the project.  On 22 September 2009 the Trust was advised by NZTA that they intended to establish a Community Connect Group and that engagement would begin in early October that year.  The group was not established. What has now emerged is not the result of such engagement. Faith in the process and support for the outcome has suffered and a weary cynicism is growing.

Assessment of need

6. We acknowledge that it is government’s responsibility to provide the highway infrastructure required to meet future needs. But what is that assessment and on what criteria and assumptions are they based?
7. The RoNS strategy has a clear economic objective.  It is one of the chosen tools to lever up economic productivity.  The published benefit cost numbers would suggest that it is an ill-chosen instrument and that it will result in a misallocation of scarce capital.
8. The Trust accepts that the city’s population will expand, and that Kilbirnie and Newtown may (through intensification) increase at an above average rate.  There are other factors working in the opposite direction. Recent figures show that vehicle use has plateaued, presumably as a response to higher vehicle running costs.  All the signs are that such costs will escalate at a rate well above normal price rises as the impact of peak oil and carbon reduction policies take effect.
9. Moreover, as long as sufficient funds are put into public transport development private vehicle commuter travel will become increasingly less attractive. The N2A-agreed high quality public transport spine study has now begun, for completion next year. This will provide a much better basis for evaluating public transport’s ability to take a load off SH1s capacity to serve the eastern suburbs and how best to meet the conflicts between north-south and east-west traffic flows, while still safeguarding the integrity and values of the Basin Reserve.
10. There is no indication that NZTA has taken the above factors into consideration in its assessment of need for large increases in road capacity, yet they are very relevant.

 The NZTA overbridge proposal

11. Having expressed our misgivings on the accuracy of its assessments of those needs, we seek to limit the harmful impact of the intended work on our city.
12. The Trust has no view on whether overbridge option A or B is better. As presented, both structures violate the urban design qualities of the area.  The workshops made it clear that an “iconic” design was explicitly rejected.  That does not dismay us because we cannot conceive that an obtrusive overbridge cutting through the structured sightlines of the two terraces (identified for enhancement under Smart Green Wellington) could ever improve the presentation of this part of the cityscape.

Second Mt Victoria tunnel

13. Whatever solution is decided for Basin Reserve traffic, no commitment need be made to the second Mt Victoria Tunnel or to the major upgrading of Ruahine St. and Wellington Rd until the effects of improved traffic flows at the Basin Reserve are evaluated. To that end an undertaking should be given that resource consent applications for those works would not be sought unless and until that evaluation proved the need – the point agreed by all N2A participants. N2A agreed that there would be 4 lanes: that has grown in the current plans to up to 8 lanes, with large earthworks to lower and ease the corner where Ruahine St and Wellington Rd. meet, so that traffic can flow though at 60kph. The real transport benefit of this is questionable (unless it is to accommodate even longer and heavier trucks than at present) and hardly desirable in a suburban residential area. There is a risk of “interim improvements” from 2014 morphing to a scale which presupposes the up-to-8-lanes solution on which work is not (according to the “public engagement” material) scheduled to begin until 2023, or thereabouts, after Transmission Gully has been completed.  By then a totally different trend in road use may be apparent. These eastern works may not be necessary on the scale presented in 2011 and public money can be used on more productive national projects.

Other options

14. An earlier Option F, with northbound SH1 in a tunnel from Dufferin St to achieve grade separation under Kent and Cambridge Terraces, was ruled out by NZTA before the “public engagement” because of cost, despite its urban design (i.e. its impact on the surrounding city, as distinct from its vehicle movement function) being clearly superior. NZTA’s December 2010 War Memorial Tunnel Scoping Report notes (p.5) that “if it was decided that the preferred option for the Basin Reserve was to provide a tunnel around the Basin to avoid the visual impacts of elevated structures, then it would be necessary to construct the war memorial tunnel”.
15. The “Option X” produced by the Architectural Centre at the time of the July workshops has attracted a lot of public attention and support, and deservedly so. In terms of producing a quality urban environment it is far superior to the NZTA model. We do not have the expertise to assess its traffic engineering merits and we are concerned that the inevitable extra costs involved would amount to a further diversion of funding from public transport.  Nevertheless, such an innovative and environmentally attractive proposal demands attention not only from the general public, but also from the governing authorities, national, regional and city.

