Tararua District Council elected members submitted their submission on the proposed toll of the Te Ahu a Tūranga – Manawatū Tararua Highway on 7 October.

The submission, an eight-page letter, signed by the mayor, was submitted to the New Zealand Transport Agency - Waka Kotahi (NZTA) and outlined Councils opposition to the toll proposal.

Our submission reads:

Tēnā koe

Tararua District Council submission on the proposal to toll Te Ahu a Turanga: Manawatū Tararua Highway

Thank you for the opportunity to provide this submission on behalf of Tararua District Council, on the NZTA Waka Kotahi proposal to toll Te Ahu a Turanga: Manawatū Tararua Highway.

Our Tararua community has spoken very loudly to highlight their outrage at this proposal, shown overwhelmingly by the high level of engagement and large turnouts to community organised public meetings. This submission supports that community sentiment.

Tararua District Council does not support the proposed toll, or a toll of any amount, on the Te Ahu a Turanga: Manawatū Tararua Highway, for the reasons outlined below.  

We support the tolling of new roads in principle to pay for new infrastructure but only when there are safe local alternatives, the toll is affordable for the local community, and tolling is part of discussions at the outset as part of a robust consultation process. None of these things apply in this case.

We are deeply concerned that tolling was never discussed throughout land acquisition and the consenting process and know it would have led to very different conversations, especially with Iwi.

We do not consider this road meets NZTA’s criteria for its own Tolling Policy stated in the 2024-27 NLTP Principles and Policies.  We have also been asked by members of the community to consider a request for a judicial review of this consultation, due to expectations of Section 48 of the Land Transport Management Act 2003 not being met in respect to no regional or community support for the proposal, and a consultation process undertaken without timely sharing of key information including the Tolling Assessment and Assessment Reports.

Not a new road – a replacement road 
Under Gate 1 of NZTA’s Tolling Policy, Legislative Requirements and Practicality Test, this highway is not a new road when you consider the context. This is a replacement road for SH3 that was irreparably damaged by slips in 2017 and was permanently closed. The Detailed Business Case for the highway repeatedly references the ‘replacement road’.

This is a replacement road built in a new location because it was impossible to rebuild in the existing location. This does not reduce the road’s intent and purpose as a replacement road.

The Minister of Transport has referred to the highway as a ‘significant upgrade.’ While the local community is grateful for the road after seven years without a proper state highway connection – we do not agree that it is a significant upgrade.

NZTA’s tolling policy states ‘NZTA may assess all state highways and significant upgrades for tolling at 2 separate stages and for different purposes: Detailed business case: assessing the use of tolling to advance the construction of a road. On approval for construction: assessing the use of tolling for PPP (or similar) repayments and/or the operation and maintenance of the road.’

The highway is not a significant upgrade – the original SH3 it replaces was flat and took seven minutes. The highway is a significant upgrade only when compared to the two local detour roads that have carried state highway traffic due to there being no other alternative. The extended time that state highway traffic has diverted to these routes does not make Te Ahu a Turanga: Manawatū Tararua highway comparable to the temporary routes. On measures of journey time and gradient, the original SH3 - if it were able to have been rebuilt in situ - would be superior.

Tolling was not considered during the Detailed Business Case or on approval of construction, or at any point during the project’s development. As such, this condition is not met.

The alternatives are not feasible or safe
Gate 1 of NZTA’s Tolling Policy requires that a feasible free alternative road be available. We assume the definition of feasible to include safe and note the Saddle Road and Pahiatua Track are not feasible or safe.

We know the accident data represents only a portion of the accidents that occur on these roads, which NZTA has acknowledged are unsafe, notably in the Detailed Business Case (below) as well as in 2019 when a permanent speed limit of 60km was introduced for the Saddle Road because the accident rate had increased 88%.

“Even with improvement works on Saddle Road, both routes are steep, narrow and winding resulting in poor safety, resilience and efficiency outcomes. These routes are not considered to provide an appropriate level of service for the State Highway 3 link.”

“While Saddle Road is sufficient as a short-term alternative route, it is not an appropriate long-term option as a regionally significant state highway.”

Over 155 reported accidents have occurred on the Saddle Road since 2018 and three people sadly lost their lives between 2018 and 2020. The Pahiatua Track is almost as dangerous with around 13 accidents a year. This is an unacceptable level of safety.

Te Whatu Ora MidCentral is struggling with capacity in both the emergency department and wards. Our local ambulance officers have reported that accidents requiring emergency services are the only accidents reported - many others go un-reported.

