Meeting of the Regional Transport Committee

 

 

Date:                 Friday 8 June 2012

Time:                10.15am

Venue:

Council Chamber

Hawke's Bay Regional Council

159 Dalton Street

NAPIER

 

Agenda

 

Item      Subject                                                                                            Page

 

1.         Welcome/Notices/Apologies 

2.         Conflict of Interest Declarations

3.         Short Term Replacements for the Regional Transport Committee  

4.         Consideration of General Business Items

Decision Items

5.         Submissions on the draft Regional Land Transport Strategy, incorporating the draft Regional Land Transport Programme

Information or Performance Monitoring

6.         General Business  

 


HAWKE’S BAY REGIONAL COUNCIL

Regional Transport Committee  

Friday 08 June 2012

SUBJECT: Short Term Replacements for the Regional Transport Committee        

 

INTRODUCTION

1.      Council has made allowance in the terms of reference of the Committee for short term replacements to be appointed to the Committee where the usual member/s cannot stand.

 

RECOMMENDATION

1.     That __________________________  be appointed as member/s of the Regional Transport Committee of the Hawke’s Bay Regional Council for the meeting of Friday, 08 June 2012 as short term replacements(s) on the Committee for _______________________.

 

 

 

 

Carol Gilbertson

Transport Manager

 

   


HAWKE’S BAY REGIONAL COUNCIL

Regional Transport Committee  

Friday 08 June 2012

SUBJECT: Submissions on the draft Regional Land Transport Strategy, incorporating the draft Regional Land Transport Programme        

 

Reason for Report

1.      The purpose of this report is to:

1.1.   introduce submissions received on the draft Regional Land Transport Strategy, incorporating the draft Regional Land Transport Programme (RLTS/RLTP);

1.2.   outline the process for hearing verbal submissions; and

1.3.   make recommendations on the submissions and any consequential changes to the draft RLTS/RLTP.

2.      Attached to this report are full copies of the submissions received (Attachment 1) (RTC members only, previously circulated) and a summary of these submissions and staff responses (Attachment 2), prepared by the Transport Advisory Group (TAG).

Background

3.      The Hawke’s Bay Regional Council is required to prepare a Regional Land Transport Strategy (RLTS) and also a Regional Land Transport Programme (RLTP). At the Regional Transport Committee meeting on 27 April 2012 the Regional Transport Committee adopted one document that contains the draft RLTS, incorporating the draft RLTP for public consultation.

4.      The Regional Land Transport Strategy (part one) identifies what is needed in our region to achieve an affordable, integrated, safe, responsive and environmentally sustainable land transport system, now and in the future and sets out a framework for our transport network. It focuses on the strategic transportation needs of the Region, looking out over a period of the next 30 years. Part two contains the Regional Land Transport Programme, which is the mechanism to seek funding from the National Land Transport Programme (NLTP) and forms the basis of a programme of works through which Approved Organisations (AOs) in Hawke’s Bay are able to request funding subsidy from NZTA for land transport activities.

5.      The draft RLTS/RLTP and the Summary Document were made publicly available from 1 May 2012 and distributed widely to individuals and organisations, in accordance with the special consultative process in the Local Government Act 2002. Public notices were featured in Hawke’s Bay Today and community papers (including Wairoa and Central Hawke’s Bay). The documents were also available to view and download from Hawke’s Bay Regional Council’s website. Public consultation closed at midday on Thursday, 31 May 2012.

6.      30 submissions were received during consultation. Of the 30 submissions received, 16 have indicated that they wish to be heard in support of their submission. Acknowledgement letters were sent to all submitters and they have received a copy of the staff response to their submission. A copy of the final RLTS/RLTP document will be sent to all submitters when it is available.

7.      Each of the 30 submissions received on the draft RLTS/RLTP have been summarised in the attached ‘Summary of Submissions Received” report (Attachment 2), with responses and recommendations provided for each matter raised. Members of the Transport Advisory Group (TAG) has been involved in preparing these recommendations.

8.      Members will today hear those submitters who wish to speak to their submission then adjourn to deliberate on all the submissions received. Consequential amendments to the RLTS/RLTP will be made as a result of the Committee’s deliberations, with a revised RLTS/RLTP being brought to the 22 June 2012 meeting of the Committee for their endorsement and referral to the Hawke’s Bay Regional Council for final adoption.

Hearing of submissions

9.      A timetable for hearing the verbal submissions is also provided as part of Attachment 2. Each submitter who wishes to be heard has been allocated a ten minute speaking time followed by five minutes to answer any questions that the Committee may have. The Committee will hear all of the verbal submitters and then adjourn to deliberate on all of the submissions received.

10.    As Members will be aware, under section 107(1) of the Land Transport Management Act 2003, the objective representatives and cultural interests representative “have full speaking rights but are not entitled to vote on matters related to regional land transport programmes.” Therefore, all Members should be actively involved in the hearing of submissions and subsequent deliberation discussions, however only the six members representing the organisations who have works within the Programme have voting rights on the final recommendations.

Next steps

11.    A revised RLTS/RLTP, that takes into consideration any changes made during this submission process, will be presented to the Regional Transport Committee on 22 June 2012 for endorsement. The Committee will then approve the RLTS/RLTP for adoption by the Hawke’s Bay Regional Council at its meeting on 27 June 2012.

12.    The final approved RLTP will be forwarded to NZTA (via online submission into the NZTA’s funding management system Transport Investment Online) by 30 June 2012, where it will be ‘nationally moderated’ for inclusion in the National Land Transport Programme (NLTP).

13.    The NLTP will be adopted by NZTA in late August 2012, with organisations learning what central government funding they have been successful in securing for land transport activities.

Decision Making Process

14.    Council is required to make a decision in accordance with the requirements of the Local Government Act 2002 (the Act).  Staff have assessed the requirements contained in Part 6 Sub Part 1 of the Act in relation to this item and have concluded the following:

14.1. Sections 83 and 84 of the Act set out the requirements of the Act where the special consultative procedure applies with consideration of the draft Regional Land Transport Strategy, incorporating the draft Regional Land Transport Programme.

14.2. The issues to be considered in this paper are those issues raised by members of the community that have submitted to the Committee on the RLTS/RLTP. All submissions are an integral part of the special consultative processes set out in Section 83 and 84 of the Local Government Act 2002

 

 

RECOMMENDATIONS

That the Regional Transport Committee:

1.    Agrees that the decisions to be made on issues submitted on the draft Regional Land Transport Strategy 2012-2042, incorporating the draft Regional land Transport Programme 2012-2015 are made after the provisions included in Section 83 and 84 of the Local Government Act 2002 have been followed;

2.    Receives, and acknowledges with thanks, the verbal and written submissions forwarded in response to the draft RLTS/RLTP;

3.    After hearing verbal submissions, considers and adopts the recommendations contained within the attached ‘Summary of Submissions and Recommendations’ report, subject to amendments agreed to by the Committee;

4.    Agrees to consequential amendments to the RLTS/RLTP;

5.    Notes that a revised RLTS/RLTP, incorporating any changes required through this submission process, will be presented to the 22 June 2012 meeting of the Regional Transport Committee for endorsement, and will be referred to the Hawke’s Bay Regional Council on 27 June 2012 for adoption.

 

 

 

Carol Gilbertson

Transport Manager

 

 

Attachment/s

Attachment 1 – Copies of all Submissions Received (previously circulated to RTC members)

Attachment 2 – Summary of Submissions Received (under separate cover)  


HAWKE’S BAY REGIONAL COUNCIL

Regional Transport Committee  

Friday 08 June 2012

SUBJECT: General Business        

 

INTRODUCTION

This document has been prepared to assist Committee members note the General Business to be discussed as determined earlier in Agenda Item 4.

Item

Topic

Councillor / Staff

1.   

 

 

2.   

 

 

3.   

 

 

4.   

 

 

5.   

 

 

6.   

 

 

7.   

 

 

8.   

 

 

9.   

 

 

10. 

 

 

 

    


Regional Transport Committee                                                                                 8 June 2012

                                                                                       Summary of Submissions Received                                                                                                            Attachment 2

Index of Submissions

Submission No

Submitter

Verbal Presentation

Page Number

1

Roark Watson

No

5

2

Roark Watson

No

6

3

Laura Swan - Haines Planning representing Harvey Norman Properties (NZ) Ltd and Harvey Norman Leasing (NZ) Ltd

No

7

4

Ken Crispin - East Coast Transportation Project Manager

Citizens Environmental Advocacy Centre Inc (CEAC Inc)

Yes

8

5

Barrie Crabbe

Yes

11

6

Garth Cowie, Port of Napier Ltd

No

13

7

Murray Douglas, Chamber of Commerce

No

14

8

Dianne Vesty, Hawke’s Bay Fruitgrowers

No

15

9

Robin Gwynn

Yes

16

10

David Webster

No

19

11

Transport Advisory Group (TAG)

Yes

20

12

Mac Kirkwood representing Karamu Enhancement Group (KEG)

Yes

21

13

Karamu Enhancement Group ( Mac Kirkwood)

Yes

23

14

Hawke’s Bay District Health Board – Dr Kevin Snee

Yes

24

15

Ngati Kahungunu Iwi Incorporated – Morry Black

Yes

25

16

Central Hawke’s Bay District Council

No

27

17

Pan Pac – Brett Gilmore

Yes

28

18

Audrey Jones

No

29

19

NZTA (Oliver Postings)

No

30

20

EF Hill  (Ted)

