Statement of evidence of Robert Clive Swears on behalf of the

NZ Transport Agency (Transportation)

Dated: 12 November 2019

REFERENCE: P. Brosnahan (paula.brosnahan@chapmantripp.com)

N. Amos (Natalie.amos@chapmantripp.com)

Before Independent Commissioners

At Hamilton

under: the Resource Management Act 1991

in the matter of: Proposed Private Plan Change 2 to the Hamilton City

Operative District Plan: Te Awa Lakes Private Plan

Change

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STATEMENT OF EVIDENCE OF ROBERT CLIVE SWEARS FOR

THE NZ TRANSPORT AGENCY – TRANSPORT ENGINEERING

1 QUALIFICATIONS AND EXPERIENCE

1.1 My full name is Robert Clive Swears. I am employed as a

Principal Road Safety / Transport Engineer in the Hamilton

Office of WSP.

1.2 My qualifications include a New Zealand Certificate in

Engineering, a Bachelor of Engineering degree with Honours

from the University of Canterbury, and a Master of

Engineering Science degree (Transport) from the University of

New South Wales. I am a Chartered Member of Engineering

New Zealand (CMEngNZ), and a Member of the Engineering

New Zealand (EngNZ) Transportation Group.

1.3 I have been carrying out professional engineering tasks

related to the investigation, design, and construction of

roading and highway projects for 29 years. I have worked on

a variety of transportation projects, plan changes and plan

formations throughout my career for developers, the NZ

Transport Agency (Transport Agency) and local authorities.

Examples of plan changes and plan formation work for which

I have recently provided advice to the Transport Agency

include:

(a) Numerous Environment Court Appeals to the Thames-

Coromandel District Plan;

(b) Calcutta Farms MPDC Plan Change 47;

(c) Hobbiton MPDC Plan Change 50; and

(d) Andrew King Environment Court Appeal to the Hamilton

City Proposed District Plan

1.4 I have been engaged by the Transport Agency to prepare

transport engineering evidence in relation to the Te Awa Plan

Change to the Hamilton City Plan which seeks to alter the

zoning of 62 hectares of Te Rapa North Industrial zoned land

to a combination of medium density residential, major

facilities and business zonings (Plan Change). I am familiar

with the proposed rezoning. I have visited the Plan Change

site area on a number of occasions, with my last site visit

occurring on 7 November 2019.

1.5 I confirm that I attended the facilitated conference for the

traffic and transport experts held on 13 September 2019. I

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also attended the further conferencing held on 1 and 22

October 2019.

2 CODE OF CONDUCT

2.1 Although this matter is not before the Environment Court, I

have read and am familiar with the Code of Conduct for

Expert Witnesses in the current Environment Court Practice

Note (2014), have complied with it, and will follow the Code

when presenting this evidence. I also confirm that the

matters addressed in this Statement of Evidence are within

my area of expertise, except where relying on the opinion or

evidence of other witnesses. I have not omitted to consider

material facts known to me that might alter or detract from

the opinions expressed.

3 SCOPE OF EVIDENCE

3.1 My evidence addresses the following:

(a) Lack of certainty regarding trip generation;

(b) Congestion;

(c) Intersection performance assessment;

(d) Road safety;

(e) Walking and cycling;

(f) The proposed adventure park;

(g) Mitigation proposed by the Applicant;

(h) Further mitigation that I consider is required; and

(i) Comments in relation to the Waikato Regional Policy

Statement.

3.2 In preparing my evidence, I have reviewed the following

statements of evidence on behalf of the Applicant, Perry

Group Limited:

(a) Transportation: Mark Apeldoorn;1

(b) Planning: John Olliver – sections related to

infrastructure and transportation.

1 Apeldoorn, 29 October 2019 (Stantec, 2019c).

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3.3 I have also considered:

(a) The Section 42A Report prepared by the Council Officer

(Grant Eccles);2

(b) Statement of evidence for Alasdair Gray, transport

engineer on behalf of Hamilton City Council;3 and

(c) The Joint Witness Statement for Transportation dated

13 September 2019.

4 SUMMARY OF STATEMENT

4.1 Based on the information provided on behalf of the Applicant,

I consider the Plan Change has a number of shortcomings,

particularly when compared to the existing zoning for the

Site.

4.2 Overall, I am concerned the Plan Change will create a private

motor vehicle centric development that is relatively remote

from employment, education, and recreational trip attractors.

In addition, despite mitigation proposed by the Applicant (as

discussed below), I consider the following matters (inter alia)

need to be resolved:

(a) Lack of certainty regarding the likely trip generation

associated with the Site and, therefore, lack of certainty

regarding the effects of and appropriate mitigation for

the Plan Change;

(b) Generating peak hour trips that exacerbate existing

congestion issues because some of those peak hour

trips are in the same direction as already congested

traffic routes;

(c) Encouraging journeys by cyclists along Te Rapa Road,

which is a heavily trafficked route frequently used by

heavy vehicles. This promotes the potential for these

vulnerable road users to come into conflict with

relatively high speed motor vehicles;

(d) Potential for road users in the vicinity of the Site to be

distracted by activities at the Adventure Park and for

such distraction to be a contributing factor to crashes;

(e) As outlined in Mr Wilson’s evidence, the proposed Plan

Change and associated activities will make it difficult to

2 Section 42A Report, 14 October 2019 (Hamilton City Council, 2019c).

3 Gray, 13 October 2019.

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organise and promote public transport routes to service

the Site. In addition, I question whether the proposed

travel demand management measures will significantly

reduce the number of private motor vehicle journeys

associated with activities at the Site;

(f) The type(s) of ITA to be prepared in relation to

development of the different components of the Plan

Change;

(g) While the information provided by the Applicant

indicates the Plan Change will not create significant

adverse effects at the Horotiu interchange, there is

uncertainty in relation to some of the modelling

information that has been provided;

(h) Because of the uncertainty associated with the

modelling and trip generation for the Plan Change, I

consider it desirable for development of the Site under

the Plan Change to be staged to allow the Applicant’s

assumptions and assertions to be tested at a later date

once additional traffic flow and modelling data is

available; and

(i) Provision for pedestrians and cyclists under various

components of the Plan Change, but particularly in

relation to movements at the Horotiu interchange.

4.3 Despite my concerns, I consider that subject to appropriate

staging of the development and refinement of mitigation for

the Plan Change there is potential for the adverse transport

effects associated with the Plan Change to be managed and

mitigated to an acceptable extent. However, there are some

aspects of the mitigation that may be needed (such as

provision for walking and cycling at the Horotiu interchange)

that are likely to be difficult to achieve.

5 LACK OF CERTAINTY REGARDING TRIP GENERATION

5.1 I have some concerns regarding the transport modelling,

which are outlined in Appendix A of my evidence. In

summary, the modelling uses the Waikato Regional Transport

Model (WRTM), which I agree is the best modelling tool to use

for considering the transport engineering effects from the

Plan Change. However, just because it is the best tool does

not mean it is an accurate tool.

5.2 While I do not expect the WRTM to identify the worst case for

every land use, it is important to recognise that the trip

generation associated with the Site may be higher than has

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been identified through the WRTM. Therefore, the adverse

effects associated with vehicle movements to and from the

Site may be more significant than have been identified

through the ITA. While Mr Apeldoorn (with reference to Mr

Gray’s Evidence in Chief (EIC) paragraph 18a) notes the

updated modelling provides more certainty, there is still

uncertainty regarding the likely trip generation and

distribution associated with the Plan Change.

5.3 Because of the uncertainty associated with trip generation for

the Site, I consider it important there are appropriate hold

points put in place through the Plan Change rules to ensure

development on the Site can be halted at a given point (or

possibly at given points) to allow further analysis to be

undertaken and consideration given to whether it is

appropriate to allow the remaining portion(s) of the Site to be

developed as originally proposed through the Plan Change.

5.4 As noted in my Appendix A, the existing and proposed

zonings for the land allow more traffic to be generated by the

Site than has been identified through the modelling. The

existing zonings set trip generation maximums, which are not

necessarily going to be met; however, through my

involvement with other matters I am aware that trip

generation thresholds are sometimes significantly exceeded.

Therefore, because of the uncertainty involved, if the Plan

Change is approved, I prefer a conservative staged approach

is taken to development of the Site so that the applicability of

the presently modelled traffic volumes can be compared with

future reality and additional mitigation provided if

appropriate. In this regard, I consider the 500 lot staging

approach proposed by the Applicant is reasonable.

6 CONGESTION

6.1 I am concerned that the Plan Change, once developed, will

generate peak hour trips that exacerbate existing congestion

issues because some of the peak hour trips will be in the

same direction as already congested traffic routes.

6.2 In paragraph 18 (Apeldoorn EIC, page 5) Mr Apeldoorn notes:

“While the directional traffic profiles of the plan change

[…] are directionally different to the currently zoned

and consented employment-based demands, the peak

generations created by those profiles are broadly

similar.”

This is an important point and one of the reasons behind the

magnitude of the adverse effects associated with the Plan

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Change. If the Site was developed in accordance with the

current Industrial zone, many of the traffic movements

associated with the existing zoning would be towards the Site

in the morning peak period and away from the Site in the

afternoon peak period. That is, the traffic movements would

be in the opposite direction to the major traffic flows given

that many journeys along Te Rapa Road in the morning peak

will be towards Hamilton and in the evening peak, many of

the journeys will be away from Hamilton.

6.3 In Appendix B of this statement I have provided examples of

the 2041 differences between Plan Change and permitted

development traffic volumes.

6.4 The information in Appendix B demonstrates that even if the

overall volumes of traffic associated with the Plan Change are

similar to what could be expected from the current Industrial

zoning, the traffic flows associated with the Plan Change are

contributing to congested flows whereas many of the traffic

flows associated with the current Industrial zoned land use

would be in the opposite direction to those congested flows.

Using the Hutchinson Road intersection as an example, the

Plan Change adds 556 vehicle movements southbound on Te

Rapa Road in the morning peak and 505 vehicle movements

northbound on Te Rapa Road in the evening peak.

6.5 Mr Apeldoorn has described (paragraph 19) the additional

peak hour quantum of demand generated by the Plan

Change. However, as noted above, while this information is

useful, it is important to consider the directional flow of the

Plan Change traffic compared with the flow under the current

Industrial zone. That is, how much of the traffic is going

towards the Site in the peak and how much is going away

from the Site?

6.6 As outlined in Appendix A of my statement, there are some

relatively significant differences between the modelled trip

generation and the permitted trip generation for the existing

zoning. Therefore, I have concerns that some of the

modelled values to which Stantec refer may be too low, which

means the analysis may not show the true extent of the

effects.

