The Nzts Development Process
This document was uploaded by user and they confirmed that they have the permission to share it. If you are author or own the copyright of this book, please report to us by using this DMCA report form. Report DMCA
Overview
Download & View The Nzts Development Process as PDF for free.
More details
- Words: 5,898
- Pages: 17
PAPER ORIGINALLY PREPARED FOR NZAA
The New Zealand Transport Strategy Development Process An assessment of the strategic development process against the Government commitments to collaboration, accountability and evidencebased Peter King 22 February 2008
In 2002 the Government made a commitment to developing policy in a manner that was forward‐ looking, Collaborative, Accountable and Evidence‐based. This paper reviews performance to date against those undertakings.
Table of Contents Executive Summary ............................................................................................................................. 3 1. Statement of Policy Development Principles .................................................................................. 4 2. Background to the NZTS .................................................................................................................. 4 3. Background to the Updated NZTS ................................................................................................... 4 4. Timeframe for consultation on the Updated Transport Strategy ................................................... 5 5. Qualities of the Discussion Paper on Sustainable Transport .......................................................... 6 5.1 Co‐Strategies ............................................................................................................................. 6 5.2 Strategy Omissions .................................................................................................................... 6 5.3 Bias ............................................................................................................................................ 6 5.4 Lack of evidence targets relate to objectives ............................................................................... 8 5.4.1. Assisting Economic Development ......................................................................................... 8 5.4.2 Assisting Safety and Personal Security .................................................................................. 9 5.4.3 Improve Access and Mobility ............................................................................................... 11 5.4.4 Protecting and Promoting Public Health ............................................................................. 13 5.4.5 Ensuring Environmental Sustainability ................................................................................ 15 Proposed relevant intermediate or detailed targets for 2040 ..................................................... 15 6.0 Changing Principles of the Strategy ............................................................................................ 17 7.0 Conclusions ................................................................................................................................. 17 8. 0 Recommendations ..................................................................................................................... 17
New Zealand Transport Strategy Development Process
Page 2
Executive Summary The New Zealand Transport Strategy (December 2002) included a commitment to being: • • • •
Forward‐looking Collaborative Accountable Evidence‐Based.
The NZAA is concerned that these commitments have not been met in the UNZTS development process. The inclusion of a target for single occupancy vehicles, incorporated into the New Zealand Energy Efficiency and Conservation Strategy without reference to the public at any stage which is incorporated into the Updated Transport Strategy as “Agreed” Government policy and which requires the implementation of road pricing and congestion charging is notable for its lack of accountability in particular. The time‐frame for consultation on the Strategy is very compressed and the time to assess submissions so limited it seems unlikely that due account of them will be made. The draft strategy does not link with many other existant strategies such as the Regional Land Transport Strategies and the National Highway Strategy casting doubt on their future should this UNZTS be adopted. Textual analysis of the draft strategy indicates considerable bias. There is very little evidence adduced to support any of the targets included in the strategy. In some cases the text even appears to contradict the feasibility of the targets. Finally the updated strategy contains no forward commitment to transport planning remaining “forward‐looking, collaborative, accountable and evidence‐based” in future. This omission leaves open the prospect of future transport policy not being based on these qualities.
New Zealand Transport Strategy Development Process
Page 3
1. Statement of Policy Development Principles The Government identified in the New Zealand Transport Strategy to 2010 that it would advance transport policy using the following principles: The Way Forward1 The government’s vision of a transport system that is affordable, integrated, safe, responsive and sustainable is ambitious. It requires ongoing development and adaption. In moving forward the government is committed to following an approach that is: • • • •
Forward‐looking Collaborative Accountable Evidence‐Based.
It might therefore be reasonably expected that the update to the New Zealand Transport Strategy would meet these criteria. This paper evaluates the process of the uNZTS development against the criteria of the NZTS.
2. Background to the NZTS The original Transport Strategy in which these principles were published was developed without consultation outside of Government. A draft document was circulated to transport sector and business industry associations in June 2002 who publicly called upon Government to release the document to the public (before that year’s general election). The Ministry did not ever itself publicly release the draft. No public submissions on the draft NZTS were ever called for. The document contains a number of errors of fact and many interpretations of fact that are questionable. It also includes a number of normative statements not normally associated with objective policy. The final document was released, substantively unamended in December 2002, having generated considerable ill‐feeling between Government and the transport sector over the process of policy development. In terms of meeting its own objectives of being “Collaborative, Accountable and Evidence‐based” the 2002 NZTS was poor process. The NZTS then became the cornerstone document of the Land Transport Management Act which gained assent in November 2003.
3. Background to the Updated NZTS Noting that the NZTS target date was 2010, toward the end of 2006 a number of transport sector organisations (including the New Zealand Automobile Association) proposed the collaborative development of a new Transport Strategy to develop a document which improved upon its predecessors. In December 2006 the Ministry of Economic Development released a draft New Zealand Energy Strategy to 2050 and an options paper the feasibility of an Emissions Trading Scheme for greenhouse gases. Simultaneously the Energy Efficiency and Conservation Authority began to consult on the 1
NZTS Page 8
New Zealand Transport Strategy Development Process
Page 4
development of a new National Energy Efficiency and Conservation Strategy. The Ministry of Economic Development held a wide range of stake‐holder engagement meetings and published heavily evidence‐laden forecasts and documents in order to inform submitters. Included in the MED forecasts was the speculation that electric‐drive vehicles could have a bearing on the future of New Zealand electricity demand. In mid‐2007 the Ministry of Transport hosted a sector‐wide conference on transport for the next 50 years. The focus of the conference was predominantly on urban planning and transport. However the leadership role of the Ministry in organising the conference was widely appreciated by the transport sector. The conference was collaborative but inconclusive and weighted heavily in terms of urban congestion. The New Zealand Energy Strategy and National Energy Efficiency and Conservation Strategies were published on 11 October 2007. Among the targets in the final NEECS not included in the draft (released December 2006) NEECS document was the target to: “ Reduce the kilometres travelled by single occupancy vehicles in major urban areas on weekdays by ten percent per capita by 2015 compared to 2007” This is only first raised in passing in the report on submissions to the NEECS published October 07. In effect this target was not consulted on. According to the Sustainable Transport discussion document2 “A Reduction of ten percent on 2007 kilometres travelled per capital by 2015 is an ambitious target that will require major and comprehensive travel demand management strategies for urban areas including economic levers such as road pricing and congestion charging initiatives” Currently both these levers are not provided for in New Zealand law. The target is described as an “agreed” Government target in the discussion paper essentially suggesting that it is Government policy and cannot be changed. The target if incorporated into a final strategy will require regional government to implement these policies through their regional land transport strategies. It is difficult to reconcile this with the commitment to being “collaborative” or “accountable”.
4. Timeframe for consultation on the Updated Transport Strategy The Discussion Paper on Sustainable Transport was released on 11th December 2007 with submissions due by 15 February 2008. This was subsequently amended to 29 February but the scope of the exercise had changed to a “rewrite”. The final updated Strategy is believed to have a due date of 1 April 2008. This effectively gives officials 30 working days to read all submissions, consider the input and include it in any final strategy document. This is not an adequate time‐line for a “collaborative”, “accountable” or “evidence based” strategy to be developed. The Automobile Association considers this process to be only a marginal improvement on that of the original NZTS. By comparison to the extensive consultation process developed for the Energy Strategy and NEECS the consultation on the updated Transport Strategy is unduly brief. 2
Page 52
New Zealand Transport Strategy Development Process
Page 5
5. Qualities of the Discussion Paper on Sustainable Transport 5.1 CoStrategies The discussion paper states that it proposes specific targets for the five NZTS objectives that will “complement transport targets under the government’s sustainability agenda, the New Zealand Energy Strategy and the New Zealand Energy and Conservation Strategy.”3 It further states that “other strategies such as the: New Zealand Tourism Strategy, the New Zealand Disability Strategy and the Positive Aging Strategy will inform the UNZTS. Sea Change, the draft domestic sea freight strategy, was launched on 5 November 2007 and a New Zealand Freight Study will be commencing soon”3 5.2 Strategy Omissions The following existent strategies are not significantly integrated into UNZTS targets or objectives: 1. 2. 3. 4. 5. 6.
