This is an HTML version of an attachment to the Official Information request 'Information about bus capacities'.

By email 
Shed 39, 2 Fryatt Quay 
Pipitea, Wellington 6011 
PO Box 11646 
Manners Street 
31 May 2019 
Wellington 6142 
T  04 384 5708 
File Ref: OIAP-7-11031 
F  04 385 6960 
Hugh Davenport 
[FYI request #9841 email] 
Dear Mr Davenport 
Information Request - 2019-093 
I refer to your request for information dated 13 March 2019, which was received by Greater 
Wellington Regional Council (GWRC) on 13 March 2019. You have requested the following 
I was on a bus this morning, that was so full it was refusing to pick up passengers (very unusual 
isn't it!). It was a single decker, bus number 3421 (route 17e, arrived at stop 7718 around 8:42am 
this morning). I noticed that there was 17 standing passengers, right the way back to the upper deck 
(which I believe isn't how it is designed). So that was 17 passengers taking up all possible standing 
I then noticed the placard that said the bus supports 32 standing passengers
I would like to request 
the following based on that information for all types of buses that operate under the Metlink brand. 
- Configuration of standing passengers shown on a top down layout of the bus showing the 
maximum supported 32 passengers standing, and 43 passengers seated. This should take into 
account say the average size of an adult human, including legs sticking out from the seats into 
possible standing area, and ability for standing passengers to hold some support while the bus 
If there is no such configuration, or GWRC have to generate this data (ie, they did not have it before 
this request), then I would like to request whether those numbers are used for the maximum capacity 
of the bus network, even if it is not possible. I would then like to request what Metlink are doing to 
make sure they have the capacity that they thought they had but didn't.
On 15 March 2019 you added the following.  

I saw a response from Metlink on a post at that mentioned 
that the bus contractors are required to have a minimum capacity of 75 passengers. I guess this is a 
request in addition to my other request

How many buses have had that minimum capacity met by actual passengers since July 2018? Ie, 
how many buses have actually had 75 passengers on it at a single time. 
If there are other routes with other contractual minimums, I would like to know how many of those 
have ever had those capacities reached by actual passengers. 
If those minimums have never been reached, I would like to know what Metlink are doing about the 
breach of contractual obligations from the bus operators?” 

On 25 March we extended the timeframe for responding to your Local Government Official 
Information and Meetings Act 1987 (the Act) request to 31 May 2019.  
GWRC’s response follows: 
GWRC cannot provide the drawings, configurations of bus passengers that have been requested 
because we do not have them.  GWRC does not perform the passenger loading calculations.  
Passenger loading calculations are done by the Certificate of Fitness issuing agent on behalf of NZ 
Transport Agency (NZTA).  The resulting passenger loading certificate is placed inside the buses 
The passenger loading is determined by the lesser of two limits, one being the design loading 
limitation of the bus and the other the floor area limitations of the bus.  For all of the criteria used to 
determine the passenger loading, please refer to section 9 of the Land Transport Rule: Passenger 
Service Vehicles 1999 (Rule 31001), which is available on the NZTA website. GWRC relies on the 
passenger loading certificate to determine which of the bus size categories a bus belongs in. 
As indicated above the passenger loading certification is the loading limitation indicated for a 
specific bus type, which GWRC/Metlink further categorise as small, medium, large and double 
decker, each with a minimum seated and standing capacity specified.  It is the category of the bus 
that Metlink uses for planning purposes to service predicted passenger volumes. The loading 
certificate for the bus may therefore in some cases display a bus capacity higher than that actually 
required by GWRC to meet its contractual requirements.   
The bus companies that provide Metlink bus services are contracted to provide a variety of vehicle 
sizes for bus services in each contract area.  Each individual bus trip has a specification for what bus 
category is permitted to operate on that trip.  
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In your follow-up request of 15 March you have asked for data on the number of buses that have had 
their minimum capacity met by actual passengers and what Metlink are doing about the breach of 
contract if those minimums have never been met?  
Specific analysis has not been done on how many buses have had that minimum capacity met by 
actual passengers since July 2018 as it is not a target to fill buses to 100% of capacity and in some 
cases the buses certified capacity may exceed the contractual requirement.  Generally as a rule of 
thumb where buses are regularly exceeding 90% of contractually specified capacity this would be a 
trigger to review bus capacity on a service.  With bus use growing in Wellington along with long 
lead times to source new buses, as well as a national shortage of bus drivers, it is not always feasible 
in the short to medium term to add additional bus capacity.  Incidents in the network that cause 
delays or cancellations of services can cause high loadings on other services and it is not feasible to 
add capacity at short notice to address these events.  
GWRC/Metlink also undertakes monitoring on a regular basis as to whether bus operators are using 
the correct bus category specified on trips.   
As noted above GWRC/Metlink does not hold or carry out specific analysis on how many buses 
have had that minimum capacity met by actual passengers, and to carry out such an analysis would 
require substantial collation and research.  For this reason I am refusing this part of your request 
under section 17(f) of the Act. 
If you have any concerns with the decision(s) referred to in this letter, you have the right to request 
an investigation and review by the Ombudsman under section 27(3) of the Act. 
Yours sincerely 
Greg Pollock 
General Manager, Public Transport