Yes

31

21

Les Hewett – Napier Heavy Traffic Community Forum

Yes

32

22

Jenny Baker

No

34

23

Murray Deakin

No

36

24

Fonterra Co-Operative Group Limited– Philippa Barriball

Yes

37

25

Wairoa District Council – Mayor Probert/Jamie Cox

Yes

37

26

Federated farmers of New Zealand – Rhea Dasent

No

38

27

Neal Taylor

No

39

28

Colin Macdonald

No

40

29

Richard Barfoot

Yes

41

30

Jim Haliburton

Yes

42

 



Timetable of Verbal Submissions

Submission No

Submitter

Time

5

Barrie Crabbe

10.30am

4

Ken Crispin - Citizens Environmental Advocacy Centre Incorporated

10.45am

8

Robin Gwynn

11.00am

12/13

Mac Kirkwood (Himself & KEG)

11.15am

14

HB District Health Board – Dr Kevin Snee

11.35am

15

Ngati Kahungunu Iwi Incorporated (Morry Black)

11.50am

Lunch

12.15pm

Hearing Reconvenes

12.45pm

17

Pan Pac – Brett Gilmore

12.45pm

20

EF (Ted) Hill

1.00pm

21

Les Hewett (Napier Heavy Traffic Community Forum)

1.15pm

24

Fonterra Co-Operative Group Limited

1.30pm

26

Fed Farmers Rhea Dasent/Bruce Wills

1.45pm

29

Richard Barfoot

2.00pm

30

Jim Haliburton

2.15pm

25

Wairoa District Council

2.30pm

11

Transport Advisory Group (TAG Members)

2.45pm

 


 




1.      Submitter: Roark Watson

Officer’s Recommendations

This submission discusses the need for an east/west arterial route; comments on proposal (Whakatu Arterial) to connect State Highway No 2 at Mangateretere to Pakowhai Road.

The submission then suggests a road link between SH2 via the Awatoto/Ravensdown fertiliser plant, (from end of Waitangi Rd and the Meeanee Rd/Brookfields Rd junction, or with an enhanced Brookfields Rd/Sears Rd terminus development – a new cross country connection). It states that this could be simpler and cheaper than the current proposal.

The submission quite accurately describes the existing transport problem for vehicles needing to traverse the plains on an east/west alignment in the vicinity of Havelock and Hastings. These include intersection delays and the need to take rather convoluted paths along a series of circuitous roads. These difficulties are similar to the problems industrial traffic faces when accessing or exiting from the Whakatu/Tomoana industrial areas from either the expressway to the west or from the eastern parts of the plains.

The Whakatu Arterial corridor has been identified in the strategy as a key capacity improvement on our arterial network for those reasons.

This follows from the identification of this corridor in the Heretaunga Plains Transportation Study (HPTS) 2012 as a strategic freight route and of strategic importance for our region.

 It will not only resolve long term east west traffic flow and access to Whakatu issues, but will facilitate growth of industry, improve the efficiency of freight movements, as well as helping to reduce the impact of freight movements on sensitive environments, such as residential areas in Hastings and Napier and the tourism area on the Marine Parade.

In recommending the development of this corridor, the HPTS considered a range of potential alignments within the overall corridor. These included using those routes raised in the submission. While the route suggested achieved an economic return, it was not as effective as building a new link, with purpose designed connections into Tomoana and Whakatu.

Importantly a new route offered the best opportunity to design and construct a route that best mitigated any potential adverse effects of such a proposal on communities and the environment.

The advocacy in the submission of a link from State Highway No 2 to the expressway utilising existing roads and a new link from the coast at Awatoto to Meeanee, was also considered as part of the HPTS. It had also been considered in previous transport studies. The possible link is not considered to be of high priority, particularly if the Whakatu Arterial link is completed. That link will provide a better east-west connection at the source of traffic generation.

For this reason further investigation of alignments is not proposed to be undertaken until the 2018-2026 period, with construction, should this prove viable, in the 2027-2046 period. As such it is not necessary to review and/or select alignments at this time.

Having said that, Napier City Council have investigated a range of options for an Awatoto to expressway route since the release of the HPTS 2004 (this study had proposed this connection for investigation).

This work indicated that the alignment suggested in the submission would not achieve a sufficiently strong BCR to attract funding (<1). This was due to increased land costs and impacts on an area of land currently used as a flood detention zone. As such the alignment has not been pursued any further by Napier City Council.

Recommendation:

That Mr Watson be thanked for his submission and be advised, based on the comments made, that no change is to be made to the RLTS

 

 

2.      Submitter: Roark Watson

Officer’s Recommendations

Suggests 'Pacific Coast Highway' be rebranded as 'The First Light (Pacific) Highway'.

As the submission observes, this matter is outside of the normal context of an RLTS. It does however raise an issue relating to the nature of our inter regional routes and their actual and potential increased use as part of our regions wider economic strategy of encouraging tourism.

While the strategy could acknowledge better and support improvements to facilitate tourism on inter regional routes (State Highways in the main), it cannot require the implementation of a name change and allied marketing initiatives, as is suggested in the submission.

The committee could however, if it so wished, refer this matter to the region’s economic development agency for consideration as part of its tourism support activities.

Recommendation:

That Mr Watson be thanked for his submission and be advised, based on the comments made, that no change is to be made to the RLTS


 

3.         Submitter:        Harvey Norman Properties (NZ) Ltd and Harvey Norman Leasing (NZ) Ltd

Officer’s Recommendations

The Harvey Norman submission supports initiatives to improve the transportation network, provided they do not adversely affect their activities i.e. reduce customer visibility, reduce on-street car parking, cycling facilities, place restrictions for service activities, or construction activities adversely affecting customer or service vehicle access to Harvey Norman sites on Holt Place and St Aubyn St.  Harvey Norman request they are individually consulted as part of the St Aubyn St/Karamu Rd corridor studies.

In general, the matters raised in this submission relate to what are typically referred to as local area traffic management initiatives. Such matters are dealt with by the relevant local Approved Organisation (AO) (in this case Hastings District Council), not by the RTC through the RLTS. 

The RLTS may impinge on some of the aspects raised in a general sense (e.g.  its policy support for AO’s considering a range of solutions when dealing with capacity issues on their networks including for instance TDM initiatives).

At the end of the day however, the RLTS does not bind any AO to any specific approach or solution. Rather it binds them to give proper consideration to such options before deciding on any specific course of action.

As part of considering these issues any responsible AO would take into account the possible impacts of it’s the actions on any potentially affected business and consult with them before any decision was made.

Recommendation:

That Laura Swan, representing Harvey Norman Properties Ltd be thanked for their submission and be advised, based on the comments made, that no change is to be made to the RLTS.

 


 

4.      Submitter:  Ken Crispin, CEAC Inc

Officer’s Recommendations

This submission expresses concerns about the impacts of road freight on communities and the need for a sustainable transport system based around the use of rail. As part of reducing the impacts of road freight and shifting freight to rail, it promotes the development of a rail hub in the form of an “inland port” which would enable the trans-shipment of freight from the hub to the port. It suggests that this hub be established at Whakatu, as has been previously proposed.

Subsequent to the receipt of the submission, an addendum has been forwarded which in the main, seeks to expand on the original points raised. It cites a recent report prepared by the Gisborne District Council’s roading engineer which discusses the retention of the Napier-Gisborne railway line. After reiterating the points about the impact of HCV in the addendum, the submission seeks some specific additions and /or changes to the RLTS.  

These include requests to include statements that the submission states support a modal shift for freight from road to rail; the establishment of an inland port at Whakatu; and references to various reports which the submission states indicate that a shift from rail/loss of a rail option will cause freight transport costs to rise and harm the regional economy of Gisborne.

The RLTS currently identifies a future role for rail in the carriage of freight. It also acknowledges that rail can have fewer impacts on the environment and is an efficient means of shifting high volumes of freight point to point. The Wider Region Transportation Study (WRTS) which is one of the 2 technical studies that underlie the RLTS, noted however, that rail is often not suited for the carriage of freight if it involves multiple handling and short haulage distances.

The study also indicates that the loss of the Napier to Gisborne rail would not in the short to medium term result in a great increase in Heavy Commercial Vehicle (HCV) trips on State Highway No 2, as current volumes of freight would require between  2-3 additional movements by truck a day. The WRTS did however identify that this could change if a timber processing mill was established in Gisborne, as this could generate substantial additional container traffic between Gisborne and the Port of Napier i.e. the number of containers coming south to the Port of Napier for export could increase – note such freight could equally move north by road to the Port of Tauranga from Gisborne.

If that freight were carried by road then an estimated additional 40 HCV movements a day may occur on the route.

This volume of containers might equally provide the opportunity for the line to become economic to operate for KiwiRail.

At this time though, the WRTS noted that there is no firm commitment to build an additional timber processing plant in Gisborne, this meaning that much of the timber is likely to be exported as logs through the Port of Gisborne.

The future of the line to Gisborne is therefore likely to be decided on KiwiRail’s ability to grow the volume of freight carried by rail in the short to medium term, so as to justify in economic terms, the cost of restitution of the line and its continued operation and the carrying out of necessary deferred maintenance.

KiwiRail, prior to the lines recent closure due to storm damage, had increased the freight volumes being carried quite substantially and the line was on track to achieve a better financial outcome for KiwiRail than it had in recent times (potentially reach the breakeven point).

Ultimately the lines future is in KiwiRail’s hands and those of the Government due to the present one-off costs involved in line repair and the need longer term to cover the ongoing maintenance of the line, a catch-up on deferred maintenance and the cost of operation of trains on the line.

