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9 BACKGROUND KiwiRail Holdings limited KiwiRail is the State Owned Enterprise responsible for the management and operation of the national rail network. This includes managing the national rail infrastructure and land as well as rail freight and passenger logistics within New Zealand. KiwiRail is also the Requiring Authority for land designated for Railway Purposes in District Plans throughout New Zealand. There are two rail lines within Hamilton City Council s jurisdiction; the North Island Main Trunk Line and the East Coast Main Trunk Line. The North Island Main Trunk (NMIT) extends through the city in a north to south direction and is the primary rail spine for the entire North Island. The East Coast Main Trunk (EMCT) branches from the North Island Main Trunk at the Hamilton Railway Station, and heads east out of the city through the suburb of Ruakura. It provides the only rail access from the Bay of Plenty and Port of Tauranga to the North Island Main Trunk. The NIMT provides a rail freight and passenger link between Wellington and Auckland, while the ECMT provides a freight link between Hamilton and the Bay of Plenty, including the Port of Tauranga and the proposed Ruakura logistics hub. These lines are key strategic freight routes and as such are an important part of the KiwiRail network. SUBMISSION KiwiRail supports the development of a Regional and Golden Triangle Inter Modal Terminal (IMP) and the broad strategic direction on land and transport management set out in the Proposed Ruakura Plan Change. 2

10 We have liaised briefly with NZTA and AT on matters of mutual interest and our submissions also raise and/or addresses similar matters. KiwiRail s submission on the Proposed Plan Change for the Ruakura Development covers: Uncertainty regarding the growth of rail traffic to and from the Inland Port Absence of rail freight modelling Level crossings Double tracking the ECMT at Ruakura Proposed and long-term rail freight projects within the Auckland Metro area Assumptions for qualitatively assessing the impacts on rail from the development Qualitative assessment of impacts on rail (by line, for low, medium and high growth) Relationship with the rail corridor Plan change provisions. INLAND PORT RAIL GROWTH UNCERTAINTY KiwiRail looks forward to partnering with the Inland Port development to help deliver its success, and bring the benefits of rail to this important venture. KiwiRail is very competitive in this market and once the rail siding is in place, we will actively pursue a high market share. However, KiwiRail cannot at this stage know how successful the Inland Port will be or how much of the contestable freight market it will win. Furthermore, although KiwiRail will pursue a high market share, for the purpose of commenting on the proposed plan change, we only speculate as to how much of the Inland Port s throughput will be handled by rail. Reinforcing this point, there appears to be no forecasting as to how rail traffic though the Inland Port might grow. Therefore we can only assess the impacts qualitatively. KiwiRail is not aware of any regional transport model that attempts to model rail freight movements (unlike urban passenger rail, which is an integral part of the Auckland and 3

11 Wellington models). We consider that some analysis would be beneficial to provide an indication of proposed freight growth to assist with certainty of staging the development and foreshadowing rail infrastructure requirements across the region and wider Golden Triangle. We note that NZTA has concerns in respect of the earlier release of land for development prior to the Waikato expressway being built. Decision requested: 1. Analysis and an indicative forecast (time series) of how rail traffic (tonnage or TEUs 20 foot equivalent units) though the Inland Port is likely to grow. GRADE SEPARATED RAIL CROSSINGS The intensification of land use development/subdivision adjoining the EMCTL creates increased traffic movements that affect rail level crossing safety. The proposal seeks to create a new rail crossing point at Spine Road. KiwiRail would not support any at grade level crossings between Ruakura Lane and Telephone Road (SH 1B) once the Waikato Expressway is in place at Ruakura. That is, Percival Road Level Crossing is removed (as the Inland Port will build over it), and no new level crossings are installed. The cost of the grade separated rail crossing and who will pay has not been addressed as part of the Plan Change application. The matter is critical to the formation of the Spine Road link with the IMT and provision of North/South connectivity, and the staging of the Knowledge Area. Is this to be funded by the Hamilton City Council or by Tainui Group Holdings Limited and Chedworth Properties Limited? 4

12 Any new grade separated rail crossings would be expected to meet the current design criteria and envelopes of the rail access provider. The design and formation of the grade separated crossing will need to be provided to KiwiRail for assessment. We note the potential timing issues with staging the construction of the Spine Road, the closure of Percival rail level crossing, and relocation of Ruakura Road. These matters need to be worked through and resolved with KiwiRail and other relevant authorities as part of this Plan Change. Decision requested: 1. The provision of grade separated rail crossings only 2. Confirmation that Spine Road rail crossing access is to be grade separated. 3. Confirmation that the overbridge design has provision for the Inland Port siding 4. Consultation and agreement with KiwiRail on the design and layout of grade separated rail crossings, the staging of this, and closure of Percival Road Level Crossing and reinstatement. RELATIONSHIP WITH THE RAIL CORRIDOR Double Tracking The ECMT at Ruakura The development straddles the ECMT, one of New Zealand s most strategically important lines. We believe that a condition for any approval should include a requirement for Tainui Group Holdings Limited and Chedworth Properties Limited to work with KiwiRail on all design elements. For example, the design of grade separated rail crossings should be consistent with the corridor provisions used for the Hamilton Ring Road crossing of the ECMT (Bridge 11). 5

