Background information Background information
ITA Guidelines were originally prepared by ARTA in 2007 in response to requirements set out in Proposed Change 6 to the Auckland Regional Policy Statement (RPS). That change was the Regional Council’s response to the Local Government Act (Auckland) Amendment Act 2004 (LGAAA)1, which required better integration between land use and transport planning in the Auckland region.
The key amendment of Proposed Change 6 was the addition of a method in the RPS requiring that ITAs be submitted whenever a new plan change or major trip generating activity was proposed. Given that this was a new requirement, it was considered that further guidance was needed regarding:
- what an ITA was,
- when an ITA should generally be prepared,
- what content to include in an ITA.
The guidelines were prepared to provide assistance to transport professionals and other practitioners when preparing ITA assessments.
The ITA guidelines are considered to be a live document that will be regularly updated in response to changes in legislation, planning and traffic engineering practices, and as a result of feedback from transport and planning professionals using the guidelines.
AT has reviewed the original ARTA guidelines giving consideration to feedback received on the current ITA guidelines and the changes that have occurred to Auckland’s governance in recent times. There have been significant changes in Auckland with the adoption of the Auckland Plan under the Local Government (Auckland Council) Act 2009 (LGACA) and the quality, compact city model that the Auckland Plan seeks to achieve as a long term vision. ITAs, along with other assessments of land use, should be consistent with and assist in achieving the vision outlined in the Auckland Plan. Auckland Council has also prepared its first Unitary Plan for the region that will drive and give direction to land use planning to achieve these outcomes.
The ITA guidelines have been prepared to assist transport professionals to draft ITAs that robustly analyse proposals, whether they are promoted by private developers, Auckland Council or Requiring Authorities2. The guidelines have a particular focus on ensuring that infrastructure provision, and the funding of that infrastructure, is considered as a key part of analysing land-use proposals. This is because the planning and funding of transport infrastructure have long lead-in times and in Auckland there is a history of misaligned land use and transport funding decisions. Developments that are not aligned with planned and funded infrastructure should identify what methods will be used to achieve delivery of the necessary infrastructure via private means, or changes should be made to the proposal to reduce the scale of investment needed. Other approaches could be to provide clear staging of development so that development and funding timeframes are aligned.
The key to successful ITAs is that they are prepared at the beginning of the planning process, to ensure that the relevant transport agencies are involved early and that the ITA covers the appropriate matters. This ensures that time is spent on an appropriate level of analysis and that sufficient information is included to avoid time delays and unnecessary costs as a proposal proceeds through the consenting process. It also recognises that the preparation of quality ITAs is an iterative process with changes made along the way following the results of modelling, feedback from relevant transport agencies or the Council.
These guidelines set out what AT, and its key transport partners KiwiRail and the NZTA consider to be best practice concerning the preparation of an ITA, and the content that should be included within an ITA.
The guidelines place a strong emphasis on the scoping of the ITA as early as possible, consideration of the likely transport mode splits for a given area, and assessing a proposal’s consistency with the future planned transport network.
Whilst these guidelines provide emphasis on best practice from an Auckland perspective, reference has been made to the NZTA Research Report 422, which also provides detailed guidance on ITAs. AT considers these guidelines as being consistent with the approaches outlined in that research report.
Statutory and policy framework
There has been significant change in the legislative framework relating to the Auckland region in recent years, which is important in considering the context for ITAs. The key legislation is briefly outlined and described below.
Local Government (Auckland Council) Act 2009 & Local Government Act 2002
The LGACA established Auckland Council as a Unitary Authority, replacing the previous Regional Council and seven territorial authorities that existed prior to its enactment.
The LGACA required the new Council to prepare a spatial plan, setting out the 20-30 year vision for the region. This document, the ‘Auckland Plan’ has now been prepared and was adopted by the Council on 29 March 2012.
The Local Government Act 2002 (LGA) continues to apply to the Auckland Council and sets out requirements such as the need to prepare a Long Term Plan (LTP) covering a period of at least 10 years into the future. An LTP outlines Council’s intended spending proposals and how these will be funded. Recent amendments to the Local Government Act also require Council to have a 30 year Infrastructure Strategy setting out the investment requirements for that 30 year period, how such investment will be funded and a list of applicable key projects.
Combined, the LGA and LGACA require the Council to have a forward vision of at least 30 years and to demonstrate what infrastructure (among other things) will be needed to support that vision, and the way in which such measures will be funded.
Resource Management Act 1991
A key legislation related to landuse development is the Resource Management Act 1991 (RMA). All of the existing planning documents in the Auckland region are still in force under this Act, and these will continue to apply until such time as the Council’s Unitary Plan is operative. These include:
- The RPS,
- A number of Regional Plans,
- The District Plans for Auckland City, Waitakere, Manukau, Rodney, North Shore, Papakura and Franklin.
The RPS and Regional Plans set out the regional objectives for Auckland and include current concepts such as the Metropolitan Urban Limit (MUL), which is proposed to be replaced by the Rural Urban Boundary (RUB) under the Unitary Plan, and rules to protect air and water quality. The District Plans set out objectives and policies for urban and rural development and associated rules that apply whenever new development is proposed.
