16 October 2021

Emissions Reduction Plan on transport isn't really about cutting emissions

With the NZ Government releasing its draft Emissions Reduction Plan that it intends to present at the COP26 conference in Glasgow, it's worth reviewing what the Government wants to do to us so it can proclaim bountiful levels of virtue signalling, although New Zealand's significance at this is vastly exaggerated by its politicians. This is all about the USA, China, India, the EU, Russia and Brazil after all

I'll leave aside for now whether the target of "net zero" will actually generate any net benefits or not, for now take it as given that the Government wants to reduce greenhouse gas emissions (GHGs). I'll also just focus on the transport policy proposals.

There has been much wailing from radical environmentalists about how weak it is, which you might think means you should be relaxed about it. However, you should not, at least in terms of transport policy.

You see it was some years ago that the only economically rational intervention needed to reduce emissions in transport was introduced – the Emissions Trading Scheme (ETS). The ETS effectively puts a cap on emissions across around 50% of NZ’s emissions, including all domestic transport emissions. 

If you fill your car with petrol or diesel, part of the price includes the cost for fuel distributors of buying emission units that you effectively use when you burn fossil fuels.  There is a fixed supply of these units, and Government policy is to reduce this supply over time (although there was a blip lately), so the price will go up. 

As the price goes up, businesses and consumers respond, which for transport means they might change the vehicle the own or use, drive less, drive differently, change modes of transport, or just pay up and save money elsewhere.  

These changes would mean the vehicle fleet would change, or there would be more use of public transport (putting fare revenue up), or more walking and cycling (increasingly the economic merits of improving those facilities), or there will less demand for more road capacity or carparks, or people will make savings elsewhere. As demand evolves, then so will how existing infrastructure and services evolve, as they always have.

However, nobody joins the Green Party trusting individuals and businesses to simply make the best choices and to be free. You join the Green Party because you believe it is ethical and necessary to use the power of the state to compel people to do what you think is best for them. Banning and taxing what is “bad”, subsidising and making compulsory what is “good”, the Greens are fundamentally illiberal, and this Labour Government has outsourced climate change policy to that ideology. After all, the Nnew Labour Party of Jim Anderton Jacinda Ardern is a party of the big mother state.

The proposals here represent the most radical shift in transport policy and regulation of the transport sector in over forty years, taking it away from the current model, which seeks to reflect user decisions and choice, to one that regulates, taxes and subsidises planners' choices.

So let me start by reminding you throughout all of this, NOTHING the CCC proposes here will reduce emissions without using the ETS to reduce the emissions units available (which would put up the price of petrol and diesel). ALL of these proposals below reflect an ideology of central command and control, all for ZERO net impact. 

You might think the Climate Change Commission (CCC) would be focused primarily on reducing emissions, but its strategy for transport is much more than that (p.54):

Decarbonising transport also offers opportunities to improve the wellbeing of New Zealanders. Air pollution, crashes and congestion from traffic impose a large cost on our health, environment and economy. For many people and communities, transport is not affordable or accessible. The transition could make transport more inclusive, safe, healthy and resilient, and better support economic activity. 

Now if reducing emissions was seen as generating other benefits that may be all well and good, but this rather glib statement is used to justify a level of intervention in transport policy that has been unheard of in New Zealand for over forty years.  

You might see the link between lower GHG and lower air pollution, but fewer crashes?  For example, reducing the number of road crashes by reducing the amount of driving is like reducing the number of workplace accidents by reducing the number of jobs. Less congestion could ONLY come if there were a significant drop in motorised road traffic, which starts to give you a hint about what this is really all about.

The claim that for “many people and communities” transport is not affordable or accessible is equally glib and nonsensical.  Where's the evidence? Are there chronic problems in people accessing work, school or other facilities? If so you'd think they'd be mass unemployment and businesses struggling to access labour. New Zealand per capita car ownership is amongst the highest in the world.  However, I doubt the CCC thinks owning, let alone using a car is “inclusive” or “safe” or “healthy”.

The CCC's plan focuses on three main strategies to reduce emissions:

1. Reducing reliance on cars and supporting people to walk, cycle and use public transport. 
2. Rapidly adopting low-emission vehicles and fuels. 
3. Beginning work now to decarbonise heavy transport and freight. 

SO let's start...