13 KiwiRail wishes to preserve the option to at least double track through all of Hamilton east towards Morrinsville, including through the Ruakura development. Ultimately KiwiRail may need to double track the majority of the ECMT between Hamilton and Tauranga, although sections where it will be extremely expensive to double track are likely to remain single track for the foreseeable future (i.e. the Kaimai Tunnel and the Waikato River Bridge). Decision requested: 1. Confirmation that the rail corridor is wide enough for double tracking 2. Consultation and agreement with KiwiRail on the design and layout of the IMT, rail siding and loop throughout the staged development to integrate with the rail corridor and to ensure the corridor maintains its physical and operational capacity while providing sufficient flexibility for rail line enhancement. PROPOSED RAIL FREIGHT PROJECTS IN AUCKLAND METRO As mentioned above, KiwiRail looks forward to partnering with the Inland Port development to help deliver its success. We are however, mindful of the wider impacts from the development on rail capacity in the Golden Triangle. KiwiRail has substantially increased rail capacity between Hamilton and Tauranga in recent years, and we anticipate that only minor capacity improvements will be required over the medium term. In contrast, additional capacity within the Auckland Metro area is very likely to be needed in the next five years. The top priority to deliver a step change in capacity is to provide triple track between Westfield and Wiri. The timing of that project is set out in the following extract from KiwiRail s Infrastructure and Engineering Business Plan FY14-16 (Section 7.1.1, Page 88): The business plan assumes that the third main will be built between Westfield and Wiri within 5 years. Timing for that construction will depend on negotiations between AT and KRG on funding contributions and access rights. 6

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17 rather than as the primary use. This provides a level of uncertainty as to the proposed and ultimate use, and consequently impacts on the transport network. While KiwiRail fully supports the IMT, the proposed logistics hub or similar activity is also considered to be an appropriate use adjoining the rail corridor, given the potential sensitivities of other land uses (primarily residential) to 24/7 operation of the rail network, in particular the potential effects of noise and vibration. Zoning Adjoining the Rail Corridor Rail forms a key part of the region s significant land transport infrastructure. KiwiRail seeks to protect our ability to operate, maintain and enhance the national rail network in the future. To achieve this, we seek to ensure that District Plans encourage adjoining land uses that do not compromise the ability to operate a safe and efficient rail network both day and night. Where sensitive activities are proposed on land adjoining the railway, appropriate controls should be imposed to ensure their long term amenity. Similarly it is appropriate that the District Plan provides controls that promote the safe and efficient operation of the region s significant land transport networks including the railway. Noise sensitive development located near existing or planned infrastructure, can result in conflicts between land uses and may impact on the operation, maintenance and upgrading of infrastructure necessary to support sustainable growth of the region Decision requested: 1. Provision of appropriate zones and activities that adjoining the rail corridor; and avoidance of residential zones and noise sensitive activities adjoining the rail corridor. 2. Appropriate controls where zones and noise sensitive activities re proposed 10

18 PLAN CHANGE PROVISIONS Objectives and Policies - 25H.4 Objective 25H.4.16 refers to the importance of network utilities but provides no policy to manage adverse effects of subdivision use and development or noise sensitive activities on the nationally and regionally significant rail network. Decision requested: 1. Amend Objective 25H.4.16a to include the rail network 2. Amend Objective 25H.4.16b to include the rail network and include noise sensitive activities or add a new provision Noise and Vibration Noise and Vibration arising from the operation (maintenance and enhancement) of the rail network is a key consideration in relation to noise sensitive activities that are located or seek to locate close to or adjoining the rail corridor. The potential for reverse sensitivity effects from noise sensitive activities establishing have the potential to lead to restraints on the operation, maintenance and enhancement of the railway corridor (and the region s significant land transport networks). It is therefore important that newly establishing sensitive receivers provide appropriate levels of acoustic and vibration attenuation. KiwiRail understands from the Marshall Day Acoustics report ( A) that there are (five) existing houses within the proposed Ruakura Logistics Area, and other existing residential dwellings near to the Logistics Area (in particular the Country Living Zone Percival and Ryburn Roads). The latter is considered by Marshall Day to be the most noise 11