6.7 With regard to Mr Gray’s position on congestion (Gray EIC,

paragraph 40), it needs to be kept in mind that the Plan

Change is intended to allow trip generation greater than

would be permitted under the existing zoning and the

directional distribution of that trip generation is likely to be

opposite to the distribution that would occur under the

existing zoning. That is, the Plan Change trip generation will

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exacerbate capacity issues because it adds to the

predominant traffic flows rather than promoting traffic flows

in the opposite direction.

6.8 I accept that congestion of the Te Rapa Road corridor (Gray

EIC, paragraph 41) is likely to require physical works to

address the congestion irrespective of the Plan Change.

However, from a State highway perspective, increasing

congestion on the Te Rapa Road corridor has the potential to

encourage trips to be reassigned to other corridors (such as

the Waikato Expressway) and result in local trips being

diverted to an interregional corridor. However, the modelling

information provided by Mr Apeldoorn (Stantec, 2019e) does

not indicate there will be particularly significant variation in

traffic volumes or level of service at the Horotiu interchange

as a result of the Plan Change.

6.9 I agree with Mr Gray (EIC, paragraph 34) that mitigation such

as four laning of Te Rapa Road is likely to be disproportionate

in relation to the adverse effects associated with the Plan

Change. In that regard, I consider the Applicant’s approach

of presenting mitigation (such as signalising the Te Rapa

Road / McKee Street intersection) to offset some of the

adverse effects associated with the Plan Change is

appropriate but I consider further measures are required.

The alternative of trying to identify proportional contributions

to address incremental adverse effects at a range of locations

is complex by comparison and does not necessarily result in

mitigation being provided in a timely manner.

6.10 From a State highway perspective, the information provided

by Stantec (2019e, pp. 15-16) indicates the Horotiu

interchange will perform no worse in the 2041 morning peak

and perform better in the 2041 evening peak. While the level

of service values are different, the tables in the report are

supported by the level of service plots in Appendix C of the

Stantec (2019e, p. 31) document. These illustrate no change

in performance for the Horotiu interchange (as a whole) in

the morning peak (when comparing the full development with

the permitted development) and an improvement in

performance of the eastern side of the interchange in the

evening peak from LoS E under the permitted development to

LoS D under the Plan Change.

6.11 In my opinion, the uncertainty associated with the trip

generation and the significant change in the directional

distribution of traffic movements from the zoned land use to

the Plan Change use constitutes significant development of

the Site. Therefore, I support the inclusion of a hold point at

development of up to 500 residential units.

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6.12 I refer to Ms Heppelthwaite’s evidence (paras 12.9, 12.16)

where she describes the differences between Section 3.8.3

and Rules 3.8.5.3(1) and (2). In particular, 3.8.3 includes a

need to consider more than 500 dwellings and significant

development in the Major Facilities zone as a trigger point,

however, Rules 3.8.5.3(1) and (2) only include reference to

more than 500 dwellings.

6.13 I consider that significant development in the Major Facilities

zone would include development which has a trip generation

greater than the 15.4 trips per hectare gross land area per

peak hour to which Stantec (2019f, p. 2) refers and which is

also considered in Appendix A of this statement.

6.14 I support the changes Ms Heppelthwaite (paras 12.9, 12.16

and 12.17) has made to Rules 3.8.5.3(1) and (2) and the

consequential inclusion of a definition of significant

development.

6.15 I have reviewed paragraphs 12.9 to 12.26 of Ms

Heppelthwaite’s statement and agree with its content from a

transport engineering perspective.

7 INTERSECTION PERFORMANCE ASSESSMENT

7.1 When considering congestion effects from the Plan Change, it

is important to also consider the intersection performance

assessment completed. Stantec (2019a, p. 1) states:

“It should also be noted that we are using a strategic

model [WRTM] to check the operation of a few

intersections which is generally difficult to do.”

7.2 I agree with Mr Grant Smith (Stantec, 2019a) in this regard

because the WRTM is intended as a regional transport model

and it is unreasonable to expect the traffic volumes in the

model to have the level of precision needed for accurately

modelling the performance of individual intersections.

Therefore, I consider caution needs to be applied to the

results of the intersection modelling provided with the ITA

and to which Mr Apeldoorn refers in his Evidence in Chief.

7.3 I have included in Appendix C to this statement examples of

matters regarding which I consider further evaluation and / or

clarification may be required with regard to modelling and

intersection performance.

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7.4 The key points to note from Appendix C include:

(a) The modelling for the Plan Change may present an

optimistic view of the mitigated adverse effects because

of the uncertainty associated with the trip generation

and network configuration included in the modelling;

(b) Clarification is needed as to whether the “peak periods”

described by experts for the Applicant refer to two-hour

or one-hour peak periods;

(c) There appear to be differences between intersection

performance as described in WRTM modelling when

compared with SIDRA modelling. These differences

raise questions as to which (if either) of the modelling

results represent the expected performance of

particular intersections;

(d) It would be useful for information to be provided

describing the performance of the Te Rapa Road /

McKee Street intersection without the proposed

signalisation to allow an understanding of the changes

in effects attributable to the Plan Change;

(e) Notwithstanding the point above, it appears there is

merit in the Applicant’s proposal to fund signalisation of

the Te Rapa Road / McKee Street intersection;

(f) Level of service information for an intersection provides

an overview of the performance of the intersection as a

whole, but does not necessarily highlight particular legs

of the intersection that may be performing very well

and / or very poorly; and

(g) There will be congestion on the transport network in the

vicinity of the Site regardless of whether the Site is

used for its current Industrial zone purpose or for the

proposed Plan Change purposes.

7.5 The other question that arises in relation to staging the

development is the nature of the analysis that should be

carried out to inform consideration for approval to develop

the remaining (approximately) 500 residential dwellings on

the Site. In his EIC (Table 1), Mr Olliver refers to a Simple

ITA being required in conjunction with development of the

residential zone, while a Broad ITA is required in conjunction

with the Adventure Park. Notwithstanding the uncertainty

associated with trip generation for the Adventure Park, the

question arises as to whether the analysis for the residential

zone should be as simple or broad. Given the potential total

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trip generation for the residential zone (approximately 10,000

vehicle movements per day in total, based on 10 vehicle

movements per day per dwelling) I consider the analysis for

the residential zone should be a Broad ITA rather than a

Simple ITA. As described by Hamilton City Council (2019a) a

Broad ITA considers (inter alia) modal split, travel demand

management, sensitivity testing, and transport network

improvements that are not necessarily addressed through a

Simple ITA. Ms Heppelthwaite has included (para 12.21)

within her proposed changes to the provisions and I support

this change.

7.6 Based on information provided by the Applicant, it appears

the Plan Change will not create significant adverse effects at

the Horotiu interchange, which is the location where adverse

effects on the State highway network attributable to the Plan

Change are most likely to be demonstrated.

7.7 However, because of the uncertainty associated with the

modelling and trip generation for the Plan Change, I consider

it desirable for development of the Site under the Plan

Change to be staged to allow the Applicant’s assumptions and

assertions to be tested at a later date once additional traffic

flow and modelling data is available.

7.8 In summary, I consider the Applicant has reasonably

proposed for development of the Site to be reviewed before

any consents are given to establish the second half

(approximately 500 residential dwellings) of the residential

component of development of the Site. This will manage

effects on intersection capacity to a reasonable extent. This

is on the basis also that Ms Heppelthwaite’s amendments to

include significant development in the Major Facilities zone

are included as a hold point and a Broad ITA is required.

8 ROAD SAFETY (MOTOR VEHICLES)

8.1 Mr Apeldoorn makes reference (EIC, paragraph 31-33) to

road safety matters associated with the Plan Change and

notes the alignment between plan change provisions and the

increased focus on road safety by central government and at

local authority levels. I agree that this is an appropriate

approach and is consistent with the Transport Agency’s

approach to road safety across the country.

8.2 In paragraph 7.1 of the ITA (Stantec, 2019b), reference is

made to road safety outcomes within the Site and external to

the Site. The works listed under “External to the Plan Change

Area” focus on provisions for pedestrians and cyclists; these

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matters are discussed in the Walking and Cycling section of

my evidence.

8.3 While I agree it is important for adequate provision to be

made for vulnerable road users (refer to Section 9 below), the

ITA does not appear to consider in any detail the potential

adverse effects of the Plan Change on other (motorised) road

users. In this regard, it would be useful for the Applicant’s

analysis to include reference to the likely changes in crash

occurrence as a result of the changes in traffic volumes

associated with the Plan Change.

8.4 The increased traffic associated with the Plan Change (and

natural growth) is likely to increase the incidence of crashes,

simply because of the increased potential for drivers to make

mistakes and for there to be conflict between road users.

8.5 Figure 1 and Figure 2 below confirm the findings of Stantec

(2019b) and illustrate that crashes occur in the vicinity of the

Site.

Figure 1: Looking south along Te Rapa Road (towards the Service Centre) on

exit from the Horotiu interchange. Note the damaged guardrail (highlighted with red circles) indicating that vehicles have left the carriageway, crossed the shared path, and struck the guardrail.

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Figure 2: Looking north along Te Rapa Road (the blue sign in the distance

provides advance warning for the Hutchinson Road roundabout) showing heavy commercial vehicle (HCV) tyre marks indicating that an HCV has braked heavily crossing the shoulder where northbound cyclists on Te Rapa Road are expected to travel.

8.6 As noted in the following section, I have significant concerns

regarding the safety of vulnerable road users in the vicinity of

the Site and particularly at the Horotiu interchange. Taking

into account the land use anticipated at the time the

interchange was established, I expect that those undertaking

the road safety audit(s) may not have anticipated residential

development in close proximity to the interchange and the

associated potential for increased numbers of pedestrians and

cyclists to be using the paths and crossings at the

interchange.

8.7 Prior to any subdivision for the residential zone and at the

proposed hold point for the Plan Change, I consider it

important that a detailed review is undertaken of the road

safety performance of the transport network in the vicinity of

the Site so that additional mitigation (if any) can be identified

and established to address adverse road safety effects that

may arise as a result of the volume and type of traffic

associated with the Plan Change. Any road safety reviews

and / or audits that are undertaken should consider the needs

of all road users, not just those that travel in motor vehicles.

8.8 Notwithstanding my concerns regarding pedestrians and

cyclists, and the potential for distraction (described under the

Proposed Adventure Park section of this statement), there

appears to be relatively little inherently associated with the

Plan Change that is likely to disproportionally worsen the road

safety performance of the network in the vicinity of the Site

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for motorised road users. However, the simple increase in

vehicle numbers is likely to create an increase in crash

numbers.

