The Draft GPS on Transport 2024
Cycling Action Network Submission
2 April 2024
CAN welcomes any opportunity to make an oral submission on this consultation. Please email: chair@can.org.nz
Introduction
Cycling Action Network (CAN) is grateful for the opportunity to provide feedback to the draft 2024 Government Policy Statement for Transport (GPS). We trust that our input will help direct the Government's ambitions for a safe and sustainable transportation system for Aotearoa.
The draft GPS heralds a significant deterioration in the approach to improving the transport system for New Zealand. For decades now, Aotearoa New Zealand has needed to take progressive action on land transport because too few people have safe, affordable and efficient options for how they get around. Prioritising private car travel over everything else means we all lose, including drivers who will experience more traffic.
New Zealanders deserve a modern and accessible transport system that provides choice and flexibility, and makes it affordable to get around by walking, cycling, public transport, as well as by driving. The draft GPS turns its back from this vision. It focuses on growing the reliance on roading and unsustainable levels of driving expensive, harmful, and damaging trucks and cars. CAN strongly opposes this strategy.
CAN aims to see more people on bikes more often. This draft GPS will significantly compromise this vision. A healthy system of transport is the result of a mix of complementary modes of mobility. For too long, the lazy approach of bundling everyone’s travel needs into a one-size-fits-all-roading format has resulted in worsening productivity, safety, health and wellbeing, liveability, and accessibility outcomes.
We simply cannot continue treating our roads and streets like we have in the past. It is critical that we do better at facilitating and enabling multiple modes of transport.
We must embrace an appropriate configuration for mobility in towns and cities that supports the human experience - independent of private cars in large part. We must embrace a low carbon inter-city and inter-regional mobility future - independent of private cars. Car dependency is hurting us already. Building more large roads and underinvesting in traditional modes - as this draft GPS proposes - will only exacerbate ill health, low productivity, stagnant innovation, deteriorating mental health levels, compromised community harmony, and larger amounts of disease, injury, and death.
Doubling down on roads and car dependency is guaranteed to eventually leave transport in New Zealand crippled with our economic performance strangled by inefficient, unsafe journeys in private cars, and a progressively unhealthy population, and degraded environment.
The difficulty of keeping up with maintenance on our existing roading network - the pothole problem - is evidence that the cost of roads is significantly challenging. Locking New Zealand into a future of many more large roads will only mean we have even higher ongoing maintenance costs that are progressively more unaffordable.
Submission responses to questions
CAN strongly disagrees with the strategic priorities and direction outlined in the GPS 2024.
The draft GPS signals a dramatic shift back to neglecting the need to provide and support transport choice, with a strong focus on driving heavy trucks and private cars. Recent efforts to rebalance the needs of public transport, walking and cycling have been gutted. This ill-fated direction will force people back into greater levels of unsustainable car dependency. CAN is deeply worried by this and disagrees with this direction in the strongest possible terms.
The Draft GPS implies there is a refocusing on economic growth as a priority. This is understandable given the cost of living crisis being experienced. We hold that working towards goals of economic prosperity and improved performance will not be sustained on the back of a short term sugar rush from building more large roads.
A responsible Government would take a longer term view of how transport contributes to our economic performance and only invest in strategies that deliver sustained benefits that are truly affordable to New Zealanders. Car dependency and heavy trucking freight are not affordable long term modes we can rely solely on. A roads-heavy strategy will create worse economic outcomes.
CAN is dismayed that there is minimal reference to climate action in the strategic priorities of the GPS, given how significantly land transport contributes to our greenhouse gas emissions profile. The GPS is a missed, and critical, opportunity to lift our game in mitigating climate breakdown. Relying on the Emissions Trading Scheme signals that this Government is not taking climate action seriously. We have strong concerns as to the future costs and consequences of international obligations we will likely fail to meet.
We hold that maintenance of transport infrastructure should be well funded. We have submitted to the Ministry in the past with our recommendations about how to better recover damage cost recovery.1 If we are to follow a user pays principle; we must see costs apportioned to the actual consumer - i.e.: the trucking company or car driver, as opposed to having the government impose trade-offs prematurely based on questionable, often subjective benefit-cost analysis that is opaque to individual citizens.
CAN strongly disagrees with the overarching priority of economic growth and productivity.
CAN would like to draw attention to broader societal goals behind stated economic outcomes like ‘growth and productivity’; which we perceive as lifting everyone’s prosperity, improving the well-being and mental health of all people, restoring sustainable and regenerative environmental quality, and reducing inequity and harm.