The Ministry of Transport puts the social cost of road crashes and injuries in their 2020 update at $4,464,000 per fatality, $467,000 per serious injury and $23,300 per minor injury1. These figures consider the loss of life and life quality, loss of output due to that loss of life and life quality, and medical, legal and vehicle damage costs. Any decision that encourages use of the less safe alternative routes can put a huge social cost onto our community making the financial impact of the tolls a negative prospect fairly quickly.

No amount of maintenance can make these alternative routes safe for the volume of traffic likely to continue if the highway is tolled, due to their inherently narrow, windy and steep terrain that allows no room for error.

These roads are also not feasible or resilient alternatives due to the number of days a year they are closed. Slips are caused by drainage issues and the geology of both alternative roads and increasing extreme weather events would suggest that regular slips are likely to continue. This reduces the feasibility of the alternative routes as long-term options for large volumes of traffic.

Traffic volumes are insufficient to meet the criteria 
Gate 1 of NZTA’s Tolling Policy requires that at least 10,000 vehicles are likely to travel the road per day. We draw your attention to two points in this requirement, firstly the total number of vehicles required to travel on the single road in question; and secondly, the likelihood of that volume travelling on the highway a day.

Firstly, the tolling assessment states the projected traffic volume likely to travel on the highway in 2025 is 10,902 based on traffic volumes before the Gorge Road was closed. The tolling assessment doesn’t say what the pre-closure figure is, so we assume it to be the number that was used in the Detailed Business Case, which was 7,600 vehicles a day.

There is no explanation in the abbreviated tolling assessment report that was released to the public part-way through consultation under OIA, to explain how 7,600 in 2017 is likely to reach almost 11,000 in 2025. This is a 43% increase over eight years (5% a year), during which time our regional economy was defined by Covid 19 and the negative growth that followed, inflationary pressures, low employment growth and recession. A redacted Tolling Assessment Report released on the last working day of consultation, also under OIA, refers to traffic volume modelling at a rate of 3% a year, which would not reach 10,000 by 2025.

It appears the figures in the tolling assessment have been overly inflated to get over the 10,000 threshold. The likely total traffic volume travelling on the highway is a vital figure for the tolling assessment and it is reasonable to expect this figure to be based on actual, and accurate, traffic volumes.

NZTA did not provide up to date traffic volume counts for the Saddle Road and Pahiatua Track in the tolling assessment, which was only made available to the public under the Official Information Act halfway through consultation. This is highly irregular and draws into question the reliability of the tolling assessment and the robustness of the consultation process.

In the absence of useful data, Tararua District Council’s roading team placed traffic count strips on the Saddle Road at the Woodville end and on the Pahiatua Track, on Tuesday 24 September. These locations were chosen to only pick up traffic on these roads, and not surrounding areas. Traffic counts are usually left longer than seven days, however, given NZTA was not able to provide any recent counts, the team took a reading after seven days.

The Saddle Road counter reported 6935 total vehicle movements with 16.63% heavy vehicles.  The Pahiatua Track reported 3001 total vehicle movements with 14.3% heavy vehicles.

This is a total of 9936 vehicle movements a day. This volume reflects a weekend spike with school holidays starting and an All Blacks game in Wellington, and it also includes highway construction traffic on the Saddle Road. A traffic count for a longer period would provide a more accurate annualised volume, along with a count of highway construction vehicles that would need to be deducted from the total. We will continue to take traffic counts at these locations.

We would like to note the peculiar behaviour of NZTA in relation to its own traffic. Midway through consultation our roading team was told by NZTA staff they had no recent counts and on 24 September, NZTA also put out traffic counts – one in Aokautere at a location that would also pick up traffic from multiple subdivisions and Masterton traffic, and one in Ashhurst that would pick up additional construction traffic diverting to sites at the bottom of the Saddle Road.

In the week prior to consultation closing, we were asked for comment by a media agency on traffic count figures collected by NZTA in August 2023, prior to consultation starting. These figures were shared with us and included a count for the Pahiatua Track that was over 1400 traffic movements higher than our Pahiatua Track reading. We assume NZTA’s August traffic counters were placed in the same locations as their counters on 24 September, which would explain the unusually high reading for the Pahiatua Track.

We question why NZTA did not share these traffic counts and their locations with our roading team when asked, or with the public in the consultation material. The fact that NZTA collected this data and chose not to share it as part of the consultation further undermines what we consider to be a flawed process.

With regard to the second aspect of this criteria – the likelihood of at least 10,000 vehicles taking the highway on a given day – we note that a portion of local traffic travelling from Pahiatua to Palmerston North is likely to continue to take the Pahiatua Track even if the highway is not tolled, as the Pahiatua Track is the most direct route to the Massey end of the city and the centre of Palmerston North, with a travel distance 10km less than the replacement road. Traffic from the Wairarapa will also likely continue to use the Mangamaire-Pahiatua Track route, with is 19km less than taking the highway.