8.9 Notwithstanding these points, I agree with the conclusions of

Stantec (2019b) that the intersections most likely to be

affected by traffic movements associated with the Plan

Change are presently performing reasonably well from a road

safety perspective.

9 WALKING AND CYCLING

Horotiu Interchange

9.1 With regard to vulnerable road users, the ITA does not appear

to provide detail in relation to facilities for pedestrians and

cyclists in the vicinity of the Horotiu interchange. As noted in

Appendix D of my statement, I have concerns regarding the

potential adverse safety effects for vulnerable road users at

the interchange.

9.2 I consider there are shortcomings associated with the

vulnerable road user routes in the vicinity of the Horotiu

interchange. While these are existing shortcomings, I

consider that if the Site was used for its Industrial zoned

purpose, the adverse effects associated with them would not

be as much of an issue. However, unless the form of traffic

control at the interchange is fundamentally changed (for

example, from the roundabout / dog bone configuration to

traffic signals) or grade separated facilities are provided for

vulnerable road users, there are very limited solutions

available to improve safety at the interchange for vulnerable

road users. However, traffic signals are not typically

regarded as a safe system solution, therefore, they may not

be appropriate.

Connectivity

9.3 In my opinion, the Plan Change is a motor vehicle centric

development. However, the Applicant has identified various

measures to promote walking and cycling as viable

alternatives to private motor vehicle journeys.

9.4 I have several concerns in relation to the effects of the Plan

Change on walking and cycling journeys. Those concerns are

summarised below and described in detail within Appendix D

of this statement.

9.5 I agree with Mr Gray (EIC, paragraph 30) that “[…] the site is

poorly connected for walking, cycling and passenger transport

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and will either result in adverse safety effects or result in

greater reliance on low occupancy vehicles, such as cars.” I

also consider that any improvements to walking and cycling

facilities through the Plan Change will result in minimal

changes to the wider transportation effects to the local and

State highway roading networks.

9.6 I agree with Mr Apeldoorn (EIC, paragraph 34(b)) that the Te

Rapa Road corridor between Hutchinson Road and Church

Street presents a higher risk environment for cyclists due to

the existing 80 km/h speed limit than would occur if the

speed limit is reduced to less than 80 km/h.

9.7 While I agree with Mr Gray that the Te Rapa Road signalised

pedestrian / cycle crossing facilities provided for vulnerable

road users must be fit for purpose and not compromise safety

for those road users, I have concerns regarding the potential

for a raised platform to be associated with a signalised

crossing facility on Te Rapa Road. Although a raised platform

may be beneficial for the relatively small number of

pedestrians and cyclists likely to be crossing Te Rapa Road,

the provision of such a facility needs to be balanced against

the needs of through traffic (particularly heavy commercial

vehicles (HCVs)) that uses Te Rapa Road.

9.8 Recognising that design detail is not required at the Plan

Change stage, the potential vertical alignment of the

connections between the Te Awa River Ride (River Ride) and

the Site may discourage some potential active mode users

from accessing the River Ride.

9.9 Notwithstanding the road safety risks associated with

encouraging cyclists to use the Horotiu interchange, I

consider it preferable to encourage cyclists to access the

shared path on the western side of the Waikato Expressway

(refer Apeldoorn EIC, paragraph 37(d)) than to not provide

facilities and, by default, encourage cyclists to use the

shoulders of the Expressway itself.

9.10 I consider that provision of the “missing link” along the River

Ride (illustrated by the dotted yellow line on Figure 4 of Mr

Apeldoorn’s EIC) is an infrastructure feature that is likely to

significantly increase the potential for cyclists to use the River

Ride. However, I understand establishing the link would

require approval from third parties, therefore, it is unclear

when or if this link will be or could be provided. Given this

uncertainty I have disregarded this as a reliable mitigation

measure.

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9.11 The Plan Change appears to incorporate a proposal ((Stantec,

2019b) Appendix A, Figure 20) to create a gap in the barrier

alongside the SH1 southbound off-ramp to accommodate the

proposed walking and cycling network. While it is feasible to

create openings in the alignment of barriers without adversely

affecting safety for road users, I consider caution needs to be

applied in relation to measures associated with the Plan

Change that have the potential to compromise safety if those

measures are not adequately designed and constructed.

9.12 In Appendix B of Mr Apeldoorn’s evidence, Stantec (2019d)

notes that to access schools for children aged 11-18, “[…] it is

anticipated that a reasonable number of older children will

cycle, making use of the River Path (say 5%).” Using

Ngaruawahia High School and Rototuna Senior High School as

examples, I consider it unlikely that many (if any) pupils

would undertake round-trip cycling journeys of more than

18 km for travel to and from those schools.

9.13 It needs to be kept in mind that the proportion of trips

associated with the Plan Change that will be assigned to the

River Ride is likely to be relatively small.

9.14 Taken as a whole, there is merit in the facilities the Applicant

proposes to provide for vulnerable road users. However,

there are also shortcomings with that mitigation as

summarised above and described in detail in Appendix D of

this statement. In my opinion, any enhancements to the

River Ride to increase the uptake of active travel modes

(particularly cycling) to and from the Site need to be designed

to ensure that all users of the path (including walkers) are

safely catered for.

9.15 In summary I consider:

(a) Road safety audit(s) is required for proposed

development at the Site in excess of 500 dwellings.

The audit(s) should consider (but not be limited to)

safety at the Horotiu interchange in relation to

vulnerable road users;

(b) Care will need to be taken in the design of pedestrian

crossing facilities on Te Rapa Road along with any

changes to safety barriers to accommodate new cycling

and walking connections, details of this can be

addressed at the ITA / resource consent stage; and

(c) Any enhancements to the River Ride to increase the

uptake of active travel modes (particularly cycling) need

to be designed to ensure that all users of the path

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(including walkers) are safely catered for. This can also

be addressed at the ITA / resource consent stage.

10 TRAVEL DEMAND MANAGEMENT

10.1 I agree with Mr Apeldoorn (EIC, paragraph 57) that

successfully applying a travel demand management approach

for the Site, to encourage a mode shift away from private

motor vehicles, would be beneficial. However, when

compared with the permitted land use, there are

shortcomings with the Plan Change from a travel demand

management perspective; these include:

(a) The Plan Change is a private motor vehicle centric

proposal because of its location and the present

availability of public transport. Therefore, encouraging

journeys via means other than private motor vehicle

(whether shared or individual journeys) is likely to be

more difficult than if there is good availability of public

transport.

(b) Achieving “[…] ownership, accountability, [and]

participation […]” for travel demand management is

likely to be more difficult to achieve with the land use

proposed under the Plan Change when compared with

the land use permitted under the current zoning. The

reason for this is that the Plan Change will introduce

numerous “owners” of the travel demand management

plan through the approximately 1000 households that

could be established on the Site. By contrast, if the

Site is used for its Industrial zoned purpose there would

be fewer stakeholders involved and greater potential for

those stakeholders to encourage people travelling to

and from the Site to participate in travel demand

management schemes. For example, a large employer

on the Site could provide transport for employees to

and from various suitable locations around the Hamilton

area.

10.2 However, with respect to the Adventure Park, reducing the

use of private motor vehicles may be more achievable than is

likely with the residential land use. The reason for this is that

the Adventure Park operator(s) has the potential to bring

groups of customers and / or staff to the Site using shared

transport. Notwithstanding that, depending on the manner in

which customers are attracted to the Adventure Park, shared

transport may not be a particularly realistic outcome.

10.3 While I have not analysed travel demand outcomes for a

range of land use activities elsewhere in Hamilton City, I

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agree with Mr Apeldoorn (EIC, paragraphs 58-59) that the

Plan Change provisions actively promote travel demand

management including the use of active modes and public

transport. However, based on my understanding of the

application of travel demand management schemes, even

those that are relatively successful do not result in very

significant changes in the volumes and types of vehicles being

used for transport.

11 PROPOSED ADVENTURE PARK

11.1 I have concerns regarding the potential for road users to be

distracted by activities on the Site and particularly activities

associated with the Lake and Adventure Park elements of the

Plan Change. While Mr Gray has referred (EIC, paragraph

38a) to “[…] rules to avoid driver distraction that has an

adverse effect on safety.” I consider that the rules associated

with screening the activities on the Site (and particularly at

the Adventure Park) from road users should be definitive and

require that there is no close and / or detailed visibility from

the transport network to activities at the Adventure Park.

Figure 3 below illustrates existing visibility from the

southbound carriageway of the Waikato Expressway towards

the Adventure Park area of the Site.

Figure 3: View from southbound carriageway of Waikato Expressway towards the lake area of the Adventure Park (highlighted with red arrow)

11.2 However, to screen the Lake and Adventure Park from close

visibility it may be necessary for screening to be provided

along the Waikato River boundary of the Site as well as along

the Waikato Expressway boundary of the Park. Figure 4

below illustrates that screening the Adventure Park from close

visibility is also likely to screen the Park from distant visibility.

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Figure 4: View from southbound carriageway of Waikato Expressway towards

the Site. Screening close visibility to the Lake and Adventure Park may require screening along the Waikato River boundary of the Park, which will also screen activities at the Park from distant visibility

11.3 Notwithstanding whether close screening also results in

distant screening, I consider the screening is most important

in close proximity to the Adventure Park where road users will

be most readily able to view activities and such viewing will

require drivers to divert their gaze from the road in front of

them.

11.4 I consider that Mr Gray has introduced an inappropriate

element of doubt in relation to the screening by referring to

distraction “that has an adverse effect on safety”. Taking into

account the very wide range of road user interests and

abilities, I consider it unlikely agreement could readily be

reached in relation to which activities are likely to have an

adverse effect on safety. Therefore, because of the novel

nature of activities at the Adventure Park and potentially also

of activities on the Lake, I consider there should be complete

visual screening of the Lake and Adventure Park from the

road network.

11.5 While I consider the proportion of road users that will be

distracted to the extent there are adverse effects on safety

will be relatively low, it needs to be kept in mind that crashes

are often defined as “rare, random, multi-factor events

always preceded by situation in which one or more road users

have failed to cope with their environment”. Given that we

have the opportunity to fully screen activities at the Lake and

Adventure Park from road users and therefore remove a

factor from the multi-factor nature of crashes, I consider the

screening to be an important component of plan change

requirements. Such an approach aligns well with the Vision

Zero approach to road safety to which reference is made in

paragraph 1.9 of the ITA (Stantec, 2019b).