War Memorial Park

16. The Architectural Centre’s option also has the great merit of providing a War Memorial Park worthy of the name.  The NZTA’s project is essentially a roading project which makes a gesture to meeting another public policy objective, the memorial park. But that gesture is a futile one.  Instead of providing a memorial worthy of the deep values such a park has to express, we get a park divided by a multi-laned highway.  It is an appalling example of a facility which should express national values being distorted and degraded by “silo policy-making.”
17. The NZTA cannot fund a required War Memorial Park because such a park would have no transport benefits.  But it can, it seems from unrefuted media reports, fund a quite superfluous grandstand which would do nothing to ease the flow of traffic, but which might do something to stem potential criticism from a certain quarter.
18. Both SH 1 and the War Memorial are Crown assets; it is a reasonable citizen expectation that decisions about a matter affecting both would be made in a “joined-up” way, and not as implied here by expecting some transport benefit, whatever benefit cost numbers are used. The War Memorial Park is a policy decision in its own right and one which we believe has wide support.  It would also seem to have transport benefits if it were achieved by a tunnel for SH 1. The Civic Trust believes that the decision to transfer responsibility for creating the National War Memorial Park to the state’s roading agency is both insulting to the war dead and unrealistic for NZTA to achieve.

Conclusion

19. The move from private transport to public transport is likely to be a key agent for change for the city over the next thirty years.  A major shift from providing for the needs of private vehicular traffic to one of investment in public transport, taken gradually over many years and working in sympathy with national pricing signals would produce levels of economic and social benefit not achievable by NZTA’s SH1 project.  That would be an investment strategy for the coming decades when the nation will be forced to face the consequences of climate change and the demands of a low carbon economy. The Cobham Drive to Buckle Street project as presented is an anachronistic imposition on the city and irrelevant to our present and future needs.  NZTA needs to go back to the N2A drawing board and it needs to take the public with them.

Alan Smith
Chairmam

The Wellington Civic Trust (the Trust) is a strong supporter of public transport, because it:

1. is consistent with the Trust’s purpose with respect to the civic quality of Wellington
2. reduces demand on road space and helps avoid need to expand roading space, thereby avoiding the generation of “induced” traffic
3. contributes to CBD quality by bringing people closer together and improving pedestrian connections, and enables the vibrancy of a compact CBD
4. has positive environmental effects such as reduced emissions and air pollution
5. reduces fuel use and so increases economic resilience as fuel scarcity increases prices.
6. provides mobility for non-car users.

We welcome the opportunity to submit on the proposed Plan, using the questions posed on the feedback form.

1. Do you support our focus areas?

We support the proposed focus areas as listed in section 4.1 on page 7, except that area 4, Improving the efficiency of the bus network by redeploying resources from poorly performing services, is too narrow. There are many ways to improve network efficiency, of which such a redeployment of resources (presumably essentially meaning reduction or withdrawal of funding) is just one. Network efficiency is much more than looking at individual poorly-performing services (however those may be defined), and withdrawal should be contemplated only after other measures have been considered. This is the only focus area that includes both an objective and a method, and we suggest that to reflect the above and for consistency the wording after “the bus network” should be deleted.

An omission is that funding is not identified as a focus area. This is under particular pressure from the new GPS on transport funding and on proposals to change Financial Assistance Rates, and also the development of the PTOM. We submit that the plan cannot be considered complete unless it recognises that funding is a key issue, and GWRC should continue to focus on it through, for example, continuing to make submissions on the above topics.

2. Do you have any comments on the policy framework?

In general we support the policy areas; they encourage the use of PT and complementary active modes. Your presentation is somewhat confusing and repetitive. Specific comments:

Policy 1.5: should be broadened to include other benefits of public transport, such as reduced land take, reduced emissions, better fuel efficiency and reduced carbon, as compared with private transport. These are important, and will become increasingly so.

Policy 1.6: should include specific reference to the use of the Golden Mile as a ceremonial way as well as the region’s key public transport route, with the result that parades and the like disrupt the entire Wellington bus network. We suggest working with Wellington City Council to minimise the potential disruption, rather than just managing diversions as they occur.

Policy 1.7: method 2 should also include GWRC making submissions on resource consent applications that could have significant transport effects, such as applications for supermarkets, malls, leisure and sports centres.

Policy1.8: refers to balancing service levels with demand, and this should include potential as well as actual demand. For instance, demand for Auckland’s Northern Busway and rail network has more than followed the increase in supply; a local example is the Airport Flyer, a commercial success where previously there was no service at all for a while.

Objective 2: the paragraph about integration talks about improving connections with other modes, “ie, …park and ride…along with…cycle parking”, excluding pedestrians, which we assume is inadvertent.

Policy 2.2, method 5: “increasing the efficiency of transfers” should include the elimination of any cost penalty for transferring. The existence of such a penalty would severely jeopardise the success if any layered approach to service provision.

If a journey now done in one vehicle is replaced by one in two vehicles with a change in the middle, it can be a huge disincentive to public transport use unless the interchange is

1. safe
2. reliable
3. suited to the actual Wellington climate
4. convenient
5. free of any cost penalty.

A Greytown–CBD PT trip with change from bus to train at Woodside is one thing; a trip from Seatoun to the CBD with change between buses at Kilbirnie is quite different in likely acceptability.

Policy 2.4: all interchange facilities should be maintained to standards of quality, not just for vehicle users, and opportunities identified.

Policy 3.1: while timetables should take account of the impact of traffic congestion, this should be only after the effect of traffic congestion on timetables has been minimised as far as possible.

Policy 3.2, method 1: real-time information screens should also be sited at places that generate (or have the potential to generate) significant volumes of traffic, such as shopping malls, sporting and leisure centres.

Policy 3.4: operational information should be published, to keep passengers and ratepayers informed.

Policy 3.5, method 4: all territorial authorities should be encouraged to provide appropriate bus priority measures, not just Wellington City Council.

Policy 5.1: one aspect of passenger comfort and safety that should be considered explicitly is visibility to and from the interior of the bus. Advertising covering windows makes for an unpleasant environment, difficult to see out; worse are the opaque logos, as used by NZ Bus, blocking vision entirely.

Policy 5.3: part of the road safety advocacy should be emphasising that the level of risk when travelling by public transport is approximately just 10% of the risk when travelling in a private vehicle.

Objective 6: consistent branding should start with Wellington Railway Station, now branded differently from every other location and with a lamentable lack of essential information such as a network map or details of the many bus services connecting with practically every train.

Policy 7.1: while it is important that fares paid reflect private benefit, it is equally as important that public benefit, eg to non-users, is reflected in an appropriate level of subsidy, and this should be made explicit.

There are real public benefits of PT to non-users; they include

1. less road traffic
2. commercial vitality of the CBD
3. use by non-driving family members such as children and older people
4. more productive land use.

Policy 7.1, Table 4: it is unclear how NZTA’s requirement of a farebox recovery rate of a minimum of 50% leads to GW’s target of 55-60%. We submit that GW should use NZTA’s minimum rate of 50%.

Policy 7.2 method 1: the simplicity of zones is important for cash fares but not for electronic ticketing. As the penetration of cashless ticketing increases (London buses are already down to single-figure percentages for cash fares) the need for zones should be reviewed. Other particular aspects that should be considered are that cash-free ticketing should give an effective discount on every fare; that fares should be capped on a daily basis; and that off-peak fares should be offered consistently (there are currently at least five separate definitions of off-peak on the Metlink network, varying between and even within operator).

The fare payment system needs to reflect general community norms for the use of e-payment, i.e. it is increasingly the usual way of paying small sums. Positive support of the NZ-wide e-ticket system being developed should be urged. Straightforward alternatives would always need to be available for people who do not use e-payment or who have a casual trip need.

Policy 8.1, method 1: repeats Policy 7.2 method 1, with the same comments.

Policy 8.1 method 2: integrated fare products are appropriate everywhere, so “where appropriate” is not required.

Policy 9.1 method 1: GW should require the Metlink brand to be used consistently across the network (and not itself erode that brand by referring to, for instance “Valley Flyer services” rather than Metlink services that are operated by Valley Flyer, assuming that the operator is relevant in the particular case).

