Our Submission on the Draft GPS 2024: It's Vital the Government Prioritises Emissions Reductions in Transport

Lawyers for Climate Action’s Submission on the Draft Government Policy Statement on Transport 2024

Lawyers for Climate Action NZ has published its submission on the Draft Government Policy Statement on Transport 2024 (Draft GPS), which you can read online here. We also spoke at Auckland Council’s extraordinary meeting on its submission on the Draft GPS on 27 March 2024 alongside Magalie Ménard and Paul Winton from All Aboard Aotearoa.

The Draft GPS is important as it sets out how the Government will fund transport over the next ten years.

This Draft GPS is a big step backwards. It removes climate change and emissions reductions as a strategic priority, and is skewed towards investments in road-building. It will not provide for an “effective, efficient, and safe land transport system”, as required by the Land Transport Management Act 2003. Rather, it charts a course for rising emissions, higher congestion, and higher public transport costs. It misses the opportunity for Aotearoa to move towards a low-emissions transport system, which should be viewed by the Government as an economic opportunity.

Our submission focuses on climate-related issues arising out of the Draft GPS 2024. Our high-level points in the Executive Summary are as follows:

  1. The Government is obliged under the Paris Agreement and the Climate Change Response Act 2002 to reduce emissions and contribute to the global effort to limit warming to 1.5℃ above pre-industrial levels. The Draft GPS risks making it very difficult for New Zealand to meet its legal commitments. 

  2. The Draft GPS proposes a shift away from direct transport decarbonisation initiatives towards a greater reliance on the Emissions Trading Scheme. The Emissions Trading Scheme alone, in its current state, will not be sufficient to meet New Zealand’s climate obligations. The Government must continue prioritising transport decarbonisation, including through greater investment in public transport and active transport modes. 

  3. To be consistent with the purpose of the Land Transport Management Act 2003, New Zealand’s binding emissions reduction targets, and having regard to the National Policy Statement for Urban Development, the Draft GPS should:

    • Specify climate change and emissions reductions as the overriding strategic priority for GPS 2024.

    • Provide a significantly increased expenditure target for the walking and cycling activity class, enable multimodal spending on walking and cycling infrastructure from other activity classes, and remove the unreasonable restrictions on using the walking and cycling activity class.

    • Significantly increase the expenditure target for the public transport activity classes.

    • Remove policy support for the construction of new roads unless the use of these roads over their lifetime can be demonstrated to be consistent with achieving New Zealand’s emissions reduction targets.

    • Remove “directions” for construction of specific new roads.

  4. In addition, a further round of consultation on the excluded emissions reduction content is necessary to ensure compliance with s 67(1)(c) of the Land Transport Management Act.

LCANZI