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11.6 Ms Heppelthwaite has highlighted to me the plan provisions

(from Mr Olliver’s evidence) which are intended to address

this matter; these are:

Information requirement 1.2.2.16(j)

In Te Awa Lakes Adventure Park, the design and layout

of activities, structures and the provision of landscaping

or other screening adjacent to the Waikato Expressway

and Te Rapa Road frontages of the site so as to avoid

as far as practicable any distraction to road users

Assessment Criteria 1.3.3 K19

The extent to which the design and layout of activities

and structures and the provision of landscaping and

other screening avoids distraction to road users on the

Waikato Expressway and Te Rapa Road.

11.7 I consider these provisions should be refined to ensure that

the screening avoids the potential for road users on the

Expressway and / or Te Rapa Road being able to view

activities at the Adventure Park. However, that screening will

not necessarily be limited to the frontages of the Site along

the Expressway and Te Rapa Road as indicated by the

Information requirement. The other matter to take into

account is that, depending on the nature of activities on the

Lake (that is not part of the Adventure Park) it may be

appropriate for those activities to also be screened from road

users.

12 MITIGATION

Proposed by Applicant

12.1 The Applicant has proposed various measures to mitigate the

adverse transport effects associated with the Plan Change.

Those measures include (but are not limited to):

(a) Enhancing the River Ride to encourage vulnerable road

user journeys via this off-road route. These

enhancements include multiple access points from the

Site onto the River Ride.

(b) Improving the safety of the Te Rapa Road cycle route

through making specific provision for cyclists at those

locations where the risks to cyclists are likely to be

greatest (for example, at the Fonterra interchange

ramps).

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(c) Replacing the existing priority control at the Te Rapa

Road / McKee Street intersection with a signalised

intersection.

12.2 From a mitigation perspective, I consider the Applicant’s

approach of proactively identifying discrete packages of

infrastructure works that can be carried out (such as

signalising the Te Rapa Road / McKee Street intersection) is

useful because it reduces the need for arguments regarding

contribution to mitigation for incremental adverse effects.

However, in relation to the midway assessment, I consider it

would be useful for the Applicant to clarify the mitigation that

could be provided if such need is identified at the midway

stage.

12.3 Similarly to the Te Rapa Road / McKee Street approach, I

consider it would be desirable for the Plan Change

documentation to include clarity regarding the discrete

package(s) of mitigation that may be provided if the need for

that mitigation is identified. As an example, the Applicant

may propose to identify a discreet package of works such as

signalisation of the Te Rapa Road / Hutchinson Road as

possible mitigation at the midway stage.

12.4 Notwithstanding my opinion that there will be relatively few

walking and cycling journeys associated with the Plan

Change, it is desirable to encourage residents of and visitors

to the Site to adopt active modes (and / or alternatives to

private motor vehicles). Establishing connectivity from the

outset will promote active mode use from the outset.

Therefore, I agree with Mr Gray (EIC, Table 2, item n) that

the improved connectivity with the Waikato Expressway

shared path should be established from the outset.

12.5 In Appendix E of this statement I have included specific

feedback in relation to the findings and proposed mitigation to

which Mr Gray has referred in his EIC.

12.6 Mr Gray refers (EIC, paragraph 38c) to the need for

clarification in relation to travel demand management. As

noted in Section 10 of this statement, I consider that travel

demand management measures will not be as successful if

the Site is used for the Plan Change activities compared to

the current Industrial zone. While successful travel demand

management that reduces reliance on single or low occupancy

private motor vehicles is a desirable outcome, which should

be encouraged, I consider caution should be applied to

assuming that travel demand management will make a

significant difference to the number of vehicle movements

associated with the Plan Change.

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12.7 Mr Gray highlights (EIC, paragraph 42) that the Applicant has

identified transportation mitigation measures to address the

adverse effects of the Plan Change. The mitigation measures

identified will not address all adverse effects of the Plan

Change, however, by offering to provide discrete mitigation

elements, the Applicant has presented a mitigation solution

that I consider is preferable to the approach where adverse

effects are mitigated in a piecemeal fashion through

development contributions.

12.8 Overall, I consider the mitigation proposed is appropriate,

subject to my comments below.

Further mitigation required

12.9 To address the concerns raised in this statement, I consider

the following additional mitigation is required in order to

address the outstanding effects.

(a) The Lake and Adventure Park are fully screened from

road users to reduce the potential for road users to be

distracted by activities on the Lake and at the Park.

Noting however that I consider amendment is needed to

the plan provisions to which Mr Olliver refers in his

evidence.

(b) In support of the view expressed by Mr Wilson (Waikato

Regional Council) and the provision proposed by Ms

Heppelthwaite [para 12.25] I consider the Applicant

should be required to reconfigure the Site as

appropriate in a manner that will better promote the

viability of public transport routes through the Site.

(c) Any measures associated with reducing reliance on

private motor vehicles for travel to / from the Site must

be such that existing routes (such as Te Rapa Road) are

not adversely affected by the Plan Change measures.

In relation to this, I reiterate my concern regarding the

raised platform on Te Rapa Road to which Mr Apeldoorn

refers in his EIC (page 12). However, I also accept that

because of the proposed nature of the development of

the Site it will be to coordinate efforts to reduce reliance

on private motor vehicles. Therefore, it may be

appropriate for the Plan Change provisions to include

requirements for the Applicant to establish and maintain

a working group of occupiers of the Site so that

reduction measures can be coordinated.

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13 WAIKATO REGIONAL POLICY STATEMENT

13.1 With respect to points raised by Ms Heppelthwaite I note:

(a) Policy 6.1.8 refers to the safe and efficient functioning

of regionally significant infrastructure; in my view the

Waikato Expressway and Te Rapa Road fall under this

category. Based on the modelling outcomes provided

by the Applicant, it appears the Plan Change achieves

the efficiency requirement of the Policy, however, I

have some concerns regarding the safe function of Te

Rapa Road and the Horotiu interchange particularly with

respect to walking and cycling journeys.

(b) Similarly, Policy 6.3 refers to maintaining or enhancing

operational effectiveness, viability and safety as well as

protecting investment in existing infrastructure. Based

on the material provided by Mr Apeldoorn and taking

into account the mitigation proposed by the Applicant, it

appears that the measures proposed largely achieve the

requirements of Policy 6.3. However, the safety and

efficiency of vulnerable road user movements remain as

issues of concern to me. From a motor vehicle

perspective, it appears the Horotiu interchange will not

be adversely affected by the Plan Change, however,

with regard to vulnerable road users much emphasis is

placed on use of the River Ride, which may or may not

be reasonable.

(c) From the perspective of upgrading the road network

beyond the Site, the Plan Change does not appear to

include provisions that result in opportunities to

upgrade existing infrastructure being obstructed (Policy

6.3) any further than they are at present. The most

obvious issue in this regard relates to the Fonterra

interchange, however, aside from formalising cycle

paths through the interchange, the Plan Change does

not appear to compromise upgrade potential.

(d) From a public transport perspective, I have concerns

regarding the likelihood that public transport routes will

be established to serve the Site that do not result in

adverse effects on existing public transport routes. In

addition, I have concerns regarding proposed facilities

to accommodate pedestrian movements across Te Rapa

Road to the north of the Hutchinson Road roundabout.

However, as noted in the Transport JWS (Issue 6),

there are options available to mitigate the adverse

effects associated with the pedestrian movements

across Te Rapa Road to the western bus stop. With

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respect to Policy 6.3, I consider it could be argued that

the Plan Change does not incorporate features that

would frustrate or obstruct the use of public transport

or transport modes that are well connected, however,

the question arises as to the safety and efficiency of

those connections.

14 CONCLUSIONS

14.1 Overall, I am concerned the Plan Change will create a private

motor vehicle centric development that is relatively remote

from employment, education, and recreational trip attractors.

In addition, despite mitigation proposed by the Applicant, I

consider (inter alia):

(a) There is uncertainty regarding the adverse effects

associated with the Plan Change;

(b) It is unlikely that some of the measures proposed by

the Applicant will result in significant reductions in the

private motor vehicle focus of activities on the Plan

Change site; and

(c) There are shortcomings associated with the mitigation

proposed for walking and cycling; these shortcomings

may result in adverse road safety outcomes for

vulnerable road users.

14.2 However, despite my concerns, the Applicant has presented a

range of mitigation measures that have the potential to

reduce the potential adverse effects associated with trip

generation created by the Plan Change. Those measures,

combined with the additional measures to which I refer in this

statement, and appropriate staging and refinement of the

development provide a level of comfort that the adverse

transport effects associated with the Plan Change can be

managed and mitigated to an acceptable extent.

Robert Swears

12 November 2019

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15 REFERENCES

Austroads, 2014. Cycling Aspects of Austroads Guides. Sydney:

Austroads.

Currie, G., 2003. Planning and Design for on-Road Public Transport

(Chapter within Traffic Engineering and Management: Volume 2),

Melbourne: Institute of Transport Studies, Department of Civil

Engineering, Monash University.

Hamilton City Council, 2019a. 15-2 Integrated Transport Assessment

Requirements - Tables. [Online]

Available at: https://www.hamilton.govt.nz/our-council/council-

publications/districtplans/ODP/appendix15/Pages/15-2-Integrated-

Transport-Assessment-Requirements.aspx

[Accessed 11 November 2019].

Hamilton City Council, 2019b. Speed Management Plan. [Online]

Available at: https://www.hamilton.govt.nz/our-

services/transport/safetyaccessimprovementprogramme/road-

risk/Documents/Speed%20Management%20Plan%20-

%20V2%20June%202019.pdf

[Accessed 31 October 2019].

Hamilton City Council, 2019c. Proposed Private Plan Change 2: Te Awa

Lakes, to Hamilton District Plan, Section 42A Hearing Report, 14

October 2019. Prepared by Grant Eccles, Hamilton: Hamilton City

Council.

Lay, M., 1998. Handbook of Road Technology: Volume 2: Traffic and

Transport, Third Edition, Amsterdam, The Netherlands: Gordon and

Breach Science Publishers.

NZ Transport Agency, 2011. Trips and Parking Related to Land Use,

Research Report 453, November 2011, Wellington: NZ Transport

Agency.

Stantec, 2019a. WRTM - Local Area Validation; internal memo dated 24

October 2019 from Grant Smith (Stantec) to Sarah Loynes (Stantec),

Christchurch: Stantec.

Stantec, 2019b. Te Awa Lakes, Integrated Transport Assessment

Update Report, Prepared for Perry Group Limited, 21 August 2019,

Tauranga and Hamilton: Stantec.

Stantec, 2019c. In the Matter of the Resource Management Act 1991

and in the Matter of Proposed Private Plan Change 2 to the Hamilton

City Operative District Plan: Te Awa Lakes Private Plan Change.

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Statement of Evidence of Mark John Apeldoorn on Behalf of the

Applicant (Transport) 29 October 2019, Hamilton: Stantec.