Regional land transport strategies (Local Government strategies) (4 mentions) National State Highway Strategy (1 mention) Airways New Zealand’s technology development plan (0 mentions) Airport Authorities Development Plans (2 mentions specifically, 12 generally) Port Companies Development Plans (1 mention) Land Transport Research Strategy ( 0 mentions)
Instead these detailed and significant bodies of work are generalised about without any reference to their content or intentions. This is significant as these strategies essentially outline the bulk of transport capital expenditure for the foreseeable future. As such there is a fundamental disconnect between policy and planned expenditure at a very high level of the strategy. “there is a fundamental disconnect between policy and planned expenditure at a very high level of the strategy” The assumption is that the capital strategies will be driven by the UNZTS, however it appears that little notice has been taken of the work undertaken by those closest to the business issues involved. The UNZTS is part of an evolving policy continuum but this is not reflected in this document. This raises serious doubts relating to “Evidence‐based” and “Collaborative” status of the discussion document. 5.3 Bias The UNZTS Discussion Paper is particularly biased as textual analysis makes plain. The bias is in favour of consideration of emissions, the environment and urban congestion. There is almost no consideration of social equity, transport disadvantaged, the aged or children. There is very limited consideration of business, exports and imports but very little concern for competitiveness. The paper also contains evident mode bias. This is in inverse proportion to the actual use of the modes in question. Limited justification is offered for an emphasis on reversing decades of mode preference other than the assertion (without evidence) that infrastructure cannot be expanded.The 3
Page 8
New Zealand Transport Strategy Development Process
Page 6
most frequently mentioned modes are rail, public transport and shipping followed by cycling and buses. Electric vehicles which are largely absent from New Zealand are mentioned almost as much as cars and light vehicles which abound. Trucks and aircraft are not mentioned much, despite their economic significance. Taxis and mobility scooters are not mentioned at all. Of the four “signpost” topics from the document’s cover “safety” scores by far the highest and followed by “sustainability”. Integration and Responsiveness are barely mentioned at all in the document text.
Topic text mentions 4 Emissions Environment Urban Congestion CO2 Mobility Tourism Rural/Provincial Business Pollution Exports Economic Development Personal Security Imports Children Equity Competitiveness Industry (ex transport industry & heading) Consent/consenting Aged/Older Disadvantaged
Mode text mentions Rail Public transport Ship Cycle/Cycling Bus Car/light vehicle Electric vehicles Aircraft Truck/Heavy Vehicle Taxi Mobility scooter
75 70 55 52 41 22 18 15 11 0 0
96 50 43 34 26 24 15 13 12 9 9 8 7 6 5 2 2 2 1 1 1
“Signpost” text mentions Safety
73
Sustainability
27
Integration
3
Responsiveness
2
This suggests that the document will not be consistent in its treatment of the five objectives of the strategy and it is a mix notably less concerned with national competitiveness than the transport policies of other nations.
4
Mentions in UNZTS document from Adobe Acrobat search
New Zealand Transport Strategy Development Process
Page 7
5.4 Lack of evidence targets relate to objectives The UNZTS document appears to suffer from being based around targets which are not supported by evidence contained within the document. This can be shown by stepping through each of the five NZTS objectives. 5.4.1. Assisting Economic Development Proposed highlevel targets to assist economic development for 2040 Travel times by principal routes within and between major urban areas and key economic nodes (eg main seaports, airports and major industrial areas) to be improved relative to 2007 for identified critical intra and inter‐regional connections, as determined with each region. This high‐level target is supported by the evidence that domestic freight volumes are expected to almost double by 20205. However this is not linked to the Transit State Highway Strategy document or provides any endorsement of it. Given that 97% of Government transport expenditure is on land transport this would seem to be an omission. Travel times by all modes will be predictable. Travel times can be predictably unsatisfactory. This is not a meaningful target. Proposed relevant intermediate or detailed targets for 2040 Lift coastal shipping’s share of inter‐regional freight to around 30 percent (currently about 15 percent of tonne‐kilometres). The document adduces evidence that coastal shipping may become more significant due to shipping industry rationalisation6. However no evidence is provided supporting this target. Indeed the lack of analysis surrounding the impact of the Emissions Trading System which some project could wipe out the New Zealand cement industry7 as well as the forest products industry then it is conceivable the mix of policies could significantly reduce the tonne‐ kilometres dispatched via coastal shipping due to carbon leakage. The AA would be interested to know what evidence informed this target. Lift rail’s share of domestic freight to around 25 percent (currently about 18 percent of tonne‐kilometres). The document produces direct evidence to contradict this target in that only three to seven percent of its share is contestable by road8. There is no evidence that the increase in domestic freight will favour the rail mode. In fact there is evidence that the increase will continue to favour heavy road transport – especially if there is strong carbon leakage due to the implementation of the Emissions Trading Scheme as the current rail task is firmly based on moving heavy industry outputs to sea ports .9
5
Page 25 reference to TERNZ study “Prediction of New Zealand’s freight growth by 2020” Page 27 UNZTS 7 Castalia”The New Zealand Emissions Trading Scheme :How do we make it work?” page 45 8 Page 32 UNZTS 9 New Zealand Freight Matrix , Booz Allen Hamilton, 2005 & TERNZ study above. 6
New Zealand Transport Strategy Development Process
Page 8
At least double the overall public transport mode share to seven percent of all passenger trips (currently about two to three percent). No evidence is adduced to show that this will assist economic development Increase walking and cycling and other “active modes” to 30 percent of total trips in urban areas (currently about 17 percent). No evidence is adduced to show that this will assist economic development Effective real‐time information systems in place to enable road users to plan their journeys to avoid congestion, thereby minimising delay and fuel wastage, by 2015. No evidence is adduced to show that this will assist economic development The document does make mention of New Zealand’s clean green reputation as a national asset to assist economic development. However it must be noted that the only attempt to quantify the value10 of this reputation came to a figure of no more than one percent of GDP. Given the bias in the transport strategy there appears to be some relative over‐valuing of this reputation without any cost‐benefit analysis to justify it. 5.4.2 Assisting Safety and Personal Security Proposed highlevel target to assist safety for 2040 Operate to world best‐practice safety standards for all modes of transport. There is no evidence that New Zealand has ever had world’s best practice safety outcomes for all modes of transport. The document notes that the progress toward the 2010 objectives are “unlikely to be reached”. While the trend line of road deaths on page 35 shows progress to 2003 from that point on the trend has plateaued showing current methods are not making any impression on the road toll. Moreover the injury figures show a decided worsening. Duigan11 suggests that a significant level of the toll improvement has been largely due to improvements in the privately owned motor vehicle fleet. Breen12 notes deficiencies in engineering and education. The text of this target speaks of “safety standards”. It is difficult to determine whether there is any obligation to meet these targets.