Economic growth and productivity are not the only outcomes that need to be supported to achieve such goals. Many of these goals are compromised by focusing too heavily on the narrow goal of economic growth.
We reject the implied premise that economic growth and productivity can be best achieved by reinforcing a roads-only paradigm. We can achieve growth and productivity while also realising broader positive outcomes through transport policy. Car dependency and a roads-heavy freight system are very inefficient and expensive choices that actually hurt productivity and leave our country in a weaker, more precarious economic position.
We know that more and bigger roads don’t necessarily mean shorter commute times or less traffic. The principle of induced demand means more people driving more often - spending more time in an unproductive way.
Enabling people and businesses to access and choose transport options other than private vehicles is a much healthier and productive strategy to grow our economy in a sustainable way.
CAN strongly disagrees that the 15 “Roads of National Significance”, and the “Roads of Regional Significance”, will boost economic growth and productivity.
The implication that our nation will be better off by building more and bigger roads is highly questionable. Again - we reject the implied premise that economic growth and productivity can be best achieved by reinforcing a roads-only ideology. Growth and productivity can be lifted in better ways by not relying on driving private vehicles. Investing in modes other than driving such as passenger rail, rail freight, public transport, and walking and cycling will actually reduce congestion, and create a more active population and a healthier, happier workforce.
CAN fully supports improving public transport through completing Rapid Transit Corridors.
Investing in better performing public transport and multimodal transport solutions is a high priority for CAN. We support improvements to public transport infrastructure and services, such as the work going into the Lower North Island rail improvements.
CAN has observed that there is a critical lacking strategy when it comes to how to best facilitate bikes with rapid transit facilities. There is a piecemeal approach around the country when it comes to accommodating bikes.
For example - in Denmark, many trains are equipped with a dedicated carriage that can carry a lot of bikes on each service, whereas in the Netherlands there are extensive bike parking facilities at train stations. We would like to see a nationally coordinated approach to better meeting both of these use cases for people making multimodal journeys with bikes. We foresee that an improvement in this area will greatly benefit tourism activities by better enabling travellers to connect with all the wonderful recreational cycling and Great Rides around our beautiful country.
We call for a nationwide approach to public transport provision that delivers a cohesive, consistent experience for people travelling. It is our view that New Zealanders and visitors shouldn’t have to face different systems, and standards just because they’re in a different city or on a different island of our country.
We call on the government to also invest in more separated cycleways and better to ensure that travelling by bike is always a safe, attractive and comfortable option for people of all ages. This need is especially great in more built up urban environments where avoiding conflict with dangerous heavy vehicles is paramount.
Regarding the Lower North Island Rail Integrated Mobility project, and acceleration of Wellington’s North-South, East-West, and Harbour Quays bus corridors:
We welcome a commitment to investment in new rolling stock and improvements to rail infrastructure in the Lower North Island.
Government funding for passenger rail and rail freight should be increased across the country, including connections between regions. Increasing use of rail for more journeys and logistics means less traffic and less damage on the roads. We would encourage the Government to take a 30+ year view to reinvigorating passenger rail across the country instead of wasting public funds on building more inefficient roads and only creating greater car dependency and even higher ongoing maintenance problems.
CAN supports the Cycle Wellington ‘Quays Please’ campaign to see well accommodated, separated cycling facilities also provided on the Wellington Harbourside Quays.
CAN strongly disagrees with increasing reliance on enforcement for improving road safety outcomes.
Reliance on increasing enforcement is a sign that more effective interventions to create a safe environment and conditions are lacking. We should be investing in systems and infrastructure that lowers the need for enforcement in general to allow policing to focus on more important criminal issues and events.
Regarding the proposal to review the vehicle regulatory system to better manage safety performance:
Transport safety regulations need to be revisioned to firstly focus on reducing the danger that travellers present to others in public space - such as roads and streets. The secondary harm of our transport system is effectively ignored with the current regulations. The safety of each vehicle occupant / rider / passenger should be the second most important consideration after the safety of others their transport choice interacts with.
CAN strongly disagrees that the measures undertaken by the draft GPS 2024 will deliver value for money.
The Draft GPS represents an irresponsible use of public money for current and future generations. It discards the considerable benefits and value for money that a modern transport system could deliver. We need transport that creates low carbon emissions, and creates greater transport choice and freedom. Not car dependency.
New Zealand cannot afford more large roading projects. The return on investment is increasingly diminishing and more roading will lead to increased harm, injuries, deaths, emissions, worsening public health outcomes from inactivity and pollution exposure, higher renewals and maintenance costs, and increasingly unaffordable fuel and vehicle maintenance and registration bills.