1. Reducing reliance on cars and supporting people to walk, cycle and use public transport. 

Let's be VERY clear, reducing reliance on cars wont reduce net emissions one iota, because the ETS means that any reduction in demand for fossil fuels used in cars will simply mean emissions units are available for others to use for other purposes. Measures to reduce car use are only economically efficient if they are cheaper than the cost of the emissions units and could arguably enable more efficient use of those units for other purposes, but there is no sense at all that this is the intention at all. After all, it would be simpler and more efficient to just reduce the number of emissions units under the ETS, which would increase the price of fuel and people would either pay up, drive less or buy a more fuel efficient vehicle.

The CCC briefly addresses this by claiming "a recent study by Concept  Consulting and Retyna estimated that relying on the NZ ETS alone to boost electric vehicle  uptake would require a carbon price of $595". Yet isn't the goal reducing emissions not boosting electric vehicle uptake? The latter is an input, the former is an output.  It shouldn't matter to politicians how New Zealanders might reduce emissions, but it apparently does.

So how does the CCC propose to "reduce reliance on cars" and support people walking, cycling and using public transport (noting that motorists already significantly support people cycling and using public transport, because around 28% of the road user charges/fuel duty and registration fees they pay is intended to be spent on all that in the next three years)?

It wants to "reduce vehicle kilometres travelled (VKT) by cars and light vehicles by 20 per cent by 2035 through providing better travel options, particularly in our largest cities".
Translated it means it wants a lot less driving, not just by private cars, but also utes, vans and other light commercial vehicles and it thinks it can achieve this by subsidising what it calls "better" travel options (better according to CCC not the users, otherwise they would use them), so people will be enticed to drive less.  Sounds nice?

Well no cities anywhere in the world have achieved the levels of reductions in motorised road traffic, even with road pricing, that are proposed here.

Five pages of the document outline the measures the CCC wants implemented.  I could spent a lot of time going through all of them, but let's look at a few key ones.  What's notable is NONE of it is about encouraging working from home or other practices that are already reducing peak, what it is about is a lot like a Green Party policy document to make driving much more difficult and to vastly increase subsidies for other modes. 

So what are some of the measures?


require transport emissions impact assessments for urban developments and factor  these into planning decisions, with requirements to avoid, minimise and mitigate transport emissions impacts.

So along with getting your resource consent for building a house, you may need a "transport emissions impact assessment". Ideally it would say zero, because of the ETS, but you can be sure the planning fetishists wont let you get away with facts like that.  If you thought there was a crisis in housing affordability, never mind, the CCC is here to add a new regulatory imposition on new developments. New construction will be required to avoid transport emissions impacts, which could be code for not allowing garages or car parks for new homes.  None of this will make any actual difference to emissions though.


It will introduce mode-shift targets for cities with a range of measures including:

• reallocating significant amounts of road/street space to rapidly deliver more dedicated bus lanes and safe separated bike/scooter lanes 
• completing connected cycle networks 
• more traffic-calming and low-traffic neighbourhoods 
• improving footpaths/crossings for pedestrians. 

There are four key points to make about this:

1. Making it easier to walk and bike is all very well, as is enabling buses to bypass bottlenecks, but these measures should have clear net benefits in themselves. Not all ideas for such measures do so, but the CCC seems uninterested in ensuring any proposals generate net benefits.
2. The overall theme is essentially to remove both traffic lanes and car parks from general motor traffic to transfer to other modes. The idea being to make it less convenient, slower and more costly to drive compared to buses and cycling. It’s not just a carrot of better alternatives, but making what people choose to do now worse, less pleasant, slower and more costly.  It's very much a philosophy of punishing motor vehicle use.
3. Talking about “traffic-calming” (an absurd term that seeks to characterise road traffic as angry) is nothing to do with reducing emissions, because motor vehicles produce more emissions when travelling slower (and there is no evidence this actually shifts travel from cars to other modes). 
4. Little modal shift is possible from commercial vehicles, beyond a few cycle bikes and couriers, it is not only impossible to shift much delivery and trade traffic from light commercial vehicles, it is counter to trends elsewhere. Internationally, light commercial vehicle traffic has been growing because of the growth of e-commerce, but the CCC is apparently utterly bewilidered by this, presumably because the Green Party aligned activists who drive this policy completely blank out any thought of motor traffic being anything other than cars (hence why they talk about “car lanes”).
5.     Removing road capacity indiscriminately will increase congestion, which increases emissions from motor vehicles. 


The CCC goes on: 

We also need to provide better travel choices in New Zealand’s regions and rural areas, including by public transport. Too many parts of regional New Zealand are only accessible by private vehicle. 

