Submission to Regional Land Transport Plan, 2021-2031
Heart of the City (HOTC) is the business association for Auckland’s city centre. We represent the interests of businesses and property owners in the city centre. We are committed to the growth and success of the city centre as a vibrant, accessible, safe and welcoming urban community.
Key points to our submission:
- The city centre has experienced a massive shock from COVID-19. On top of that, spending in the city centre was already trending down before COVID as were the perceptions and experience of access, for both customers and suppliers, caused by long term, large scale and cumulative construction. Many businesses continue to be severely impacted by the City Rail Link construction. The approach to investment and implementation of RLTP funded projects in the city centre must take into consideration the importance of the need for a thriving, appealing and successful city centre.
- We must also see overall improvements in how investment and change is undertaken in the city centre, and ensure that planning is holistic and integrated, and that innovation underpins the strategic direction for change.
- There must be a strong focus on “dig once”. Projects must be sequenced to ensure this is achieved. Auckland Transport recently deferred the Wellesley Street project due to the need to achieve savings due to Covid, however the consequences of this are significant as it will mean additional disruption to an area that has already had significant disruption caused by the City Rail Link works. This is not an acceptable way of dealing with city centre transformation.
- HOTC would like to see a stronger focus on ensuring reliable and affordable public transport is provided, both day and night, with associated infrastructure that is high quality and safe, and other modes supported. This must also be supported by a well-resourced and enduring Travel Demand Management (TDM) programme.
- HOTC also believes that there must be equitable access. Importantly, we maintain that until such a time there is universal public transport, day and night, Auckland Transport needs to 2 continue to have a role in affordable, off street, short term parking. The inclusion of short term parking in the redevelopment of the Downtown carpark is essential.
- HOTC considers that, subject to a successful business case, funding for Access for Everyone and also bus priority infrastructure and measures is a priority and should not be put at risk through insufficient funding.
- We also need to ensure that goods and freight can get to where they need to go. HOTC cannot accept the ongoing cannibalisation of kerbside loading space. Investment and priority is needed to fast track strategic kerbside planning to enable innovative solutions, such as for loading and servicing in the city centre.
- We are supportive of the proposal to procure only electric or hydrogen buses from July 2021. We must address air quality issues in the city centre and this a key initiative to support this.
- In principle, we support the concept of congestion charging across Auckland (but further analysis is required before HOTC can respond on the proposal for a city centre cordon) and the removal of Fringe Benefit Tax for public transport but cannot support an Employee Remote Work policy proposal.
- We cannot forget the fundamentals through this budget. There must be appropriate levels of investment for maintenance and enforcement. We continue to see examples of public spaces deteriorating after significant investment due to assets not being fixed or replaced in a timely manner, and ongoing poor enforcement, particularly for illegal parking.
Our submission will cover
- Funding, including Regional Fuel Tax (RFT)
- Priorities for investment
- City centre priorities
- Climate change
- Maintenance and asset maintenance
- Major/other investments
- City Rail Link
- Rapid Transit (Light Rail)
- Policy Changes, including congestion charging
1. Funding, including Regional Fuel Tax and congestion charging
HOTC recognises that the Draft RLTP’s programme of investment in city centre transport projects and services is subject to uncertainty about Waka Kotahi funding contributions over the 2021-31 period. We note that AT’s capital programme within this RLTP is based on the assumption that it can be funded by Auckland Council and National Land Transport Fund (NLTF) on a 50:50 co-funding mix, the same as assumed in Auckland Council’s Draft LTP 2021-31.
If insufficient funding is forthcoming from Waka Kotahi, AT indicates that the following projects in the city-centre would be ‘at risk’ due to being lower priority compared to other projects agreed to in ATAP 2021-31;
- Albert and Vincent Street Bus Priority Improvements
- Access for Everyone
- Ferry Decarbonisation
- Downtown Bus Improvements (Quay Park, Customs Street and Wynyard Quarter)
- Walking and Cycling Programme, Phase 2
Subject to the completion of a successful and agreed business case, HOTC wants to ensure that Access for Everyone is given priority for investment and that its implementation is not put at risk due to insufficient funding. This could be a significant driver for how public space redevelopment and access projects are undertaken for the city centre.