19 sensitive due to their close proximity to the IMT. There are also educational facilities within close proximity. All of these are also in close proximity to the rail corridor. The applicant proposes that short stay workers accommodation and ancillary residential units are controlled activities (25H.5.2). The assessment criterion for the former is noise and the latter reverse sensitivity and both must comply with 25H.11 (Noise and Vibration). KiwiRail considers that the residential activities within the Logistics Area should be Restricted Discretionary as a minimum. Reference to 25H specifies should (rather than shall) comply with relevant noise and vibration rule 25H.11. Reference to short term and ancillary does not provide sufficient indication of the occupation. With respect to Notification Rules KiwiRail seeks to be recognised as an affected party and notified where new noise sensitive activities seek to locate adjoining or close to the rail corridor. This Marshall Day Acoustics report ( A) also highlights the proposed zoning of the area north of the ECMT and to the west of the Waikato Expressway as large Lot Residential (not part of this plan Change), a change from the what was originally proposed as the Ruakura Logistics/Industrial Area (p 4). While this rezone is not shown as part of this Plan Change KiwiRail notes the extent of the IMT bordering and extending to the expressway, in combination with the operation of the railway could create an unsuitable environment for noise sensitive activities, particularly residential activities in this location, leading to reverse sensitivity effects on rail activities. KiwiRail supports the logistics/industrial area in this location as opposed to Large Lot Residential, but considers that the proposed rezone and reverse sensitivity provisions to address that should be considered at this stage, in a more comprehensive way. KiwiRail supports the internal noise approach and limit for noise sensitive activities such as, but not limited to, residential activities of 35 db Leq 1 hour in bedrooms and 40 db Leq 1 hour in 12

20 other habitable rooms proposed by Marshall Day Acoustics. KiwiRail considers that this provides for a more robust effects based approach than an external noise approach. For other activities KiwiRail considers that use of the AS/NZS2107:2000 or similar recognises the nuances of other activities, with some exceptions. KiwiRail supports the vibration standard Rule 25H.11.5, but seeks that both amenity and building effects are addressed and compliance be demonstrated through by an acoustics specialist certification. The standards proposed in Rule 25H.9.4 (should be 25H.11.4) Noise Sensitive Activities Activities in all Areas, that apply to the construction of new and altered buildings to be used for noise sensitive activities is supported by KiwiRail, subject to amendments to (d) to provide a greater threshold of 100 metres and (e)(i) to apply an internal noise performance standard and limit and (replaces or) (e)(ii) an acoustic design certificate signed by a suitably qualified acoustic specialist shall state that the internal noise is met and provided to the Council. Decision requested: 1. Amend the noise performance standards in 25H.11 to use an internal noise performance standard and limit. For new or modified residential activities, and specified other noise sensitive activities, this shall be 35 db Leq 1 hour in bedrooms and 40 db Leq 1 hour in other habitable rooms, within 100 metres of the rail corridor 2. Internal design noise limits take into account future use of the rail line, by the addition of 5db to existing measured levels 13

21 3. Apply AS/NZS2107:2000 for other activities (other than residential activities and other specified activities such as primary outdoor amenity areas and teaching spaces) that sets out different criteria for different spaces. 4. Amend Rule 25H.9.4 (should be 25H.11.4) (d) to provide a greater threshold of 100 metres rather than 40 metres and (e)(i) to apply an internal noise performance standard and limit and (and replaces or) (e)(ii) an acoustic design certificate signed by a suitably qualified acoustic specialist shall state that the internal noise meets 35 db Leq 1 hour in bedrooms and 40 db Leq 1 hour in other habitable rooms is to be provided to the Council, and (f) bedroom is any room that can be used for sleeping (other than for example living and dining areas). 5. Add to Rule 25H.9.4 (and other relevant provisions): the primary outdoor living area shall be located and/or designed to meet 40 db Leq 1 hour within 60 metres of the rail corridor. 6. Confirmation that the proposed ventilation standards are adequate. 7. Require a no complaints covenant, where the provision of noise and vibration provisions are not met. 8. Amend Rule 25H.11.5 Vibration from Railway Lines Activities within all zones to provide the standard for amenity effects within 60 metres of the rail corridor and the standard for building effects within 20 metres of the rail corridor. 9. Restricted Discretionary Activity for 25H.5.2 short stay workers accommodation and ancillary residential units and a limited notification rule with KiwiRail to be notified 10. Consequential amendments to other relevant provisions and references 11. KiwiRail is identified as an affected party in the Notification Rules and notified where new noise sensitive activities seek to locate adjoining or close to the rail corridor or existing noise sensitive activities are altered. 12. Apply noise and vibration provisions to the Knowledge Area where noise sensitive activities are proposed. 14

22 Building Setbacks 25H and Landscape Screening 25H Ruakura Logistics Area No building setbacks from the railway designation corridor are proposed and this will need to be considered further (25H.5.5.4) to provide sufficient space building maintenance access, without the need to access the rail corridor and effects of vibration. Landscape screening is proposed adjoining the rail corridor. The planting setback, species, height of the planting and maintenance will need to be discussed with KiwiRail to ensure that the potential adverse effect of vegetation encroachment onto the corridor is avoided, and sightlines maintained. Decision requested: 1. Provision of building setbacks adjoining the railway designation 2. Specification of landscape details including planting setback, species, height of the planting and maintenance and discussion with KiwiRail as to its suitability Definitions 25H.15 KiwiRail notes that Sensitive Land uses are defined in the context of high voltage transmission lines only. The Plan Change refers to Noise sensitive activities which are not included in the definitions. In the absence of a definition it is difficult to ascertain the nature and extent of those activities being referenced to provide for appropriate noise and vibration performance standard/s. The definition of Transport corridor does not include the rail corridor. 15

23 Decision requested: 1. Define noise sensitive activities 2. Define railway corridor. 16