CAN strongly disagrees that NZTA should explore a variety of funding and financing options to help address New Zealand’s infrastructure deficit.
The infrastructure funding deficit is due to decades of car dependency not paying the full costs of the privilege of driving. CAN recommends that the Government should explore a more holistic funding proposition such as we have described in previous consultations1.
Outcomes the Government expects will be achieved
CAN strongly disagrees with the outcomes expected to be achieved through the draft GPS 2024.
This draft GPS will not achieve the outcomes expected because it doubles down on the same priorities and planning approach that have created existing problems. It will instead actively worsen outcomes.
We find it incredulous to call a fund that is tasked with fixing a backlog of potholes as a “prevention fund” - especially as, if fewer potholes is an important objective; more work needs to go into enabling traffic and freight to avoid using roads. If we want fewer potholes in the future - we wouldn’t build more pothole-prone roads that practically guarantees MORE unaffordable maintenance in future.
CAN is deeply concerned that the Draft GPS will lead to higher amounts of disease, injury and death.
We are dismayed at the low level of acknowledgement of public health displayed in the GPS, given the enormous impact on the public’s health and wellbeing our transport system has. More driving leads to unhealthy levels of inactivity, isolation and loneliness, respiratory conditions and other preventable health conditions2.
Regarding the outcomes expected to be achieved under the priority of value for money:
CAN has consistently advocated that cycling projects provide excellent value for money reaching cost benefit ratios of between 10:1 and 20:1 depending on the scope included in analysis.
We note that very few of the proposed roading projects come close to delivering such significant benefits for the costs involved. More people cycling and walking leads to better public health outcomes, which we would hope would play a much larger role in transport policy.
Investment in land transport
CAN agrees with lifting fees, petrol excise, and road user charges.
We direct you to the analysis we have done in the past1 - calling for much broader changes to cost recovering and funding systems.
CAN strongly disagrees with plans to return to the previous practice of regular fuel excise duty and road user charge increases.
We again direct you to the analysis we have done in the past1 - calling for much broader changes to cost recovering and funding systems.
CAN strongly disagrees with the proposed Activity Class descriptions and funding ranges.
We are alarmed at the decrease in funding for walking and cycling and advise that levels for those activity classes at minimum stay unchanged from present. Recent years of transport investment have demonstrated that the funds for these activities should actually be increased further.
Where footpaths, shared paths, and cycleways are a core part of the transport network, their maintenance costs should be integrated with that of the road network.
Statement of ministerial expectations
CAN strongly disagrees with ministerial expectations.
We are dismayed at the statements of the Minister and his apparent lack of understanding of, and the importance of, delivering a diversified and complementary transport system. Roads everywhere do not comprise a performant transport system. We are left with the impression that he only values roading, driving and making more of the expensive, inefficient transport conditions the country is already suffering from.
Further recommendations
- Plan for the transport outcomes we need, and avoid perpetuating what unbridled car dependency has forced on us.
- Take a longer-term view and adopt a broader perspective of societal outcomes when it comes to transport. “Growth” and “productivity” are not sufficient goals in their own right.
- Expand passenger rail and rail freight across the country, as this is crucial to minimising total transport system costs.
- Reverse the ill-advised return to under-investing in walking and cycling, and instead increase the funding pool for these activity classes.
- Tackle transport funding properly1 to establish a sustainable, equitable, and transparent investment and cost recovery model that the people of New Zealand can trust and feel confident in.
- Retain Inclusive Access as a policy focus. People of all ages and abilities need to be comfortable and accommodated in a well functioning transport system.
- Retain the ability for Councils to invest in walking and cycling as part of subsidised local road improvements, at their discretion
- Funding for projects that have multiple objectives, such as Te Ara Tupua (the Wellington–Petone seawall transport corridor protection and shared path), should be split proportionately and not exhaust funding levels from the walking and cycling activity classes.
Summary
CAN has serious objections and concerns about the direction of the draft GPS. We strongly disagree with most aspects, in fact. We recommend that it is significantly altered as communicated above.
- https://alex-m-dyer.medium.com/funding-the-future-of-transport-7c507b03b33e
- Patrick Miner, Barbara M. Smith, Anant Jani, Geraldine McNeill, Alfred Gathorne-Hardy, “Car harm: A global review of automobility's harm to people and the environment,” Journal of Transport Geography,
https://www.sciencedirect.com/science/article/pii/S0966692324000267