The tolling assessment states that in 2025, 6856 vehicles would use the highway a day – which is well below the 10,000 threshold – and that 3088 would use the Saddle Road. The assessment does not specify how many may take the Pahiatua Track, but these figures suggest it to be 976 vehicles a day from a total of 10,920. Considering our roading team’s traffic count for the Pahiatua Track was 3001, we expect significantly more than 1000 would continue to use this southern detour.

There doesn’t appear to have been any allowance in the tolling assessment for the likelihood of this existing local traffic pattern continuing, which would reduce the potential total traffic travelling on the highway. We suggest that the tolling assessment allows for this likelihood and deducts a realistic Pahiatua Track portion from the total potential highway traffic volume.

We also believe more than the 37% proposed in the consultation document would continue on the alternate routes due to the toll’s prohibitive price, further eroding the potential traffic that may take the highway.

The toll tariff is unreasonable and would significantly affect the roading network
Gate 2 of NZTA’s Tolling Policy requires the toll tariff to be reasonable and not to result in a traffic volume change that unduly impacts the wider network. The proposed toll of $4.30 for a light vehicle and $8.60 for a heavy vehicle is prohibitive for the majority of people in our district. The Tararua District has high levels of deprivation and low income and is heavily reliant on the Palmerston North Hospital and supporting health services. A toll would be further disadvantageous to those people who already have to travel to receive care.

The tolling assessment does not appear to have factored in the affordability of the proposed toll for the Tararua community and the resulting impact on the roading network. The tolling assessment estimates one third of existing traffic would continue on alternative routes but we believe this figure to be much higher. The toll’s unaffordability would further reduce the number of vehicles that may take the highway and increase the likelihood of high traffic volumes continuing on the alternate routes, along with the continuation of the safety and maintenance problems on these routes.

Consequently, Council is taking the firm stance of not taking back the Saddle Road, Pahiatua Track and Ballance Valley Road once the highway opens if it is tolled, due to the unaffordable maintenance costs for our 10,200 rate payers. We have requested current maintenance costs from NZTA under the Official Information Act and believe these are in the millions annually.

The Tararua District’s deprivation figures from the 2018 Census are:

• Employment 58/67
• Income 59/67
• Crime 20/67
• Housing 51/67
• Health 53/67
• Education 64/67
• Access to Services 39/67
• Overall Deprivation 48/67

Any introduction of a toll will significantly increase the access to services deprivation as all these services are in Palmerston North. We are not expecting improvement when the new census data is released.

Tolling revenue is unlikely to result in a meaningful contribution
We understand the maintenance costs for the Saddle Road, Pahiatua Track and Ballance Valley Road are considerable. These maintenance figures have not been factored into the tolling assessment as an ongoing cost for NZTA. If the highway is tolled, NZTA will be maintaining four roads, not just one highway.

Conversely, if the highway was free, as originally intended, NZTA would only be maintaining one road and maintenance for the alternate routes would revert to Council at a basic level in line with traffic volumes similar to before the Gorge Road closed.

We request that the maintenance costs for the alternative routes be included in the tolling assessment as a cost. Further, we request that a realistic portion of Pahiatua traffic is deducted from the tolling assessment to reflect the high likelihood that existing traffic patterns will continue for traffic going to the Massey end and for Wairarapa traffic continuing to use the bypass and Pahiatua Track.

The total potential traffic that may pay a toll is further reduced by the high likelihood that the Tararua community will not take the highway due to the cost. Based on overwhelming public sentiment we estimate this to be a majority figure for locals, closer to 75% than the one third proposed in the tolling assessment.

As such, we do not consider a toll on this road would make a meaningful contribution to the National Land Transport Fund.

A toll would negate project purpose and outcomes
Gate 2 of NZTA’s Tolling Policy requires that tolling does not significantly or unduly reduce project outcomes or result in new or additional dis-benefits.  We note the tolling assessment makes no specific mention of the Tararua District community and draw your attention to the many negative impacts that a toll would create for our community.

The project proclaimed broader outcomes remit for years, for example on the project website: ‘The project scope is wider than infrastructure, with key result areas focused on broader outcomes such as creating local employment and upskilling communities.

And on Alliance partner Aurecon’s website: “As well as the creation of a safe, efficient and resilient transport connection, the construction of Te Ahu a Turanga: Manawatū Tararua Highway will provide an important economic boost to the Manawatū region and lower North Island.”

NZTA’s business case for the new highway emphasised the importance of providing a safe and efficient route for the residents of Tararua and Manawatū. However, if a significant portion of residents avoid the toll road due to the cost, this goal will not be achieved. Increased traffic on alternative routes would also reduce the safety and efficiency benefits the highway was intended to deliver.