With respect to the development of an “inland port”, the RLTS already recognises, albeit in a slightly modified form, the need to investigate, and if appropriate, develop a freight distribution centre at Whakatu. This was proposed in the HPTS 2012 as a project that could be undertaken by interested parties (e.g. industry or the PONL) in the 2012-2017 period and is now shown in the programme contained within the RLTS for future action. 

Any freight distribution centre does need careful assessment as stated in the HPTS. The HPTS identified that the operation of more trains (sufficient in freight carriage terms to lower the number of current HCV movements and handle the predicted growth in freight trips of 20-25% over the life of the RLTS) between Whakatu and the port at Napier, will have quite significant impacts on the road transport network (around the Napier CBD in particular), due to the many rail crossings that exist along the route.

The HPTS identified that there would be substantial costs to overcome these impacts at a minimum of 3 significant crossing points, close to the Napier CBD and lesser costs at other crossings along the route. 

This aspect, according to the HPTS, needs to be carefully considered against any benefits that may arise from shifting more freight to the port on rail through the establishment of a freight distribution centre at Whakatu.

The issue of whether a move from rail to road freight would increase costs and harm the Gisborne economy (and by inference our economy) is not as clear as the submission suggests. The Gisborne District report which the submission appears to be relying upon to make these types of statements, only identifies these factors as risks or potential consequences. It also states in appendix 1 (this contains local analytical data as opposed to the desktop reviews of overseas studies referenced) the following;

“Important to note however is that the Gisborne District Council has not quantified any of the potential impacts due to the time permitted to prepare this report”.

The appendix also contains the following statement;

“Freight users have in the past preferred to use road transport ahead of rail due to the comparative flexibility and convenience of road freight.  Road haulage has also been competitive on price.  For a number of years the only way that the rail service has been able to compete with road freight, in terms of pricing, is by operating at a loss.  It has not been possible, based on past volumes to on-charge the full cost of the rail service to the customer”.

Even so it is acknowledged that there is a strong case for the RLTS to support the retention of rail as a freight option between Napier and Gisborne and that the availability of rail as a freight carriage option is highly desirable generally. However that does not require the adoption of a “negative” stance on the carriage of freight by road, as this mode is equally valid and used by many businesses as their best option.  

Recommendation:

That CEAC be thanked for their submission and be advised, based on the comments made, that no change is to be made to the RLTS.

 

 


 

5.      Submitter: Barrie Crabbe

Officer’s Recommendations

The submission expresses support for the broad direction of the strategy. In particular it supports the use of HPMV on selected routes due to their improved efficiency and because they will help to reduce the number of HCV trips on our network; the development of an “inland port” at Whakatu; the construction of the Pakowhai/expressway roundabout; the 4 laning of Prebensen Drive and Ford Road extension; and the use of rail to provide a commuter service from Eskdale to Pakipaki. The submission then raises matters relating to the provision of environmental mitigation on roads (e.g. swales for runoff), raising road user charges for HCV’s, and the wider use of rail in the region. Lastly the submission promotes the installation of a roundabout at the intersection of Meeanee Quay and the expressway incorporating access to the airport.

The use of HPMV on our roads has been mandated by Government.  The use of any particular route is subject to a permitting process managed by territorial authorities and NZTA. The use of these vehicles is intended to improve the economic efficiency of freight movement on roads and the submission has correctly identified the key benefits as stated by Government.

With respect to  the submissions support for the development of an “inland port” at Whakatu, as previously noted for other submissions, the RLTS already recognises, albeit in a slightly modified form, the need to investigate, and if appropriate, develop a freight distribution centre at Whakatu. This was proposed in the HPTS 2012 as a project that could be undertaken by interested parties (e.g. industry or the PONL) in the 2012-2017 period and is now shown in the programme contained within the RLTS for investigation.  Any freight distribution centre does need careful assessment as stated in the HPTS. The HPTS identified that the  operation of more trains (sufficient in freight carriage terms to appreciably lower HCV movements) between Whakatu and the port at Napier, will have quite significant impacts on the road transport network (around the Napier CBD in particular), due to the many rail crossings that exist along the route. The HPTS identified that there would be substantial costs to overcome these impacts at a minimum of 3 significant crossing points (close to the Napier CBD) and lesser costs at other crossings along the route.  This aspect, according to the HPTS, needs to be carefully considered against the benefits that may arise from shifting more freight to the port on rail through the establishment of a freight distribution centre at Whakatu.

The Pakowhai/expressway roundabout has been included in the RLTP for implementation in the first 3 years of the programme and this is supported in the RLTS, which also shows it as a capacity improvement designed to address part of our freight movement problems on the Heretaunga Plains. It is proposed to be undertaken along with the linked but separate development of the Whakatu arterial link which runs from the Napier Road/SH No 2 intersection to the expressway.

Likewise, the Prebensen drive/Ford Road extension has been included in the RLTP for early implementation as part of the regions solutions to long standing freight movement problems on the Heretaunga Plains and to the Port of Napier.

The development of a rail commuter service was investigated as part of the HPTS 2012. This study concluded that a commuter service as is suggested by the submission would not be economically or practically viable. The line is not located for easy commuter access nor are there sufficient commuter facilities along the route to generate sufficient patronage to justify the considerable capital cost of setting up a service and operating it to modern standards.

Environmental mitigation is always undertaken when new routes are developed. This is required under the Resource Management Act 1991. Stormwater, noise, and air emissions are appropriately considered and determined through that process. The RLTS therefore does not involve detailed provisions relating to such matters; rather it provides a broad framework to consider the environmental consequences of transport as a whole and encourages use of transport methods which aim, at a structural level, to reduce such effects (e.g. moving people to walking and cycling rather than using private motor vehicles).

The submission promotes the view that roaduser charges should be raised for HCV’s. This is a matter outside of the RLTS. Roaduser policy and charges are set by Government and are based around the impact of such vehicles on roads. In principle the user charges already recover the costs of the operation of such vehicles on our roads.

The installation of a roundabout at the intersection of Meeanee Quay and the expressway and the incorporation of the airport access, is not currently included in the RLTP. The need for such a work has not been considered by the RTC at this time. However, given the projected growth of the airport, NZTA are continuing discussions to resolve ongoing access issues in this vicinity, which may resolve in the longer term the problems identified in the submission. Ultimately it is for NZTA and Napier City Council (as the responsible AO) to evaluate whether a roundabout at that location is necessary and to propose it for inclusion in the RLTP first.

Recommendation:

That Mr Crabbe be thanked for his submission and be advised, that based on the comments made, no change is to be made to the RLTS.

 

 


 

6.      Submitter: Port of Napier Ltd

Officer’s Recommendations

The submission supports the strategy and the programme contained in the document. It states that the strategy represents the collective “voice” of the region to the provision of key infrastructure needed to future proof our network and support our economy. 

The submission focuses on the need for our region to construct the key or top projects identified in the RLTP, including the 4 laning of Prebensen Drive and Ford Road extension, the at-grade roundabout at the intersection of Pakowhai Road and the expressway and the Napier Road/SH No2 intersection  to expressway link known as the Whakatu arterial.

These works are all included in the strategy and RLTP and are consistent with our approach to undertake key capacity improvements on our network to deal with current and future freight demands.

Recommendation:

That Mr Cowie and the Port of Napier Limited be thanked for the submission and support and be advised, based on the comments made,  that there is no need to make a change the RLTS.

 

 


 

7.      Submitter: Hawke’s Bay Chamber of Commerce

Officer’s Recommendations

The submission, in the main, supports the strategy and RLTP. The submission commends the strategy for the clear focus on providing infrastructure to support the region’s economy. In particular the submission supports the use of “R” funds to support the 3 key projects of Prebensen Drive/Ford Road extension, the Whakatu arterial and the roundabout at the intersection of the expressway and Pakowhai Road.

The submission also seeks clarification on where the upgrading of SH No 2 north and south of the Heretaunga Plains for HPMV operation sits within the strategy and programme.

Reference is then made to rail and what the Chamber sees as the strategic importance of the link to Gisborne. Lastly the submission indicates that there is a need to factor in access to/from the airport, given the likely future expansion of travellers and freight through the airport. 

Both the strategy and the RLTP support the key projects identified in this submission and do so on the basis of promoting the growth of our region’s economy. 

HPMV are covered in the strategy in section 4.4.4.1. This section identifies that SH No 5 is now HPMV capable. It also indicates the key barriers to HPMV operations on SH No 2 south and north of the Heretaunga Plains. 

The route south is currently restricted by the capacity of the bridge over the Tukituki River at Waipukurau and the much more problematic Manawatu Gorge route.

The bridge at Waipukurau was proposed for HPMV upgrade in the Wider Region Transportation Study (WRTS), but is presently not programmed in either the RLTS or RLTP for specific HPMV investigation / upgrade. This is because the WRTS indicated the most likely demand for HPMV was dependant on the Ruataniwha irrigation project going ahead and /or the resolution of the Manawatu Gorge issues in the first instance. Neither of these is likely to impact in the short term.

Likewise the route to the north was evaluated for HPMV in the WRTS and the bridge at Putorino identified as a probable barrier. This has also been left out of the RLTS /RLTP. This was because there are numerous other “local” structures identified in the WRTS as needing upgrade/replacement for HPMV to operate on this route (forestry was seen as the likely user) and this was seen as a longer term issue which was subject to funding becoming available.