Stantec, 2019d. Te Awa Transport Caucusing - Safety; memo dated 2

October 2019 from Sarah Loynes (Stantec) to various transport

experts, Hamilton: Stantec.

Stantec, 2019e. Te Awa PC 2: Final Model Update Report TN25 October

2019, Hamilton: Stantec.

Stantec, 2019f. Te Awa - Transport Modelling Caucusing 2, Meeting

Notes from meeting of 22 October 2019, Hamilton: Stantec.

Waikato District Council, 2019. One Public Map Viewer. [Online]

Available at:

https://maps.waikatodistrict.govt.nz/IntraMaps90/?project=Waikato&co

nfigId=b2549ae1-f643-4ac6-9586-

211ba985dd8f&project=Waikato&configId=b2549ae1-f643-4ac6-9586-

211ba985dd8f

[Accessed 6 November 2019].

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APPENDIX A - SUMMARY OF ITA UPDATE REPORT

Modelling

A.1 In his introduction to the modelling section Mr Apeldoorn

(EIC, page 5) makes some points in relation to the Plan

Change and the modelled effects of traffic associated with the

Plan Change on the existing and future road network. In

paragraph 18 (Apeldoorn EIC, page 5) Mr Apeldoorn notes

“While the directional traffic profiles of the plan change […]

are directionally different to the currently zoned and

consented employment-based demands, the peak generations

created by those profiles are broadly similar.” This is an

important point and one of the reasons behind the magnitude

of the adverse effects associated with the Plan Change. If the

Site is used for its zoned purpose, many of the traffic

movements associated with the existing zoning will be

towards the Site in the morning peak period and away from

the Site in the afternoon peak period. That is, they would be

in the opposite direction to the major traffic flows given that

many journeys along Te Rapa Road in the morning peak will

be towards Hamilton and in the evening peak many of the

journeys will be away from Hamilton. Therefore, even if the

volumes of traffic associated with the Plan Change are similar

to those associated with the zoned land use, the traffic flows

associated with the Plan Change are contributing to

congested flows whereas many of the traffic flows associated

with the zoned land use would be in the opposite direction to

those congested flows.

A.2 With regard to the additional peak hour demands associated

with the Plan Change, Mr Apeldoorn (EIC paragraphs 19 and

20) states that 453 trips in the AM peak hour (singular) and

311 trips in the PM peak hour (singular) equate to the trip

generation that might be realised from 350 to 400 houses.

Considering this from a conservative perspective (in favour of

the Applicant) Mr Apeldoorn is indicating that each house

would generate approximately (311 trips / 350 houses =)

0.89 trips in the peak hour. By contrast, suburban and outer

suburban dwellings have design trip generation rates of 1.2

and 0.9 trips per hour per household respectively (NZ

Transport Agency, 2011, p. 98).

A.3 Based on land use category “8.5 Supermarket” the design

peak hour trip generation for a 3000 m² supermarket would

be about (17.9 x 3000 / 100 =) 537 trips per hour (NZ

Transport Agency, 2011, p. 98).

A.4 The household trip generation rate (0.89 trips) is higher than

identified by Stantec (Stantec, 2019e, p. 5) and the

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supermarket rate yields 226 more trips in the PM peak than

the 311 trips identified by Mr Apeldoorn (EIC, paragraph 20).

A.5 Trip generation is an important matter for consideration in

relation to the Plan Change because of the uncertainty

associated with some of the trip generation information

provided by the Applicant. As noted in the record of a

meeting of the transport experts (Stantec, 2019f), Mr (Dave)

Smith (transport expert for Fonterra and Ports of Auckland)

and I raised questions in relation to household trip generation

rates such as those described in Table 3.2 of the Stantec

(2019e, p. 5) model update report. The Stantec (2019e)

document indicates that in the two hour AM peak period 1042

dwellings would have trip generation rates of 0.21 trips per

household “in” and 0.81 trips per household “out”; by

contrast, the two hour period PM period would have trip

generation rates of 0.84 trips per household “in” and 0.25

trips per household “out”. As recorded in the meeting notes,

I understand that the rates described in Table 3.2 (Stantec,

2019e) “[…] were only the home-based trips and there are

additional trips in the model that are associated with linked

trips […] All agreed that this explanatory text should be

provided in the modelling report […]” (Stantec, 2019f, p. 2).

To date, I have not received the updated information,

therefore, the question remains as to the adequacy of the trip

generation rates used in the WRTM model to represent

household trip generation. The reason for these questions is

that the total household trip generation used in the WRTM is

described as being ((0.21 + 0.81) x 0.57 =) 0.58 trips per

household in the AM peak and ((0.84 + 0.25) x 0.57 =) 0.62

trips per household in the PM peak, both of which are

somewhat less than typical design household trip generation

rates. While there may be a rational explanation for the

difference, it would be useful for this to be clarified to address

the uncertainty that otherwise arises in relation to the

modelling results.

A.6 With regard to the modelling, peak period references made by

the Applicant sometimes describe a one hour period and on

other occasions they describe a two hour period. Therefore,

when considering peak period information presented by any

of the parties associated with this matter, it is important to be

aware of the peak period to which reference is made. I note

that Mr Apeldoorn refers (paragraph 19) to the (singular) AM

and PM peak hour periods, however, some of the modelling

information presented is described in terms of two-hour peak

periods, to which a peak hour factor is applied to identify the

traffic volumes likely to be associated with a representative

single peak hour period.

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A.7 As recorded in the notes from the meeting of 22 October

(Stantec, 2019f), “In relation to the permitted volumes for

the 7 ha, that are partially occupied by the service centre,

these can be calculated as being (500)+(5 x15.4)= 577 per

peak hour, which equates to (577 / 0.57 =) 1012 vehicle

movements for the two hour modelled period. The equivalent

modelled flows for the commercial and service centre (from

Table 3-2 of the technical note [ (Stantec, 2019e)]) are 685

vehicle trips in the two hour AM peak period and 868 vehicle

trips in the two hour PM peak period. Or peak hour modelled

flows (at 0.57 conversion) of (685 x 0.57 =) 390 vehicle trips

per hour in the AM and (868 x 0.57 =) 495 vehicle trips per

hour in the PM peak. As such the modelled volumes in the

AM peak hour are (577 – 390 =) 187 vehicle movements per

hour less than the number of permitted trips and in the PM

peak hour the modelled volumes are (577 – 495 =) 82

vehicle movements per hour less than the number of

permitted trips. These values are based on a modelled

assumption that the 5 hectares of Te Awa Lakes Business 6

zoning activities will have the same vehicle trip generation as

the current industrial zoning on the site.”

A.8 The calculations described in the preceding paragraph were

included in the meeting notes based on feedback from Mr

Dave Smith and me. For the avoidance of doubt, I agree with

Mr Apeldoorn that we did not discuss the specifics of the

calculations at the meeting, however, Mr Dave Smith and I

proposed their inclusion in the notes to provide clarity

regarding trip generation differences to which reference has

been and will be made.

A.9 My reason for including the paragraph from the meeting notes

verbatim in this appendix is to highlight that the modelled trip

generation for the 7 ha (as an example) is less than the

permitted trip generation for the 7 ha. While I do not expect

the WRTM to identify the absolute worst case for every land

use, it is important to recognise that the trip generation

associated with the Site may be higher than has been

identified through the WRTM model. Therefore, the adverse

effects associated with vehicle movements to and from the

Site may be more significant than have been identified

through the ITA. Because of the uncertainty associated with

trip generation for the Site, I consider it important there are

appropriate hold points put in place through the Plan Change

rules to ensure development on the Site can be halted at a

given point (or at given points) to allow further analysis to be

undertaken and consideration given to whether it is

appropriate to allow the remaining portion(s) of the Site to be

developed as originally proposed through the Plan Change.

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APPENDIX B - DIFFERENCES BETWEEN PLAN CHANGE AND

PERMITTED TRAFFIC VOLUMES

B.1 As examples, with reference to Stantec (2019e, p. 20), the

2041 changes (between the Plan Change and the permitted

development) in traffic volumes turning to and from

Hutchinson Road in the peak period are as described in Table

1 below.

Table 1: 2014 difference in turning volumes at Hutchinson Road

Turning Movement Period

AM PM

Left turn out from Hutchinson Road 556 -201

Right turn out from Hutchinson Road 416 -149

Left turn in to Hutchinson Road 101 637

Right turn in to Hutchinson Road 42 505

B.2 This means that, when comparing the permitted development

with the Plan Change, approximately 970 additional vehicle

movements exit Hutchinson Road in the morning peak and

1140 additional vehicle movements enter Hutchinson Road in

the evening peak.

B.3 With respect to the Horotiu interchange, the change in traffic

volumes is as described in Table 2Error! Reference source

not found.. The first six rows of the table describe the

western side of the interchange (which accommodates

northbound movements to and from the interchange) and the

second six rows describe the eastern side of the interchange

(which accommodates southbound movements to and from

the interchange).

Table 2: Difference in turning volumes at Horotiu interchange

Turning Movement Period

AM PM

Right turn from northbound off-ramp

onto dog bone

-32 159

Left turn from northbound on-ramp

onto Great South Road

0 26

Through movement from Great South

Road onto dog bone

12 131

Left turn from Great South Road to

northbound on-ramp

5 -35

Right turn from dog bone onto

northbound on-ramp

34 27

Through movement from dog bone

onto Great South Road

164 -41

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Right turn from southbound off-ramp

onto dog bone

-3 4

Left turn from southbound off-ramp

onto Te Rapa Road (towards

Hutchinson Road)

-31 54

Through movement from Te Rapa

Road towards dog bone

200 -19

Left turn from Te Rapa Road onto

southbound on-ramp

217 -28

Right turn from dog bone (Great

South Road) onto southbound on-

ramp

18 -11

Through movement from dog bone

onto Te Rapa Road (towards

Hutchinson Road)

-37 301

The information in the table above (which is taken from (Stantec, 2019e,

pp. 18-19)) confirms the information from Table 1. For example, the 416

additional vehicles turning right from Hutchinson Road in the morning peak

must approach the eastern side of the Horotiu interchange. The 200

movements from Te Rapa Road onto the dog bone4 plus the 217 left turn

movements from Te Rapa Road onto the southbound on ramp represent

the 416 additional right turn movements from Hutchinson Road.

4 Dog bone = the twin roundabouts of the intersection connected by a solid median

island. From a plan view, the constructed form bears a resemblance to a dog’s bone.

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APPENDIX C - INTERSECTION PERFORMANCE ASSESSMENT

C.1 When considering congestion effects from the Plan Change, it

is important to also consider the intersection performance

assessment completed. Stantec ( (Stantec, 2019a, p. 1)

states “It should also be noted that we are using a strategic

model [WRTM] to check the operation of a few intersections

which is generally difficult to do.” Therefore, I consider

caution needs to be applied to the results of the intersection

modelling provided with the ITA and to which Mr Apeldoorn

refers in his Evidence in Chief.