Policy 9.2 method 5: area timetables should also be considered, on the lines of the useful and comprehensive Wairarapa one.

Objective 10: the status of the Public Transport Operating Model is unclear, with policy 10.3 describing its requirements, but elsewhere it appears to be under development and not finalised (policy 10.1 method 3).

Policy 11.1: subsidies should be set to reflect public benefit: seeking to “minimise” them runs the risk of imposing a disproportionate and uneconomic burden on fare payers. The cost of PT provides public benefits which, reiterating what we noted above,  include

1. less road traffic
2. commercial vitality of the CBD
3. use by non-driving family members such as children and older people
4. more productive land use.

3. What do you think of the layered service approach?

We support this approach, provided that all interconnections are of high quality. They are potentially the weak link in the chain.

4. Do you have any comments in the future network plan?

It looks appropriate, but we are surprised that Lower Hutt, the second-biggest CBD in the region, is excluded from the Rapid Transit Network. In Wellington City, we suggest that the most effective way to serve the airport may be through Newtown, and that the plan should not exclude that option.

5. Do you have any comments on the guidelines for consistent service levels?

Services should be consistent across the network in every respect, including branding, information and fares. Any variations should be clearly explained and logical, and not based on distinctions that from a passenger point of view should be irrelevant, such as the operator of a particular service.

With respect to the standards specified in Table 5:

1. The rapid transport network aims at minimising travel times, and for passengers overall travel time includes any waiting time. Having as a standard an off-peak rail waiting time of 30 minutes, over half the length of the typical journey (45 minutes Wellington-Upper Hutt, 1 hour Wellington-Waikanae), means that waiting time is likely to extend the typical journey by 25% or so (unless passengers can adapt their schedules to the timetable), meaning that times are very unlikely to be competitive with the private car, which can operate on demand.
2. It is not clear why train passengers are expected to accept frequencies 3-4 times worse than bus passengers.
3. For the above reasons, all RTN/QTN services should have a minimum service interval of 15 minutes.
4. A rail distance between stops of at least 3 km would require the closing of over half the stations in the Hutt Valley (15 stations in the 22 km between Petone and Upper Hutt), a large proportion of those on the Kapiti Line (10 stations in the 19 km between Takapu Rd and Pukerua Bay), and most on the Johnsonville line (7 stations, 10 km). Clearly this is unrealistic without a drastic redrawing of the region’s railway map, with its associated consequences.
5. It is unclear how the desired farebox recovery levels are arrived at.
6. A specific corridor may be part of more than one network, for instance express and all-stops trains share the same tracks, and conventional and limited-stop buses coexist on the same route. The network plan should make provision for this type of operation.

6. Please provide any additional comments below

Part A: The statistical information is interesting and useful, but mostly it is just a snapshot of 2009/10. There is little indication of trends except for the summary of patronage shown in Figures 3-5: it is hard to work out the trends from the block diagram format of the first two, and in the third one the highest and lowest case scenarios are projected from 2006 rather than from the present day, which seems rather strange.

Section 8.2: We could see no explanation of the reasoning behind the proposed service levels shown in Table 8. For instance, why should Lower Hutt and Porirua East have lower levels of service than the regional average, Wainuiomata much worse?

Section 9: It is unclear why the importance of commercial services means that GW does not intend to make use of contracting requirements.

Section 9.2, Controls: we support the need for controls over network branding, fares and real-time information: without such consistent features a grouping of services cannot be considered to be a network.

Appendix 2: the RTN infrastructure requirements may need to be relaxed, at least in the short term. For instance, the route along the Golden Mile should clearly be part of the network, but complete segregation and high-quality stations may not be easy to achieve in the short term.

Appendix 3: the “Classifying layers” section is confusing; it suggests that some parts of the local connector network will have higher levels of service than others but giving no reasoning behind the selection of the particular examples. We ask that all such departures from the standards given elsewhere in this document should be justified and made explicit.

Appendix 6, Table 20: the table seems to think that the only way of revising fares is to increase them. That is not the case: there are plenty of examples in consumer-based activities, including transport, where price reductions have been used to stimulate demand and returns. Focussing solely on fare increases eliminates the possibility of that sort of innovation, used with much success elsewhere.