Hold on, is this really about emissions? There was public transport by rail and bus across regional and rural areas for decades, but it largely disappeared because people stopped using it and chose to drive and be driven. If they STILL choose to do this and pay for their emissions, then so what?

Why does the CCC think it knows where needs to be serviced by public transport, especially if demand for public transport isn’t remotely enough to justify a bus service, or does the CCC think that policies can make driving so expensive, slow and unpleasant people will be cajoled into riding public transport?  

The CCC then starts to really blend a mix of specifics and generalities.


It advocates building a light rail line in Auckland to Mangere. Why will this reduce emissions compared to electrifying buses along the route?  Why is this specific proposal here other than it is a pet project of the Government?

Then it says "plan for and substantially increase investment in urban public transport nationwide; this 
includes commuter rail networks in Auckland and Wellington, and a major uplift in all urban bus networks”

This is general economic nonsense. What is the benefit in this? It reads, once again, like a Green Party policy wishlist, with nothing specific and no justification at all for the quality of spending or the net benefits.  For Wellington does it mean expanding networks further to the Wairarapa and to the Manawatu, encouraging people to live even further from Wellington city? What if this "substantial investment" simply saw trains and buses carrying few people for much of the day?  Does the CCC really think constantly supplying more public transport generates modal shifts?

Then it goes onto social policy:


The Commission recommends reducing public transport fares, and many submissions on Hīkina te Kohupara called for lower cost public transport to make it more competitive with  cars. For low-income people, the cost of public transport is a barrier, along with convenience and accessibility. 

What has this to do with emissions? On the one hand it is about competitiveness with cars (which is primarily about travel time and convenience, not price), but then about helping people on low incomes. Wouldn't people on low incomes be equally helped by cheaper prices for more fuel efficient cars? No, you see it isn't about outcomes, it is about ideology - an ideology that devalues private motor transport.


And after dismissing the value of pricing through the ETS, the CCC gets wildly enthusiastic about road pricing, taxing parking and ANY OTHER MEASURES it thinks can price you out of driving. It wants to investigate how such taxes can encourage mode shift, so it isn't good enough to tax you to expand slower, less convenient and less comfortable options, or to make driving slower, more difficult and less convenient, you have to be taxed more so that you'll just give up and say "ok, I'll take the bus"... or you might just emigrate of course.

Now I'm an advocate of road pricing to apply user pays to road use, but it should absolutely NOT be a tool for social engineers for penalising road use enough so their favoured modes get used.  It's like taxing meat so high you'll just give up and be a vegetarian.... although that will no doubt give them ideas.

After all, if pricing is such a good tool, just use the ETS. Reduce the number of emission units available, put up the price of the remaining ones, and the price of petrol and diesel will get higher and higher and people will decide what to do... but that isn't good enough for the Green Party inspired car haters.


Hīkina te Kohupara noted that central and local government will need to review investment in urban highways and road expansion. These projects could induce more private vehicle travel. 

Who cares if there is more private vehicle travel, if it is carried out by zero emission vehicles and the vehicle users are paying for the use of the road (and it isn’t getting congested). This really IS the Green “anti-car fascist” fantasyland that regards people driving more as being inherently bad.

Submissions on Hīkina te Kohupara supported this view and suggested that projects should only be funded if they help to reduce transport emissions. For this reason, we will ensure further investments that expand roads and highways are consistent with climate change targets, and avoid inducing further travel by private motorised vehicles.

Really? So urban highway and road expansion should ONLY be funded if it helps reduce emissions? What if it saves lives, what if it eases congestion, improving productivity?  So let’s be clear here this means absolutely no road widening, no new roads. Not even the idea that road pricing can be used to sustainably expand road capacity, because the CCC has decided people must drive less.  This is consistent with no major road improvements in Auckland, no extension of the Waikato Expressway, no second Terrace Tunnel or Mt Victoria Tunnel in Wellington.  

This is a profound shift in policy.  For many years New Zealand's transport funding system was based on road users paying motoring taxes that are used to pay for maintenance and to upgrade the network to meet their priorities based on reducing congestion, reducing travel time, improving safety and access, but now what motorised road users want no longer matters.