As the region has limited funds over the next 10 or so years and these are focussed on the development of the 3 key freight routes on the Heretaunga Plains, no provision has been included in the RLTP for these. However, it may be appropriate to include likely HPMV projects in the summary programme (medium term 2018-2026 or long term 2027-2046) contained in the RLTS. This might better reflect the TAG submission relating to targets.

The section dealing with rail mostly reflects the advice provided by KiwiRail to the consultant who prepared the WRTS or directly to the RTC via the regional manager for KiwiRail. The rail line to Gisborne is seen as a strategic link in our transport infrastructure and the RTC has publicly stated this and supported the retention of the line long term.  This position could be re-stated in the strategy; however it could not bind KiwiRail to maintaining the line, if KiwiRail deemed it to be uneconomic to do so. As such it would simply repeat the committees already known position.

The airport is recognised as a generator of trips on our transport network. The issue of managing the access point from/to SH No 2 is the responsibility of NZTA. Given the projected growth at the airport, NZTA intend to continue discussions with the Airport to resolve any ongoing access issues. Provision to undertake investigations have been made in NZTA’s long term programme.

Recommendation:

That the Hawke’s Bay Chamber of Commerce be thanked for the submission and support and be advised, based on the comments made, that the RLTS is to be modified to include reference to HPMV in the targets section.

 

 

8.      Submitter: HB Fruitgrowers Association

Officer’s Recommendations

The submission fully supports the strategy and RLTP as they stand.  The submission acknowledges past consultation with them on what is required and supports the projects and funding sources identified in the RLTS/RLTP.

The comments of support from the submitter are noted and appreciated.

Recommendation:

That the Hawke’s Bay Fruitgrowers Association be thanked for the submission and support but be advised that no change is to be made to the RLTS or RLTP.

 

 


 

9.      Submitter: Dr R Gwynn

Officer’s Recommendations

The submission extensively discusses the issue of fuel price forecasts in the RLTS on the basis that such forecasts would indicate that the price of fuel is likely to rise and that this will influence the future form of our transport network (i.e. our network should be based on a presumption that there will be fewer not more private motor vehicle trips and that rail provides the best alternative).

The submission then discusses in some detail the future of rail in our region and strongly advocates for the retention of the Napier to Gisborne line.

The strategy does not include forecasts of the price of energy. The submission put the view forward that it should. This matter was discussed at the RTC when the draft was considered for adoption for consultation. The submission traverses the discussion points made at that time. However this type of forecast was not included.

The strategy has not ignored this issue as suggested in the submission, rather the strategy contains a range of solutions for transport based on the understanding that energy supply and cost volatility will have impacts on the ongoing role of private motor vehicles on our network, the carriage of freight and the need to strengthen other modes over time.

Travel demand initiatives and corridor studies are recognised as key tools which will be used to identify and evaluate whether other modes and solutions are necessary and effective. Walking, cycling, increased public transport services, the use of rail for freight and the evaluation of a freight distribution centre at Whakatu are part of those activities. This approach would likely not be altered even if fuel price forecasts were included in the strategy.

At the same time, the strategy acknowledges that there will be an ongoing and most likely continuing significant role for private motor vehicles throughout the period of the strategy. While many will debate this, there are a number of important documents which have been developed, which we should take cognisance of. 

The statements in the strategy which the submission has questioned, were drawn from the analysis contained in the “Land River Us” Futures document (p.83) produced by the Hawke’s Bay Regional Council and the analysis undertaken for the HPTS 2012. The futures document contained a detailed analysis of technology changes looking out over the next 50 years. The analysis was produced using inputs from experts in transport across national and international boundaries (e.g. Nature 2008, Volvo Group Global 2010, and Economist).

The HPTS 2012 also included investigation of future vehicle use and ownership, by the consultancy undertaking the study, using international and national information sources (GHD who undertook the HPTS 2012 is an international consultancy that provides specialist services in the fields of public transport and in particular rail and light rail systems).

The submission appears in parts to mix issues around freight carriage and private motor vehicle use.  The strategy is clear insofar as it indicates that while the use of private motor vehicles is likely to increase throughout the period of the strategy; this is not of major concern in terms of the operation of our network.

It indicates (based on the findings of the HPTS) that commuter congestion is limited, as no parts of our network are likely to suffer such congestion other than on a few links at peak times. With the use of TDM and corridor studies, these “level of service” issues can be largely addressed.

In that respect HDC are already investing in TDM initiatives to manage “peak hour congestion” on the Havelock-Hastings road link, while it is proposed to undertake similar investigations for parts of Kennedy Road in Napier.  At other locations where levels of service will decline, local area traffic management adjustments are all that is required to address predicted problems. In essence the strategy recognises that commuter type congestion is minimal and can, for the most part, be managed over the term of the strategy without significant investments in the capacity of our road network.

The submission also appears to suggest that rail would be an alternative to private motor vehicles. The HPTS showed that this is not the case, the costs of using rail to handle commuter demand are very high and the economic return from such investments, low (BCR 1>). The rail line as it presently stands is also assessed as being poorly located to service future commuter demand, even if a decision were made to develop rail passenger services based on existing lines in the region.

As noted in responses to earlier submissions, the RLTS does identify an ongoing future role for rail in the carriage of freight and proposes investigations into the establishment of a freight distribution centre to support this.

It also acknowledges that rail can have fewer impacts on the environment and is an efficient means of shifting high volumes of freight, point to point. The Wider Region Transportation Study (WRTS) which is one of the 2 technical studies that underlie the RLTS noted however, that rail is often not suited for the carriage of freight if it involves multiple handling and short haulage distances.

In terms of the future of the Napier-Gisborne rail line, the WRTS study indicates that the loss of the line would not in the short to medium term result in a great increase in Heavy Commercial Vehicle (HCV) trips on State Highway No 2, as current volumes of freight would require between  2-3 additional movements by truck a day.

The WRTS did however identify that this could change if a timber processing mill was established in Gisborne, as this could generate substantial additional container traffic between Gisborne and the Port of Napier i.e. the number of containers coming south to the Port of Napier for export could increase – note such freight could equally move north by road to the Port of Tauranga from Gisborne.

If that freight were carried by road then an estimated additional 40 HCV movements a day may occur on the route. This volume of containers might equally provide the opportunity for the line to become fully economic to operate for KiwiRail.

At this time though, the WRTS noted that there is no firm commitment to build an additional timber processing plant in Gisborne, this meaning that much of the timber is likely to be exported as logs through the Port of Gisborne.

The future of the line to Gisborne is therefore likely to be decided on KiwiRail’s ability to grow the volume of freight carried by rail in the short to medium term, so as to justify in economic terms, the cost of restitution of the line and its continued operation and the carrying out of necessary deferred maintenance.

Movements in the price of fuel as the submission states will occur, would also support rail as a longer term freight transport option between Napier and Gisborne over road in any event.

KiwiRail, prior to the lines recent closure due to storm damage, had increased the freight volumes being carried quite substantially and the line was on track to achieve a better financial outcome for KiwiRail than it had in recent times (potentially reach the breakeven point operationally).

Ultimately the lines future is in KiwiRail’s hands and those of the Government due to the present one off costs involved in line repair and the need longer term to cover the ongoing maintenance of the line, a catch-up on deferred maintenance and the cost of operation of trains on the line.

Recommendation:

That Dr Gwynn be thanked for his submission and the committee determine whether it wishes to include forecasts of future fuel costs in the strategy and a more detailed analysis on how this factor may affect future transport in our region.

 

 

10.    Submitter: Mr David Webster

Officer’s Recommendations

The submission raises the retention of the Palmerston North-Napier-Gisborne rail line and asks whether the RLTS / RLTP have struck the “right” balance between road and rail. It then discusses how best to utilise the line (mainly the Napier to Gisborne section) and in particular suggests carrying more forestry product and increasing the tourist use.

The submission suggests that the rail line from Palmerston North to Napier is vital to our region and the line north from Napier to Gisborne highly desirable. This is agreed.

The strategy includes discussions on rail, its current role and future services. It also discusses other transport, including resolving the long standing impacts of HCV/HPMV on our roads, as these are causing community concerns especially in residential areas and other tourism and tourist accommodation areas such as the Marine Parade.

In terms of funding, the RTC has responsibilities for the allocation of funds for roading infrastructure not rail. It is therefore difficult for the RTC to directly influence decisions on rail as compared to road.

However, the strategy has still retained a sound focus on the role of rail and recognises rails role in the carriage of freight. It acknowledges that rail can have fewer impacts on the environment and is an efficient means of shifting high volumes of freight point to point.

The strategy, on the basis of the findings of Wider Region Transportation Study (WRTS) which is one of the 2 technical studies that underlie the RLTS, notes however, that rail is often not suited for the carriage of freight if it involves multiple handling and short haulage distances.

With respect to the future of the Gisborne line, the WRTS indicated that the loss of the Napier to Gisborne rail would not in the short to medium term result in a great increase in Heavy Commercial Vehicle (HCV) trips on State Highway No 2, as current volumes of freight carried by rail would only require 2-3 additional movements by truck a day. The WRTS did however identify that this could change if a timber processing mill was established in Gisborne, as this could generate substantial additional container traffic between Gisborne and the Port of Napier i.e. the number of containers coming south to the Port of Napier for export could increase – note such freight could equally be moved north by road to the Port of Tauranga.

If that freight were carried by road south, then an estimated additional 40 HCV movements a day may occur on the route. This volume of containers might equally provide the opportunity for the line to become economic to operate for KiwiRail. At this time though, the WRTS noted that there is no firm commitment to build an additional timber processing plant in Gisborne, this meaning that much of the timber is likely to be exported as logs through the Port of Gisborne in the meantime.

The future of the line to Gisborne is therefore likely to be decided by KiwiRail’s ability to grow the volume of freight carried by rail in the short to medium term, so as to justify in economic terms, the cost of restitution of the line and its continued operation and the carrying out of necessary deferred maintenance.

KiwiRail, prior to the lines recent closure due to storm damage, had increased the freight volumes being carried quite substantially and the line was on track to achieve a better financial outcome for KiwiRail than it had in recent times (potentially reach the breakeven point).

Ultimately the lines future is in KiwiRail’s hands and those of the Government due to the present one off costs involved in line repair and the need longer term to cover the ongoing maintenance of the line, a catch-up on deferred maintenance and the cost of operation of trains on the line.

Recommendation:

That Mr David Webster be thanked for his submission but be advised that no change is to be made to the RLTS.

 

 

11.    Submitter: Transport Advisory Group (TAG)

Officer’s Recommendations

This submission seeks RTC approval to make editorial changes; suggested changes as part of the Auditor’s feedback; and introduce a revised targets and measures section into the document.

Background comments and need for the suggested changes are noted.

Recommendation:

That the RTC agree to all necessary editorial and formatting changes being made to the document; and following the TAG presentation on the targets and measures this revised section be inserted into the final RLTS.

 

 


 

12.    Submitter: Mr M Kirkwood

Officer’s Recommendations

This submission raises issues relating to the scope of the RLTS and Government influence on the form of a strategy; the need to have a greater focus on integration of transport and in particular the use of rail; the future cost of fuel for road transport versus rail; the need for “rail hubs”, the need for rail to be commercially viable at the same time; the impacts of HCV and future HPMV on local roads/motorists/communities; and the promotion of cycling and cycleways. The work of Napier and Hastings and the Regional Council in this area is supported.

Broadly the RLTS scope meets the various legislative requirements which it must address. The submission suggests that the strategy is unduly affected by restraints imposed by Government. This may well be correct insofar as the law sets out the general purpose and content of these types of documents. While this may be perceived as inappropriate in the submission, as a major funder of transport, Government is entitled to require what it sees as appropriate performance and policy outcomes.

The strategy has a focus on integration within it. Rail has a recognised role in the carriage of freight. The strategy already acknowledges that rail can have fewer impacts on the environment and is an efficient means of shifting high volumes of freight point to point. The strategy, on the basis of the findings of Wider Region Transportation Study (WRTS), which is one of the 2 technical studies that underlie the RLTS, notes however, that rail is often not suited for the carriage of freight if it involves multiple handling and short haulage distances.

With respect to the future cost of fuel for road versus rail, this equation will play out over time and be reflected in the relative cost competitiveness of each mode and the consequent ability to attract customers. In that regard there are other factors that favour rail or road in any given circumstance, and these along with cost, are best assessed by the provider and user at the time through normal market mechanisms. 

With respect to  the submissions support for “rail hubs” at Whakatu, as previously noted for other submissions, the RLTS already recognises, albeit in a slightly modified form, the need to investigate, and if appropriate, develop a freight distribution centre at Whakatu. This was proposed in the HPTS 2012 as a project that could be undertaken by interested parties (e.g. industry or the PONL) in the 2012-2017 period and is now shown in the programme contained within the RLTS for investigation. 

Any freight distribution centre does need careful assessment as stated in the HPTS. The HPTS identified that the  operation of more trains (sufficient in freight carriage terms to appreciably lower HCV movements) between Whakatu and the port at Napier, will have quite significant impacts on the road transport network (around the Napier CBD in particular), due to the many rail crossings that exist along the route.

The HPTS identified that there would be substantial costs to overcome these impacts at a minimum of 3 significant crossing points (close to the Napier CBD) and lesser costs at other crossings along the route.  This aspect, according to the HPTS, needs to be carefully considered against the benefits that may arise from shifting more freight to the port on rail through the establishment of a freight distribution centre at Whakatu.

The development of rail hubs at other locations has not been evaluated, although the WRTS did consider a facility to service forestry in the Wairoa area. If such facilities are to proceed, the economics of the rail hubs operation would need to be competitive with other options. If such hubs do work then the strategy would not prevent such options from being developed.

HCV and HPMV can impact on other road users and communities.  The introduction of HPMV by Government, is however, intended (along with a range of other benefits) to assist in reducing such impacts by enabling the carriage of equivalent freight volumes on road by fewer vehicles. Locally this is shown (refer to comments in Panpac submission) by a reduction in the number of vehicles carrying product from the Panpac Mill to the Port of Napier, since HPMV permits were granted to the Company for that route. 

The strategy has a focus on walking and cycling in terms of Travel Demand Measures (TDM) responses to managing our transport network. Recreational cycling is part of that equation as it places cycling in the public eye and by association promotes it as an activity not just for recreation, but also as an alternative mode for journeys to work.

Recommendation:

That Mr M Kirkwood be thanked for the submission and support for the cycling initiatives of Hastings, Napier and the Regional Council but that no change is to be made to the RLTS or RLTP.

 

 


 

13.    Submitter: Karamu Enhancement Group

Officer’s Recommendations

This submission is generally supportive of the approach of the RLTS to walking and cycling. It sets out what the submission identifies as the key benefits of these activities and some issues relating to proximity of HCV/HPMV to walking and cycling pathways. It then goes on to suggest a tool  for  promoting and marketing these facilities as follows;

“That the cycleways and walkways already established and those being developed be part of Tourism Hawke’s Bay and other local regional council’s publications and promotions. That certain walkways and cycleways be suggested for possible specific purposes – suitable for pushing a pram, riding a bike over ‘challenging’ stretches of specific stretches, river walks”. 

 

The location of walkways and cycling paths on the road network is determined by the responsible Approved Organisation (AO) in accordance with national design guidelines. Where they are off road the location is often determined by the type and function of the public space through which they are passing.

While the strategy can provide support for the provision of cycleways, the specific location and design of such facilities is not generally a matter which the strategy is designed to deal with.

Again, the concept of using these facilities in the promotion of tourism is not directly a matter for the strategy, even if it is a sound idea.  For those reasons, this matter could be passed by the RTC to the regional tourism organisation to follow up on.

The Hawke’s Bay Regional Council will be producing a Regional Cycling Strategy during 2012, some of the comments made by the submitter could be taken into account in the development of that Strategy.

Recommendation:

That the Karamu Enhancement Group be thanked for the submission and support for the strategies approach to cycling activities and current cycling initiatives in the region, but be advised that no change is to be made to the RLTS.

 

 


 

14.    Submitter: Hawke’s Bay District Health Board

Officer’s Recommendations

The submission seeks a wording change for the aim dealing with public health and the inclusion of the term “equity” along with an explanation in our principles section.

The submission seeks the use of following wording to represent the public health aim of the strategy; “a transport network that promotes safe active and healthy methods to get around.”

The current wording is “opportunities are provided for us to use active and healthy methods to get around.” 

The current wording was adopted by the RTC following its consideration of a number of reports addressing the aims to be included in the strategy. The proposed changes introduce “safety” and the idea of “promoting” to the aim. Safety is however already addressed under its own aim which deals with “safety and personal security” so this change seems unnecessary and a duplication.

The notion of “promoting” as opposed to the current approach of “providing opportunities”, seems on the surface of it, to be a more passive approach and less desirable if we are to pursue model shift through the strategy i.e. a shift from using private motor vehicles for trips to walking and cycling. 

The principles section in the strategy follows the direction contained in the GPS and IRS for transport.  Neither of these documents refer to equity as a guiding principle for transport investment by the Government.

That is not to say that equity issues as explained in the submission are not considered already. Where they are taken account of is in the processes used to consider transport projects and investments in public transport services.  Effects on landuses, land values, congestion, crashes, pollution, and cost of movement are all considered.

Public transport has long been targeted to assist those who are “transport disadvantaged” as well as social and general users. The public transport plan recognises these issues and schemes such as the Total Mobility Scheme (TMS) which provides a subsidised taxi service to people who do not have access, due to a health disability, to private motor vehicles and normal public transport services. 

Given this background, it would be more relevant to discuss “equity” under one of the existing and most suited aims of the strategy.

 

Recommendation:

That the Hawke’s Bay District Health Board  be thanked for the submission and be advised, based on the comments made, that a) no change is to be made to the aim for public health and b) that reference to “equity” issues will be included in the explanation of the aim for “Access and Mobility” in the RLTS.

 

 

15.    Submitter: Ngati Kahungunu Iwi Incorporated

Officer’s Recommendations

This submission raises issues related to the need for the strategy to use correct information relating to growth; the potential impact on development of Maori lands; the need for ongoing engagement with Maori over such things as wahi tapu; insufficient consideration of rail freight options, safety issues associated with HCV and HPMV; costs of network improvements to cater for HPMV; and increased emissions and effects on health and safety.

It is agreed that the strategy needs some further refinement with regard to the aims and their relationship to policies and targets. It is intended that these changes will be presented as part of the hearing of submissions for consideration of the RTC.  These changes should help address the concern raised in this submission.

The growth projections used for the strategy have been sourced from official publications/statistics, formally adopted strategies and one off research papers. Profiles of current and future population and households were drawn from the Heretaunga Plains Urban Development Strategy (HPUDS) and a research paper written prepared for the Regional Council by the University of Waikato National Institute of Demographic and Economic Analysis.