On 30 September 2013, the Council notified the draft Auckland Unitary Plan. The Unitary Plan seeks to give effect to the “quality, compact” growth model outlined in the Auckland Plan. The Unitary Plan sets out the triggers for when the preparation of an ITA is required and directs that ITAs should be prepared in accordance with this guideline (see When to use these guidelines).
Land Transport Management Act 2003
The Land Transport Management Act 2003 (LTMA) was recently amended. The Act now requires that a Regional Land Transport Plan (RLTP) be prepared by AT showing the transport objective, policies and priorities for Auckland over a 10 year horizon. Detailed information about the actual projects, their costs and predicted funding sources must be prepared for the first 3 years of the programme, however more general information over a 10 year period is usually also provided to align with the Council’s LTP. The RLTP must be reviewed every 3 years to ensure that it is kept up to date, but can be varied at any time by following the prescribed process.
The RLTP sets out the expected funding for projects and relies in many cases on a subsidy being provided by the NZTA. At the time of writing, the funding available through current sources will not be sufficient to enable the full programme of works planned by AT and as such projects have been allocated a priority based on criteria in the Integrated Transport Programme (ITP).
This is relevant to ITAs as any new projects proposed in response to development must be cognisant of whether such a project is already funded, and where this is not the case, applicants will need to consider the appropriate staging and timing of such projects or whether developers will need to fund, or contribute towards, the funding of such projects.
As part of the amendments to the LTMA, the Public Transport Management Act 2008 was repealed and the various public transport system provisions (as amended) have been included in the LTMA. The LTMA provisions also include the mechanism for adopting the new Public Transport Operating Model. As under the LTMA, the new provisions require AT to prepare a Regional Public Transport Plan (RPTP) for a period of at least 3 years in advance, and up to 10 years into the future. The new RPTPs have a slightly different purpose and required contents to those under the PTMA and focus on identifying and listing the bus, rail and ferry services that are integral to the public transport network in the region. AT has released its RPTP showing the services proposed through to 2022.
Housing Accords Special Housing Areas Act 2013
This recent legislation sets up a number of new processes to allow housing to be built more quickly in the Auckland region.
The Act allows the Minister of Housing to enter into housing accords with territorial authorities which set benchmarks for the provision of housing over certain timeframes. An accord has been signed between the Minister and Auckland Council committing to the construction of 39,000 houses over a 3 year period.
The Act allows the Minister to declare development areas “Special Housing Areas” (SHA) on the recommendation of the territorial authority. Where a SHA has been declared then developers may apply for “qualifying developments” which will be assessed under the Act, which has shorter processing timeframes and more limited notification to affected parties and appeals than the RMA.
SHAs allow developers to apply under the rules of the PAUP as if that plan were operative, or to apply for a change to the Unitary Plan (for example where a Future Urban zone applies) to permit housing to be built. All provisions of the PAUP are therefore deemed to apply, including the requirements to provide an ITA in the circumstances summarised in Section 1.1.
ITAs role in the legislative context
The need for integration of transport and land use has been reinforced by the legislative changes described above and the recently notified Unitary Plan.
The Unitary Plan is a key tool in giving effect to the Auckland Plan vision, a key part of which is to accommodate at least 60% of expected growth within existing urban boundaries. Other strong themes in both the Auckland Plan and Unitary Plan and which are reflected in the RPS are3:
- Ensuring a transport system that is integrated with landuse and that provides travel choices,
- That future state highway, arterial roads, railway lines and airport noise zones are protected,
- That transport infrastructure is planned, funded and staged in accordance with development,
- That development supports the planned Rapid and Frequent public transit network (RTN/FTN),
- Where development is out of centres, that it integrates with the transport network and provides appropriate mitigation, and,
- That public transport, walking and cycling are made more attractive by incorporating walking and cycling connections within private developments and encouraging an urban form that is supportive of public transport.
ITAs are an important document to ensure that any development proposal is assessed and shown to be meeting the objectives as specified above, that transport related effects are avoided, remedied or mitigated and that where mitigation is needed that this is appropriately identified and tied to when the development is occurring.
A well prepared ITA provides the information that is needed by RMA decision makers in determining whether a particular development meets the objectives and policies of the Unitary Plan, the RMA, and whether such a proposal is worthy of consent being granted.
While ITAs are primarily prepared in support of RMA applications, they play a very important role in bridging the legislative gap that occurs between land use planning under the RMA and transport planning and funding which occurs under the LGA and LTMA. An ITA that appropriately identifies the transport projects that are necessary to support a development, and when such projects are necessary, will assist AT and other transport agencies with forward planning.
The following diagram outlines the numerous interactions that occur between an ITA and decision making under the relevant legislation and demonstrate why well prepared and accurate ITAs are of such importance:
1 This has now been superseded by the Local Government (Auckland Council) Act 2009.
2 These organisations are collectively referred to as “applicants” from here on.
3 Sections 2.3 and 3.3 of the RPS.