(Final version of our submission agreed 7 August 2017)

Submission on Otago Regional Council's application to DCC to build the bus hub

I/We wish to lodge a submission on the above notice of requirement:

Name: Peter Dowden Role: co-president Organisation: Bus Users Support Group Ōtepoti Dunedin

Submission details:

  • We support this application
  • We wish to speak in support of our submission at a hearing
  • If others make a similar submission, we will consider presenting a joint case with them at a hearing

The specific parts of the notice of requirement that this submission relates to are:

  • the proposed design

Our submission is below We seek the following recommendation or decision from the Dunedin City Council as described below

  • We have read and understand the Privacy statement

Bus Go Dunedin is proud to support the Otago Regional Council's Public notice of requirement for a designation application to build a bus hub.

We believe the intention to build a bus hub is consistent with the Resource Management Act 1991 section 5 "to promote the sustainable management of natural and physical resources."

Our support is conditional on some details of the applicant's project which appear to fail to meet the requirements of the Act. Our concerns relate to health, safety and amenity and to efficiency.

Health, safety and amenity

Lack of weather protection

The lack of protection from rain for passengers walking to and from the main city retail area, and transferring between bus stops at the hub as proposed represents a downgrade of facilities, as all current principal bus stops in the city centre are linked from George St and/or to one another by uninterrupted veranda cover apart from street crossings.

Lack of pedestrian safety

The majority of passengers departing from the bus hub will do so on to southbound buses departing from the eastern side of Great King St, which will require a crossing of the road for all people originating from the Octagon, Library or George St areas. This flow of pedestrians is poorly provided for in the design, with the sharply-angled shape of Community House deflecting the flow of pedestrians away from the hub. These people heading to the opposite side of the hub are then provided with a street crossing which also heads away from their desire line. People who spot their bus ready to depart on the far side of the hub are likely to wander across the street, in conflict with turning buses arriving and departing the hub at the Moray Pl intersection. The hub development includes the blocking of a popular pedestrian route over publicly-owned land behind Community House, when this route could provide a safer route to the heart of the Hub, with its own mid-block street crossing located where buses are travelling in a straight line, not turning.

Granting the applicant's notice of requirement for a designation may therefore be unlawful as it would breach Section 5 (2) of the Act: "sustainable management means managing the use, [and] development ... of ... physical resources in a way, ... which enables people and communities to provide for their social, economic, and cultural well-being and for their health and safety."

The new hub may be unlawful if it provides a lower standard of amenity than existing bus stops. This would breach section 7 of the Act, which states: "all persons exercising functions and powers under it, in relation to managing the use, development, and protection of natural and physical resources, shall have particular regard to ... (c) the maintenance and enhancement of amenity values."

To fully comply with sections 5 and 7 of the Act, Bus Go Dunedin requests that the application be declined unless it provides for the health and safety and amenity of users with the following:

  • continuous rain protection along both sides of the street, linking all bus stops to one another, and to George St
  • a safe, direct route to and from the hub for pedestrians, located far from turning buses


Once again to quote the Resource Management Act 1991's purpose, section 5 "to promote the sustainable management of natural and physical resources." and section 7 "persons exercising functions and powers under it, in relation to managing the use, development, and protection of natural and physical resources, shall have particular regard to— ... (b) the efficient use and development of natural and physical resources"

Bus Go Dunedin has researched the behaviour of bus operations in the city centre. At principal "timing point" stops, we note that buses spend far more time simply waiting than they do loading or unloading passengers. At another important city stop, in George St outside Farmers department store (not a timing point), we have spent long periods closely observing the uninterrupted arrival, loading/unloading and swift departure of a steady stream of buses. All but one of Dunedin's bus routes serving the city centre use this present stop, which has room for two buses (or three at a squeeze). The fact that this stop is able to accommodate almost all present Dunedin bus traffic (in one direction) should provide an alternative model for the Hub design.

Here is a link to a timelapse video of the Farmers stop. The continuous arrival and departure of buses at this non-timing stop can be clearly understood:

Bus Go Dunedin is aware of opposition to the hub. We have no desire to see bus passengers benefit at the great expense of retailers, motorists or visitors to the Police Station, and we support the concerns of many opponents to the hub proposal. As advocates for passengers we take no comfort from non-users of the bus service getting a harder time visiting the city.

Bus Go Dunedin, while supporting this application, would agree to a reduction to about half its size of the hub design, if such a request is made by any objector, thereby providing for efficient use and development of physical resources as required by the Act.

This will provide transferring passengers a much easier transfer and will allow a far more efficient and continuous use of the hub by buses. The hub would only consume half the number of on-street parking spaces. In our submission to the Otago Regional Council on its hub design consultation (December 2016) we outlined how such a reduced-size hub could operate: