This is the response I sent to the Government Policy Statement on land transport (GPS 2024). They are open for feedback until April 2 2024 (email GPS@transport.govt.nz). My original draft used much stronger language but Mrs (bless her) convinced me to tone it down in the hope they will actually read it. The quoted parts are snipped from the GPS, the other bits are mine.

"New Zealand has among the least affordable houses in the world, the result of a persistent undersupply of houses. New Roads of National Significance and major public transport projects will unlock access to greenfield land for housing development and support greater intensification to ultimately improve housing supply, choice and affordability."

A better approach would be to tackle the problem of why building costs are so high and build more houses in areas already served by roads and other infrastructure. Kāinga Ora has done some promising work on getting build costs down. And what we need most in this area is denser housing rather than increasing city sprawl and gobbling up productive farmland. New roads are not really part of that despite the mention of intensification in the above quote.

"It is unfair to ask people using the roads to fund rail infrastructure."

Everything that travels by rail means it is not traveling by road. Rail is very good for road users. The statement also assumes all road users pay their fair share. There is doubt about whether the heaviest trucks do in fact pay proportionate to the demands they place on the roads. I have more detail on this point further down.

"Over the past six years there has been almost $2.5 billion invested but rail freight (net tonne kilometres) is lower now than it was in 2012."

Possibly exacerbated by frequent and long closing of various lines. The route from Auckland to Whangarei has been closed for over a year now. I notice on table 4 there looks to be a huge drop in expected spend on rail, and Stuff reports it could go to $20m per year. KiwiRail boss Peter Reidy says they need $120m to keep running.

"Investment in walking and cycling should only take place where there is either clear benefit for increasing economic growth or clear benefit for improving safety and demonstrated volumes of pedestrians and cyclists already exist."

This is counter-factual, especially the last bit. If a road is unsafe to walk or cycle on then people won't walk or cycle. Therefore there will not be existing volumes of pedestrians and cyclists. If the road is made safe, or a decent footpath or cycleway is added then people will use them. Not everywhere, of course, but we were told for decades no one could manage cycling over the Auckland harbour bridge until they actually tried it. Turns out even little kids can do it. So the criteria for where to put these things needs to get a lot better at working out where people will walk or cycle. Assuming just because they won't risk their lives on an existing road does not mean it can't be usefully made safe.

And what about new roads? Clearly there will be no existing volumes of anything, vehicles, cycles, walkers, but this seems to assume there will be no facilities for non-vehicle traffic in that case.

It is very easy to find clear benefits for walkers and cyclists. They shop more, despite what many retailers believe. They also use less hospital resources because they stay healthier. But to see this you have to think about the larger picture rather than pure cost of transport. I don't see any evidence of that broad thinking under "Funding ranges for activity classes/Walking and Cycling" and the budget (table 4) shows a massive drop in this funding.

"Increased public transport fare box recovery and third-party revenue will be expected from local government"

As with rail generally, every public transport journey is a car that is not on the road. Public transport is very good for motorists. As such it is a common good and should be subsidised. If you increase PT fares you get more cars, more congestion, more pollution not to mention uglier cities that are full of roads and parking buildings. These things should be built into any cost benefit analysis because they are all real costs. Even the last one which creates mental health costs.

"The Government expects that funding in this activity class will not be used to make multi- modal improvements, i.e., cycleways and busways, or fund traffic calming measures, such as speed bumps and in-lane bus stops. Funding may be used to remove speed bumps that exist on high volume corridors. It is expected that NZTA will prioritise reliable travel times in all investment decisions in this activity class."

If a busy road runs past a school the danger to school children should be a higher priority than to keep the traffic flowing as quickly as possible. Where bus lanes and cycleways and footpaths are useful, the most sensible option is to do them as part of an upgrade, as this would be much cheaper.

There is a lot in this report about value for money and linking expenditure with revenue. Given the stress on roads over other transport mechanisms and the acknowledgement that roads need constant maintenance why is there not more detail on road user charges? These are being introduced for EVs and trucks already have them. The assumption is that petrol tax does the same job for vehicles that use petrol. But is the revenue raised in proportion to the damage a vehicle does to the road? Heavy trucks do far more than cars and more than light trucks, and bikes do an unmeasurably small amount. Is the tax rate set correctly? To paraphrase your

"It is unfair to ask people using the roads to fund rail infrastructure."

It is also unfair to ask people not using trucks to fund truck infrastructure, which is what our roads are becoming. The Stuff article I referred to above points out that 'super heavy' trucks are now using Taranaki roads carrying logs that used to be carried by trains. Their roads cannot handle these super heavy trucks without a rebuild. They need deeper foundations. This is unlikely to be a problem specific to Taranaki. Are the super heavy truck road user charges enough to cover the cost of rebuilding the roads they use, or are the rest of us having to subsidise them?

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