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Thank you for the opportunity to comment on Reshaping Streets.
Spokes Canterbury (http://www.spokes.org.nz/) – is a local cycling advocacy group with approximately 1,200 followers. Spokes is affiliated with the national Cycling Action Network (CAN – https://can.org.nz/). Spokes is dedicated to including cycling as an everyday form of transport in the greater Christchurch and Canterbury areas. Spokes has a long history of advocacy in this space including writing submissions, presenting to councils, and working collaboratively with others in the active transport space. We focus on the need for safe cycling for those aged 8 to 80.
Aotearoa has for decades prioritised the flow of vehicle traffic and parking over encouraging active forms of transport. Councils and government are now trying to rebalance this outcome often in ways that retrofit small changes which, while they have some benefit, do little to change behaviours. They tend to leave a patch work of safe and unsafe areas without consideration of destinations. It takes just one unsafe intersection to discourage wider trips.
Spokes agrees with the following changes as they will help but it is important not to forget that there are costs involved in trialling infrastructure and sometimes it is better to do things properly once, putting in permanent, well designed and implemented, holistic infrastructure from the start.
We need to make it safer, and more attractive to use active transport in our towns and cities. It is clear that when appropriate safe infrastructure is put in place, and it connects to desirable destinations, it will be used by a wide range of people. Before COVID cycling in Christchurch was increasing by 10% per year due to the investment in the cycleways, and it is pleasing that the numbers are now recovering to a similar level.
We are also seeing a push back against safe cycling infrastructure in the current local body elections. Cycleways are being labelled as “gold plated” without any understanding of the cost benefits of such infrastructure or that a significant part of the cost is related to upgrading intersections, underground services and sea-walls that would have needed to be done in any case.
To meet our zero climate goals will require a reduction of kilometres travelled by the light vehicle fleet or 20% by 2035 by providing better travel options in our towns and cities. The current system takes years to consult on and build.
Lower speed limits are another way to create more liveable spaces and make roads safer for all.
While it is necessary to speed up the rate of change, the importance of community engagement should not be under-estimated particularly in the early design phase. Listening to concerns and explaining why change is happening leads to better outcomes and increased community acceptance.
Proposal 1A: Provide RCAs with new powers and requirements to install pilots, and set requirements for how to install them
The pilot needs to be functional, safe and fit for purpose, this may mean some temporary improvement of the road surface. It also needs to integrate well with the wider cycling and walking network. If this is part of an essential connection in a wider network then a permanent solution may be better.
A longer timeframe and appropriate monitoring will enable the benefits and impacts to be fully realised before a decision is made about whether to make the changes permanent or return to the original. Currently, public and political pressure results in ‘experimental diversions’ to be prematurely cancelled.
The government should also have greater powers to request that Waka Kotahi and KiwiRail also install pilots such as on the Auckland Harbour Bridge, and down railway lines and crossings.
Proposal 1B: Enable pilots to be used as a form of consultation, by using feedback collected during the pilot to consider whether to make street changes permanent
Supported with qualification on process.
A trial allows the community to see how the changes will work. Many people find it difficult to visualise change from drawings. It can also take some time for people to become used to a change.
Some effort to talk to the local community, businesses and advocacy groups during the design phase will be more likely to get buy in from the community. Communities have good ideas.
Proposal 1C: Enable pilots to be installed for up to two years
Fully supported and timeframe is suitable. This allows time to change the habits of the people who are against or unsure about the changes. This also allows time for local stakeholders to record the benefits of calmer neighbourhoods.
Proposal 1E: Allow RCAs to lower the speed limit to support a pilot, in areas with a posted speed limit under 60km/h, during the pilot.
Fully supported. Lower speeds are essential to, and consistent with, pilots to create safe places and calmer neighbourhoods.
Proposal 1F: Update rules for trialling TCDs, so that RCAs can trial TCDs as part of pilots and choose how they notify people about TCD trials.
Fully supported. Traffic Control Device rules must be updated so that they cannot be challenged in a court of law. This would jeopardise the entire process.
FILTERING AND RESTRICTED TRAFFIC
Proposal 2A: Enable RCAs to install modal filters if the objects they use are safe
- Fully supported. This will significantly reduce the time required to install modal filters.
- Fully supported. This will significantly reduce the time required to manufacture signs and also ensure that respective signs are consistent throughout the motu (Island).