Forecasts used in the profiling of production were drawn from Statistics NZ publications and industry sector research publications (i.e. national representative organisations state of industry forecasts). While it is agreed that various industries suffer from cyclical economic changes, and that under performance in some sectors is evident at this time, due to the international financial crisis, the medium and long term forecasts used remain the most reliable formally produced information available.

The strategy may have indirect impacts on Maori land development opportunities, as identified in the submission. However, no proposals for new works can proceed simply on the basis of inclusion in the strategy or the RLTP. All projects have to satisfy other legislative requirements which are designed to investigate and decide on the detail of any work, including whether it should proceed at all. These include the RMA 1991.

When any project is progressed by the responsible Approved Organisation (AO) appropriate consultation will undoubtedly occur as a matter of best practice. Under the RMA 1991 consultation is built into the process as a legal requirement in any event. This will enable proper consideration of matters such as wahi tapu sites.

The strategy does have a focus on integration. Rail has a recognised role in the carriage of freight. The strategy already acknowledges that rail can have fewer impacts on the environment and is an efficient means of shifting high volumes of freight point to point. The strategy, on the basis of the findings of the Wider Region Transportation Study (WRTS) which is one of the 2 technical studies that underlie the RLTS, notes however, that rail is often not suited for the carriage of freight if it involves multiple handling and short haulage distances.

The RLTS also recognises, albeit in a slightly modified form, the need to investigate, and if appropriate, develop a freight distribution centre at Whakatu. This was proposed in the HPTS 2012 as a project that could be undertaken by interested parties (e.g. industry or the PONL) in the 2012-2017 period and is now shown in the programme contained within the RLTS for investigation. 

The Government, when it introduced the permit system for HPM, published an assessment of the safety, economics and environmental outcomes which would arise from the operation of such vehicles. This showed that these vehicles would be safer than existing HCVs generally because they would be built to stricter safety standards. It also indicated that HPMV would further assist safety outcomes by reducing the number of trips required to haul a given volume of freight by road. At the same time the Governments assessment indicated they would generate significant energy and cost savings and consequently be more efficient and reduce the level of emissions comparative to using current HCV. Likewise the effects on health were expected to be reduced.

This assessment also reviewed the anticipated costs of required improvements to the network to enable HPMV operations. In brief it showed that the costs were far outweighed by the economic, safety and environmental gains forecast, this creating a significant net national gain for our country. The strategy recognises these potential gains by supporting the use of HPMV where there is an appropriate route available or can be made available.

Recommendation:

That Ngati Kahungunu Iwi Incorporated be thanked for the submission but be advised that no change is to be made to the RLTS.

 

 


 

16.    Submitter: Central Hawke’s Bay District Council

Officer’s Recommendations

This submission generally supports the key projects identified in the RLTS/RLTP which are proposed to improve access to processing industry and the port. The submission then outlines the role of SH No 2 through Central Hawke’s Bay and asked that this be recognised by re-prioritising 2 safety projects on the state highway. One is the College Road to Silverstream passing lanes and the other the Te Mahanga south bound passing lanes.

The key projects contained in the RLTP/RLTS are all focussed on the need to address long standing freight carriage problems by facilitating better access for producers to processing industry (at Tomoana Whakatu) and/or for finished product to move to the Port at Napier. The 3 key projects to be “R” funded all fall into this economic development category, although they do address environmental and a number of safety related issues as well.

The RLTP was subject to extensive discussion with all Councils having opportunities to put forward projects for consideration both at the TAG and the RTC. The passing lanes identified in the submission were put forward by NZTA as part of those processes and have been included in the programme. Available “R” funds will not however cover these works in the next 3 year period.

Recommendation:

That CHBDC be thanked for their submission but be advised that no change is to be made the RLTS or RLTP

 

 


 

17.    Submitter: Panpac

Officer’s Recommendations

This submission supports the RLTS and notes that the issues and challenges identified have been derived from a thorough process. The submission states that the vision and aims will help future proof our regions transport network. In particular the submission strongly supports opening of more routes up to HPMV and prioritising any necessary works to achieve this. 

This strategy acknowledges the benefits of HPMV to our region’s economy and it supports extending the number of routes available for HPMV, subject to funding and suitability of the route.

It identifies issues on the network that need to be resolved to enable HPMV, especially major structures that need upgrading as a key issue for us to address.

However, with the current funding limitations for our region, a number of HPMV improvements will need to await further funding becoming available, either specifically for HPMV works or in conjunction with other necessary works.

The RLTP for instance, allows for seismic upgrade works to be undertaken on a number of structures over the next 3 years, and this work should allow associated HPMV needs to be addressed at the same time. 

 

Recommendation:

That Panpac be thanked for their submission and be advised, based on the comments made, that the RLTS is to be modified to include reference to HPMV in the targets section.

 


 

18.    Submitter:  Audrey Jones

Officer’s Recommendations

The submission asks that State Highway No 38 between Wairoa and Lake Waikaremoana be sealed.  The submission suggests that there are no plans for improvements to those parts of the region to the north of Napier. (please read in conjunction with submissions 23,27,and 28)

 

 

The sealing of State Highway No 38 has at various times been prioritised and at others given much less priority. Previous “commitments” by Government to seal the route have not been delivered on. Many reasons exist for this.

Given the low Investment and Revenue Strategy (IRS) profile (used to support funding applications), it was accepted by the RTC when preparing the draft RLTP that this project was unlikely to proceed in the short to medium term (next 10 years).  In addition, NZTA who are responsible for the State Highway, did not see it as a priority over the next 10 year RLTP period. Consequently the project is not shown in the RLTP.

It is possible however to include this project in the summary programme in the RLTS. However, there are many worthwhile projects that are not included in this summary. To include them all would involve creating what might become a prohibitively long list of projects.

Also the importance of the projects which are currently listed could potentially be lost in the detail. Lastly as these extra projects have not been previously ranked by the RTC this could potentially create confusion as to their importance and timing for the region as a whole.

While the current RLTP does not promote any major new projects in the northern part of our region, it must be remembered that of the original approximately $75m of “R” funds available here, the Matahorua Gorge deviation as part of the last RLTP, has already taken over $25m or around 1/3rd of the total funds available. Right from the outside the RTC agreed that the works now being promoted represented the “share” of the fund to be allocated to upgrades to the network on the Heretaunga Plains. These works are currently costed at requiring around $23m of the “R” funds.

 

Recommendation:

That Audrey Jones be thanked for his submission and be advised, based on the comments made, that no change is to be made to the RLTS or RLTP.

 

 

19.    Submitter: New Zealand Transport Agency

Officer’s Recommendations

The submission supports the overall direction of the strategy insofar as it has an appropriate focus on economic development, safety and greater network optimisation. It also notes that the strategy has a focus on TDM initiatives and on cycling and walking. It asks for more detail to be provided around corridor management studies and notes that NZTA want the region to take a “one network” approach regardless of ownership of various parts of the road network, and for this to be recognised in the strategy. Lastly NZTA suggest that the “About us” and “Our future” sections should precede the strategy sections so as to better contextualise the “solutions”, these including the yet to be finalised “targets”. 

The submission has raised two key points for consideration, whether there should be (if information is available at this time) more detail provided around corridor studies and a reference to a “one network” approach in the strategy.  If there is more information available relating to corridor studies then it would be appropriate to include this in the strategy, especially  where it is directly relevant to the aims of the strategy and would actively helps us to achieve them.

With respect to including reference to a “one network” plan approach, this could easily be done. However the term is “new” and needs to be better understood in terms of its implications for all Approved Organisations (AO’s).

In principle, the concept of a “one network” approach is logical and would seem to follow what is essentially done now.  Examples of the approach are the way various agencies combined to deliver the HPTS and WRTS, which are foundation documents for this strategy.

A benefit of taking this approach across all transport functions would potentially be better implementation and coordination of projects. If that is indeed the case then it could well be reasonable and desirable for the strategy to promote the formal adoption this methodology. The last point made by NZTA would help to make the document flow more logically if the RTC agrees to the change.

Recommendation:

That NZTA be thanked for their submission and be advised, based on the comments made, that the RLTS is to be modified to include further reference to corridor studies where suitable information is available; will include appropriate reference to investigating and implementing a “one network” approach within the region with wording provided by NZTA; and if found appropriate by the RTC to move the sections highlighted in the submission.

 


 

20.    Submitter:  Ted Hill

Officer’s Recommendations

The submission suggests that the closure of the Gisborne rail line provides an opportunity to convert the rail line through Napier and Hastings to other uses, for instance an alternative truck route to avoid the Marine Parade. 

The submission then suggests that the region needs a contingency plan to deal with failures on key roads in and out of our region and cites the closure of the Manawatu Gorge as an example. The submission specifically identifies the Mohaka Bridge as another such risk.

The submission then questions current financial planning for public transport (PT) services citing “empty” 30/40 seater buses running around and an inability to match “foot volumes” with seating. It suggests instead that aerial cableways would be a better option on routes such as to Flaxmere / Havelock / Marewa / Taradale / the port.

The Gisborne to Napier railway line is currently not operating due to storm damage. This line does not include the sections of line referred to in the submission (through Hastings and Napier). As such the suggestion to convert these sections to an alternative road for freight vehicle (to avoid the Marine Parade) is improbable as there is no likelihood of its closure.

The line from Napier south is well utilised and economic for KiwiRail. It provides a vital link for freight heading south out of our region and connects us with the central north island and the main north island trunk railway system.

Through “lifeline” strategies, our region has response plans to deal with any failures of key infrastructure. These lifeline strategies identify how we would respond. It is quite true that the failure of some components (e.g. the Mohaka bridge) would have greater consequences than others.