The project’s 2018 Business Case states the project has a Benefit Cost Ratio of 1.8. This is based on a reduction in Vehicle Operating Costs of $139,645,552, crash reduction savings of $24,231,055, travel time savings of $384,655,022, carbon emission reduction of $5,585,822 and wider economic benefits of $187,118,114. This equates to a total 2018 Net Present Benefit Value of $741,235,564. This benefit erodes from $185,308,891 to $496,627,827 depending on whose estimate is used for the total traffic who choose to use, or can afford to use, the replacement road. The updated values erode the benefit ratio to between 0.4 and 1.1. Given the significant drop in benefit value, we believe a more thorough assessment of the impact of the toll proposal is required.

From the outset, this project has been promoted to our community as ‘more than a road’.

It would be ironic, and damning, if at this late stage, a toll is imposed that would handicap the Tararua economy and prevent the project purpose being realised.

A toll would cause significant social and economic harm for the Tararua community
As noted above, our district has high levels of socioeconomic deprivation, and many residents will avoid the highway if tolled due to unaffordability.

For those who commute daily for work or business, the toll would pose an additional financial hardship. This raises equity concerns, as tolling would disproportionately impact the most vulnerable members of our community. While those who can afford the road will benefit from quicker travel times and a safer more direct route, those who cannot afford it would be left using the slower, less safe alternatives, entrenching inequality in the region.

Our entire community has borne the cost of this closure for seven years already with businesses closing in Woodville soon after the permanent closure of the Gorge route, and an increase in fuel and vehicle costs leading to increased costs for all goods and services into the Tararua District reflected in increased freight costs.

Our district continues to feel the impacts of Cyclone Gabrielle. Introducing a toll on a critical transport route would add another burden to a community already dealing with recovery challenges. The proposed toll could slow economic recovery efforts by adding financial strain to residents and businesses still trying to rebuild.

This road is the primary route for accessing clinical and health services, with a large proportion of residents needing to travel regularly for healthcare to our hospital in Palmerston North. Our mental health, cancer, dialysis, addiction and social services are all located in Palmerston North. Adding a toll to this route would create barriers to accessing essential medical services.

Our rangatahi studying at Massey University and UCOL will not be able to afford to take the safe route to study. Our local schools and sports clubs who travel to Palmerston North for sport many times a week will be taking our children over the Saddle Road and the Pahiatua Track, compromising their safety because the schools will not be able to pass this extra cost on to parents. This is unacceptable for our children.

This consultation has not been carried out in good faith
It is clear this consultation has been prepared in haste and without the usual due diligence. There is no excuse for omitting vital information the public need to make an informed submission. The fact that the tolling assessment was not available until partway through consultation and released under the Official Information Act – and a further redacted tolling assessment report was released in the final days of consultation – places all submissions made before the tolling assessment was released at a disadvantage.

We understand submissions will be summarised and assessed against the toll criteria – how can a submission be fairly assessed if the tolling assessment wasn’t available?

As noted above, we also challenge the modelling used in the tolling assessment’s traffic volume calculations and draw your attention to the absurdity of the local roading authority having to do a traffic count in the absence of actual data in the consultation material, along with the unusual situation of NZTA conducting traffic counts but not sharing that information publicly.

On the basis of this flawed consultation process, we request that this consultation be null and void. The redacted Tolling Assessment Report that was released to us on Friday 4 October highlights “substantial uncertainties” and states the scope and limitations of the assessment, such as the exclusion of demand response and other impacts, means the results should be “interpreted cautiously.”

The report also mentions that given the time constraints for this assessment it remains “high level”. The social and economic implications for a vulnerable community such as the Tararua District should have been given far more consideration. This has been a poorly rushed process in order to propose tolling before the highway opens.

Conclusion
While we recognise the financial challenges associated with constructing and maintaining transport infrastructure and understand the rationale for considering tolling as a means of alleviating pressure on the National Land Transport Fund, this toll proposal does not adequately account for the unique situation in our district.

The replacement of the SH3 route is essential infrastructure and tolling the replacement road will disproportionately affect an already vulnerable population. The social and economic impacts on our community, particularly with regard to access to healthcare, daily commuting, and the ongoing recovery from Cyclone Gabrielle, make the current tolling proposal untenable.

The negative impacts on our community far outweigh the potential benefits for the national transport network.

We are grateful for the far-reaching support that has been forthcoming from Councils around the north island. Please refer to the map below for councils who support a toll-free Te Ahu a Turanga: Manawatū Tararua Highway.

Thank you for considering this submission. We look forward to NZTA’s response to the requests we have made and to the community’s feedback.

Ngā mihi

Tracey Collis
Mayor for the Tararua District