1. The Trust commends the Council for the presentation of the plan – the language is plain and direct and issues for comment have been highlighted to facilitate public involvement. The areas of ‘focus approach’ is particularly useful.
2. We accept the strategy on which the plan is based, as explained in the opening comments from both the Mayor and the Chief Executive. Rates affordability is a key issue. The city has to continue to invest in core infrastructure and if acceptable living standards are to be maintained, so must essential services. A number of service charges are being increased. This is no doubt inevitable because the ratepayer should not have to bear the full burden of unavoidable increased in costs. It would, however, be a shame if service charges forced an increasing number of our citizens to be priced out of services previously within their reach. That would amount to a partial loss of citizenship.

Deep water pool feasibility study (Overview, page 19)

1. The proposal to spend $650,000 on a feasibility study for the construction of a deep water pool at the Wellington Regional Aquatic Centre does not seem to be in tune with a plan where the general emphasis is on financial prudence in the face of rising costs.
2. We are told that this proposal has been discussed for some years. It seems strange to move on it at a time which is the least propitious. The wish to equip the city with facilities that can attract major national and international events is understandable, but the pace of development has to be measured – measured against the financial commitments which it is prudent to undertake in a very uncertain environment. Those concerned that the city does not financially over commit itself are still calming their nerves following the the $45m sports centre at Kilbirnie.
3. Unfortunately the deep water pool proposal, coupled with the waterfront Kumumtoto toilet project (see later in our submission), will become symbolic of a council strategy of financial restraint not matched by its subsequent decision-making.

Climate change (2.5, page 45)

4. The year 2011/12 will take us closer to the target years set by the Council by which time the city’s emissions of green house gases will have been dramatically reduced (by 2020 a reduction of 30% and by 2050 a reduction of 80%). Given that the majority of councillors still seem keen on making life easier for the private motorist, with major public infrastructure being devoted to roads, we see little evidence that the Council is preparing the city for a low carbon future. Last year the Council adopted an additional target of a 3% reduction on 2001 levels to be achieved by the end of 2012/13.

This annual plan should have indicated where we now are in respect of that target and have listed new initiatives in an effort to achieve it.

Urban planning – 2040 Central City Framework (6.1 page 80)

7 The Trust notes that in 2011/12 the Wellington 2040 Central City Framework will be finalised. The success of that process will be at least partly dependent on effective engagement with the public. As long ago as the end of 2009 the Trust made a submission in response to the 2040 discussion document. Last August a closed councillors workshop discussed the issue. There has been no feedback from the Council in terms of our submission. On 4 April there was a strange news item in the Dominion Post regarding the 2040 related Space Syntax study, which suggested that it had proposed a waterfront promenade! Exercises which gaze into the distant future are vulnerable to comments from those of a cynical frame of mind. If the public is to be effectively engaged it has to be kept informed and closed workshops and inexplicable press items do not help. We await the promised framework with interest and the provisions it will make for effective public involvement in what we, uncynically, believe is a very important project.

District plan (6.3, page 85)

8 The District Plan is a readily accessible document through the Council’s website. Unfortunately it is also a misleading document, as the Trust found in its research on the decisions relating to the airport company’s success in getting a non-notified resource consent to erect a sign 12 times larger than the maximum stated in the plan. We had hoped that there might be a reference in the annual plan to a review of the presentation of that document, so that the ordinary citizen could read and understand it without the need for a professional interpreter.

Earthquake Risk Mitigation (6.4, page 87)

9 The Trust is pleased that the Council is reviewing its earthquake risk assessment programme and the time allowed for strengthening work. We fully appreciate the very hard decisions that have to be made in this policy area. As an organisation which places a high priority on heritage values, we would be concerned about the consequences of any policy which forced the demolition of character buildings. But the Council has a responsibility to take reasonable steps to ensure the safety of its citizens and visitors. What concerns us is that a significant number of older buildings (estimated from 600 to 3,800) do not even meet the statutory requirement of at least 34% strength of the building code required for new buildings. Whether or not that statutory requirement should be reviewed is also a matter which should be addressed by the Council, with a view to making representations to ministers.