2. Rapidly adopting low-emission vehicles and fuels. 

So there is a big push to subsidise low emission light vehicles and e-bikes, which the manufacturers and retailers of such vehicles will be pleased by.  Then there is the curious named 

“Introduce measures to avoid New Zealand becoming a dumping ground for high-emitting vehicles”


This really shows the contortion of thinking, distrust of individuals and confected socialist view of economics behind the CCC’s approach.  It says:

With many countries phasing out ICEs, there is a risk that unwanted ICEs will end up on our roads. Manufacturers will make choices on where to continue to send ICE vehicles based on government policies.

Let’s unpack that. Why would these vehicles be “unwanted”? Vehicle importers will only import vehicles they believe people actually “want”, what the CCC means is that they are unwanted by the CCC. Vehicle don’t just get “sent” and “dumped”, they are imported by businesses to sell to willing consumers. Is the CCC saying consumers buy vehicles that they don’t approve of, or don’t think are good for them or the country?  Well of course, it’s just that the CCC knows this would sound far too dismissive and patronising of the peasants. They should simply not be allowed to make choices that are not approved of.

What the CCC wants is to BAN imports of petrol and diesel light vehicles from 2030.  The intention is to shift sales to electric vehicles and hybrids, but what will the effect actually be? At present, vehicle manufacturers have strong incentives to lower the cost of electric and hybrid vehicles to be competitive with petrol and diesel. Indeed a key reason petrol cars became popular was because the price of them progressively came down, though not due to governments banning the alternatives.  The effect of a ban on petrol and diesel vehicles will be to inflate the cost of electric vehicles.

The cascading effect of this will be to keep the vehicle fleet older, as people wont be able to afford as many newer cars, which pushes older cars out of the fleet. The older vehicles will be less fuel efficient and less safe, and it will be poorer people who own those cars.  The idea that significant subsidies are going to bridge the gap between those who can afford a new EV and those who can only afford 15-20 year old secondhand cars priced less than $2000 is ludicrous.  The CCC thinks there could be shared ownership schemes for such vehicles, which may be true, but what stops that now? 

Furthermore, how utterly dare them to suggest that people on low-incomes, who can afford cars now, should surrender their petrol cars to be part of a "shared ownership scheme" with the community, to share a car.  So no more actually private transport, but rather share a car...  bad luck on holiday weekends when you can't take the family away... but be happy, you're "saving the world".


Then you REALLY get into an agenda which stinks of socialist envy.  

“Set a maximum CO2 limit for individual light ICE vehicle imports to tackle the highest emitting vehicles”

So even before the ban on petrol and diesel cars, it wants to ban the emissions level of light vehicles imported, noting 

“The highest emitting light vehicles – with some exceptions – tend to be luxury vehicles rather than vehicles providing a significant productivity benefit over lower emissions options (for example, towing capability)”

How DARE people buy “luxury” vehicles!  Stay in your lane peasants, by which I mean bike lane. You shall NOT buy the Aston Martin or the Bugatti, you must only buy vehicles with a “significant productivity benefit”.  Seriously? Just fuck off.  If you want to buy a Bugatti and pay through the nose for your fuel (and therefore emissions), it is none of the government's business..

3. Beginning work now to decarbonise heavy transport and freight. 

So there is lots of "nice" stuff around subsidising low emission trucks and pouring fortunes of taxpayers' money down the yawning maw of Kiwirail for no net benefit on emissions (seriously).  There is NOTHING about enabling larger mass and dimension trucks (which really DOES allow for less fuel to be consumed per tonne hauled), but then that shows how there is little interest in evidence based thinking here. It's all taken up by emotive fuzzy nonsense like this:

Coaches and trains are an alternative to interregional air travel in some places. 


Well I can't WAIT to see Green MPs and the CCC showing us how they do that....

Increasing the number, efficiency, and quality of such options could reduce emissions, as could communications technology. Investment in rapid rail could help to provide a replacement to interregional air travel for longer distances, however there are still likely to be a number of flights through domestic aviation, meaning improving its sustainability is also important.

Really?  Take travel from say Wellington to Hamilton, or Christchurch to Dunedin.  Is an 8 hour or 4 hour coach trip really an alternative to a 1 hour flight?  By what conceivable means would increasing coach services really be an alternative to flying?  The mental gymnastics to think that billions of dollars of spending on rapid rail, in a country with the topography and population of NZ, could ever be a viable replacement for air travel shows two things either:
- How besotted the CCC is to the wild fantasies of the Green Party oriented lobby on transport planning or
- The poor quality of advice being taken by the CCC on these issues.


