Submission On The Government Policy Statement On Land Transport 2024

New strategic priorities

The draft GPS on land transport puts a strong emphasis on economic growth. This is to be achieved primarily through road construction, with a particular focus on the Roads of National Significance, plus urban road expansion to support the provision of additional housing on lower cost urban fringe land. Both will facilitate increased travel by private vehicles. There is no discussion on how this can be reconciled with New Zealand’s international obligations to reduce its greenhouse gas emissions.

Transport infrastructure investments can have a lifespan of 100 years or more. If New Zealand is to achieve a net-zero emissions future beyond 2050, then investment decisions for long-lived infrastructure need to be made strategically in a way that benefits the current economy and supports a future economy that uses 80% less fossil fuel.

Building roads to reach the outer fringes of cities for housing developments is an outdated approach, first implemented in the USA in the middle of the last century. Today’s urban design favours a blended model of living, working, education and leisure activities. Multi-modal transport solutions are an integral part of it, with benefits for emissions, health and productivity.

Apart from a reference to allowing time-of-use charging, travel demand management is largely ignored in the draft GPS despite its potential to improve the effectiveness of the existing transport network. Highest priority should be given to measures which optimise the use of the existing transport networks in delaying or avoiding new construction. The draft GPS includes congestion pricing and reversible traffic lanes but appears to discourage other effective measures including Bus/T2/T3 priority lanes and cycle lanes, presumably because these are seen as disadvantaging (single occupancy) cars.

We need to be smart in the use of investment and technology in all areas - road, rail, bus, cycle, pedestrian and other forms of transport - to enable improved and more sustainable transport outcomes for people, communities and business.

Measures to effectively and permanently improve road safety are included. However, perversely, the draft GPS also seeks to increase vehicle speeds by reversing lower speed limits introduced in recent years on some 2-lane rural roads, and by removing 30km/hr speed limit areas in urban centres. There is ample evidence that demonstrates that lower speeds can save lives.

Inconsistencies which conflict with the stated intent

• Facilitating green field development supported by road access will encourage car-dependent development in urban fringes. The resulting land use will inevitably be low density, discouraging the use of public transport and other alternatives to the single-occupant private vehicle. As has been documented many times, these factors will increase travel by car adding to traffic congestion and carbon dioxide emissions.
• The consultation draft refers to the fast tracking of consents for major infrastructure projects, while stating that walking and cycling projects, which have a much lower cost, are to be subject to a rigorous consultation process (with community members and business owners).
• There is no suggestion that roads defined as being of national significance should first be subject to a cost benefit analysis. Instead, it is implied that it is self-evident that they demonstrate a clear benefit for economic growth simply by being defined as such. Auckland Transport’s decision to not go ahead with the Mill Road route or East West Highway based on their poor benefit-to-cost ratios demonstrates that this assumption cannot be justified.
• Walking and cycling projects, on the other hand, can only be included where they can be shown to benefit economic growth (presumably through passing some cost benefit analysis threshold) or have clear road safety benefits. The reasoning behind this double standard appears to be based on political dogma, rather than on rational thinking.
• Investments in state highway improvements are to support economic growth and productivity, and a safe and resilient transport system. However, this activity class may not be used to fund cycleways, busways, or traffic calming measures (such as speed humps and in-lane bus stops). The exclusion of these “multi-modal improvements” is presumably based on the assumption that state highways are provided for the movement of cars and trucks irrespective of their functions, which can vary greatly depending on their location. State highways should be used for the efficient, safe and effective movement of people and goods, not simply for the use of cars and trucks. Alternative modes of transport must be incorporated in road projects, where appropriate, and not excluded from consideration by a siloed approach to transport funding.
• The consultation draft signals a transition to road use funding based on vehicle (axle) weight, distance travelled, and (where appropriate) the degree of congestion, plus the increased use of toll roads. The proposed increase in the motor vehicle registration fee is, however, inconsistent with this approach as it applies to all registered vehicles irrespective of their usage. Also, any increase in fees during a cost-of-living crisis is unhelpful.
• The consultation draft states that the government is committed to providing an additional crossing of the Waitematā harbour that (at a minimum) provides for additional road connections between the North Shore and Auckland CBD. It is difficult to reconcile this with the statement that “Effective public transport provides commuters with more choice and helps to reduce travel times, congestion and emissions”. The North Shore Busway is by far Auckland’s most effective rapid transit facility. Providing more general traffic lanes into the CBD will encourage commuters to switch to private transport from the busway; and further, it is unclear how the additional road traffic will be accommodated into, through and beyond the CBD.
• Requiring an increase in fare box recovery will inevitably result in an increase in fares. This will discourage the use of public transport and increase the use of private vehicles which will add to travel delays.

What is missing

• Recognition of the importance of integrating land use development with rapid transit in the major urban centres; including recognition of the need for measures to encourage and facilitate higher density mixed use development around stations. The strategic approach to the acquisition of land that the NZTA (Waka Kotahi) is to adopt should also apply to strategic land holdings around existing or planned stations.
• Acknowledgement of the reality that expanding and upgrading road networks is ultimately self- defeating as it encourages more travel by car. The benefits in terms of reducing congestion and travel times are likely to be temporary.
• Provision of a strategy and funding path to improve the rail network for freight and inter-urban travel, particularly in the Tauranga-Hamilton-Auckland-Whangarei area.
• Measures to reduce the heavy reliance on fossil fuels of the New Zealand transport systems. These include facilitating the use of alternatives to fossil fuels for road freight movement, and the further electrification of the rail network.
• The development of a transport strategy that delivers economic productivity and value for money for infrastructure that will last beyond 2050. Any long-lasting infrastructure project attracting current investment must be able to demonstrate clear benefits to a future economy that uses 80% less fossil fuels. If not, the investment is not future-proof, and may even fail to deliver the expected 10-to-20-year returns-on-investment.

What we support

• Allowing time-of-use (congestion) charging and greater use of dynamic lanes to manage demand.
• Measures to put transport funding on a firmer footing including greater use of toll roads and the development of innovative funding options. While public-private partnerships can benefit both parties, when they go wrong the public usually picks up the losses which can be substantial. Alternative models should be investigated.
• A much greater focus on effective policing aimed at reducing drink driving and drug driving combined with a large increase in fines for traffic offences. Distracted driving (particularly using mobile phones while driving) should be targeted also.
• A substantial increase in road maintenance funding combined with actions to reduce costs through improving the effectiveness of road maintenance activities. The proposed focus on whole-of-life costs should be specifically applied to road pavement construction.
• Increasing the funding horizon from 3 to 10 years combined with a greater focus on the 30-year infrastructure plan. New Zealand must avoid the continual re-allocation of transport planning and funding priorities that accompany a change of government. This wastes precious time and resources when both are increasingly in short supply. We need a cross-party collaborative approach to long term transport infrastructure planning that makes full use of independent expert advice and that is accompanied by a well-designed consultation process.
• Delivery of public electric vehicle charging (subject to cost-benefit analysis). Electric vehicles are a proven technology, with lifecycle studies showing their emissions of CO₂ to be 70% less than combustion-fuelled vehicles in countries with clean electricity generation. However, it is not feasible to replace all our vehicle fleet fast enough to meet our agreed emissions reduction targets, and doing so would create unsustainable waste streams. EVs need to be supplemented by public transport, urban re-form (e.g. densification around transport hubs) and the use of low-powered vehicles such as e-bikes.