Submission to Climate Change consultation for Ministry for Environment

Submission to Climate Change consultation for Ministry for Environment

Submission to Ministry for the Environment regarding climate change target

CAN is deeply concerned about climate change.  

CAN strongly supports evidence-based decision-making, and the evidence available strongly supports robust action.

CAN is concerned that the current Ministry for the Environment discussion document calculates the cost of action on climate change, but fails to set out the far higher costs of taking little or no action, which is the current national policy. 


CAN believes that, where challenges exist to the reduction of greenhouse gases from sectors like agriculture, for example, emissions from transport can feasibly be reduced by inexpensive, healthy changes in population lifestyle, which are already occurring.  Transport systems should be energetically targeted to reduce emissions in the shortest possible term, while other sectors improve over the longer term.

At 17%, New Zealand’s transport emissions are lower than many OECD countries in relation to our overall greenhouse gas emissions.  They are, however, higher than the global average of 15%, and produced mainly from road transport.  CAN believes that transport emissions could be reduced substantially.

Road transport accounted for 12,688 of 14,075 kilotonnes of CO2-e emissions in 2013, according to the Ministry of Transport.  Further, much of our road transport is in small vehicles: light passenger vehicles travelled 31 billion kilometres out of a total of 40.4 in 2013.  Thus commercial, heavy freight and bus transport make up less than 23% of overall road transport.  Extrapolating, our car use causes 70% of transport emissions.

Added to this, a large proportion of these trips are very short –up to two-thirds are under 6km in some NZ jurisdictions. Our median work journey is 10.3km according to the Household Survey but 74% of these journeys are done by car, with 49% under 5km in length.  So, many of these are suitable for bicycle transport.  Should cycling be adequately encouraged, and road conditions improved such that cyclists feel safe, an initial goal of transferring 75% of all sub-6km trips to bicycle would, CAN submits, be reasonable (and very beneficial for public health).  This measure alone, while a significant adjustment to the lifestyle of some, has the potential to eliminate about a third of all transport GHG emissions.  Shifting many journeys to public transport would assist further.  

Many sensible measures for improving road conditions –lower speed limits, better driver training, removal of traffic lanes and car parking, route restrictions for heavy vehicles, re-design of junctions etc. – are set out in several Government policies including ‘Getting There’ and the Cycling Safety Panel’s report. Many of these measures are low- or zero-cost, and even engender medium-term cost savings (particularly due to improvements in public health).  Construction of specific cycling infrastructure is another, more expensive option, but even this measure has been reliably assessed as giving a benefit-cost ratio of 8 to 1 (Christchurch City Council), even before long-term environmental rewards are calculated.

Encouragement of travellers to use their bicycle, and education of all road users and authorities on safe and convenient ways to accommodate cycling, are both necessary parts of any coherent mitigation strategy.

National cycling policy required

These goals and measures must be set out in a strong national policy to promote cycling, if we are to reduce our transport emissions.  A national policy must state clear performance indicators, e.g. 20% of all trips to be by bike by 2025.  These must be accompanied by a permanent, qualified national staff who monitor progress and direct policy at both national and local levels.  Examples of national strategies are available, in English, from many European countries.

Current commendable measures enacted by Government are underway –the Nga Haeranga National Cycle Trail, the Urban Cycleway Programme, the high-level Cycle Safety Panel established under the auspices of the NZTA.  However, in comparison with high-carbon-producing transport modes, cycling is drastically underfunded.  Cycling should justifiably receive at least the same per capita funding as car driving now receives.  Failing this, the $100m Urban Cycleway Programme should be repeated not just tri-annually, but every year, until every journey which feasibly can is made by bicycle.

All these measures are coming on the back of a boom in cycling and the historic change in attitudes to transport known as ‘peak car’.  Census and household travel surveys show a surge in cycling numbers, and particular districts now show up to 16% cycling modal share for work trips.


International evidence points incontrovertibly to denser, mixed-use-zoned, liveable towns being more conducive to health and wellbeing for their citizens, as well as dramatically reduced per-capita carbon emissions.  A higher quality of urban design and zoning will not only reduce travel demand and enable low-carbon transport, but result in improved quality of life for New Zealanders.