10
“Our Clean Green Image, What’s it worth” Ministry for the Environment 2001 Initial Evaluation (“Stocktake”) of Road Safety to 2010 Strategy, Parker Duignan for MOT, 2004 12 Review Of The Road Safety To 2010 Strategy , Jeanne Breen for MOT, 2004 11
New Zealand Transport Strategy Development Process
Page 9
Proposed relevant intermediate or detailed targets for 2040 Road deaths no more than 200 per annum. Given the UNZTS own evidence that the 2010 target will not be reached and the lack of any supporting evidence to show this target is achievable, this target must be regarded as aspirational without supporting rationale. This is in contrast to the 2010 target which was set following exhaustive analysis. Over 40 percent of the light vehicle fleet to have four star or better occupant protection (currently ten to 15 percent) by 2015 and 90 percent by 2040. No evidence is provided as to whether this level of fleet development will occur naturally or will require intervention by Government. No Benefit Cost analysis is provided balancing crash risk against public mobility requirements. This target seems to prejudice the Vehicle Fleet Strategy Discussion paper (not released). Over 25 percent of light vehicles to have electronic stability control (currently less than five percent) by 2015 and 95 percent by 2040. No evidence is provided as to whether this level of fleet development will occur naturally or will require intervention by Government. No Benefit Cost analysis is provided balancing crash risk against public mobility requirements. Proposed supporting targets Targets around serious injuries and social costs resulting from road crashes and for subsets of road traffic, such as targets for various road user groups and freight safety will be developed by mid 2009. It is difficult to be confident of any road deaths target without a properly developed injuries and social costs study. The Road Safety 2020 Strategy will be in place by 2010. Targets for rail will focus on safety at level crossings and the level of trespassing on the rail network. This will also be developed by mid 2009. Social cost targets for aviation safety to 2010 have been agreed and are regularly reported against. Each type of aircraft has its own target level expressed as social cost per seat hour of passenger exposure (see Appendix C). Targets to 2015 are expected to be developed by late 2009. Targets for maritime safety to 2010 have been developed by Maritime New Zealand and look to reduce the number of fatalities, accidents and injuries per year for a range of vessels and for workplace activity (see Appendix C). The undertaking to carry out proper evaluation and analysis for modes other than road is a comforting one but does not constitute a target. A vehicle fleet strategy discussion paper on the New Zealand vehicle fleet will be developed by the end of 2007 and a New Zealand vehicle fleet strategy by early 2008. New Zealand Transport Strategy Development Process
Page 10
A large number of pre‐existing targets appear to anticipate the outcome of this. 5.4.3 Improve Access and Mobility Proposed highlevel targets to improve access and mobility for 2040 All individuals have access to the facilities and activities they need, such as work, education, medical care and shopping centres, to participate in society. This target fails to include any reference to the affordability of access Travel times by all modes will be predictable. Predictability is only a useful indicator if the base performance level is acceptable. The text (page 42) refers only to British rail timetables – where rail is the least used passenger mode in New Zealand. Travel times by principal routes within and between major urban areas and other key activities (such as tourist attractions, hospitals and airports) to be improved relative to 2007 for identified critical intra and inter‐regional connections as determined with each region. This target fails to indicate it applies to roads undermining its value Proposed relevant intermediate or detailed targets for 2040 At least double the overall public transport mode share to seven percent of all passenger trips (currently about two to three percent). There is no evidence that this level of mode share can be achieved and is certainly outside the existing targets of Regional Land Transport Strategies. There is no provision of a benefit cost analysis to show this target is economically desirable. There is no evidence to show that the inclusion of such a target will in fact improve access and mobility for the majority of the population. Increase the public transport mode share of peak hour travel (journeys to work) in Auckland, Wellington and Christchurch from an average of nine percent to 20 percent and work with each region to optimise peak hour travel targets. There is no evidence that this level of mode share can be achieved and is certainly outside the existing targets of Regional Land Transport Strategies. There is no provision of a benefit cost analysis to show this target is economically desirable. There is no evidence to show that the inclusion of such a target will in fact improve access and mobility for the majority of the population. Increase walking and cycling and other “active modes” to 30 percent of total trips in urban areas (currently about 17 percent). There is no evidence that this level of mode share can be achieved and is certainly outside the existing targets of Regional Land Transport Strategies. There is no provision of a benefit cost analysis to show this target is economically desirable. There is no evidence to show that the inclusion of such a target will in fact improve access and mobility for the majority of the population. New Zealand Transport Strategy Development Process
Page 11
Proposed supporting targets Review regional passenger transport mode share targets by 2012 through scheduled reviews of regional land transport strategies, and subsequent regional passenger transport plans. To propose reviewing Regional Land Transport Strategies which on the whole are based on considerable analysis and evidence against the proposed UNZTS targets for which there no evidence is difficult to reconcile with principles of collaborative‐ness and accountability. Implement the initiatives outlined in the walking and cycling strategy’s (Getting there – on foot, by cycle) implementation plan to a level that begins to achieve a shift to these modes by 2015. There is no evidence to show that the inclusion of such a target will in fact improve access and mobility for the majority of the population. Investigate the need to revise funding procedures for walking and cycling projects to ensure all costs and benefits of such projects are accounted for in their assessment by 2009. Revisions should be based on evidence and collaboration. Provide advice on urban design (government will decide on the desirability of providing national guidance on urban design, as outlined in the NZEECS). The Accessible Journey report contains recommendations on how to improve public transport accessibility and includes National Accessibility Design Performance Standards. These will be implemented progressively by 2025 to support our increased public transport patronage target. This section completely ignores evidence that access to a motor vehicle assists access and mobility. It is notable that lack of access to a motor vehicle is a component of the New Zealand Deprivation Index. A report by Infometrics to the Ministry of Social Development reported that access to a motor vehicle significantly improved an individual’s prospects of finding employment. There is evidence from the text of the UNZTS document of close‐minded thinking on access and mobility. The assumption is that the task of improving access and mobility is one of providing public transport. It notes: It should be noted that inadequate funding for infrastructural improvements and public transport services may be a barrier to providing good access and mobility in rural regions such as Northland.13 Affordability of running costs of a motor vehicle is a key determinant of access and mobility in such areas. While it is noted in the UNZTS document that 11% of households do not have access to a motor vehicle it does not provide any indication of whether these households a predominantly inner‐city ones which can rely on public transport, walking or cycling. In many rural communities public transport is not feasible and walking or cycling inefficient. The UNZTS discussion document gives limited consideration is given to the social benefits of the affordability of access to a motor vehicle in rural or provincial New Zealand14. But no corresponding 13 14
UNZTS page 43 UNZTS Page 40
New Zealand Transport Strategy Development Process
Page 12
