Objection — Better Journeys on Green Lane West (pending analysis of AT data)

Objection — Better Journeys on Green Lane West (pending analysis of AT data)

City Builders Association Limited · Mark Pervan, Director · 21–29 September 2026

Sent to Auckland Transport (ATEngagement@at.govt.nz, chief.executive@at.govt.nz). Aimsun follow-up also copied to ATOfficialInformation@at.govt.nz. This page is the public record of those letters. It is an objection, not a withdrawal or close-out. AT LGOIMA files (CAS-1395336-C1W8J4 modelling pack, and the CAS-1411140-H3N0H3 response and parking survey files) are not republished here.

Status

• 29 September 2026: AT decided LGOIMA CAS-1411140-H3N0H3 as a partial grant. Only a July 2024 typical-weekday parking survey was released; event-day and pack-in surveys, displacement analysis and mitigation were refused under s 17(e) as not held. City Builders has challenged that decision (Letter 3 below). Status: sent to AT, awaiting decision (decision sought by 13 October 2026; 20 working days is 28 October 2026).
• AT advises the project moves to Auckland Council at the end of September, public engagement is paused, and the Transport, Infrastructure and Development Committee (TIDC) will choose between Option 6, Option 9 and a lower-cost Option TBC.
• AT has confirmed the Manukau Road to Great South Road section is proposed as a peak T2 lane, not a bus lane. Earlier letters below are kept as sent.
• Formal objection on access and parking grounds, sent so it is on the project file.
• Analysis of AT's released material is underway / partly complete (Aimsun follow-up below).
• Further comment may follow. Do not treat this as a closed or limited submission.
• Peak-hour bus lanes (7–10am and 3–6pm weekdays, St Andrews Road to Manukau Road) remove about 116 on-street spaces. The claims that those spaces are "mostly unused" and that far "alternatives" suffice are rejected on the material seen so far.

Letter 1 — Access and parking objection (21 September 2026)

I object to the current Green Lane West proposal proceeding while Auckland Transport's material is still being properly analysed.

This is a formal objection on access and parking grounds. It is sent now so it is on the project file. Do not treat this as a closed or limited submission.

1. The data has not been properly tested

The "mostly unused" claim is not supported without published occupancy counts that show:

• survey dates and times;
• section-by-section results for the 116 spaces;
• whether any count was taken on a Showgrounds event day, pack-in day or pack-out day;
• matching counts on the side streets that already take overflow.

Until that is produced and tested, the claim should not justify removing kerbside space. Quiet weekday averages do not speak for the days that matter on this corridor.

2. There is no parking immediately outside the Showgrounds

There is no reliable public on-street parking at the Showgrounds frontage on Green Lane West. What is offered instead is limited paid parking inside the venue; paid parking at Alexandra Park (Campbell Crescent / Gate B / Gate D); and "limited" street parking on Puriri Drive and surrounding streets further away. Do not count Alexandra Park, Puriri Drive, Campbell Crescent or Clinical Centre weekend parks as "outside the Showgrounds."

3. Booth staff cannot "just park somewhere else"

Exhibitors and booth crew are all-day users. They cannot leave a stand at 2.40pm because a bus lane starts at 3pm. Overflow already lands on Claude, Emerald, Gardner, Crescent, Maungakiekie and streets behind the venue. Removing Green Lane West kerbside in the peak windows on event and pack-in days pushes that captive fleet further into those streets. Pack-in is worse: Gate 1 loading sits in the same hour as the morning bus lane.

4. Side streets are already saturated

AT's September 2023 review around Greenlane Clinical Centre found average peak occupancy of about 87%, and up to 99% on some sections of Claude Road, Emerald Street, Gardner Road and Crescent Road. Pointing to "alternatives" on streets already measured as full is not mitigation.

5. Access that must be proven, not assumed

• Clinical Centre (214 Green Lane West): Gate 1, Claude Road access, 30-minute drop-off, taxis and shuttles must work when the kerbside is a bus lane.
• Cornwall Park District School (193 Green Lane West): constrained access; arterial parking removed in the same hour as drop-off/pick-up risks circling onto Wheturangi, Maungakiekie and the school access.
• Showgrounds: event traffic sits under a Transport and Traffic Management Plan. Event-day and pack-in scenarios in AT's data must be identified, or AT must say they are not in it.