Contingency planning on an ongoing basis also ensures that failures are minimised while at the same time identifying what an appropriate response should be if a failure occurs. The reality is however, that you cannot failure proof any link on an absolute basis.  To try to do so would also be very expensive and result in over investment in many situations.

Improved (PT) bus services have greatly increased patronage levels over the last few years and on that basis estimates of future patronage levels and costs have been completed. While it can appear that buses run at times with few passengers being carried, the Hawke’s Bay Regional Council has a policy (contained in its Regional Public Transport Plan) to provide services that “Ensure the appropriate size bus is used on each service by catering for peak loadings at the service peak time”. Availability of a service is important to stimulate and accommodation growth and peak loadings although this can mean buses appear under-used.

The suggestion that aerial “skyways” should be introduced as an alternative, while possible and having a number of potential benefits, brings with it a significant and probably prohibitive start up cost. Such systems are expensive to develop as an alternative to an existing public transport services (with all its existing investment) and funding would likely have to be found entirely locally.

 

Recommendation:

That Ted Hill be thanked for his submission and be advised, but based on the comments made, that no change is to be made to the RLTS.

 

 

21.       Submitter:  Les Hewett - Napier Heavy Traffic Community Forum Committee

Officer’s Recommendations

This submission generally expresses support for the assessment contained in the strategy dealing with environmental sustainability. The submission comments on proposals to deal with HCV on our network and a numbers of queries are raised relating to flows, costs and the operation of Prebensen Drive once 4 laned.  Noise originating from expressway traffic is discussed and the submission suggests that the current asphaltic concrete surfaced sections should be extended between the Kennedy road over bridge and the Meeanee Road overbridge as a noise mitigation measure for residents.  The proposed Whakatu Arterial Road appears to be supported although the submission suggests that HCV traffic may need to be “forced” to use it through traffic management measures to prevent the continued use of Farndon Road.  The submission then makes brief comments on the need to retain the Napier to Gisborne rail line.

The HCV and LCV traffic flows quoted in the submission are drawn from the HPTS 2012. The figures represent total HCV and LCV trips across the entire network.  It cannot therefore be assumed that the routes identified in the submission will be subject to these increased flows alone. However the proportionate increase that these figures indicate will occur is applicable. The submissions assumptions of increased HCV and LCV movements on the roads listed, is thus broadly correct.

In addition the strategy’s focus on using the expressway to connect our key freight network together will influence HCV and LCV traffic levels. This key freight route commences with the Whakatu Arterial, links along Pakowhai Road to a new roundabout at the intersection with the expressway, heads north along the expressway and then uses Prebensen Drive to access Onekawa (through the Ford road extension) and  the Port using the 4 laned Prebensen Drive.

This proposal was extensively tested as part of the HPTS 2012. This study was based on a strategic regional modelling process and was undertaken independently by GHD for NZTA, HBRC, NCC and HDC. These works all achieved sound BCR results which indicate that they all result in improved network performance.

Noise (and vibration) effects along the expressway have been long debated, as is noted in the submission.  The use of asphaltic concrete is known to lower noise levels, however it is an expensive (in terms of upfront cost) new surface treatment for existing (and even for new) roads. 

What road surfacing is used by an Approved Organisation (AO) on an existing road as part of road surface maintenance programmes or partial (rather than full rebuilds) upgrades of routes, is more of an operational decision rather than a matter for the strategy. For new roads it is acknowledged that the choice of surface is more open, but is subject to environmental assessment in terms of the RMA 1991 as a route is considered in any case. 

The strategy could, if the RTC was inclined, include some reference to use of noise lowering materials on new routes in the environmental section, although this is again, getting more into design detail rather than strategic considerations. In that respect the current text already gives weight to better management of off road effects and does this in a more strategic and appropriate way (in fact the submission extensively quotes this section and supports the text).

The Whakatu Arterial has, as just one of its roles, the role of capturing heavy traffic which might otherwise find its way onto the coastal route. Farndon Road currently provides direct access to the coastal route for HCV exiting the Tomoana Whakatu industrial areas and it is agreed that the detailed design of any intersection connecting it with the future Whakatu Arterial will need to address this aspect. However this is not a matter for the strategy to address, rather it is a matter for detailed design by HDC.

 The comments made in the submission regarding the retention of the Napier to Gisborne rail line are acknowledged. 

Recommendation:

That Mr Les Hewett - Napier Heavy traffic Community Forum Committee be thanked for the submission and be advised, based on the comments made, that no change is to be made to the RLTS.

 

 


 

22.    Submitter: Jenny Baker

Officer’s Recommendations

The submission requests that the strategy should include, in the issues and challenges section, reference to reducing carbon emissions; uncertainties around oil based fuel and alternative fuels.  It is suggested that environmental sustainability should be added to the principles section, that cycling/walking should be more clearly linked to commuting; ensure education and enforcement include an environmental sustainability focus; and the development of targets dealing with PT trips, vehicle occupancy, and tonnes of carbon emitted, vehicle kilometres travelled, regional fuel sales and percentage of household expenditure on transport.

The submission also expresses support for the PT targets in the strategy and the section on light rail. A number of query/comments are also included. 

The strategy identifies uncertainty about fuel availability as a challenge we face. The text also raises cost and volatility but is not clearly worded and the meaning is lost. It was intended that this challenge state “dealing effectively with uncertainty about fuel availability due to ongoing cost and supply volatility”.

The issues do not contain reference to this matter and it may well be appropriate to include an “issue” statement as a lead in to the above “challenge” statement as follows; “geopolitical events affecting supply, increasing demand from emerging economies and limited sources of oil”

Statements could also be included, if the RTC thought it appropriate, in the issues and challenges relating specifically to reducing carbon emissions as this is already implicit in a number of our interventions and investments (e.g. TDM/corridor studies/PT).

The suggestion to incorporate environmental sustainability into the principles section is not considered necessary as it is already identified as one of the strategies overarching aims. In addition, if the RTC agrees with other suggested changes to the strategy relating to issues, challenges and policies/targets, this will be more than adequately addressed.

With reference to cycling, some adjustments to the text could be made in the “Walking and Cycling” section to place a stronger focus on walking and cycling as a means of managing commuter demand, but it should be noted that this issue is already covered in the section dealing with TDM and it may simply be duplication.

At present education and enforcement is provided mainly as part of targeted funded programmes such as RoadSafe HB and NZ Police activities and in alignment with the Government Safer Journeys approach. It would be difficult to extend the mandate of these organisations to environmental education and probably inappropriate in any event. 

The range of targets suggested need to be considered against our ability to effectively monitor and report against them. In that regard TAG have developed a series of proposed targets for the RTC to consider which meet the criteria of being specific, certain, realistic, achievable and measurable. These do address some of the issues that the submission seeks to cover.

The support for other components of the strategy is acknowledged.  The queries raised can be answered in the cover letter which will accompany the RTC decision on the submission.

Recommendation:

That Jenny Baker  be thanked for her submission and be advised, based on the comments made, that the RLTS is to be modified to include further reference in the issues section to the supply/cost of fuel, reducing carbon emissions, along with a re worded challenge as noted above.

 

 


 

23.    Submitter: Murray Deakin

Officer’s Recommendations

The submission asks that State Highway No 38 between Wairoa and Lake Waikaremoana be sealed. (please read in conjunction with submissions 18, 27 and 28)

 

 

The sealing of State Highway No 38 has at various times been prioritised and at others given much less priority. Previous “commitments” by Government to seal the route have not been delivered on. Many reasons exist for this, some of which include; changes in government funding policy through to a simple lack of funds, the cost of the work compared to the benefits (low BCR) and an apparent lack of interest from the Bay of Plenty to match funding to connect up the route on the eastern side. 

Given the “chequered” history, poor economics  and in the light of the low IRS profile (used to support funding applications), it was accepted by the RTC that this project was unlikely to proceed in the short to medium term (next 10 years).  In addition, NZTA who are responsible for the State Highway, did not see it as a priority over the next 10 year RLTP period. Consequently the project is not shown in the RLTP.

It is possible to include this project in the summary programme in the RLTS. However, there are many worthwhile projects that are not included in this summary, as it would have been necessary to include  a prohibitively extensive number of projects. The importance of the projects which were listed would have potentially been lost in the detail. In addition these extra projects have not been previously ranked by the RTC, so this would have create some confusion as to their importance for the region as a whole.

Recommendation:

That Murray Deakin be thanked for his submission and be advised, based on the comments made, that no change is to be made to the RLTS or RLTP.

 

 


 

24.    Submitter:  Fonterra

Officer’s Recommendations

The submission supports a number of components in the strategy including; the short term focus on completing key components of the freight network; maintenance of road freight routes  generally , the use of alternatives to road such as rail; and the further development of HPMV routes.

The submission then supports initiatives which may help the growth of their industry and expresses a desire to work with the region to manage transport demands arising from this growth and lastly strongly supports investment in new and improved infrastructure for state highways and local roads that contribute to a safer transport network. 

The comments of support from the submitter are noted and appreciated.

Recommendation:

That Fonterra be thanked for the submission, and be advised, based on the comments made, that no change is to be made to the RLTS or RLTP.

 

 

 

25.    Submitter: Wairoa District Council

Officer’s Recommendations

The submission seeks to expand the strategies focus on tourism by inclusion of more information on existing activities and expected future changes. It also suggests that statements around tourism be included in the issues and challenges section. 

The strategy does not contain extensive reference to tourism either in the contextual “About us” and “Our Future” sections or in the more strategy focussed parts.