C.2 Because the information presented is the best available I

have not presented alternative modelling results as an

argument against the information presented by Mr Apeldoorn.

However, I consider that the modelling results do not

necessarily provide an accurate indication of the effects

associated with Plan Change traffic. While similar issues are

associated with conclusions based on most forms of transport

modelling, we need to consider the implications on the

transport network if the modelling results present an overly

optimistic view of the mitigated adverse effects associated

with the Plan Change.

C.3 In his introduction to “Table 1: Local Area Validated

Intersection Performance Summary” Mr Apeldoorn refers to

modelling results included in his Appendix C and notes that

Table 1 is a summary of “these further analyses”. Based on

Mr Apeldoorn’s paragraph 28, I understand that the

intersection analyses described in Table 1 describe “[…] the

performance levels at the future 2041 year.” However, in

relation to the table there are various questions that arise

including:

(a) The intended meaning of the “full” and “zoned” model

scenarios. As noted under Issue 4 of the 13 September

2019 transportation experts Joint Witness Statement

(JWS), the experts agreed to use specific terminology

in relation to the Plan Change. The terms used by Mr

Apeldoorn are different to any of the terms described in

the JWS, therefore, it is unclear to what the modelling

results refer.

(b) Reference is made to “peak period”, however, it is

unclear whether the peak relates to a two-hour peak or

a one-hour peak.

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(c) As an example, the Horotiu East Interchange is

described in Table 1 (based on SIDRA5 modelling that is

included as Appendix E of Mr Apeldoorn’s EIC) as

having an intersection Level of Service (LoS) A for the

AM and PM peaks. However, with reference to

Appendix C of the Model Update Report (Stantec,

2019e), the interchange intersections are shown (based

on WRTM modelling) as having LoS C and D in the AM

and PM peaks when the Site is fully developed.

Therefore, questions arise regarding the likely actual

levels of service for the intersections given the apparent

conflict between the WRTM results and the SIDRA

results. The difference between the modelling results

makes it difficult to draw conclusions regarding the

magnitude of adverse effects associated with the Plan

Change.

(d) Another example is the signalised Te Rapa Road /

McKee Street intersection, which is described as having

LoS B for both the AM and PM peak periods with the

“full” and “zoned” SIDRA model scenarios (Apeldoorn

EIC, pp. 9-10). In Appendix C of the Update Report

(Stantec, 2019e) the WRTM performance of the Te Rapa

Road / McKee Street intersection is described as

follows:

(i) 2041 AM full development: D

(ii) 2041 PM full development: F

(iii) 2041 AM permitted development: D

(iv) 2041 PM permitted development: F

C.4 I accept that the WRTM is a network modelling tool and

SIDRA is an intersection modelling tool, however, Mr

Apeldoorn’s evidence does not appear to provide clarity

regarding the basis for these apparently significant

differences.

C.5 Mr Apeldoorn does not appear to provide the full picture in

relation to the benefits (or otherwise) of some of the

mitigation proposed as part of the Plan Change. For example,

in paragraph 28(d) of his EIC Mr Apeldoorn states “The

proposed signals at the McKee Street / Te Rapa Road

intersection exhibit a degree of saturation level […] of up to

5 SIDRA (or, more correctly, SIDRA INTERSECTION) is transport modelling "[…]

software used as an aid for design and evaluation of individual intersections and networks of intersections." Refer http://www.sidrasolutions.com/

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0.81.” However, he does not appear to have provided a

direct comparison of the performance of the intersection

without signals compared with its performance with signals.

C.6 I have searched the ITA Update Report (Stantec, 2019b) for

reference to the performance of the unsignalised Te Rapa

Road / McKee Street intersection and note (inter alia):

(a) “In the evening peak period intersections on Te Rapa

Road at and around McKee Street are at LoS D-E in the

base case without the plan change and these

deteriorate to LoS D-F with the plan change. Again, a

response at McKee Street is expected to significantly

address this;” (paragraph 6.66, page 50).

(b) “The McKee Street intersection is shown as operating at

LoS E in the PM peak for both the base and with plan

change cases. It is likely that a response (as indicated

in the 2021 analysis) to this intersection will result in

both an intersection as well as a link LoS improvement.”

(paragraph 6.69, page 51).

(c) “It is evident that McKee Street intersection is currently

and will continue to be a constraint in the network

without remedy.” (paragraph 6.85, page 59.

(d) “[…] an upgrade to this intersection is needed in the

short term to address congestion and delay unrelated to

the proposal.” (paragraph 6.112, page 82).

(e) “The introduction of a signalised intersection at McKee

Street that will provide for signal controlled pedestrian

crossing of the carriageway […] Additionally, cycle paths

will be separately established to safely guide cyclists

through the intersection […]” (paragraph 7.1, page 92).

C.7 Therefore, on balance, it appears there is merit in the

Applicant’s proposal to fund signalisation of the Te Rapa Road

/ McKee Street intersection. However, it would be useful for

the Applicant to supply information that provides an

understanding of the unsignalised performance of the

intersection.

C.8 Notwithstanding the concerns I have raised regarding the

applicability of the traffic volumes and levels of service

identified to date through the modelling (both network and

intersection), Tables 6.2 and 6.3 of the Model Update Report

(Stantec, 2019e, pp. 15-16) indicate that the changes in level

of service due to the Plan Change are generally not significant

to the extent that the levels of service are changed by a letter

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value (for example, from LoS E to LoS F). However, each

level of service describes a range of delays and the values

relate to the intersection as a whole rather than individual

movements at each intersection. Therefore, you could have a

mid-range level of service (for example LoS C) where the

intersection as a whole is performing at a reasonable level,

but the level of service for the intersection may result from a

very poor level of service for a given approach and better

levels of service for other approaches. The other matter in

relation to levels of service is that LoS F is an open-ended

scale; therefore, comparing LoS F for one scenario with LoS F

for another scenario does not mean that nothing has

changed. It may mean that a poor level of service has

deteriorated further, with the “further” ranging in scale from

very little to an infinite deterioration.

C.9 However, based on information in Tables 6.2 and 6.3

(Stantec, 2019e), it is clear there will be congestion on the

transport network in the vicinity of the Site regardless of

whether the Site is used for its currently permitted purpose or

used for the proposed Plan Change purposes.

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APPENDIX D - WALKING AND CYCLING

D.1 This appendix describes my consideration of walking and

cycling aspects of the Plan Change.

D.2 I agree with Mr Gray (EIC, paragraph 30) that “[…] the site is

poorly connected for walking, cycling and passenger transport

and will either result in adverse safety effects or result in

greater reliance on low occupancy vehicles, such as cars.” I

also consider that any improvements to walking and cycling

facilities through the Plan Change will result in minimal

changes to the wider transportation effects to the local and

State highway roading networks.

D.3 I agree with Mr Apeldoorn (EIC, paragraph 34(b)) that the Te

Rapa Road corridor between Hutchinson Road and Church

Street presents a higher risk environment for cyclists due to

the existing 80 km/h speed limit than would occur if the

speed limit is reduced to less than 80 km/h.

D.4 To the north of the Hutchinson Road intersection, Hamilton

City Council (Hamilton City Council, 2019b) has identified in

their Speed Management Plan that 80 km/h is the intended

speed limit on Te Rapa Road as far south as Ruffell Road.

That is, the “higher risk environment” to which Mr Apeldoorn

refers, is presently intended to remain.

D.5 I agree with Mr Apeldoorn that the risks presented to cyclists

using Te Rapa Road are higher than desirable. Ideally, where

motor vehicle speeds are at a level such that collisions with

cyclists are likely to result in death or serious injury, it is

desirable for cyclists to be separated from motor vehicles.

However, my understanding is that Hamilton City Council

does not presently intend to provide separate facilities for

cyclists along Te Rapa Road nor (as noted above) for the

speed limit to be reduced under the Hamilton City Council

Speed Management Plan (Hamilton City Council, 2019b).

D.6 While I agree with Mr Gray that the Te Rapa Road signalised

pedestrian / cycle crossing facilities provided for vulnerable

road users must be fit for purpose and not compromise safety

for those road users, I have concerns regarding the potential

for a raised platform to be associated with a signalised

crossing facility on Te Rapa Road. While a raised platform

may be beneficial for the relatively small number of

pedestrians and cyclists likely to be crossing Te Rapa Road,

the provision of such a facility needs to be balanced against

the needs of through traffic (particularly heavy commercial

vehicles (HCVs)) that uses Te Rapa Road.

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D.7 Mr Apeldoorn refers (Apeldoorn EIC, paragraph 34(c)) to

paragraph 5.10 of the ITA in which reference is made to the

Applicant’s proposal for “Connectivity at multiple points on

[…] the river frontages […]” to provide walking and cycling

access. While I consider the Te Awa River Ride (River Ride) is

more likely to be used by active mode users travelling to and

/ or from the Site if there is good connectivity to the River

Ride, it would be useful for the Applicant to provide more

information as to how the connections from the Site to the

River Ride will be achieved given the topography across which

those connections are to be provided.

D.8 Recognising that design detail is not required at the Plan

Change stage, the potential vertical alignment of the

connections to the River Ride may discourage some potential

active mode users from accessing the River Ride.

Notwithstanding that the fleet of vehicles presently defined as

bicycles may change (for example, electric bikes), I consider

it likely that the types of vehicles associated with active mode

use will be adversely affected by steep gradients.

D.9 As examples of my concerns regarding the vertical alignment

that may be associated with connections from the site to the

River Ride, I have included below Figure 5 Error! Reference

source not found.and Figure 6Error! Reference source

not found., which illustrate the existing connection from the

eastern end of Hutchinson Road to the River Ride and a

portion of the vertical gradient between the Site and the River

Ride.

Figure 5: Looking west towards Hutchinson Road along the connection from

Hutchinson Road to the River Ride. Photograph shows the vertical sag curve that active mode users must traverse to access the River Ride.

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Figure 6: River Ride looking north from near the Hutchinson Road connection

to the River Ride. The Site is on the left and the Applicant is proposing connections from the Site to the River Ride along the section of the path between here and the Waikato Expressway bridge across the Waikato River.

D.10 I agree with several of the points Mr Apeldoorn has made in

relation to walking and cycling; in particular:

(a) If investment linked to the Plan Change is to be

made for walking and cycling infrastructure it is

preferable for that investment to be made on

those routes that provide for safer journeys for

cyclists. In the case of the Site, the safer route is

the River Ride (refer Apeldoorn EIC, paragraph

37(b)).