Waterfront (6.5, pages 88 and 164)

10 It is noted that discussions are continuing with interested developers for site 10 in the Kumutoto section of the waterfront. The Trust strongly supports an appropriate development of that site conforming to the standards set out in Variation 11. The Council and the waterfront company have repeatedly said that developers for sites needed to know what the district plan requirements for a site were before developing and submitting their proposals. We are therefore surprised that the Council has not pressed for a hearing of the appeals submitted against the commissioners’ approval of the variation. While the Trust considered that the variation approach was a mistaken path, we do not think that a halt in the process without explanation is appropriate. The Trust is aware that unless the company can get revenue from this site the outlook for paying back the Council loan (which could rise to $20m) is bleak.

11 The draft waterfront Development Plan for 2011/12 states that master planning for Queens Wharf has been completed and the results presented to the Council early in 2011. The company “is not recommending that it be progressed in its totality, rather that it be reviewed for viability in 2 or 3 years” (p171). However, it is investigating some development of the southern arm of the Outer-T for the operations of the helicopter company. Presumably the public will be given an opportunity to comment on this proposal for a partial development of this iconic site. But it is also time that the public was privy to the master plan. That is a prerequisite for evaluating the appropriateness of the Outer-T project. Queens Wharf is at the heart of the waterfront project and public engagement and transparency are principles at the heart of the waterfront project process.

12 The Trust notes that the Kumutoto toilets project is not listed in works scheduled for 2011/12. It was on the list for 2010/11. According to the second quarter report to the Council Controlled Organisations Committee construction was expected to begin in the third quarter. That quarter has come and gone but there is no sign of construction. We are, of course hopeful that this means that the company is not proceeding with a project which in current circumstances should have a very low priority.

Parking fees (7.3, page 97)

13 The proposal to increase parking fees by $1 is reasonable in current circumstances. We are concerned about the implications of extending, for some areas, the time when charges apply in the evening. While a $1 increase in the fee is unlikely to alter parking habits, an extension of the charging period will. It could have an adverse effect on bars, cafes and restaurants. We assume that during weekdays (apart from Fridays) parks in the central city are not heavily used. It is not therefore a case of rationing the supply. We would have thought it would have been more prudent to increase the charging period by one hour only and monitor its impact.

Sharmian Firth

Chair

Comments:

1. While entitled ‘the GPS on Land Transport funding’, it does not cover KiwiRail’s expenditure on the rail network. It therefore misses any opportunities for looking at the transport network as a whole, and is unlikely to achieve full value for money since this approach cannot optimise the use of all existing resources and infrastructure. For example, Hamilton to Tauranga is proposed as a RoNS while the parallel railway line has received some upgrading and is capable of more. 
2. The document also excludes sea transport, an integral part of the transport network: for example, the interisland ferries and their terminals are an essential link in both State Highway 1 and the Main Trunk railway.
3. The document appears to assume that past trends will continue into the future, unabated. It does not appear to recognise that traffic on State highways has not increased since 2005, and it does not appear to recognise the issues of climate change or peak oil. It does not appear to recognise the risks involved in pursuing a path that is dependent on the internal combustion engine.
4. The vision makes no mention of sustainability or environmental issues.
5. Walking and cycling funding is essentially restricted to the model community programmes in Hastings and New Plymouth, and the health and economic benefits of active modes do not appear to be recognised.
6. The focus on economic growth and productivity is not supported by the proposed expenditure on RoNS projects, many of which have low benefit/cost ratios, some less than 1 (e.g. Transmission Gully), meaning that the expenditure produces a net economic disbenefit.
7. There is no mention of any link between transport and urban form, and the effects on cities such as Wellington of increasing the capacity of access roads while proposing no changes to inner-city roading do not appear to be considered.
8. While expenditure on State highway construction increases, there is no corresponding increase in maintenance expenditure.
9. Local roads provide essential links to State highways, but expenditure on these is static.
10. The reduction in Road User Safety expenditure does not appear to be consistent with the objective of improving road safety.
11. Reduced expenditure on public transport infrastructure (approximately 4% of that on State highway construction) does not appear to recognise the economic, environmental and safety benefits of public transport use. NZTA figures show, for example, that every additional peak train boarding creates an economic benefit of approximately $17, and the risk per kilometre involved in being a bus passenger is approximately one-tenth of that of travelling in a car. There is also evidence that investment creates more jobs when spent on public transport rather than roading – see http://t4america.org/wp-content/uploads/2011/02/lessons-from-the-stimulus.pdf, for example.