We would also give greater priority to enabling better bus priority and improvements in the city centre, as it’s critical that there is reliable and efficient bus access into the city centre. This will be critical to enabling mode shift and reducing congestion. We note that this needs to be cognisant of the process for Light Rail.
Regional Fuel Tax:
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.
While we have previously supported a regional fuel tax of 10 cents per litre (plus GST) as an interim measure, we ask for greater transparency regarding the spending of this tax on specific transport projects and services. We wish to avoid the RFT, which is the equivalent of a significant rates increase (especially for transport operators), being used as a ‘top up’ for overall transport budgets.
We note the ongoing underspend of the Regional Fuel Tax. We are concerned that:
- the RFT is being under-spent
- businesses and residents are being over-taxed
- infrastructure is not being built at the required pace.
2. Priorities for Investment
a) City centre priorities
The city centre has experienced a massive shock from COVID-19. Impacted businesses, which employ people from all over the city, have lost half a billion dollars of consumer spending over the last year plus all the costs associated with changing alert levels.
On top of that, spending in the city centre was already trending down before COVID as were the perceptions and experience of access, for both customers and suppliers, caused by long term, large scale and cumulative construction. Many businesses remain seriously impacted by this construction, particularly from the City Rail Link.
The approach to investment and implementation of RLTP funded projects in the city centre must reflect the importance of attracting people back to the city centre. Whilst we are supportive of a number of priorities for investment that are outlined in the RLTP, including investment into Access for Everyone, in order to successfully achieve a positive outcome for the city centre, we would like to see:
- Holistic and connected planning within Auckland Transport, and across the Council group to achieve successful transformation in the city centre. This is necessary to ensure place, movement and operational needs are met optimally.
- Effective timing and sequencing of projects to ensure the city centre is attractive and accessible while it is being transformed.
- Scheduled works are cost-effective and efficient, with a “dig once” approach.
- New spaces must be maintained and looked after – ongoing management and maintenance is vital to success.
- Innovation in how the city operates, for example in servicing and loading, to underpin aspirations for the place – businesses need to get stock.
Access for everyone: Subject to the completion of a successful and agreed business case, HOTC wants to ensure that Access for Everyone is given priority for investment and that its implementation is not put at risk due to insufficient funding. This may require a review of the overall priorities for city centre investment in the coming years, including the current City Centre Targeted Rate (CCTR) capital programme led by Auckland Council and other planned Auckland Transport projects.
Midtown Bus Improvements: The RLTP currently has $132M allocated to support investment into the places like Wellesley Street as well as in and around the University. We are supportive of prioritising investment around public transport nodes. It was extremely disappointing that funding for the Wellesley Street infrastructure development was deferred in 2020, and planned Watercare works in the area were also not coordinated. We urge Auckland Transport to approach city centre development with a “dig once” approach and take this into consideration when looking at budgeting and phasing. The consequence of this deferment will be additional disruption to businesses in the Wellesley Street area, which could have been avoided if works were timed with the current Wellesley Street/Albert street intersection closure, as originally planned.
Bus Stations/exchanges: Significant funding has been allocated in the RLTP to support bus exchanges in Wynyard Quarter and the Beach Road area, as outlined in the Bus Reference Case 2020. It is not clear how the proposed Downtown Carpark sale, and the idea of a bus interchange, fits within this investment and overall strategy as it is not referred to in the Bus Reference Document, and whether this triggers any changes.
Introduction of bus lanes: HOTC recognises the importance of rolling out dedicated bus lanes in the city centre to increase reliability of bus services. However, the implication of the introduction of bus lanes is that other essential functions such as taxis and rideshare are not always able to access some areas. We would like a more holistic approach to planning and rolling out of bus lanes and these must go hand in hand with other strategic work such as integrated kerbside planning.
- To support the significant capital investment programme being undertaken in the city centre, HOTC would also like to see:
- A fully funded large scale TDM (travel demand management) programme.