(b) Confident cyclists are likely to continue to use Te

Rapa Road (refer Apeldoorn EIC, paragraph

37(c)), therefore, it is appropriate to provide for

those cyclists. However, a careful balance is

required between making the Te Rapa Road route

safer for confident cyclists while not making it

attractive to less confident cyclists. I consider that

the Applicant has proposed a reasonable balance

by providing facilities for cyclists at those locations

likely to represent the greatest risk (for example,

the Fonterra ramps) while not proposing extensive

upgrades that might otherwise encourage less

confident cyclists onto Te Rapa Road.

(c) Notwithstanding the road safety risks associated

with encouraging cyclists to use the Horotiu

interchange, I consider it preferable to encourage

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cyclists to access the shared path on the western

side of the Waikato Expressway (refer Apeldoorn

EIC, paragraph 37(d)) than to not provide facilities

that might otherwise encourage cyclists to use the

shoulders of the Expressway itself.

Notwithstanding that, cyclists do presently ride on

the Expressway as illustrated in Figure 7Error!

Reference source not found. below; such

journeys may be encouraged if residential

dwellings are established at the Site.

(d) While I consider it preferable for cyclists not to use

the Expressway, as noted below, I have concerns

regarding the road safety risks associated with the

route between the Site and the shared path on the

western side of the Expressway, which involves

numerous road crossings on the Horotiu

interchange.

(e) Mr Apeldoorn is correct (refer Apeldoorn EIC,

paragraph 38) that I invited cyclists among the

145 colleagues in our Hamilton office to advise

whether they would use the River Ride or Te Rapa

Road for journeys from the Site to The Base (as an

example of a cycling journey that could be

undertaken). While the sample size was relatively

small, the results indicate that approximately 50%

of people would use the River Ride and 50% would

use Te Rapa Road. One of the reasons given for

not using the River Ride is the safety and

efficiency implications of encountering other active

mode users on the less structured River Ride

route. As volumes of cyclists and pedestrians

increase on the River Ride, the safety and

efficiency issues are also likely to increase. Once

again, it is a question of balance, however, I am

concerned that the Plan Change will encourage

cyclists to use the River Ride, which will reduce

the level of service on the River Ride and may

result in cyclists being encouraged onto Te Rapa

Road. Widening the River Ride and / or including

markings to encourage lane discipline may assist

to reduce the potential for conflict between active

mode users on the River Ride. However, based on

my observations, the conventions ordinarily

observed on the road network (such as travelling

on the left) are not always followed on off-road

paths.

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Figure 7: Cyclist travelling north on Waikato Expressway (photograph taken

from the northbound on-ramp at the Horotiu interchange).

D.11 I am not convinced that the travel times along Te Rapa Road

(refer Apeldoorn EIC, paragraph 37(b)) will be similar for

cyclists when compared with travel times along the River

Ride. Therefore, depending on the ability and confidence of

the affected cyclists, some cyclists will choose to use Te Rapa

Road in preference to the River Ride because the route is

shorter in terms of travel time and distance.

D.12 The Applicant has proposed enhancements to the River Ride

that I consider will increase the likelihood for cyclists to use

the River Ride in preference to Te Rapa Road or some other

on road routes that will take cyclists to similar destinations to

the south of the Site. However, it would be useful for

clarification to be provided regarding the works proposed for

cyclists given that some of the infrastructure works illustrated

by Mr Apeldoorn (refer Apeldoorn EIC, Figure 4) are not

directly aligned with works illustrated elsewhere in his

statement (for example, the “River Ride – Ethos - Route for

all” diagram that is the 11th diagram in Appendix A). In this

example, the Appendix A diagram illustrates the existing

walking and cycling connection from the Waikato Expressway

overbridge through to Horotiu Bridge Road, while the Figure 4

diagram does not.

D.13 I consider that provision of the “missing link” along the River

Ride (illustrated by the dotted yellow line on Figure 4 of Mr

Apeldoorn’s EIC) is an infrastructure feature that is likely to

significantly increase the potential for cyclists to use the River

Ride. However, I understand establishing the link would

require approval from third parties, therefore, it is unclear

when or if this link will be or could be provided.

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D.14 For the River Ride improvement work from the northern part

of the Plan Change site through to south of Pukete Road in

the south, I consider that one of the key aspects of the River

Ride that it would be desirable to address is the “missing link”

between the southern boundary of the Fonterra site through

to Pukete Road. However, because construction of the link

requires third-party approval, it may not be practicable to

provide the link. This in turn reduces the desirability of the

River Ride and may result in some walking and cycling

journeys being replaced with private motor vehicle journeys

and / or some cycling journeys being transferred onto Te

Rapa Road.

D.15 Similarly to provision of the “missing link”, Crime Prevention

Through Environmental Design (CPTED) improvements that

increase the desirability of the River Ride will increase the use

of the route and have the potential to reduce private motor

vehicle journeys to and / or from the Site. While it appears

unlikely that the change in private motor vehicle journeys will

be significant as a result of the River Ride CPTED

improvements, I consider it important for the improvements

to be made to maximise the attractiveness of the River Ride

D.16 Mr Apeldoorn makes reference (EIC, paragraph 81(e)) to the

distance from the Site to schools. Based on a route from the

approximate centre of the Site to Horotiu School via the River

Ride the journey is about 1.9 km.

D.17 In Appendix B of Mr Apeldoorn’s evidence Stantec (2019d)

notes that to access schools for children aged 11-18, “[…] it is

anticipated that a reasonable number of older children will

cycle, making use of the River Path (say 5%).” Using

Ngaruawahia High School and Rototuna Senior High School as

examples, the cycling journey from Hutchinson Road to those

schools is approximately 9.3 km and 9.4 km respectively.

While the Applicant’s assumption that 5% of older children

will cycle to the schools may be correct, I consider it unlikely

that many (if any) pupils would undertake round-trip cycling

journeys of more than 18 km for travel to and from school.

D.18 While the proximity of the Site to the River Ride (Gray EIC,

paragraph 31) is a significant benefit from a vulnerable road

user perspective, because it allows walking and cycling

journeys to be carried out away from the road transport

network, it needs to be kept in mind that the proportion of

trips associated with the Plan Change that will be assigned to

the River Ride is likely to be relatively small. The reason for

this is, in part, because of the distance from the Site to trip

attractors such as those associated with employment,

education, and recreation.

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D.19 Any vulnerable road user journeys that require pedestrians

and / or cyclists to traverse the Horotiu interchange expose

those road users to vehicle movements at the interchange

where many of the motor vehicles have exited from or are

intending to enter onto the Expressway with its current

100 km/h speed limit. While there is potential for the speed

limit within the interchange roundabouts to be reduced, the

vehicle operating speeds are unlikely to be significantly

different to what they are at present.

D.20 The journey from Te Rapa Road alongside the Site to the

shared path on the western side of the Expressway follows

the route illustrated in Figure 8 below.

Figure 8: Route from Te Rapa Road adjacent to the Site (bottom right hand corner) to shared path on western side of Expressway (image source: Waikato District Council (2019))

D.21 The images below illustrate the sight distance from crossing

locations and the volumes and types of traffic to which

pedestrians need to give way at the crossing locations on the

Horotiu interchange.

A B

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Figure 9: Pedestrian’s view from the median to approaching traffic at crossing

location A (refer Figure 8Error! Reference source not found.).

Figure 10: Pedestrian’s view from the side of the Expressway on-ramp to

passing traffic at crossing location B (refer Figure 8Error! Reference source not found.).

D.22 While it is appropriate and important for there to be provision

for vulnerable road users at the interchange, I am concerned

that the Plan Change will promote higher volumes of

vulnerable road users at the interchange than were

anticipated at the time the interchange was designed. Those

concerns relate to the potential for vulnerable road users to

be exposed to relatively high volumes of relatively high speed

traffic, which is a situation that may not arise to the same

extent under the existing zoning for the Site.

D.23 Taken as a whole, there is merit in the facilities the Applicant

proposes to provide for vulnerable road users. However,

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there are also shortcomings with that mitigation as described

above. In my opinion, any enhancements to the River Ride to

increase the uptake of active travel modes (particularly

cycling) to and from the Site need to be designed to ensure

that all users (including walkers) are safely catered for.

D.24 In addition, there are shortcomings associated with the

vulnerable road user routes in the vicinity of the Horotiu

interchange. While these are existing shortcomings, I

consider that if the Site was used for its Industrial zoned

purpose, the adverse effects associated with them would not

be as much of an issue. However, unless the form of traffic

control at the interchange is fundamentally changed (for

example, from the roundabout / dog bone configuration to

traffic signals) or grade separated facilities are provided for

vulnerable road users, there are very limited solutions

available to improve safety at the interchange for vulnerable

road users. However, traffic signals are not typically

regarded as a safe system solution, therefore, they may not

be appropriate.

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APPENDIX E - RESPONSES TO THE EVIDENCE OF MR GRAY

E.1 With regard to the Evidence in Chief of Mr Gray, I note that

he did not have the advantage of time available to the other

experts because of the earlier deadline for his evidence.

E.2 Mr Gray notes (EIC, paragraph 26) that “With additional

development the Te Rapa Road corridor becomes sufficiently

less attractive because of congestion and delays that traffic

diverts to other routes.” From a State highway perspective,

the potential exists for traffic to divert onto SH1 (the Waikato

Expressway), which will introduce effectively local trips onto

an inter-regional corridor. While I consider this undesirable

from a trip assignment perspective, based on the modelling

results provided it appears unlikely that the relatively small

amount of traffic that might be diverted on to SH1 will be of a

magnitude such that it creates significant adverse effects on

the Expressway.

E.3 I agree with Mr Gray (EIC, paragraph 30) that “[…] the site is

poorly connected for walking, cycling and passenger transport

and will either result in adverse safety effects or result in

greater reliance on low occupancy vehicles, such as cars.”

E.4 While the proximity of the Site to the River Ride (Gray EIC,

paragraph 31) is a significant benefit from a vulnerable road

user perspective, because it allows walking and cycling

journeys to be carried out away from the road transport

network, it needs to be kept in mind that the proportion of

trips associated with the Plan Change that will be assigned to

the River Ride is relatively small. The reason for this is, in

part, because of the distance from the Site to trip attractors

such as those associated with employment, education, and

recreation.

E.5 I agree with Mr Gray (EIC, paragraph 34) that mitigation such

as four laning of Te Rapa Road is likely to be disproportionate

in relation to the adverse effects associated with the Plan

Change. In that regard, I consider the Applicant’s approach

of presenting mitigation (such as signalising the Te Rapa

Road / McKee Street intersection) to offset some of the

adverse effects associated with the Plan Change has been

useful. The alternative of trying to identify proportional

contributions to address incremental adverse effects at a

range of locations is complex by comparison and does not

necessarily result in mitigation being provided in a timely

manner.