We support the overall focus on economic productivity, value for money and transport (not just road) safety, but we submit that that a fourth priority should be added, that of sustainability and resilience.

To make full progress with these priorities, we submit that the following initiatives are necessary:

1. The surface transport network should be considered and funded as a whole, achieving full synergies between modes;
2. Full benefits of each project should be taken into account, irrespective of funding class, to develop overall funding priorities;
3. The benefit and cost factors assessed should included economic outcomes, health, the environment, safety, urban form and sustainability.

We submit that following this approach would produce a Government Policy Statement on Surface Transport Funding that fully contributed to the government’s goals and the country’s well-being.

Alan Smith
Chair
Wellington Civic Trust

Contact: Mike Mellor, Trustee, ph: 027 684 1213

Category winner — ‘Enhancement or Protection of the City’s Built Environment’

Te Wharewaka, by Architecture+

The runner-up was the Chews Lane Project byAthfield Architects.

Category winner — ‘The City’s Public Spaces’

Te Ahumairangi Hill Lookout, Tinakori Hill

The runner-up was Taranaki Wharf West.

Category winner — ‘Art in the City ~ People’s Choice’

Colin Webster-Watson’s Frenzy, Taputeranga Reserve, Owhiro Bay

The Civic Trust is not too concerned about the attitude taken by the NZTA in this matter. Central government always leans on its smaller and weaker partner in government. Moreover, NZTA’s bloodline goes back to the Ministry of Works, an organisation with many qualities, but not, unfortunately, any related to engagement with the public. We expect better of that arm of government which is community-based. This issue will be a true test of whether or not our Council can, despite the lure of central government cash, approach this matter determined to act in the best interests of the communities it represents.

The Trust agrees that the Council should confirm that it supports the Ngauranga to airport plan and consequently a multi-modal approach, containing a state highway component. But the nature of that component has only been agreed in broad terms. The problem areas have been identified, but the solutions have not. Those that have been discussed have drawn significant public criticism and the Council may find that there is no acceptable solution involving major construction. The Trust agrees that we should be a supportive partner, but the purpose of this partnership is to find solutions which do not sacrifice the welfare and values of our communities to satisfy a growth strategy that may seem increasingly irrelevant as this century advances into a low carbon future.

We would expect the Council to evaluate options in the light of studies associated with the 2040 project and its commitment to reduce emissions by 80% by 2050. Those studies and commitments do not sit easily with a major further investment in roading.

The Trust agrees with the officer’s report at para 5.2 as to the role of the Council in assisting NZTA to design a fair and open consultative process and facilitate its implementation. But it should be made clear that the options are NZTA proposals and not the Council’s.

In August 2009 the Trust convened a seminar focused on the threat to the area around the basin reserve. In a letter we sent to Hon Stephen Joyce following the seminar we said:

The community groups represented at the meeting expressed their concern that they were not being involved at a stage where they were able to influence a decision. They believed that they had the knowledge and ability to make a positive contribution to a search for a solution. They considered that it was not necessary to sacrifice community interests to satisfy the wider public interest.

On 22 September 2009 the Trust was advised by NZTA that they intended to establish a Community Connect Group and that they would begin preliminary engagement with community groups in early October 2009. Eighteen months later we are still waiting for the first meeting. And this is the organisation which imposes a three-week deadline on this Council!

The Council should facilitate public discussion of the options presented by NZTA but it should not commit to any one solution. Indeed in the light of feedback it may decide that none of the options presented is in the best interests of the city.

NZTA wants the council to commit to both investigations and to construction. How can this Council commit to works without the benefit of a report on environmental impacts and without seeking and evaluating the views of those likely to be affected? That point has to be made clear in the Council’s response to the NZTA and the Wellington Civic Trust would expect all councillors, including the nine who sought this well-named extraordinary meeting, to support such a response.

Peter Brooks
Wellington Civic Trust
04  479 6812