targets are mentioned and the issue is effectively orphaned. Were these costs to escalate unduly this could have a significant negative impact on rural and provincial communities. No evaluation of the impact is provided. The assertion that “an aging population means the need for accessible public land transport will increase”15 is at best contentious. Evidence from the Ministry of Transport travel survey indicates that older New Zealanders do not favour public transport. This is particularly important when no targets for personal security have been proposed. Finally the access and mobility of New Zealanders as domestic tourists depends almost entirely on the private motor vehicle. Given that two‐thirds of all tourism in New Zealand is domestic tourism and the viability of tourism enterprises (which supports 9.9 percent of the workforce)16 depends on the access and mobility of New Zealanders, maintaining the affordability of access and mobility of New Zealanders by private car should be given somewhat more consideration. 5.4.4 Protecting and Promoting Public Health Proposed highlevel target for promoting and protecting public health for 2040 Public health effects of transport to be at accepted international standards. Proposed relevant intermediate or detailed targets for 2040 Ensure a substantial reduction in premature deaths and serious illnesses arising from air pollution from motor vehicles. The HAPINZ Study clearly notes that “premature” means weeks or days. While improving air quality is a significant matter targets should be based on readily quantifiable and verifiable exceedences of WHO standards. Manage noise to minimise any public health effects. The text of the UNZTS discussion paper17 makes no reference to applying such standards to rail. Any such standards must be mode neutral. 35 percent of the vehicle fleet to have emissions technology consistent with Euro 2 (or equivalent) standard by 2015. This target seems to prejudice the Vehicle Fleet Strategy Discussion paper (not released) calling into question its openness. Imported used petrol, LPG, CNG and diesel vehicles (light and heavy) are to be of Euro 4 (or equivalent) standard by 2012. Imported new petrol, LPG, CNG and diesel vehicles (light and heavy) are to be of Euro 4 (or equivalent) standard by 2009. This target seems to prejudice the Vehicle Fleet Strategy Discussion paper (not released) calling into question its openness. 15
UNZTS page 39 UNZTS Appendix B page 60 17 UNZTS page 46 16
New Zealand Transport Strategy Development Process
Page 13
Increase walking and cycling and other “active modes” to 30 percent of total trips in urban areas (currently about 17 percent). The claim that increasing the total proportion of trips by walking and cycling will improve public health are not supported by any evidence. The point here is that the target is a mode‐ share one, rather than a total activity level one. That is the level of car trips must decline and active modes increase. Thus a trip taking children to organised sports by vehicle is counted as a passive mode while the child’s activity on the sports field isn’t counted as a trip at all. Equally a trip by vehicle to and from a tramping track is a trip each while the hike itself is only one. A highly probably outcome of achieving such a target is that weekend sports would suffer as parents decline to walk or take public transport to their children’s sports fixtures. The claims that active transport modes are more important than recreational use are dubious. In particular the claim that: “While walking and cycling for leisure are growing in popularity, the fitness gains are marginal because of the decrease in walking and cycling for day‐to‐day transport.”18 is wholly unsubstantiated. The absence of targets relating to personal security has a direct bearing on the active mode share of trips particularly by children. The suggestion that the cause of reduction in activity levels is the private motor vehicle is unsupported. There is evidence that electronic media and declining access to recreation grounds have had a significant impact on public activity habits.19 Proposed supporting targets Investigate the need to revise funding procedures for walking and cycling projects to ensure all costs and benefits of such projects are accounted for in their assessment by 2009. Revisions should be based on evidence and collaboration, however there is no indication this will occur The National Environmental Standard on Air Quality includes ambient air quality standards that must be met by regional councils by 2013. These standards cover carbon monoxide, nitrous oxide, ozone, particulates and sulphur dioxide. To help councils meet these standards further targets are being proposed within the vehicle fleet strategy discussion paper.
18 19
UNZTS Page 44 http://www.obesityresearch.org/cgi/content/abstract/12/6/896
New Zealand Transport Strategy Development Process
Page 14
5.4.5 Ensuring Environmental Sustainability It should be re‐iterated that there is no legal definition of “environmental sustainability”. This absence of definition is problematic as noted in the Next Steps review. It is disappointing that nothing has been done to clarify the meaning of this target. Government agreed highlevel targets for ensuring environmental sustainability for 2040 Halve per capita domestic transport greenhouse gas emissions. No evidence is adduced which suggest this is a feasible target. Local environmental impacts of transport (including air and water quality) to be at accepted international standard. No evidence provided this is not the case Government agreed relevant intermediate or detailed targets for 2040 Become one of the first countries in the world to widely deploy electric vehicles. No evidence provided that this is a feasible target A biofuels sales obligation that will begin at a level of 0.53 percent from 2008, increasing to 3.4 percent of annual petrol and diesel sales by 2012. The AA has made a separate submission on the Biofuels Sales Obligation Reduce the kilometres travelled by single occupancy vehicles, in major urban areas on weekdays, by ten per cent per capita by 2015 compared to 2007. The NZEECS contains evidence of projected savings from this measure. We have already noted the lack of collaboration involved in deriving this target. Reduce the rated CO2 emissions per kilometre of combined average new and used vehicles entering the light vehicle fleet to 170 grams CO2 per kilometre by 2015 (currently around 220 grams CO2 per kilometre) with a corresponding reduction in average fuel used per kilometre. The NZEECS contains evidence of projected savings from this measure. This seems to prejudice the forthcoming the Vehicle Fleet Strategy Discussion paper. Ensure 80 percent of the vehicle fleet is capable of using at least a ten percent blend of bio‐ ethanol or bio‐diesel, or is electric powered, by 2015. The NZEECS contains evidence of projected savings from this measure. This seems to prejudice the forthcoming the Vehicle Fleet Strategy Discussion paper Proposed relevant intermediate or detailed targets for 2040 Identify and remove any barriers to the uptake of plug‐in hybrid and full electric vehicles that meet appropriate safety standards.
New Zealand Transport Strategy Development Process
Page 15
Effective real‐time information systems in place to enable road users to plan their journeys to avoid congestion, minimising delay and fuel wastage, by 2015. Lift rail’s share of domestic freight to around 25 percent (currently about 18 percent of tonne‐kilometres). No evidence is provided that this is feasible or would result in emissions savings. Lift coastal shipping’s share of inter‐regional freight to around 30 percent (currently about 15 percent of tonne‐kilometres). No evidence is provided that this is feasible or would result in emissions savings. At least double the overall public transport mode share to seven percent of all passenger trips (currently about two to three percent). No evidence is provided that this is feasible or would result in emissions savings. It is entirely possible that increasing the size of the Public Transport task by this degree would result in empty buses running around cities during the day increasing congestion and providing worse emissions performance than private vehicles. Increase the public transport mode share of peak hour travel (journeys to work) in Auckland, Wellington and Christchurch from an average of nine percent to 20 percent and work with each region to optimise peak hour travel targets. No evidence is provided that this is feasible or would result in emissions savings. It is entirely possible that increasing the size of the Public Transport task by this degree would result in empty buses running around cities during the day increasing congestion and providing worse emissions performance than private vehicles. Increase walking and cycling and other “active modes” to 30 percent of total trips in urban areas (currently about 17 percent). By reducing New Zealanders urban mobility (including all work‐related and delivery trips) so that a third of all trips are undertaken on foot emissions reductions are inevitable. However the implied price of carbon of such policy is likely to be uneconomic. No net loss of indigenous vegetation or fauna from infrastructure construction or maintenance. Given that the Department of Conservation estate covers 30% of New Zealand total land area20 any loss of indigenous vegetation or fauna through construction or maintenance on road corridors should be relatively minor compared to the potential for regrowth on other Crown lands. The need for such an offset is not established.
20
www.treasury.govt.nz/publications/research‐policy/ppp/2006/06‐07/03.htm
New Zealand Transport Strategy Development Process
Page 16
6.0 Changing Principles of the Strategy The glaring omission from the principles of the strategy is the lack of commitment to The Way Forward The government’s vision of a transport system that is affordable, integrated, safe, responsive and sustainable is ambitious. It requires ongoing development and adaption. In moving forward the government is committed to following an approach that is: • • • •
Forward‐looking Collaborative Accountable Evidence‐Based.
This suggests that future Government policy will no longer be required to be any of these things.
7.0 Conclusions In 2002 the Government committed to a programme of being: Forward looking; Collaborative; Accountable; Evidence‐based. To date there is very little evidence that it has developed New Zealand transport strategies or drafts in a manner which are: 1. Collaborative 2. Accountable or 3. Evidence based. This does not suggest that the resulting Strategies will be qualitatively comparable with those of other nations. It also suggests that the resulting Strategies will continue to create on‐going problems of reconciliation with stated Government spending objectives.
8. 0 Recommendations It is recommended that the Strategy be redeveloped in a manner in accordance with the Way Forward principles. It is recommended that the Strategy incorporate the Way Forward Principles.