6. What must be recorded now

Record this as an objection. Until analysis is finished and answered:

• do not treat the "mostly unused" claim as settled;
• do not finalise detailed design or the traffic resolution on that claim;
• place these letters on the project file.

Still required:

1. Occupancy surveys for the 116 spaces, and matching side-street counts, including a midweek trade-show day and a pack-in day.
2. A space-by-space list of which of the 116 parks sit on the Showgrounds Green Lane West frontage.
3. Displacement analysis for Clinical Centre peaks, school drop-off/pick-up, and Showgrounds event/pack-in days that overlap 7–10am and 3–6pm.
4. How Gate 1 loading, exhibitor parking, Clinical Centre drop-off and school access operate when the kerbside is a bus lane.
5. Day-one mitigation — not "we will monitor."

Letter 2 — Aimsun follow-up (addition, 21–22 September 2026)

This is an addition to the parking objection and to the 13 August 2026 objection. It is not a withdrawal or close-out. Place it on the project file with CAS-1395336-C1W8J4.

After considering the Aimsun pack released 16 September 2026:

• Option 5 and Option 6 are indistinguishable network-wide (differences inside seed noise).
• Where local changes are robust, they are mostly worse under Option 6 (routes and intersections).
• The pack has no do-minimum, no Gate 1 / Showgrounds / school movements by name, no event-day demand, and no occupancy survey for the 116 spaces.

The parking and access objection stands. Bus reliability is a legitimate aim; using an untested average and distant parks to dismiss access effects is not.

Summary findings from the pack

The released pack is an Auckland Council Aimsun Next microsimulation (Greenlane West, Great South Road to Manukau Road; modelled day 7 April 2022; AM 07:00–10:00 and PM 15:00–18:00; Option 5 vs Option 6 only). Network flow, speed, delay and unfinished trips show no meaningful Option 6 benefit. Robust local degradations exist but object IDs have no street names in the pack — AT must map them to the named accesses.

Still missing relative to the LGOIMA ask: do-minimum; destination-named turning movements and 95th-percentile queues at Clinical Centre Gate 1, Showgrounds and Cornwall Park District School; event/pack-in demand; parking occupancy; ID-to-name lookup / native files; published calibration.

Letter 3 — Response to AT decision on CAS-1411140-H3N0H3 (29 September 2026)

Sent to Auckland Transport (ATOfficialInformation@at.govt.nz), copied to Auckland Council Official Information and Cr Andy Baker (Chair, Transport, Infrastructure and Development Committee). It asks for a fresh s 13 decision, makes a new s 10 request, and asks for an s 12 transfer to Auckland Council.

I have your letter of 29 September 2026 and the file Parking Survey.zip.

This is not an acceptance of the decision. It is a record of what was asked, what was refused, what the attached survey does and does not show, and what must now be released or transferred before TIDC considers Options 6, 9 and TBC.

1. The 21 September request, restated

The request was for five things, not a generic parking dashboard:

• Occupancy surveys for the 116 affected spaces and matching side-street counts, including a midweek trade-show day and a pack-in day.
• A space-by-space list of which of those 116 spaces sit on the Showgrounds Green Lane West frontage.
• The displacement analysis for Clinical Centre peaks, school drop-off / pick-up, and Showgrounds event / pack-in days that overlap 7–10am and 3–6pm.
• How Gate 1 loading, exhibitor parking, Clinical Centre drop-off and school access operate when the kerbside is a special vehicle lane.
• Day-one mitigation — not a promise to monitor later.

Item 2 is answered. Items 1, 3, 4 and 5 are not.

2. Item 2 — geography accepted

I accept the statement that there is currently no kerbside parking on the Auckland Showgrounds frontage, and that the 116 spaces affected by peak-hour special vehicle lanes sit west of Manukau Road (St Andrews Road to Manukau Road).

That clarification does not dispose of items 1, 3, 4 or 5. Showgrounds Gate 1, exhibitor movement, Greenlane Clinical Centre and Cornwall Park District School sit on or take access from the Manukau Road to Great South Road section, where the live proposal is a peak T2 lane, not a bus lane. The operational questions attach to that section. Treating a west-of-Manukau parking map as an answer to east-of-Manukau access is a category error.

3. Item 1 — the attached survey is not the information requested

The zip contains an Eliga dashboard export (Greenlane West Parking Survey Summary.pdf, PDF created 8 July 2024), a .pbix file, and four filtered screenshots. On the face of that material:

• The inventory is 122 spaces, not the 116 used in public statements and in the request.
• Headline occupancy is a corridor average of 17–19%, weekday 27–30%, weekend 4–10%, mean duration 5.1 hours.
• The only daily comparison visible in the screenshots is Saturday versus Tuesday.
• There are no side-street counts.
• There is no trade-show day and no pack-in day, which you have now confirmed were never surveyed.

The same files undermine the corridor average you are relying on. When the dashboard is filtered to the eastern 62 spaces at the Manukau Road intersection — the spaces that actually interact with Clinical Centre, school and residential side streets — weekday occupancy rises to 53–59%, with average occupancy 33% (AM) / 36% (PM). Averaging those spaces with the long, lightly used string further west produces the 19% figure. That is not an occupancy survey of the 116 affected spaces. It is a dilution.

A 2024 typical-weekday dashboard, with no event day, no pack-in day and no side streets, does not answer a 2026 request about those three conditions. Section 13 of the LGOIMA requires a decision on the request as made. Substituting a different, older, incomplete product is not compliance.

I do not ask you to invent a new field survey under LGOIMA. I do ask you to stop describing this file as if it were the requested survey.

4. Items 1, 3 and 5 — the s 17(e) refusals are too wide

You have refused:

• occupancy surveys for a midweek trade-show day and a pack-in day;
• any displacement analysis for Clinical Centre peaks, school drop-off / pick-up, and Showgrounds event / pack-in days overlapping 7–10am and 3–6pm;
• any post-implementation monitoring or day-one mitigation plan;

each under section 17(e) of the LGOIMA, on the basis that "the requested information does not exist".

Section 17(e) is available only where the document alleged to contain the information does not exist or, despite reasonable efforts, cannot be found. It is not a licence to refuse every document that is adjacent to the question. The Ombudsman's guide Information not held: A guide to sections 18(e) and (g) of the OIA and sections 17(e) and (g) of the LGOIMA requires a reasonable search, a record of that search, and consideration of other information that would meet the request. Section 17B requires the agency to consider consulting the requester before relying on s 17(e) or s 17(f). Your letter does not record that consultation, or the search.

LGOIMA does not require Auckland Transport to create a displacement model that was never built. It does require release of information already held that answers the same subject matter. That includes, at minimum:

• the 28 February 2025 optioneering / productivity modelling and every later model run for Options 6, 9 and TBC;
• any parking, access or "people-moving" assessment used to support the November 2025 consultation statement that "116 parking spaces will be unavailable during SVL hours, but most are not being used, and alternative parking options exist";
• any traffic management plan, event access plan, or correspondence with Auckland Showgrounds, Tātaki Auckland Unlimited, Greenlane Clinical Centre / Te Whatu Ora, or Cornwall Park District School covering Gate 1, pack-in / pack-out, exhibitor vehicles, ambulance / drop-off, or school peak access under a peak SVL / T2 layout;
• any draft or final monitoring framework, mitigation schedule, or "day-one" operational controls prepared for handover to Auckland Council;
• the TIDC / Council papers that define Option 6, Option 9 and Option TBC, including costs, benefits, trade-offs, and any statement of residual parking or access effects.

If any of that is held by Auckland Council, or is more closely connected with Council's functions from 1 October 2026, section 12 requires transfer of that part of the request promptly and in any event within 10 working days. A s 17(e) refusal at Auckland Transport, in the same letter that announces the handover, without a s 12 transfer, is the wrong statutory path.

Please now either: (a) release the documents listed above, or (b) transfer the request under s 12 to Auckland Council and confirm the date and reference of transfer, or (c) confirm, after a recorded reasonable search, that none of those classes of document exist, and provide the search record (systems searched, date range, teams asked, and who certified the result).

"Does not exist" for a finished displacement report is not the same statement as "we never looked at Clinical Centre, school or Showgrounds peaks." If the second statement is the true one, put it in writing. That is official information about the state of the analysis, and TIDC is entitled to see it before it chooses an option.

5. Item 4 — T2 rules are not an operations answer

I note the correction that the Manukau Road to Great South Road proposal is a T2 lane, not a bus lane, that left-turn access into the lane remains available within 50 metres of a left turn, that right turns across the lanes continue, and that Showgrounds loading is said to occur on-site.

That is a restatement of the default T2 / Land Transport (Road User) Rule position. It is not a description of how Gate 1, exhibitor vehicles, Clinical Centre drop-off or school access will function at 7–10am and 3–6pm on an event day or a pack-in day, when the kerbside lane is no longer general traffic and on-street parking on the western section is also removed.

Please release any existing note, email, drawing, TMP or meeting record that addresses those four movements under the consulted layout or under Options 6, 9 or TBC. If the only held information is the four sentences in your letter, say so in those terms.

6. The TIDC update does not freeze the request

You advise that the project team transfers to Auckland Council at the end of this month; that Council has directed no further public engagement at this stage; and that TIDC will consider:

• Option 6 — the November 2025 consulted design;
• Option 9 — the design that was being prepared for engagement;
• Option TBC — an intermediate, lower-cost option still to be confirmed.

That is a change of decision-maker, not a change to the duty to release official information. The option papers, costings, benefit statements and residual-effects statements that TIDC will use are official information now. They are more closely connected with Auckland Council's functions from 1 October 2026. Transfer them under s 12. Do not wait for TIDC to pick an option and then tell the public what was decided.

Council's instruction to halt public engagement does not authorise a paperless choice between three corridor options that include peak removal of 116 spaces and a T2 lane past a hospital, a school and a national showgrounds, on a record that contains no event-day occupancy, no side-street counts and no displacement analysis. If that is the state of the file, TIDC should receive that fact in writing, not a corridor average from July 2024.

7. Decision sought by 13 October 2026

This letter is:

• A request under s 13 that you revisit the 21 September request and issue a fresh decision that matches the request as made.
• A new, particularised request under s 10 for the classes of document listed in section 4 above, including Options 6, 9 and TBC papers.
• A request that any part more closely connected with Auckland Council be transferred under s 12, with written confirmation of the transfer.

Please treat the new request as urgent. TIDC is being asked to choose a corridor option on an incomplete effects record. Twenty working days from today is 28 October 2026. I expect a transfer decision well before that, given s 12's 10-working-day cap.

If the decision remains that the only held parking evidence is the July 2024 Eliga export, and that no displacement, event-day, school, Clinical Centre, Gate 1 or day-one mitigation document exists, say that in a form that can be put in front of TIDC and, if required, the Ombudsman under s 27(3).

Sign-off

Mark Pervan
Director, City Builders Association Limited
330 Dominion Road, Mount Eden
www.thecitybuilder.com · 021 737 826
founder@citybuildersassociation.org

Related answer: When is a transferred LGOIMA request due?

Update, 29 October 2026: options paper still to be written

Auckland Transport answered our request for the options papers on Green Lane West (Options 6, 9 and TBC) on the due date, 29 October 2026. The papers were refused under s17(e) of LGOIMA because they have not been written yet. The TIDC committee is expected to consider the options later this year, and responsibility has moved from Auckland Transport to Auckland Council under the transport reform.

The response also confirmed:

• No parking displacement analysis has been done.
• There are no midweek trade-show, pack-in day or side-street parking counts.
• There is no day-one mitigation plan yet. The approach relies on talks with the Showgrounds, the Clinical Centre and local schools, plus monitoring after the change.
• Raw survey data was withheld because it contains number plates.

We asked on 29 October for attachments the letter said were included but were missing. Our related request (CAS-1411140) remains with the Ombudsman as case 049295.

What this means

Auckland Council now owns this decision and the options paper is still to be written. That makes now the time for residents, businesses and the Showgrounds community to ask the TIDC committee for a parking displacement assessment and a day-one mitigation plan before any option is chosen.

1 November 2026: letter to the TIDC chair and deputy chair

Mark Pervan (Director, City Builders Association Limited) wrote to Cr Andy Baker (Chair) and Cr Shane Henderson (Deputy Chair): "Green Lane West options: no parking displacement or business impact analysis exists. Please do not decide until it does". Citing the 29 October LGOIMA response (CAS-1414798), it asks the committee to require and publish, before deciding: a parking displacement analysis (including Clinical Centre, school and Showgrounds event days, 7-10am and 3-6pm), a business impact assessment per option, side-street and event-day counts, a day-one mitigation plan, and redacted survey data. Otherwise, defer the decision. Status: sent, awaiting reply.