Tourism is an important element in our regional economy and should be better recognised. Some reference in the issues and challenges section should also be made.

Recommendation:

That Wairoa District Council be thanked for the submission, and be advised, based on the comments made, that changes will be made to the RLTS so as to a) provide information on tourism in the region at present and in the future and b) set out an issue and challenge statement for tourism.

 


 

26.    Submitter:  Federated Farmers

Officer’s Recommendations

The submission promotes the view that discussions around levels of service and the prioritisation of roading should be had in light of the large contribution that farmers pay towards roading in land value rates, road user charges and fuel taxes and the importance of roading to farm inputs and outputs. The submission then supports the high prioritisation of the Whakatu Arterial Link and the Pakowhai and Links Road intersection; the retention of the Napier-Gisborne rail line; the provision of a stock effluent facility between Napier and Wairoa; the inclusion of a discussion in the Strategy around how the rail line fits with the strategic objectives; and the efficient and safe integration of freight transport methods.

The strategy is not designed to prioritise roading on the basis of payment; rather it must follow the criteria set by government for the ranking of projects as set out in the Government Policy Statement (GPS) and in the Investment and Revenue Strategy (IRS) by the New Zealand Transport Agency (NZTA). While the issue is legitimate, determining what might be a fair share of funding by payment is a policy matter for the Government to determine, not this strategy.

The support of the strategy’s focus on developing key arterial freight links is acknowledged, along with the support for building a stock effluent between Napier and Wairoa and the retention of the Napier to Gisborne rail line.

Lastly the strategy has a focus on integration within it. Rail has a recognised role in the carriage of freight. The strategy acknowledges that rail can have fewer impacts on the environment and is an efficient means of shifting high volumes of freight point to point.

The strategy, on the basis of the findings of Wider Region Transportation Study (WRTS) which is one of the 2 technical studies that underlie the RLTS, notes however, that rail is often not suited for the carriage of freight if it involves multiple handling and short haulage distances.

The RLTS also recognises, albeit in a slightly modified form, the need to investigate, and if appropriate, develop a freight distribution centre at Whakatu.

This was proposed in the HPTS 2012 as a project that could be undertaken by interested parties (e.g. industry or the PONL) in the 2012-2017 period and is now shown in the programme contained within the RLTS for investigation. 

Horizons Regional Council have signalled they are well underway to designing a stock effluent facility near Woodville. As there is potential for trucks travelling south from Hastings to use this facility the RTC has decided to not include provision for a second stock effluent site at this time.

Recommendation:

That Federated Farmers be thanked for the submission and be advised, based on the comments made, that no change is to be made to the RLTS.

 

27.    Submitter:  Neal Taylor

Officer’s Recommendations

The submission asks that State Highway No 38 between Wairoa and Lake Waikaremoana (a length of approximately 15 kilometres) at Onepoto, be sealed. The submission states that this is the most heavily used section of State highway No 38 still unsealed. (please read in conjunction with submissions 18, 23 and 28)

 

The sealing of State Highway No 38 has at various times been prioritised and at others given much less priority. Previous “commitments” by Government to seal the route have not been delivered on. Many reasons exist for this, some of which include; changes in government funding policy through to a simple lack of funds, the cost of the work compared to the benefits (low BCR) and an apparent lack of interest from the Bay of Plenty to match funding to connect up the route on the eastern side. 

Given the “chequered” history, poor economics and in the light of the low IRS profile (used to support funding applications), it was accepted by the RTC that this project was unlikely to proceed in the short to medium term (next 10 years). 

Importantly, NZTA who are responsible for the State Highway did not see it as a priority over the next 10 year RLTP period. Consequently the project is not shown in the RLTP.

It is possible to include this project in the summary programme in the RLTS. However, there are many worthwhile projects that are not included in this summary, as it would have been necessary to include a prohibitively extensive number of projects. The importance of the projects which were listed would have potentially been lost in the detail. In addition these extra projects have not been previously ranked by the RTC, so this would have create some confusion as to their importance for the region as a whole.

Recommendation:

That Neal Taylor be thanked for his submission, and be advised, based on the comments made, that no change is to be made to the RLTS or RLTP.

 

 


 

28.    Submitter: Colin MacDonald

Officer’s Recommendations

The submission asks that State Highway No 38 between Wairoa and Lake Waikaremoana as far as Onepoto, be sealed. (please read in conjunction with submissions 18, 23 and 27)

 

The sealing of State Highway No 38 has at various times been prioritised and at others given much less priority. Previous “commitments” by Government to seal the route have not been delivered on. Many reasons exist for this, some of which include; changes in government funding policy through to a simple lack of funds, the cost of the work compared to the benefits (low BCR) and an apparent lack of interest from the Bay of Plenty to match funding to connect up the route on the eastern side. 

Given the “chequered” history, poor economics  and in the light of the low IRS profile (used to support funding applications), it was accepted by the RTC that this project was unlikely to proceed in the short to medium term (next 10 years).  In addition, NZTA who are responsible for the State Highway, did not see it as a priority over the next 10 year RLTP period. Consequently the project is not shown in the RLTP.

It is possible however to include this project in the summary programme in the RLTS. However, there are many worthwhile projects that are not included in this summary. To include them all would involve creating what might become a prohibitively long list of projects.

Also the importance of the projects which are currently listed could potentially be lost in the detail. Lastly as these extra projects have not been previously ranked by the RTC and this could potentially create confusion as to their importance and timing for the region as a whole.

Recommendation:

That Colin MacDonald be thanked for his submission and be advised, based on the comments made, that no change is to be made to the RLTS or RLTP.

 


 

29.    Submitter: Richard Barfoot

Officer’s Recommendations

This submission supports the strategy. After outlining concerns about logging traffic using the Marine Parade route to the port, the submission suggests that a right turn control be placed at the Farndon Road intersection with Pakowhai Road to stop HCV traffic heading north along Farndon Road. The submission then supports more use of rail and the retention of the Napier to Gisborne rail line. Lastly a suggestion is made to lobby for more government funding given that a local MP is now the Associate Minister of Transport.

This submissions support for the approach to rail outlined in the strategy and the retention of the Napier to Gisborne rail line is acknowledged.

The suggestion to introduce a right turn control for heavy traffic heading north along Pakowhai Road at the Farndon road intersection is not a matter which the RLTS can address, this is an individual Approved Organisation matter.

The fact that the Associate Minister of Transport is a local MP may assist the region to deal with its transport needs. It is unlikely except a broader policy commitment level, that the Associate Minister could intervene in normal funding processes, as  once the government “sets the rules” in the GPS, the NZTA Board is responsible for delivery through the NZTA , not the minister or his associate.

Recommendation:

That Richard Barfoot be thanked for the submission and be advised, based on the comments made, that no change is to be made to the RLTS or RLTP.

 

 


 

30.    Submitter: J.R.Haliburton

Officer’s Recommendations

The submission casts doubts on the viability of the Napier to Gisborne rail line due to changes in transport (better roads/heavy loads on trucks/faster cars/air travel) and because it is “no exit” line and not connected through to the Bay of Plenty and opposes using subsidies to keep the line open. As an alternative it suggests the use of sea transport and states this would have environmental benefits and be more economic. The submission then promotes 2 new projects on State Highway No 2 north of Napier for consideration, these being to divert the highway from Tutira to Eskdale via the Waikoau Valley and building a new bridge to traverse the Waikare Gorge at Putorino similar to what has been done at Matahorua.

The changes to transport outlined in the submission have undoubtedly affected how rail is utilised today compared to past use. The “no exit” situation on the Napier to Gisborne rail line would not appear to act as a limiting factor on its use although having a connection to the north may have increased its appeal. 

Even without a link through to the north, KiwiRail, prior to the lines recent closure due to storm damage, had increased the freight volumes being carried quite substantially and the line was on track to achieve a better financial outcome for KiwiRail than it had in recent times (potentially reach the breakeven point), this suggesting that a link north was not necessary for the line to be a success today.

The use of shipping between Gisborne and Napier and other ports has been previously investigated, rail shipping requires a high volume of freight on an ongoing basis to be economic to operate. Like rail, forestry could provide such volumes in the future. Competition on pricing will then determine which mode is used to carry the product, this includes road.

The proposal to build a new route for State Highway No 2 from Tutira, south to Bayview via the Waikoau Valley has been examined in the past. However there is no proposal to do so at this time or in the near future. The need for a new route on the suggested alignment at this time is not obvious as the current route handles demand adequately. If funding was not constrained or the current route was suddenly subject to major ongoing failure, or both, this idea might be investigated again.

The proposal to bypass the Waikare Gorge and build a new bridge has also been examined quite recently. When “R” funding was introduced this project was included in the list of possible works that could be undertaken with the then available “R” funds and it was given an “R” funding allocation.

Due to a reduction in the total “R” funds available to our region and substantial cost escalations on the projects already undertaken (e.g. the Matahorua deviation was originally in the “R” funded programme at $6-8m cost, end cost was about $23m), many projects have had to be “abandoned” for now and this was one of those.

It is possible however to include this project in the summary programme in the RLTS. However, there are many worthwhile projects that are not included in this summary. To include them all would involve creating what might become a prohibitively long list of projects.

Also the importance of the projects which are currently listed could potentially be lost in the detail. Lastly as these extra projects have not been previously ranked by the RTC and this could potentially create confusion as to their importance and timing for the region as a whole.

Recommendation:

That J.R.Halliburton be thanked for the submission and be advised, based on the comments made, that no change is to be made to the RLTS or RLTP.