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Open Letter to Goff on the Regional Seal Extension Program

Mayor Phil Goff
Auckland Council
Level 27, 135 Albert Street
Auckland CBD
Attention: His Worship Mayor Phil Goff
Cc: All Councillors, Chair and CE Auckland Transport
1 November 2017

Dear Mayor Goff,
Re: Open Letter on the Regional Seal Extension Program
The draft 10 Year Budget has a planned seal extension budget somewhere between $1.2 and $3.3 million per annum. This is too low and the purpose of this open letter is to bring this concern to the attention of all Councillors and the Mayoral office.
This is a regional issue with Franklin, the Hauraki Islands, Rodney and Waitakere having 868 kilometres of unsealed roads. This represents 12% of the total legal road network of Auckland. Not all of the unsealed network requires sealing. However, a third of the unsealed network now presents a health and safety hazard along with numerous other adverse effects.
An investment of $10 million per annum for the next 10 years would achieve up to a third of the unsealed roading network being sealed. I am requesting of you, Mr Mayor, to accelerate the seal extension program by increasing the budget to this level. The health effects of road dust must be addressed with all urgency and without any further delay.
Dust from unsealed roads also create economic costs from reduced productivity of land, crops and livestock, and increased road and vehicle maintenance costs. Noting, animals also breath in the dust and their health is also affected via lung absorption of harmful dust particles.
Airbourne dust from unsealed roads can deposit on rooves contaminating drinking water, as well as deposit on gardens and houses causing nuisance and reducing amenity.
What is dust?
This dust is defined as dry, solid particles that range in diameter from less than 1 micron in size to 100 microns. Particles less than 10 microns in size reach the alveolar region of the lungs when inhaled.
Road dust monitoring in New Zealand.
Monitoring of the 10 micron sized particles on unsealed roads by the New Zealand Transport Agency has revealed multiple exceedances of health based air quality criteria. The monitoring found that ambient levels of 10 micron particles are directly correlated with traffic, and measured maximums were up to two to three times above the accepted national level.
The Auckland Unitary Plan has zoned vast areas of rural Auckland as Countryside Living allowing subdivision and increased traffic as a right of current land ownership. Increased population growth of Auckland’s satellite townships is also well underway due to rezoning. Combined with Council’s increased tourism promotion of coastal and rural activities traffic volumes on unsealed roads are up and are steadily increasing.
Even low volume roads propose a combination of safety and health hazards along with the other adverse effects. (Refer to Referenced literature).
Health effects of road dust
Historically, airborne dust from unsealed roads was considered primarily a nuisance issue. However, the full health impacts of suspended particles (dust in the air) is now well recognised throughout New Zealand.
There is now widespread, global scientific consensus that exposure to particulate pollution causes predominantly respiratory and cardiovascular effects, ranging from subclinical functional changes (e.g. reduced lung function) to symptoms (increased cough, exacerbated asthma) and impaired activities (e.g. school or work absenteeism) through to doctors’ or emergency room visits, hospital admissions and death (World Health Organisation). The effects, in terms of escalating severity, are described as increased visits to doctors for many individuals, hospital admission for some individuals and death for a few individuals. The exposure-response relationship is essentially linear and there is no ‘safe’ threshold; adverse effects on health are observed at all measured levels (World Health Organisation).
In 2013, the International Agency for Research on Cancer (IARC) classified particulate matter as carcinogenic based on an increased risk of lung cancer. This is consistent with the World Health Organisation global guidelines for particulate matter, which are based on all airborne particles having the same potential to cause adverse health effects, regardless of chemical composition or physical characteristics.
Auckland Council recognises the adverse health effects of vehicular pollution and is investing heavily into reducing these emissions through alternative transport modes and user taxes. Yet dust particles less than 10 microns in size are just as potentially harmful as diesel particulates, but this identified hazard is without the corresponding preventative investment enjoyed by the urban population.
New research from the World Health Organization further indicates particulate matter is associated with artherosclerosis, adverse birth outcomes, childhood respiratory disease as well as Alzheimer’s disease and other neurological endpoints, cognitive impairment, diabetes, systemic inflammation and aging.
In addition to the above, the Ministry for the Environment Good Practice Guide for Assessing and Managing Dust notes that there may also be health effects from contaminants associated with (road) dust (MfE, 2016):
• Some mineral dusts contain quartz (silica), the finer fractions of which can cause the lung disease known as silicosis when present at high concentrations;
• Some dust may contain toxic metals such as mercury or lead;
Irrespective of road dust composition, those most at risk to particulate pollution will be the elderly, the very young, the unborn, those with pre-existing heart or lung conditions, those with asthma or diabetes, and smokers. Many communities affected by high levels of dust pollution from traffic on unsealed roads tend to comprise high proportions of these already particularly at-risk groups.
In a nutshell, the Auckland Council needs to address this health hazard.
Six proactive and practical funding answers.
In my opinion the Mayoral Office must;
1. a) recognise the hazards of dust from unsealed roads as a significant hazard and,
2. b) determine funding options to accelerate the sealing program to minimise or isolate the hazard.