New Zealand Transport Strategy Development Process
Page 17
The New Zealand Transport Strategy Development Process An assessment of the strategic development process against the Government commitments to collaboration, accountability and evidencebased Peter King 22 February 2008
In 2002 the Government made a commitment to developing policy in a manner that was forward‐ looking, Collaborative, Accountable and Evidence‐based. This paper reviews performance to date against those undertakings.
Table of Contents Executive Summary ............................................................................................................................. 3 1. Statement of Policy Development Principles .................................................................................. 4 2. Background to the NZTS .................................................................................................................. 4 3. Background to the Updated NZTS ................................................................................................... 4 4. Timeframe for consultation on the Updated Transport Strategy ................................................... 5 5. Qualities of the Discussion Paper on Sustainable Transport .......................................................... 6 5.1 Co‐Strategies ............................................................................................................................. 6 5.2 Strategy Omissions .................................................................................................................... 6 5.3 Bias ............................................................................................................................................ 6 5.4 Lack of evidence targets relate to objectives ............................................................................... 8 5.4.1. Assisting Economic Development ......................................................................................... 8 5.4.2 Assisting Safety and Personal Security .................................................................................. 9 5.4.3 Improve Access and Mobility ............................................................................................... 11 5.4.4 Protecting and Promoting Public Health ............................................................................. 13 5.4.5 Ensuring Environmental Sustainability ................................................................................ 15 Proposed relevant intermediate or detailed targets for 2040 ..................................................... 15 6.0 Changing Principles of the Strategy ............................................................................................ 17 7.0 Conclusions ................................................................................................................................. 17 8. 0 Recommendations ..................................................................................................................... 17
New Zealand Transport Strategy Development Process
Page 2
Executive Summary The New Zealand Transport Strategy (December 2002) included a commitment to being: • • • •
Forward‐looking Collaborative Accountable Evidence‐Based.
The NZAA is concerned that these commitments have not been met in the UNZTS development process. The inclusion of a target for single occupancy vehicles, incorporated into the New Zealand Energy Efficiency and Conservation Strategy without reference to the public at any stage which is incorporated into the Updated Transport Strategy as “Agreed” Government policy and which requires the implementation of road pricing and congestion charging is notable for its lack of accountability in particular. The time‐frame for consultation on the Strategy is very compressed and the time to assess submissions so limited it seems unlikely that due account of them will be made. The draft strategy does not link with many other existant strategies such as the Regional Land Transport Strategies and the National Highway Strategy casting doubt on their future should this UNZTS be adopted. Textual analysis of the draft strategy indicates considerable bias. There is very little evidence adduced to support any of the targets included in the strategy. In some cases the text even appears to contradict the feasibility of the targets. Finally the updated strategy contains no forward commitment to transport planning remaining “forward‐looking, collaborative, accountable and evidence‐based” in future. This omission leaves open the prospect of future transport policy not being based on these qualities.
New Zealand Transport Strategy Development Process
Page 3
1. Statement of Policy Development Principles The Government identified in the New Zealand Transport Strategy to 2010 that it would advance transport policy using the following principles: The Way Forward1 The government’s vision of a transport system that is affordable, integrated, safe, responsive and sustainable is ambitious. It requires ongoing development and adaption. In moving forward the government is committed to following an approach that is: • • • •
Forward‐looking Collaborative Accountable Evidence‐Based.
It might therefore be reasonably expected that the update to the New Zealand Transport Strategy would meet these criteria. This paper evaluates the process of the uNZTS development against the criteria of the NZTS.
2. Background to the NZTS The original Transport Strategy in which these principles were published was developed without consultation outside of Government. A draft document was circulated to transport sector and business industry associations in June 2002 who publicly called upon Government to release the document to the public (before that year’s general election). The Ministry did not ever itself publicly release the draft. No public submissions on the draft NZTS were ever called for. The document contains a number of errors of fact and many interpretations of fact that are questionable. It also includes a number of normative statements not normally associated with objective policy. The final document was released, substantively unamended in December 2002, having generated considerable ill‐feeling between Government and the transport sector over the process of policy development. In terms of meeting its own objectives of being “Collaborative, Accountable and Evidence‐based” the 2002 NZTS was poor process. The NZTS then became the cornerstone document of the Land Transport Management Act which gained assent in November 2003.
3. Background to the Updated NZTS Noting that the NZTS target date was 2010, toward the end of 2006 a number of transport sector organisations (including the New Zealand Automobile Association) proposed the collaborative development of a new Transport Strategy to develop a document which improved upon its predecessors. In December 2006 the Ministry of Economic Development released a draft New Zealand Energy Strategy to 2050 and an options paper the feasibility of an Emissions Trading Scheme for greenhouse gases. Simultaneously the Energy Efficiency and Conservation Authority began to consult on the 1
NZTS Page 8
New Zealand Transport Strategy Development Process
Page 4
development of a new National Energy Efficiency and Conservation Strategy. The Ministry of Economic Development held a wide range of stake‐holder engagement meetings and published heavily evidence‐laden forecasts and documents in order to inform submitters. Included in the MED forecasts was the speculation that electric‐drive vehicles could have a bearing on the future of New Zealand electricity demand. In mid‐2007 the Ministry of Transport hosted a sector‐wide conference on transport for the next 50 years. The focus of the conference was predominantly on urban planning and transport. However the leadership role of the Ministry in organising the conference was widely appreciated by the transport sector. The conference was collaborative but inconclusive and weighted heavily in terms of urban congestion. The New Zealand Energy Strategy and National Energy Efficiency and Conservation Strategies were published on 11 October 2007. Among the targets in the final NEECS not included in the draft (released December 2006) NEECS document was the target to: “ Reduce the kilometres travelled by single occupancy vehicles in major urban areas on weekdays by ten percent per capita by 2015 compared to 2007” This is only first raised in passing in the report on submissions to the NEECS published October 07. In effect this target was not consulted on. According to the Sustainable Transport discussion document2 “A Reduction of ten percent on 2007 kilometres travelled per capital by 2015 is an ambitious target that will require major and comprehensive travel demand management strategies for urban areas including economic levers such as road pricing and congestion charging initiatives” Currently both these levers are not provided for in New Zealand law. The target is described as an “agreed” Government target in the discussion paper essentially suggesting that it is Government policy and cannot be changed. The target if incorporated into a final strategy will require regional government to implement these policies through their regional land transport strategies. It is difficult to reconcile this with the commitment to being “collaborative” or “accountable”.
4. Timeframe for consultation on the Updated Transport Strategy The Discussion Paper on Sustainable Transport was released on 11th December 2007 with submissions due by 15 February 2008. This was subsequently amended to 29 February but the scope of the exercise had changed to a “rewrite”. The final updated Strategy is believed to have a due date of 1 April 2008. This effectively gives officials 30 working days to read all submissions, consider the input and include it in any final strategy document. This is not an adequate time‐line for a “collaborative”, “accountable” or “evidence based” strategy to be developed. The Automobile Association considers this process to be only a marginal improvement on that of the original NZTS. By comparison to the extensive consultation process developed for the Energy Strategy and NEECS the consultation on the updated Transport Strategy is unduly brief. 2
Page 52
New Zealand Transport Strategy Development Process
Page 5
5. Qualities of the Discussion Paper on Sustainable Transport 5.1 CoStrategies The discussion paper states that it proposes specific targets for the five NZTS objectives that will “complement transport targets under the government’s sustainability agenda, the New Zealand Energy Strategy and the New Zealand Energy and Conservation Strategy.”3 It further states that “other strategies such as the: New Zealand Tourism Strategy, the New Zealand Disability Strategy and the Positive Aging Strategy will inform the UNZTS. Sea Change, the draft domestic sea freight strategy, was launched on 5 November 2007 and a New Zealand Freight Study will be commencing soon”3 5.2 Strategy Omissions The following existent strategies are not significantly integrated into UNZTS targets or objectives: 1. 2. 3. 4. 5. 6.