- Kerbside/loading and servicing strategy with investment for implementation. We understand that the some of this is now a key workstream falling out of the Access for Everyone business case, however this work should not be contingent on the successful completion of A4E.
b) Climate Change and the environment
HOTC is supportive of investment to meet climate change goals. In particular, we support funding that will ensure all new buses procured from 1 July 2021 will only be electric or hydrogen - this will go some way in addressing air quality issues in the city centre. 5
c) Maintenance and enforcement
- Ongoing management, maintenance and enforcement are vital to maintain a successful and attractive city centre. We continue to see examples of public spaces deteriorating after significant investment due to assets not being fixed or replaced in a timely manner, and ongoing poor enforcement, particularly for illegal parking. These are significant issues that must be addressed.
- We understand that camera technology put in place to help support more effective parking enforcement is not operating due to resource issues. We simply can’t afford to keep letting our streets and spaces not work and adequate investment must be put in place to ensure this is realised.
- The level of road (including footpath) maintenance is a serious issue. To ensure sufficient funding is available to cover renewals within the RLTP, Auckland Council and AT need to advocate to the government to increase funding in the Local Road Maintenance Activity Class in the 2024 GPS.
- We would also like Auckland Transport to be efficient with maintenance and renewals contracts and look at what other opportunities exist for improvements to streets under existing contracts (such as, if appropriate, changes to improve loading zones rather than just replacing like for like).
d) Major/other investments
HOTC is supportive of a number of regional investment projects which will improve access to the city centre. In particular, we support:
- SH16 Northwest bus Improvements: It is critical that there is significantly improved access from the Northwest into the city centre to support the economy here. HOTC would like to understand how this is being future proofed with respect to the current Light Rail business case process.
- HOTC has been a supporter of the Northern Pathway (SkyPath) since its original inception and we continue to support the idea of being able to cycle across the harbour. The current situation is extremely disappointing and we would like to see a solution that could enable this to be achieved. We recognise the opportunity that enabling cycling and walking across the harbour could bring to the city centre, both for domestic access but also as creating another attraction that would build Auckland’s appeal as a tourism destination.
- Note the following was included as an addendum to our submission: While a second harbour crossing was not referenced in the RLTP, we believe a second harbour crossing is required and that work needs to start immediately on this.
3. City Rail Link
HOTC would not like to see any additional funding requests for the CRL from Auckland Council funding.
4. Light Rail
HOTC has an ongoing interest in the development of the Light Rail business case and is expected to be included in stakeholder consultation during the period of its development. Any decision for a route in the city centre will be significant and will have major implications to how specific streets could function in the future, as well significant disruption.
If the right rapid transit solution can be found and it is well planned, governed and executed, it will help transform our city. However, if it is not well considered and it does not learn from the City Rail Link experience, the negative impacts across Auckland will be enormous. There needs to be proactive consideration for support for business that is appropriately funded and set aside from the project budget.
5. Policy Changes
Removal of Fringe Benefit Tax (FBT) Public Transport
Heart of the City is supportive of the proposal to remove FBT for public transport initiatives by employers for employees. This will enable employers to offer employees subsided public transport options and would also align with Auckland Transport TDM (travel demand programmes).
Employee Remote Work
HOTC does not support this proposed policy response. We cannot support the intent from the RLTP to advocate/lobby for central government intervention to encourage employees to have a ‘one day for work from home’ policy in place, not least because $4.4B is being invested in public transport to improve access to the city centre and also to support city centre recovery.
In November 2020 Auckland Council’s Chief Economist Unit reported that the number of people in the city centre on the average workday under Level 1 restrictions is about 80-85% of pre-lockdown levels. Some, but not all, of lost city centre spending appears to have shifted to other major centres in Auckland. None of these centres have seen declines as large as in the city centre.
Heart of the City acknowledges the benefit to air quality and congestion that increased working from home has had during COVID. HOTC is supportive of the idea of flexible working which can support reduced congestion, including for example encouraging different start and finish times. This proposal fails to acknowledge the economic impact of working from home.
HOTC is supportive of the principle of congestion charging across Auckland to address major productivity issues for business, however, we have yet to complete our analysis regarding potential impacts on the city centre. We will be engaging with Central Government on The Congestion Question. In brief, it is HOTC’s current view that:
- Congestion charging can’t be introduced in isolation:
- it will be vital to link any congestion charging with the opening up of better public transport in Auckland
- further analysis is important before HOTC can respond on the proposal for a city centre cordon
- An easy to access city centre is vital to its success