Last month the government released their draft policy statement (GPS) for transport. It represents a significant change from GPS’ of the previous government and is a positive step forward, not just in its funding bands but in its language too. Consultation on the GPS closes today at 5pm. Here’s our submission.
Summary:
Greater Auckland strongly supports the 2018 draft Government Policy Statement (the GPS). The GPS represents a bold, welcome and overdue shift in New Zealand’s transport policy that focuses on the wider impacts of transport on the lives of all New Zealanders.
In particular, Greater Auckland strongly supports:
- The stronger focus on road safety
- The emphasis on “access” as a critical transport outcome and the greater focus on providing improved travel options (especially public transport, walking and cycling) to deliver access
- The greater focus on environmental outcomes
- The improved balance across different transport investment areas in the activity class “funding bands”, particularly the increased funding for public and active transport and the introduction of a the “rapid transit” and “transitional rail” activity classes.
Greater Auckland notes that the GPS was released before the Auckland Transport Alignment Project (ATAP) had been completed. A number of changes to the GPS are likely to be required to give effect to ATAP.
The following sections provide more detail on these areas of support, as well as some suggested wording improvements or amendments to the GPS.
Section 2 – Strategic Direction
We support the broad structure of the strategic direction, including the four priorities of safety, access, environment and value for money. We agree that safety should be recognised as the highest priority.
Safety
New Zealand faces a road safety crisis, with much of the gains of the past few decades being lost as more New Zealanders are killed or seriously injured on the country’s roads. As discussed in the ATAP report, this increase has been particularly high in Auckland – and especially for vulnerable road users.
We particularly support the following parts of this section:
- Recognition in paragraph 23 that mistakes by road users are inevitable and the focus needs to be on minimising the consequences of these mistakes.
- Recognition in paragraph 30 of the “Vision Zero” approach to road safety. This approach has delivered substantial improvements in road safety outcomes in the countries it has been implemented.
- Faster implementation of the new “Speed Management Guide”, as referred to in paragraph 35. The risk of death or serious injury increases exponentially with speed and therefore reducing speeds is one of the best ways to improve safety outcomes, particularly for pedestrians and those riding a bike.
- Recognition of the need to improve the safety of walking and cycling. This will help to increase the use of these travel modes.
We suggest the following amendments:
| Paragraphs | Suggested change |
| General comments |
|
Access
We support the emphasis placed on “access” as a key transport outcome. Fundamentally access is the purpose of transport, which enables us to reach social and economic opportunities.
Multiple parts of this section highlight the importance of travel choice to access, which we strongly support. The value of travel choice has been consistently underplayed by previous transport policy documents, which has then been reflected in the imbalance in their funding priorities. Travel choice enables people to move around in the way that best suits their needs and can help to reduce household transport costs by no longer ‘forcing’ households to own multiple vehicles.
We particularly support the following parts of this section:
- Recognition of the strong links between land-use and transport in paragraphs 50 and 51. It is frequently noted that the best transport plan is a good land-use plan.
- The strong focus on Auckland, particularly in relation to the very large amount of growth projected to occur in this city. This section will need to be updated to reflect the final ATAP document.
- The greater emphasis placed on transport supporting high quality places in paragraphs 71 to 73. Our streets make up a very large part of our public space and make a critical contribution to our quality of life.
- The important role of public transport in moving large numbers of people in a constrained space (paragraphs 74-76)
- The focus on equitable access and specific desire to push for modal shift to public transport, walking and cycling in paragraphs 86-93
- The shift in policy to allow NZTA to fund footpaths as a critical part of the transport network, as signalled in paragraph 93
- The greater emphasis on long-term, system-wide resilience that is detailed in paragraphs 99-102
We suggest the following amendments:
| Paragraphs | Suggested change |
| 63-70 (Auckland) |
|
| 74 (Public Transport) |
|
| 81-85 (Regional Economic Development) |
|
Environment
Our transport system creates unacceptable environmental impacts and we support the greater emphasis that has been placed on reducing these impacts in the GPS.
We particularly support the following parts of this section:
- The strong focus on reducing greenhouse gas emissions from the transport sector
- The emphasis on reducing greenhouse gas emissions through improving the quality of more sustainable transport options like public transport, walking and cycling
- The recognition (in paragraph 114) of the importance in integrating land use and transport to reduce environmental impacts. Urban sprawl is extremely difficult to serve with sustainable travel options.
We have no suggested amendments to this section.
Value for Money
We support the emphasis on value for money in the GPS, although we think a very different approach to the concept of value for money is required to regain public confidence that investing in transport actually delivers long-lasting benefits to society.
In particular, we think the current benefit-cost analysis process has fundamental flaws and needs major overhaul to avoid some of the perverse outcomes it currently creates (further explained here: https://volterra.co.uk/wp-content/uploads/2016/09/Transport-land-use-and-economics-Paul-Buchanan.pdf ).
