Today is the final day for feedback on the Draft Government Policy Statement on Land Transport 2021 (GPS) which will be for the years 2021 to 2031. It is also the final day for submissions on the Draft NZ Rail Plan which we wrote about just over a week ago. The GPS is one of the countries most important transport documents because as the name implies, it sets out the government’s transport policies and guides what is invested in.
Submissions close at 5pm tonight and although we’re still finishing ours off, I thought it would be useful to highlight a few key areas to think about. We also covered some of this along with our initial thoughts back in March.
In general we support the direction of GPS 2021 but also have a number of suggested improvements.
The Draft GPS has been being preparation for some time and since the it was released the world has changed. The COVID-19 disruption creates and has highlighted many challenges and opportunities for transport in the coming years. We believe the GPS has a key role to plan in shaping our medium to longer term responses to these and will need to be updated to reflect our new situation. One change in particular is there is clearly a need to further increase the walking and cycling activity class to reflect the need to provide high-quality facilities for people using active modes.
Section 1: The Role of the GPS
We believe it is important for the GPS to guide all government investment into transport, especially now that there will be much more Crown investment outside normal National Land Transport Programme (NLTP) processes (NZ Upgrade Programme, Provincial Growth Fund investment in transport, COVID-19 economic stimulus etc.). Section 1.1 should be clarified to ensure that all of the government’s investment into transport contributes to key transport goals.
Section 2: Strategic Priorities
We support the four strategic priorities at a high level
- Safety – the wording should be tweaked to emphasise the importance of making active modes safer to help support mode shift
- Better Travel Options – more direction about the kind of trips that most need better travel options would be helpful (e.g. trips to higher density areas, short-trips to school, travel for people living in high deprivation areas etc.). In addition, more clarity on what is meant by better travel options would also be useful – if the goal is to reduce car dependency then that should be made clearer.
- Improving freight connections – this is probably the weakest of the four areas and in need of the most work. Looking at the “how this will be done”, the focus seems to largely be about looking after existing networks and shifting to a more multi-modal freight system. This should be made more explicit in the explanation of the priority as currently there is a risk that the priority is wrongly used as a way of justifying large uneconomic motorways.
- Climate Change – Paragraphs 70-77 provide a really good explanation of this strategic priority and similar explanatory text would be useful for the other priorities. However, the actions to deliver this priority area are weak and unclear. The GPS needs a much stronger focus on the scale of change that’s required to meet climate commitments and how that change will be achieved across mode shift, shaping urban form, electrifying vehicle fleets etc.
Section 3: Funding Land Transport
The wording of this section is messy and difficult to read so could do with clarification and simplification. This needs to include providing much more clarity on what should be funded 100% by NZTA (i.e. nationally significant rapid transit as well as state highways) and what should have normal cost-sharing arrangements between the NZTA and local authorities.
The criteria for considering financing could also do with clarification. The current wording seems far too positive towards PPPs given the massive issues faced by existing PPPs and very low current interest rates.
The discussion of innovation in paragraphs 99-102 provides an overly optimistic and unbalanced perspective. While new ways of delivering transport can potentially be beneficial, they can also be an expensive distraction that takes away time, money and focus from critical business as usual activities – e.g. Devonport ridesharing trial. These paragraphs should help guide sorting good innovation (i.e. clearly delivers the desired outcomes in a more effective way) from bad innovation (doing new stuff for the sake of it).
We support splitting PT infrastructure and PT services activity classes to get greater clarity on the levels of investments in each and prevents the issue of one large infrastructure sucking up all of the funding increase, as happened following the 2018 GPS. However, unlike the differentiation between state highways and local roads, this activity class does contain projects that are funded with different shares between central and local government. For example, the Northern Busway extension is fully funded by central government while the Eastern Busway is shared between the council and government. This makes it especially important for section 3.1 to highlight that strategic PT investments should be 100% govt funded like state highways are.
As mentioned earlier, we believe that the upper and lower limits walking and cycling activity class should be increased, if for nothing else, as part of the response to COVID-19.
We also believe some better direction and clarity is needed around splitting up and/or shifting funding over multiple activity classes. Following GPS 2018, a number of public transport as well as walking and cycling projects that are parts of state highway improvements already underway, and that were initially being funded from the state highway activity class, were split off to be funded by the PT and W&C classes. This severely undermined the change in direction in the 2018 GPS. For example the increase in funding for public transport was almost entirely consumed by the class now having to cover the costs of the Northern Busway extension, which was previously included in the State Highway activity class. This direction should also apply to projects in development so that say, a new cycleway built alongside a large new state highway doesn’t consume the majority of walking and cycling budget.
Along with the view that the ‘role of the GPS‘ guide all transport investment, GPS 2021 should include information on the total levels of government investment into transport sector across all activities.
As mentioned, submissions close at 5pm.