E.6 Mr Gray has raised various comments regarding the proposed

mitigation in his Table 2 (Gray EIC, page 13), I have adopted

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his table format and commented as follows in relation to

some of these matters.

Proposed mitigation Timing / comment in response

With commencement of the Plan Change

a “Te Rapa Road /

McKee Street

Intersection -

Signalisation”

As noted previously, it is useful that the

Applicant has identified a discreet

package of mitigation that can be

included from the commencement of the

Plan Change. However, it would be

useful to be provided with information

regarding the performance of the

unsignalised intersection so this can be

compared with the performance of the

signalised intersection.

I agree with Mr Gray that it is desirable

for there to be flexibility in this

mitigation; for example, there may be

benefit in creating a signalised

crossroads that incorporates the

presently closed Old Ruffell Road and

closes the existing Te Rapa Road / Ruffell

Road signalised intersection. I

acknowledge that neither the Applicant

nor Mr Gray has proposed this, however,

this is an example of the flexibility that

could be considered for inclusion with the

mitigation.

d “Te Rapa Road

Signalised

Pedestrian/Cycle

Crossing”

While I agree with Mr Gray that the

facilities provided for vulnerable road

users must be fit for purpose and not

compromise safety for those road users,

I have concerns regarding the potential

for a raised platform to be associated

with a signalised crossing facility on Te

Rapa Road. While a raised platform may

be beneficial for the relatively small

number of pedestrians and cyclists likely

to be crossing Te Rapa Road, the

provision of such a facility needs to be

balanced against the needs of through

traffic (particularly HCVs) that use Te

Rapa Road.

g “Te Awa River

Trail

As noted in the body of my statement, I

consider that one of the key aspects of

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improvement

works from the

northern part of

the site, south to

Pukete Road.”

the River Ride that it would be desirable

to address is the “missing link” between

the southern boundary of the Fonterra

site through to Pukete Road. However,

because construction of the link requires

third-party approval, it may not be

practicable to provide the link. This in

turn reduces the desirability of the River

Ride and may result in some walking and

cycling journeys being replaced with

private motor vehicle journeys and / or

some cycling journeys being transferred

onto Te Rapa Road.

gii “CPTED

improvement”

Similarly to provision of the missing link,

CPTED improvements that increase the

desirability of the River Ride will increase

the use of the route and have the

potential to reduce private motor vehicle

journeys to and / or from the Site. While

it appears unlikely that the change in

private motor vehicle journeys will be

significant as a result of the River Ride

CPTED improvements, I consider it

important for the improvements to be

made to improve the safety and

maximise the attractiveness of the River

Ride.

After Plan Change Commencement - proposed beyond 500 units.

j “Hutchinson

Road / Te Rapa

Road

Intersection -

not construction

- monitoring

recommended”

I agree with Mr Gray that mitigation

should not be arbitrarily applied based

on a specified level of development

unless the mitigation is required to

address adverse effects. However, I also

consider it important that potential

future mitigation options (similar to the

Te Rapa Road / McKee Street

signalisation) are available and identified

at an early stage so the scale of

mitigation that is likely to be appropriate

can be identified.

k “Te Rapa Road -

Additional

northbound/

southbound lane

between

Fonterra

Similarly to upgrading the Te Rapa Road

/ Hutchinson Road intersection (item j in

Mr Gray’s table), I consider that

mitigation such as providing additional

capacity on Te Rapa Road should be

subject to need (as identified through an

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Interchange and

Hutchinson Road

[…]”

ITA) rather than arbitrary development

thresholds. However, again, I consider it

desirable for potentially appropriate

mitigation, such as increasing capacity

on Te Rapa Road, to be identified at an

early stage.

l “Hutchinson

Road Minor

Arterial and

Collector Road

Cycle and

Pedestrian

Facilities”

There is little merit in providing localised

facilities for vulnerable road users unless

those facilities connect with other

facilities within the wider transport

network. While the other facilities may

be planned (as opposed to already

constructed) I agree with Mr Gray

regarding the importance of there being

connectivity for the vulnerable road user

transport network.

n “Pedestrian/cycle

connectivity

between the

Waikato

Expressway

shared path and

the northern

part of the plan

change”

Notwithstanding my opinion that there

will be relatively few walking and cycling

journeys associated with the Plan

Change, it is desirable to encourage

residents of and visitors to the Site to

adopt active modes (and / or

alternatives to private motor vehicles).

Establishing connectivity from the outset

will promote active mode use from the

outset. Therefore, I agree with Mr Gray

that the improved connectivity with the

Waikato Expressway shared path should

be established from the outset.

However, I also consider it desirable to

have addressed the road safety issues

likely to be associated with pedestrians

and cyclists travelling through the

Horotiu interchange.

E.7 I have concerns regarding the potential for road users to be

distracted by activities on the Site and particularly activities

associated with the Lake and Adventure Park elements of the

Plan Change. While Mr Gray has referred (EIC, paragraph

38a) to “[…] rules to avoid driver distraction that has an

adverse effect on safety.” I consider that the rules associated

with screening the activities on the Site (and particularly at

the Adventure Park) from road users should be definitive and

require that there is no visibility from the transport network

to activities at the Adventure Park. Noting that it may be

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difficult to completely screen activities, given the distance

over which road users (in particular in the Waikato

Expressway) may be able to view the Adventure Park, I

consider the screening is most important in close proximity to

the Adventure Park where road users will be most readily able

to view activities and such viewing will require drivers to

divert their gaze from the road in front of them. However, to

screen the Lake and Adventure Park from close visibility it

may be necessary for screening to be provided along the

Waikato River boundary of the Site as well as along the

Waikato Expressway boundary of the Park, which appears

likely to also result in the Lake and Park being screened from

distant view.

E.8 I consider that Mr Gray has introduced an inappropriate

element of doubt in relation to the screening by referring to

distraction “that has an adverse effect on safety”. Taking into

account the very wide range of road user interests and

abilities I consider it unlikely agreement could readily be

reached in relation to which activities are likely to have an

adverse effect on safety. Therefore, because of the

potentially novel nature of activities on the Lake and at the

Adventure Park, I consider there should be complete visual

screening of the Lake and the Adventure Park from the road

network.

E.9 While I consider the proportion of road users that will be

distracted to the extent there are adverse effects on safety

will be relatively low, it needs to be kept in mind that crashes

are often defined as “rare, random, multi-factor events

always preceded by situation in which one or more road users

have failed to cope with their environment”. Given that we

have the opportunity to fully screen activities on the Lake and

at the Adventure Park from road users and therefore remove

a factor from the multi-factor nature of crashes, I consider

the screening to be an important component of plan change

requirements. Such an approach aligns well with the Vision

Zero approach to road safety to which reference is made in

paragraph 1.9 of the ITA (Stantec, 2019b).

E.10 Mr Gray refers (EIC, paragraph 38c) to the need for

clarification in relation to travel demand management. I

support his view and note that travel demand management

measures are less likely to be as successful if the Site is used

for the Plan Change land use than if it is used for the existing

Industrial zoned land use. While successful travel demand

management that reduces reliance on single or low occupancy

private motor vehicles is a desirable outcome, which should

be encouraged, I consider caution should be applied to

assuming that travel demand management will make a

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significant difference to the number of vehicle movements

associated with the Plan Change.

E.11 I agree with Mr Gray (EIC, paragraph 38d) that

comprehensive design to incorporate appropriate mitigation

measures should be carried out at the earliest practicable

stage so that potentially suitable mitigation options are not

obstructed due to committed subdivision measures.

E.12 Mr Gray concludes (EIC, paragraph 40) that the Plan Change

will result in traffic increases “[…] on a busy corridor not well

suited to pedestrian and cyclist connectivity.” However, the

Applicant is proposing some measures (such as

improvements to the River Ride) that will partially offset the

adverse safety effects associated with vulnerable road users

travelling on the Te Rapa Road corridor.

E.13 With regard to the congestion to which Mr Gray refers in the

same paragraph (40), it needs to be kept in mind that the

Plan Change is intended to allow trip generation greater than

would be permitted under the existing Industrial zoning and

the directional distribution of that trip generation is likely to

be opposite to the distribution that would occur under the

existing zoning. That is, the Plan Change trip generation will

exacerbate capacity issues because it adds to the

predominant traffic flows rather than promoting traffic flows

in the opposite direction.

E.14 Notwithstanding the point above, I accept that congestion of

the Te Rapa Road corridor (Gray EIC, paragraph 41) is likely

to require physical works to address the congestion

irrespective of the Plan Change. However, from a State

highway perspective, increasing congestion on the Te Rapa

Road corridor is likely to encourage trips to be reassigned to

other corridors (such as the Waikato Expressway) and result

in local trips being diverted to an interregional corridor.

E.15 Mr Gray highlights (EIC, paragraph 42) that the Applicant has

identified transportation mitigation measures to address the

adverse effects of the Plan Change. The mitigation measures

identified will not address all adverse effects of the Plan

Change, however, by offering to provide discrete mitigation

elements the Applicant has presented a mitigation solution

that I consider is preferable to the approach where adverse

effects are mitigated in a piecemeal fashion through

development contributions.

E.16 I note that Mr Eccles (Hamilton City Council, 2019c) is reliant

on the evidence of Mr Gray, however, there are several

matters in relation to Mr Eccles statement that indicate

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optimism regarding the likely uptake of alternative transport

modes that are not directly related to private motor vehicles.

In that regard, I consider caution should be applied to any

assumptions that there will be significant mode shift from

private motor vehicles to alternative transport modes to the

extent that the adverse effects on the road network will be

significantly reduced. The assumptions made by Mr Eccles

(Hamilton City Council, 2019c) to which caution should be

applied include:

(a) Mr Eccles (paragraph 4.19) considers that public

transport can be developed to the Site. Strictly

speaking, I agree with him, however, the question

is whether the public transport route can be

efficient and allow the route to go through the Site

rather than requiring a return journey along the

same route within the Site.

(b) Mr Eccles makes reference (paragraph 4.22) to

network capacity and notes that the Plan Change

would consume capacity earlier than might

otherwise be anticipated. However, he does not

appear to refer to the uncertainty associated with

trip generation / distribution and the importance of

staged analysis being undertaken.

(c) For the reasons noted in my statement, I consider

Mr Eccles is optimistic (paragraph 4.36) regarding

the potential for the River Ride to accommodate

walking and cycling journeys of a quantum that

makes a material difference to the adverse traffic

effects of the Plan Change on the road network.