Seal extension (new road sealing) funding already has its own unique funding line in the previous 10 Year Budget. This uniqueness is because the previous Mayor, Councillors and Auckland Council officers recognised the importance of advancing the sealing program.
The previous Council chose to increase the seal extension budget using funding provided through the Interim Transport Levy. I understand this was always intended to be lifted significantly this LTP round.
I have made numerous presentations to Auckland Transport, including three meetings presenting to their Board of Directors on this subject. Their message has been clear and consistent. Auckland Transport will happily seal as many kilometres of road as Auckland Council gives them the funding to do so.
The current levels of funding from Auckland Council are grossly inadequate, boarding on negligence regarding public health and safety. This must be corrected immediately by lifting funding to $10 million per annum for a 10 year period ie: $100 million capital program over 10 years.
My challenge to you Mr Mayor, with the vast resources at your disposal through both the Mayoral Office and the Finance Division of Auckland Council, is to find the funding solution to this. It should not be up to me as a Councillor representing one Ward to provide these solutions. However, to be helpful and constructive I have identified six proactive and practical funding solutions for you to consider.
Option 1: Funding from the General Rate take
The unsealed network ranges across the regions of Franklin, the Hauraki Islands, Rodney and Waitakere. Therefore, a capital investment program funded from the General rate take leveraged against Auckland Council’s Treasury’s borrowing power is justifiable. Many Aucklanders from across the region who do not live on the unsealed road network use the network. They either currently drive on these roads, have driven on these roads, or they or their families may do so in the future.
This is particularly the case on weekends and public holidays when Aucklanders drive to coastal, forest and other rural destinations for recreation. The international and domestic tourism market does the same throughout the week. These people are currently being exposed to a health risk which Auckland Council must mitigate.
Thus, another possibility open to you is to accelerate the road sealing program using existing regional funding from regional general rates.
Option 2: NZTA Subsidy
The Mayoral Office, Council Officers and representation from Auckland Transport could unite to lobby the Crown to bring back the Financial Assistance Rate (FAR) subsidy for rural seal extensions which was in place with the legacy Councils.
This would be a very real win for Auckland Council, Auckland Transport and the Auckland ratepayers.
Thus you may consider this as a priority conservation with the new Minister of Transport.
Option 3: Using the Crown Infrastructure Partnership model as a capex tool.
Investigate use of the Crown Infrastructure Partners (CIP) to facilitate partnerships between the Government and Auckland Council to enable private investment in roads as to unlock rural land for development. Under this model, the debt would be covered by private investors.
Exploring this funding mechanism with the new Government is an option.
Option 4: Regional Fuel Tax
If a regional fuel tax is introduced, you have the very real option of lobbying for some of this to be earmarked for accelerating the seal extension program.
There are representatives from Local Government New Zealand, the New Zealand Transport Agency, the Ministry of Business, Innovation and Employment, Iwi, the Department of Conservation, the Ministry for the Environment and the Ministry of Health all on the Road Dust Working Group of the Road Controlling Authorities Forum (NZ) Inc who can assist Auckland Council with the necessary key research, experts and data to achieve this outcome.
This may be the simplest option to address the issues raised in this letter.
Option 5: Target Rates
The Local Board areas of Franklin, the Hauraki Islands (Waiheke and Great Barrier), Rodney and Waitakere could introduce a targeted rate for road sealing under your direction in the next 10 Year Budget. This would, however, introduce an increase in rates for ratepayers who believe they already pay a General rate to Auckland Council to provide core Council services, including safe roading.
The introduction of both a regional fuel tax plus an additional targeted rate for transport improvements is likely to receive a negative ratepayer reaction. This would be further compounded if other types of regional targeted rates were also to be introduced on top of the fuel tax and a transport targeted rate.
Option 6: Funding from the Rural Rate take
Rural Auckland receive fewer Council services that their urban counterparts. To reflect this a rating differential is applied to lifestyle and rural properties. However, there is still a large quantum of rural rates being collected totalling in the tens of millions, in return for minimal local expenditure on Council services ie: in many cases only the maintenance of an unsealed road is provided by Council through the general rural rates collected.
Therefore, a final possibility open to you is to accelerate the road sealing program by using more of the existing rural and lifestyle general rates specifically for this purpose.
In closing, my intention is to more fully inform you about the safety and health hazards, along with numerous other adverse effects, the unsealed network presents with respect to health & safety legislation, the Auckland Plan and public wellbeing. It is my hope that you will consider this open letter as a catalyst to correct the situation.
Equally, while I realise the 10 Year Budget is yet to go out for public consultation, I am concerned funding to accelerate the seal extension program has not been identified as a priority early in the drafting of the 10 Year Budget process.
There are many priorities to juggle in the 10 Year Budget but protecting the health and safety of Aucklanders must surely be of utmost importance.
Again, I trust you will receive this as a positive input.

Yours sincerely
Cr Greg Sayers
Councillor Rodney Ward
Auckland Council

Reference Material:
Road Controlling Authorities Forum (Nz) Inc. Special Interest Group: Low Volume Roads. April 2017.

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