The CCC continues to say sniffily:

 “there are still likely to be a number of flights through domestic aviation” 

indicating a level of arrogance and haughtiness to sneer as if “well SOME people will still fly no matter how many tens of billions we have borrowed to build much slower alternatives”. 


It continues:

Air travel connects us within Aotearoa and to the world. It also provides for people who can’t use other modes for long-distance trips, for medical, business or other reasons.

“Other reasons”!  Keep in your lane peasants, air travel for medical and business purposes is more important than you wanting to fly to visit your relatives. GET THE BUS! 

On shipping it is also fantasyland by saying it will

 “work towards net zero-carbon shipping on key trade routes by 2035

How exactly?  NZ has no domestically based international merchant shipping fleet, and is entirely a taker of what overseas shippers supply.  Is the CCC seriously thinking about telling those companies that unless they are zero carbon by 2035, they can’t haul goods to and from NZ?  To be fair "work towards" is just bureaucrat speak for do nothing.

Lastly, it wants to ban new recreational boats being powered by fossil fuels from 2035.  Back to yachting without a motor then?


As you'll see I became increasingly frustrated reading this policy doggerel.  It deserves to be thrown in the bin, as most of it is unremitting drivel.  It claims to be about reducing emissions, but is in fact an ideological crusade against private vehicle use, and for all of the talk of shifting the car fleet towards zero emission vehicles, it doesn't actually want people to use them all that much.  For all of the talk about the poor, it wants to make it more expensive for them to own the cars they usually purchase and to accept as an alternative "shared ownership" (the little people shouldn't get to own their OWN car, just share it with "the community").  The desire to reduce driving, EVEN OF ZERO EMISSION VEHICLES, demonstrates this is not remotely anything to with reducing emissions to combat climate change, it's pure naked opportunism to attack the very idea of private ownership of a motor vehicle and private use of motor vehicles. After all, if NZ had a 100% electric car fleet tomorrow (even 50%), none of this nonsense could be tenable.

Sure walking and cycling produce no emissions, and it's all very well for people to do that more for all sorts of reasons, but the fetishisation of railways and public transport, when expanding it far beyond people's willingness to pay will just mean a vast and grotesque waste of capital (see high-speed railways in Spain) and a lot of energy used to do very little.  

However it's the mistrust of individuals that particularly annoys me and how underhand the entire strategy is in pretending that this isn't the case.  It says NZ would be a "dumping ground" for "unwanted" vehicles, yet these vehicles WILL be wanted by NZers willing to buy them, but the CCC doesn't want to admit it doesn't like the choices people make.  Furthermore it sneers at those who buy "luxury" cars, as if they shouldn't be allowed to, because indeed, it wants to ban luxury cars that use petrol or diesel.

It sneers that if it cajoles politicians to hike taxes enough to have more trains and buses, that some people will still fly conceding there might be (first and foremost) MEDICAL reasons to fly? 

It's a vision that emanates not just from the Green Party's control fetishists on the hard left, but from the new urbanist schools of planning from the United States, who ever bemoan why Americans drive so much, and who wonder why they can't have the public transport systems of higher density cities of Europe and Japan (whilst also embracing laws like the Resource Management Act that enable councils to ban property use and development allowed in such countries). 

ACT and National should come out quite clearly and say they will bin most of this nonsense. 

It wont affect climate change.
It wont reduce net emissions.
It wont improve outcomes for the poorest.
It will make it more expensive to own and operate a car (and a boat)
It will increase taxes.
It will make it harder to drive.
It will put up the cost of freight and therefore inflation.

So you should make a submission to the CCC and your local MP opposing the strategy.

Tell them that you oppose a target on the amount of kilometres driven, that you oppose banning imports of certain types of motor vehicles or boats, that you oppose "transport emissions impacts" to be factored into council planning decisions, that you oppose blanket measures to make driving more difficult and less convenient, that you oppose more taxpayers' money being spent to subsidise transport that people aren't willing to pay for, that you oppose road projects only being advanced if they reduce emissions.

Tell them that if reducing emissions is the goal, then allowing the price of petrol and diesel to inflate under the ETS is the best way to transparently reveal the cost of these policies to consumers.  It will mean petrol becomes $3 then $4 then $5 a litre, but it will be an honest reflection of Jacinda Ardern's "nuclear free moment" and its impact on the public. It would mean more people walk and bike and ride public transport, but by choice inflicted on them by a Government wanting to virtue signal for no discernible impact on climate change.

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