Regional land transport strategies (Local Government strategies) (4 mentions) National State Highway Strategy (1 mention) Airways New Zealand’s technology development plan (0 mentions) Airport Authorities Development Plans (2 mentions specifically, 12 generally) Port Companies Development Plans (1 mention) Land Transport Research Strategy ( 0 mentions)
Instead these detailed and significant bodies of work are generalised about without any reference to their content or intentions. This is significant as these strategies essentially outline the bulk of transport capital expenditure for the foreseeable future. As such there is a fundamental disconnect between policy and planned expenditure at a very high level of the strategy. “there is a fundamental disconnect between policy and planned expenditure at a very high level of the strategy” The assumption is that the capital strategies will be driven by the UNZTS, however it appears that little notice has been taken of the work undertaken by those closest to the business issues involved. The UNZTS is part of an evolving policy continuum but this is not reflected in this document. This raises serious doubts relating to “Evidence‐based” and “Collaborative” status of the discussion document. 5.3 Bias The UNZTS Discussion Paper is particularly biased as textual analysis makes plain. The bias is in favour of consideration of emissions, the environment and urban congestion. There is almost no consideration of social equity, transport disadvantaged, the aged or children. There is very limited consideration of business, exports and imports but very little concern for competitiveness. The paper also contains evident mode bias. This is in inverse proportion to the actual use of the modes in question. Limited justification is offered for an emphasis on reversing decades of mode preference other than the assertion (without evidence) that infrastructure cannot be expanded.The 3
Page 8
New Zealand Transport Strategy Development Process
Page 6
most frequently mentioned modes are rail, public transport and shipping followed by cycling and buses. Electric vehicles which are largely absent from New Zealand are mentioned almost as much as cars and light vehicles which abound. Trucks and aircraft are not mentioned much, despite their economic significance. Taxis and mobility scooters are not mentioned at all. Of the four “signpost” topics from the document’s cover “safety” scores by far the highest and followed by “sustainability”. Integration and Responsiveness are barely mentioned at all in the document text.
Topic text mentions 4 Emissions Environment Urban Congestion CO2 Mobility Tourism Rural/Provincial Business Pollution Exports Economic Development Personal Security Imports Children Equity Competitiveness Industry (ex transport industry & heading) Consent/consenting Aged/Older Disadvantaged
Mode text mentions Rail Public transport Ship Cycle/Cycling Bus Car/light vehicle Electric vehicles Aircraft Truck/Heavy Vehicle Taxi Mobility scooter
75 70 55 52 41 22 18 15 11 0 0
96 50 43 34 26 24 15 13 12 9 9 8 7 6 5 2 2 2 1 1 1
“Signpost” text mentions Safety
73
Sustainability
27
Integration
3
Responsiveness
2
This suggests that the document will not be consistent in its treatment of the five objectives of the strategy and it is a mix notably less concerned with national competitiveness than the transport policies of other nations.
4
Mentions in UNZTS document from Adobe Acrobat search
New Zealand Transport Strategy Development Process
Page 7
5.4 Lack of evidence targets relate to objectives The UNZTS document appears to suffer from being based around targets which are not supported by evidence contained within the document. This can be shown by stepping through each of the five NZTS objectives. 5.4.1. Assisting Economic Development Proposed highlevel targets to assist economic development for 2040 Travel times by principal routes within and between major urban areas and key economic nodes (eg main seaports, airports and major industrial areas) to be improved relative to 2007 for identified critical intra and inter‐regional connections, as determined with each region. This high‐level target is supported by the evidence that domestic freight volumes are expected to almost double by 20205. However this is not linked to the Transit State Highway Strategy document or provides any endorsement of it. Given that 97% of Government transport expenditure is on land transport this would seem to be an omission. Travel times by all modes will be predictable. Travel times can be predictably unsatisfactory. This is not a meaningful target. Proposed relevant intermediate or detailed targets for 2040 Lift coastal shipping’s share of inter‐regional freight to around 30 percent (currently about 15 percent of tonne‐kilometres). The document adduces evidence that coastal shipping may become more significant due to shipping industry rationalisation6. However no evidence is provided supporting this target. Indeed the lack of analysis surrounding the impact of the Emissions Trading System which some project could wipe out the New Zealand cement industry7 as well as the forest products industry then it is conceivable the mix of policies could significantly reduce the tonne‐ kilometres dispatched via coastal shipping due to carbon leakage. The AA would be interested to know what evidence informed this target. Lift rail’s share of domestic freight to around 25 percent (currently about 18 percent of tonne‐kilometres). The document produces direct evidence to contradict this target in that only three to seven percent of its share is contestable by road8. There is no evidence that the increase in domestic freight will favour the rail mode. In fact there is evidence that the increase will continue to favour heavy road transport – especially if there is strong carbon leakage due to the implementation of the Emissions Trading Scheme as the current rail task is firmly based on moving heavy industry outputs to sea ports .9
5
Page 25 reference to TERNZ study “Prediction of New Zealand’s freight growth by 2020” Page 27 UNZTS 7 Castalia”The New Zealand Emissions Trading Scheme :How do we make it work?” page 45 8 Page 32 UNZTS 9 New Zealand Freight Matrix , Booz Allen Hamilton, 2005 & TERNZ study above. 6
New Zealand Transport Strategy Development Process
Page 8
At least double the overall public transport mode share to seven percent of all passenger trips (currently about two to three percent). No evidence is adduced to show that this will assist economic development Increase walking and cycling and other “active modes” to 30 percent of total trips in urban areas (currently about 17 percent). No evidence is adduced to show that this will assist economic development Effective real‐time information systems in place to enable road users to plan their journeys to avoid congestion, thereby minimising delay and fuel wastage, by 2015. No evidence is adduced to show that this will assist economic development The document does make mention of New Zealand’s clean green reputation as a national asset to assist economic development. However it must be noted that the only attempt to quantify the value10 of this reputation came to a figure of no more than one percent of GDP. Given the bias in the transport strategy there appears to be some relative over‐valuing of this reputation without any cost‐benefit analysis to justify it. 5.4.2 Assisting Safety and Personal Security Proposed highlevel target to assist safety for 2040 Operate to world best‐practice safety standards for all modes of transport. There is no evidence that New Zealand has ever had world’s best practice safety outcomes for all modes of transport. The document notes that the progress toward the 2010 objectives are “unlikely to be reached”. While the trend line of road deaths on page 35 shows progress to 2003 from that point on the trend has plateaued showing current methods are not making any impression on the road toll. Moreover the injury figures show a decided worsening. Duigan11 suggests that a significant level of the toll improvement has been largely due to improvements in the privately owned motor vehicle fleet. Breen12 notes deficiencies in engineering and education. The text of this target speaks of “safety standards”. It is difficult to determine whether there is any obligation to meet these targets.
10
“Our Clean Green Image, What’s it worth” Ministry for the Environment 2001 Initial Evaluation (“Stocktake”) of Road Safety to 2010 Strategy, Parker Duignan for MOT, 2004 12 Review Of The Road Safety To 2010 Strategy , Jeanne Breen for MOT, 2004 11
New Zealand Transport Strategy Development Process
Page 9
Proposed relevant intermediate or detailed targets for 2040 Road deaths no more than 200 per annum. Given the UNZTS own evidence that the 2010 target will not be reached and the lack of any supporting evidence to show this target is achievable, this target must be regarded as aspirational without supporting rationale. This is in contrast to the 2010 target which was set following exhaustive analysis. Over 40 percent of the light vehicle fleet to have four star or better occupant protection (currently ten to 15 percent) by 2015 and 90 percent by 2040. No evidence is provided as to whether this level of fleet development will occur naturally or will require intervention by Government. No Benefit Cost analysis is provided balancing crash risk against public mobility requirements. This target seems to prejudice the Vehicle Fleet Strategy Discussion paper (not released). Over 25 percent of light vehicles to have electronic stability control (currently less than five percent) by 2015 and 95 percent by 2040. No evidence is provided as to whether this level of fleet development will occur naturally or will require intervention by Government. No Benefit Cost analysis is provided balancing crash risk against public mobility requirements. Proposed supporting targets Targets around serious injuries and social costs resulting from road crashes and for subsets of road traffic, such as targets for various road user groups and freight safety will be developed by mid 2009. It is difficult to be confident of any road deaths target without a properly developed injuries and social costs study. The Road Safety 2020 Strategy will be in place by 2010. Targets for rail will focus on safety at level crossings and the level of trespassing on the rail network. This will also be developed by mid 2009. Social cost targets for aviation safety to 2010 have been agreed and are regularly reported against. Each type of aircraft has its own target level expressed as social cost per seat hour of passenger exposure (see Appendix C). Targets to 2015 are expected to be developed by late 2009. Targets for maritime safety to 2010 have been developed by Maritime New Zealand and look to reduce the number of fatalities, accidents and injuries per year for a range of vessels and for workplace activity (see Appendix C). The undertaking to carry out proper evaluation and analysis for modes other than road is a comforting one but does not constitute a target. A vehicle fleet strategy discussion paper on the New Zealand vehicle fleet will be developed by the end of 2007 and a New Zealand vehicle fleet strategy by early 2008. New Zealand Transport Strategy Development Process
Page 10
A large number of pre‐existing targets appear to anticipate the outcome of this. 5.4.3 Improve Access and Mobility Proposed highlevel targets to improve access and mobility for 2040 All individuals have access to the facilities and activities they need, such as work, education, medical care and shopping centres, to participate in society. This target fails to include any reference to the affordability of access Travel times by all modes will be predictable. Predictability is only a useful indicator if the base performance level is acceptable. The text (page 42) refers only to British rail timetables – where rail is the least used passenger mode in New Zealand. Travel times by principal routes within and between major urban areas and other key activities (such as tourist attractions, hospitals and airports) to be improved relative to 2007 for identified critical intra and inter‐regional connections as determined with each region. This target fails to indicate it applies to roads undermining its value Proposed relevant intermediate or detailed targets for 2040 At least double the overall public transport mode share to seven percent of all passenger trips (currently about two to three percent). There is no evidence that this level of mode share can be achieved and is certainly outside the existing targets of Regional Land Transport Strategies. There is no provision of a benefit cost analysis to show this target is economically desirable. There is no evidence to show that the inclusion of such a target will in fact improve access and mobility for the majority of the population. Increase the public transport mode share of peak hour travel (journeys to work) in Auckland, Wellington and Christchurch from an average of nine percent to 20 percent and work with each region to optimise peak hour travel targets. There is no evidence that this level of mode share can be achieved and is certainly outside the existing targets of Regional Land Transport Strategies. There is no provision of a benefit cost analysis to show this target is economically desirable. There is no evidence to show that the inclusion of such a target will in fact improve access and mobility for the majority of the population. Increase walking and cycling and other “active modes” to 30 percent of total trips in urban areas (currently about 17 percent). There is no evidence that this level of mode share can be achieved and is certainly outside the existing targets of Regional Land Transport Strategies. There is no provision of a benefit cost analysis to show this target is economically desirable. There is no evidence to show that the inclusion of such a target will in fact improve access and mobility for the majority of the population. New Zealand Transport Strategy Development Process
Page 11
Proposed supporting targets Review regional passenger transport mode share targets by 2012 through scheduled reviews of regional land transport strategies, and subsequent regional passenger transport plans. To propose reviewing Regional Land Transport Strategies which on the whole are based on considerable analysis and evidence against the proposed UNZTS targets for which there no evidence is difficult to reconcile with principles of collaborative‐ness and accountability. Implement the initiatives outlined in the walking and cycling strategy’s (Getting there – on foot, by cycle) implementation plan to a level that begins to achieve a shift to these modes by 2015. There is no evidence to show that the inclusion of such a target will in fact improve access and mobility for the majority of the population. Investigate the need to revise funding procedures for walking and cycling projects to ensure all costs and benefits of such projects are accounted for in their assessment by 2009. Revisions should be based on evidence and collaboration. Provide advice on urban design (government will decide on the desirability of providing national guidance on urban design, as outlined in the NZEECS). The Accessible Journey report contains recommendations on how to improve public transport accessibility and includes National Accessibility Design Performance Standards. These will be implemented progressively by 2025 to support our increased public transport patronage target. This section completely ignores evidence that access to a motor vehicle assists access and mobility. It is notable that lack of access to a motor vehicle is a component of the New Zealand Deprivation Index. A report by Infometrics to the Ministry of Social Development reported that access to a motor vehicle significantly improved an individual’s prospects of finding employment. There is evidence from the text of the UNZTS document of close‐minded thinking on access and mobility. The assumption is that the task of improving access and mobility is one of providing public transport. It notes: It should be noted that inadequate funding for infrastructural improvements and public transport services may be a barrier to providing good access and mobility in rural regions such as Northland.13 Affordability of running costs of a motor vehicle is a key determinant of access and mobility in such areas. While it is noted in the UNZTS document that 11% of households do not have access to a motor vehicle it does not provide any indication of whether these households a predominantly inner‐city ones which can rely on public transport, walking or cycling. In many rural communities public transport is not feasible and walking or cycling inefficient. The UNZTS discussion document gives limited consideration is given to the social benefits of the affordability of access to a motor vehicle in rural or provincial New Zealand14. But no corresponding 13 14
UNZTS page 43 UNZTS Page 40
New Zealand Transport Strategy Development Process
Page 12
targets are mentioned and the issue is effectively orphaned. Were these costs to escalate unduly this could have a significant negative impact on rural and provincial communities. No evaluation of the impact is provided. The assertion that “an aging population means the need for accessible public land transport will increase”15 is at best contentious. Evidence from the Ministry of Transport travel survey indicates that older New Zealanders do not favour public transport. This is particularly important when no targets for personal security have been proposed. Finally the access and mobility of New Zealanders as domestic tourists depends almost entirely on the private motor vehicle. Given that two‐thirds of all tourism in New Zealand is domestic tourism and the viability of tourism enterprises (which supports 9.9 percent of the workforce)16 depends on the access and mobility of New Zealanders, maintaining the affordability of access and mobility of New Zealanders by private car should be given somewhat more consideration. 5.4.4 Protecting and Promoting Public Health Proposed highlevel target for promoting and protecting public health for 2040 Public health effects of transport to be at accepted international standards. Proposed relevant intermediate or detailed targets for 2040 Ensure a substantial reduction in premature deaths and serious illnesses arising from air pollution from motor vehicles. The HAPINZ Study clearly notes that “premature” means weeks or days. While improving air quality is a significant matter targets should be based on readily quantifiable and verifiable exceedences of WHO standards. Manage noise to minimise any public health effects. The text of the UNZTS discussion paper17 makes no reference to applying such standards to rail. Any such standards must be mode neutral. 35 percent of the vehicle fleet to have emissions technology consistent with Euro 2 (or equivalent) standard by 2015. This target seems to prejudice the Vehicle Fleet Strategy Discussion paper (not released) calling into question its openness. Imported used petrol, LPG, CNG and diesel vehicles (light and heavy) are to be of Euro 4 (or equivalent) standard by 2012. Imported new petrol, LPG, CNG and diesel vehicles (light and heavy) are to be of Euro 4 (or equivalent) standard by 2009. This target seems to prejudice the Vehicle Fleet Strategy Discussion paper (not released) calling into question its openness. 15
UNZTS page 39 UNZTS Appendix B page 60 17 UNZTS page 46 16
New Zealand Transport Strategy Development Process
Page 13
Increase walking and cycling and other “active modes” to 30 percent of total trips in urban areas (currently about 17 percent). The claim that increasing the total proportion of trips by walking and cycling will improve public health are not supported by any evidence. The point here is that the target is a mode‐ share one, rather than a total activity level one. That is the level of car trips must decline and active modes increase. Thus a trip taking children to organised sports by vehicle is counted as a passive mode while the child’s activity on the sports field isn’t counted as a trip at all. Equally a trip by vehicle to and from a tramping track is a trip each while the hike itself is only one. A highly probably outcome of achieving such a target is that weekend sports would suffer as parents decline to walk or take public transport to their children’s sports fixtures. The claims that active transport modes are more important than recreational use are dubious. In particular the claim that: “While walking and cycling for leisure are growing in popularity, the fitness gains are marginal because of the decrease in walking and cycling for day‐to‐day transport.”18 is wholly unsubstantiated. The absence of targets relating to personal security has a direct bearing on the active mode share of trips particularly by children. The suggestion that the cause of reduction in activity levels is the private motor vehicle is unsupported. There is evidence that electronic media and declining access to recreation grounds have had a significant impact on public activity habits.19 Proposed supporting targets Investigate the need to revise funding procedures for walking and cycling projects to ensure all costs and benefits of such projects are accounted for in their assessment by 2009. Revisions should be based on evidence and collaboration, however there is no indication this will occur The National Environmental Standard on Air Quality includes ambient air quality standards that must be met by regional councils by 2013. These standards cover carbon monoxide, nitrous oxide, ozone, particulates and sulphur dioxide. To help councils meet these standards further targets are being proposed within the vehicle fleet strategy discussion paper.
18 19
UNZTS Page 44 http://www.obesityresearch.org/cgi/content/abstract/12/6/896
New Zealand Transport Strategy Development Process
Page 14
5.4.5 Ensuring Environmental Sustainability It should be re‐iterated that there is no legal definition of “environmental sustainability”. This absence of definition is problematic as noted in the Next Steps review. It is disappointing that nothing has been done to clarify the meaning of this target. Government agreed highlevel targets for ensuring environmental sustainability for 2040 Halve per capita domestic transport greenhouse gas emissions. No evidence is adduced which suggest this is a feasible target. Local environmental impacts of transport (including air and water quality) to be at accepted international standard. No evidence provided this is not the case Government agreed relevant intermediate or detailed targets for 2040 Become one of the first countries in the world to widely deploy electric vehicles. No evidence provided that this is a feasible target A biofuels sales obligation that will begin at a level of 0.53 percent from 2008, increasing to 3.4 percent of annual petrol and diesel sales by 2012. The AA has made a separate submission on the Biofuels Sales Obligation Reduce the kilometres travelled by single occupancy vehicles, in major urban areas on weekdays, by ten per cent per capita by 2015 compared to 2007. The NZEECS contains evidence of projected savings from this measure. We have already noted the lack of collaboration involved in deriving this target. Reduce the rated CO2 emissions per kilometre of combined average new and used vehicles entering the light vehicle fleet to 170 grams CO2 per kilometre by 2015 (currently around 220 grams CO2 per kilometre) with a corresponding reduction in average fuel used per kilometre. The NZEECS contains evidence of projected savings from this measure. This seems to prejudice the forthcoming the Vehicle Fleet Strategy Discussion paper. Ensure 80 percent of the vehicle fleet is capable of using at least a ten percent blend of bio‐ ethanol or bio‐diesel, or is electric powered, by 2015. The NZEECS contains evidence of projected savings from this measure. This seems to prejudice the forthcoming the Vehicle Fleet Strategy Discussion paper Proposed relevant intermediate or detailed targets for 2040 Identify and remove any barriers to the uptake of plug‐in hybrid and full electric vehicles that meet appropriate safety standards.
New Zealand Transport Strategy Development Process
Page 15
Effective real‐time information systems in place to enable road users to plan their journeys to avoid congestion, minimising delay and fuel wastage, by 2015. Lift rail’s share of domestic freight to around 25 percent (currently about 18 percent of tonne‐kilometres). No evidence is provided that this is feasible or would result in emissions savings. Lift coastal shipping’s share of inter‐regional freight to around 30 percent (currently about 15 percent of tonne‐kilometres). No evidence is provided that this is feasible or would result in emissions savings. At least double the overall public transport mode share to seven percent of all passenger trips (currently about two to three percent). No evidence is provided that this is feasible or would result in emissions savings. It is entirely possible that increasing the size of the Public Transport task by this degree would result in empty buses running around cities during the day increasing congestion and providing worse emissions performance than private vehicles. Increase the public transport mode share of peak hour travel (journeys to work) in Auckland, Wellington and Christchurch from an average of nine percent to 20 percent and work with each region to optimise peak hour travel targets. No evidence is provided that this is feasible or would result in emissions savings. It is entirely possible that increasing the size of the Public Transport task by this degree would result in empty buses running around cities during the day increasing congestion and providing worse emissions performance than private vehicles. Increase walking and cycling and other “active modes” to 30 percent of total trips in urban areas (currently about 17 percent). By reducing New Zealanders urban mobility (including all work‐related and delivery trips) so that a third of all trips are undertaken on foot emissions reductions are inevitable. However the implied price of carbon of such policy is likely to be uneconomic. No net loss of indigenous vegetation or fauna from infrastructure construction or maintenance. Given that the Department of Conservation estate covers 30% of New Zealand total land area20 any loss of indigenous vegetation or fauna through construction or maintenance on road corridors should be relatively minor compared to the potential for regrowth on other Crown lands. The need for such an offset is not established.
20
www.treasury.govt.nz/publications/research‐policy/ppp/2006/06‐07/03.htm
New Zealand Transport Strategy Development Process
Page 16
6.0 Changing Principles of the Strategy The glaring omission from the principles of the strategy is the lack of commitment to The Way Forward The government’s vision of a transport system that is affordable, integrated, safe, responsive and sustainable is ambitious. It requires ongoing development and adaption. In moving forward the government is committed to following an approach that is: • • • •
Forward‐looking Collaborative Accountable Evidence‐Based.
This suggests that future Government policy will no longer be required to be any of these things.
7.0 Conclusions In 2002 the Government committed to a programme of being: Forward looking; Collaborative; Accountable; Evidence‐based. To date there is very little evidence that it has developed New Zealand transport strategies or drafts in a manner which are: 1. Collaborative 2. Accountable or 3. Evidence based. This does not suggest that the resulting Strategies will be qualitatively comparable with those of other nations. It also suggests that the resulting Strategies will continue to create on‐going problems of reconciliation with stated Government spending objectives.
8. 0 Recommendations It is recommended that the Strategy be redeveloped in a manner in accordance with the Way Forward principles. It is recommended that the Strategy incorporate the Way Forward Principles.
New Zealand Transport Strategy Development Process
Page 17
Related Documents
The Nzts Development Process
October 2019 23
Development Process
November 2019 23
Tptp Development Process
November 2019 14
1_software Development Process
November 2019 21
Vehicle Development Process
August 2019 22