Despite New Zealand spending tens of billions of dollars on transport over the past decade we have clearly gone backwards on all of our key transport outcomes: congestion is worse, the number of people dying on our roads is increasing and transport emissions have grown. Value for money needs to be considered in this more holistic way so there is much greater accountability for the actual high level impacts of public investment in the transport system.
This section goes some way towards addressing our concerns, and therefore we particularly support the following:
- Recognition in paragraph 131 of the need for investment analysis to be undertaken in a way that takes into account changes in demand, technology and innovations. For example, the impact of road pricing on the need for major investments in Auckland must be taken into account in the investment assessment process.
As noted earlier, we consider substantial changes to this section are required to better show how value for money at a system-wide level is being achieved.
Transitional Rail Funding
We support the creation of the transitional rail activity class to provide a sustainable funding model for rail projects. Critical rail projects, like Auckland’s third main, have previous suffered from a lack of certainty and no clear path for receiving funding. Other rail projects, like City Rail Link or electrification, have required ad hoc funding arrangements that are very complex and have led to substantial delays for these key initiatives.
This section should be updated to reflect ATAP, which includes key projects like Pukekohe Electrification and the Third Main.
Themes
We support the themes identified in the GPS, particularly “mode neutrality” and “integrating land use and transport”.
Mode neutrality is a particularly important change to transport policies. Previously there has not been a level playing field for different types of projects, making it particularly difficult for rail, public transport and other key investments to proceed – even though they have often been very high priorities.
Section 3 – Investment in Land Transport
We support the major changes to this section, including the improved balance across investment areas and the creation of new activity classes for rapid transit and transitional rail. The only amendments we suggest are:
- Ensuring there are fair and consistent funding arrangements across different projects that perform a similar role in the transport system (e.g. rapid transit and strategic roads). While funding assistance rates are determined by NZTA, the GPS could provide some guidance to this work.
- Ensuring the funding details in each activity class give effect to ATAP and enable delivery of the ATAP Package.
- Paragraphs 196-199 appear to be out of date and need to be updated to align with the most recent version of ATAP.
Again, submissions close at 5pm today.
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Excellent submission. Thanks Greater Auckland. One point that encouraged me to raise “Environment” to the same priority as “Safety” and “Access” in my submission, was this statement from the recently-published the Low-Emissions Economy Report by the Productivity Commission:
“The Government should make emissions reductions a stronger strategic focus in transport investment. This should include changes to the Government Policy Statement on Land Transport to broaden its scope to cover the whole land transport system and make the transition to a low-emissions economy a strategic priority.”
The changes required to lower carbon emissions in transport would the same changes required to improve safety and access anyway, but raising its importance will surely tip the analysis of each project towards PT.
Thank God Almighty for you lovely transport anoraks who go through this stuff and actually make sensible and line-by-line submissions.
Matt,
I submitted yesterday myself. Using their website feedback form.
But I noticed the first question they asked there was one about the relative priorities of the four priorities.
They asked if the GPS’ priority of safety and access above the other two priorities was right.
And for feedback why or why not.
It appears that GA prefers safety be put above all the other 3 in terms of priority?
My submission agreed with safety and access but also said that environment must also come up there as well.
in fact if you look at it, we often degrade the environmental and safety outcomes at the same time with poor decisions made for the expediency of value for money and/or improved access reasons.
In the short term we do need to prioritise safety, the road toll demands it, but we can’t simply postpone the environmental affects until the next GPS 10 year period (or even wait 3 for the next GPS update either to do something concrete with regard environmental priorities.
Having to meet all these mid year “end of year” feedback deadlines for the local and central government consultation. Right now means I feel like I’ve been through consultation and feedback hell already this week with deadlines left right and centre.
Yes.
” as more New Zealanders are killed or seriously injured on the country’s roads”
Do we not care about those who are not New Zealanders? How about referring to “people” rather than being nationality-specific.
great work GA.
I particularly appreciate your request to remove or reduce the distinction between peak and offpeak PT. As Auckland grows and diversifies (in terms of work patterns and lifestyles) then congestion will become increasingly prevalent across the entire day/week. Indeed, I understand that some Saturdays already see higher travel demands on the state highway network than during the traditional weekday peak periods.
Auckland is growing into a real city, where lots of different people do lots of different things at lots of different times. That means we need a PT network that is sufficiently fast, frequent and connected so that it can flexibly accommodate a wide-range of travel patterns. Some off-peak inbound trips, for example to the city in the middle of the day, may in turn generate peak outbound trips. As Auckland grows, the distinction between peak and off-peak travel will reduce.
And there’s no reason why PT can’t meet these demands while also improving overall efficiency: As you noted in an earlier post where you compared Auckland’s bus fleet to Vancouver and Brisbane, growing off-peak supply/demand essentially means wringing more value out of fixed vehicle assets.
Done, basically just said support GA’s post/submission.
great work.