Modal filters should also be fit for purpose, wide enough gaps to fit a disability trike, large wheelchair or cargo bike and easy to navigate around for everyone no matter their age or capability.
Proposal 2B: Ensure legislation provides clear powers for RCAs to filter traffic, by removing the requirement in the LGA1974 that facilities built on roads cannot, in the opinion of a council, ‘unduly impede vehicular traffic entering or using the road’
Fully supported. If this is not implemented it will not be effective in preventing vehicular traffic from using specific sections of the road network. It is essential to make the ability to remove carparks explicit and to properly enforce illegal parking.
Proposal 2C: Enable RCAs to restrict or prohibit the use of some or all motor vehicles on specified roadways to support public transport use, active travel, health and safety, emissions reductions, and/or to create public spaces that promote community well-being
Fully supported. There is limited available road space. The prohibition of motor vehicles, when considered necessary, will enable limited road space to be reallocated to active and passenger transport modes.
Proposal 2D: Provide RCAs with an explicit power to install TCDs
Fully supported. Time required to install Traffic Control Devices will be significantly reduced.
Proposal 3: Establish powers and requirements for RCAs to create School Streets in partnership with local schools
Fully supported. This is one of the most important changes proposed. We need effective and improved safety for children to walk, scoot and cycle to school. School vehicle drop off zones are making many school entrances unsafe for active transport and adding significantly to road congestion. Walking speed needs to be better defined. Many active transport modes can and do move faster than walking speed and can be safe in a mixed environment with enough space.
Proposal 4: Establish clear powers and requirements for residents to hold Community Streets, provided they have approval from RCAs
Fully supported. It is important that communities learn to interact on a larger scale and the road reserve provides an appropriate space for these activities to be undertaken. The proposal empowers communities, based on their local knowledge and requirements, to take the initiative to create welcoming and safe spaces to bring local residents together at allocated times, without the fear of private vehicles travelling through. Walking speed needs to be better defined.
CLOSING ROADS FOR OTHER FUNCTIONS AND EVENTS
It should be easier have road closures or partial closures for events and trials of infrastructure. Clear guidance and documentation need to be provided to community groups to make the processes easier and more likely to succeed. Some sort of government liability insurance for community groups could be investigated to help these initiatives to succeed. It is currently too easy for authorities to use safety concerns, expensive mitigations and liability to stop community groups from having any chance of successfully organising a closure for functions and events.
Waka Kotahi controlled roads and facilities, including opening road tunnels and bridges should also be included in the legislation.
Proposal 5A: Allow RCAs to close roads for reoccurring events, by removing the 31-day limit per year for road closures in the LGA 1974
Proposal 5B: Bring together powers and requirements to close roads for events in one piece of legislation and update notification requirements so that RCAs can notify the public in any way that they consider appropriate at least two weeks before an event.
One piece of legislation would rationalise the requirements, remove current and potential inconsistencies and make it easier to implement and administer. Updating notification requirements makes sense. All events are different and might require specific and appropriate notification processes. The Streets Layout rule will mean that streets will be safe for everyone during events. Insurance requirements could be reduced
Proposal 6A: Remove the requirement for local authorities to use the special consultative procedure when establishing pedestrian malls. Instead, they must apply the consultation principles in the LGA 2002.
Fully supported. Pedestrian Malls should be designed for mixed active transport use where ever possible rather than pedestrian only. Renaming them would be beneficial (eg Active Community Spaces) as it implies considerate collective use.
Proposal 6B: Remove the ability for people to appeal to the Environment Court when a pedestrian mall is being created. People would be able to challenge the installation of a pedestrian mall through judicial review.
Fully supported. Consistency is important to ensure changes are not open to legal challenges.
Proposal 6C: Shift legislative provisions for pedestrian malls to the proposed Street Layouts rule
Fully supported. For the same reasons set out above.
Proposal 7: Remove special notification requirements for creating transport shelters. Instead, RCAs would be able to publicly consult on transport shelters in the same way they do for other features, like bus stops.
Fully supported. Transport shelters (good quality designed facilities) are important in the Public Transport journey. Inadequate transport shelters are one of the key factors in deterring people from using Public Transport. Transport shelters should be designed well to safely share the space with other active transport users.
The process is fully supported.