Urban sprawl has a compounding effect on transport emissions.  By increasing distances between journey nodes, sprawl increases transport demand, while simultaneously reducing transport choice and hence efficiency.  Progressive urban design policies such as the Ministry’s own 'Urban design Protocol' must be strengthened, broadened in scope, and enforced, to halt the creation of suburban sprawl and begin to retro-fit car-dependent neighbourhoods.  

Electric cars and biofuels

The Ministry’s discussion document refers to electric cars as a solution for some journeys, but CAN submits that these would make a small contribution at best.  Electric cars may emit less greenhouse gases if powered by renewable energy while driving, but they still have a significant carbon footprint: about a third of a petrol vehicle's lifetime carbon footprint is created in manufacture, and electric cars have a similar manufacturing demand to fossil-fuel vehicles.  The mining of lithium and other rare chemicals for battery production also has a significant carbon footprint (along with other environmental effects), reducing the benefits of this measure.  Further, electric cars can continue to facilitate suburban sprawl.  What is needed is a break with the car-dependent thinking of the past century and the consideration of transport in a systematic and holistic way.

The discussion document also talks about biofuels, which may provide substitute fuels for some journeys.  Again, persistence with car-dependent thinking, prolonged by new technologies, is inadvisable in the long term.  Biofuel production overseas has suffered from conflict with food production, and prolongs carbon production. 

Public transport 

Better public transport is urgently required.  Multi-modal trips must be supported by a fully integrated transport system allowing travellers to switch from walking, to bike, to train or bus and so on.  Combining bike and bus or train trips can expand the reach and catchment of public transport systems.  A bus stop, for example, with a catchment of 10 minutes walk will have a catchment radius of about 800 metres or 50 Ha; a 10-minute cycling catchment gives a 3km radius, or 2,800 Ha.  This dramatically improves transport demand and land requirements for parking at hubs and stations.  CAN is not qualified to comment in detail on public transport issues, but notes that benefit-cost ratios for current car-dependent transport investments such as Roads of National Significance are marginal and, with the co-benefits for both public health and the environments of train and bus projects, questions the wisdom of further spending on roads.

Freight transport is likewise outside the remit of CAN.  CAN believes, however, that the neglect of rail freight services on a national scale in recent decades, in favour of road freight, is a policy which urgently requires objective economic analysis.  CAN notes that the delivery of small freight items, up to about 40kg, can be done by cargo bike, as was common from the 1890’s to the 1950’s and that this should be given serious consideration in transport policies.  NZ Post is currently replacing bicycles with electric vehicles for postal delivery.  CAN feels that this policy is contrary to good environmental practice, and should be carefully studied for its impacts on the environment, the maintenance and purchase costs for the vehicles, the health of postie staff, and road safety.


The Ministry’s discussion document declines to adequately account for the economic opportunities offered by the transition to a low-carbon economy.  An example is in the potential for the bike and electric bike industry to expand exponentially in New Zealand, with corresponding reductions in the balance of trade.  With a strong uptake of transportation cycling, increases would be required in manufacture, repair, servicing and accessorising, which can much more feasibly be carried out in New Zealand than car manufacture.  Any reduction in overseas spending on motor vehicles has the potential to contribute substantially to the national economy.  

Studies on the cycling economy have been carried out in the UK and EU, where 650,000 jobs were created in the recent cycling boom.  Research papers and economic appraisals are available from the UK Cycling Embassy, from ECF and others.


CAN submits that, with robust action, transport emissions could be reduced by substantially more than the 40% below 1990 overall goals mentioned by many contributors to the climate change debate.  The transport sector can thus punch above its weight in reducing overall GHG emissions.  

Lifestyle changes are inherent in this, changes which are already coming about, and these are to be welcomed not only for their reductions in GHG emissions, but the many co-benefits like improved health and the liveability of our cities and towns.

Transport systems should be energetically targeted to reduce emissions in the shortest possible term. Demand reduction, transport management and active transport must be given high priority.



Sent to at 4.16pm on June 3rd, 2015

Document Type: