The NZTS Development Process

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.

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:
• Collaborative
• Accountable
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

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

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. Regional land transport strategies (Local Government strategies) (4 mentions)
2. National State Highway Strategy (1 mention)
3. Airways New Zealand’s technology development plan (0 mentions)
4. Airport Authorities Development Plans (2 mentions specifically, 12 generally)
5. Port Companies Development Plans (1 mention)
6. 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

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 96
Environment 50
Urban 43
Congestion 34
CO2 26
Mobility 24
Tourism 15
Rural/Provincial 13
Business 12
Pollution 9
Exports 9
Economic Development 8
Personal Security 7
Imports 6
Children 5
Equity 2
Competitiveness 2
Industry (ex transport industry & heading) 2
Consent/consenting 1
Aged/Older 1
Disadvantaged 1

Mode text mentions “Signpost” text mentions
Rail 75 Safety 73

Public transport 70 Sustainability 27
Ship 55 Integration 3
Cycle/Cycling 52
Responsiveness 2
Bus 41
Car/light vehicle 22
Electric vehicles 18
Aircraft 15
Truck/Heavy Vehicle 11
Taxi 0
Mobility scooter 0

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


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”
6
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.

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).
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.
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
11
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

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.

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
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.
population.
population.

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
UNZTS page 43
14
UNZTS Page 40

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.
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
Imported new petrol, LPG, CNG and diesel vehicles (light and heavy) are to be of Euro 4 (or
This target seems to prejudice the Vehicle Fleet Strategy Discussion paper (not released)
calling into question its openness.

15
UNZTS page 39
16
UNZTS Appendix B page 60
17
UNZTS page 46

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
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
UNZTS Page 44
19
http://www.obesityresearch.org/cgi/content/abstract/12/6/896

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
Identify and remove any barriers to the uptake of plug‐in hybrid and full electric vehicles
that meet appropriate safety standards.

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.
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.
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

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:
• Collaborative
• Accountable
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.

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