NZTA's failure to take action on reducing emissions
In response to our letter to the Climate Change Commission pointing out how the NZ Transport Agency/Waka Kotahi is failing or faking action on reducing emissions, Waka Kotahi wrote this letter on 23 December 2022.
Here's our analysis of the situation which shows how Waka Kotahi is avoiding taking action (whilst publicly proclaiming it is focused on reducing emissions):
Here's our analysis of the situation which shows how Waka Kotahi is avoiding taking action (whilst publicly proclaiming it is focused on reducing emissions):
- Waka Kotahi does not address the issue of the Benefit Cost Ratio undermining the best practice transport planning practice (Avoid - Shift - Improve) as described in point 1 of our 24 November letter. However our recent constructive dialogue on this matter gives us some hope there will be some significant change to the way BCR is used by the agency.
- Waka Kotahi advises “In its IDMF [Investment Decision Making Framework] Waka Kotahi considers greenhouse gas emissions of proposed investments”. Having studied the IDMF process in practice, Waka Kotahi’s approach of merely “considering” emissions has not resulted in action to reduce emissions and explains Waka Kotahi’s failure to reduce emissions.
Furthermore Waka Kotahi’s approach of 'considering emissions' does not align with its public statements such as "Our climate change action focuses on reducing greenhouse gas emissions”. Hence we recommend any increase in emissions should be treated as a “showstopper" and approval of any such investment must only be by high threshold (including Board level approval). - Waka Kotahi hasn't addressed its ”interim climate policy" that does not require emissions to be quantified: "Until transport GHG emission budgets and associated emission reduction plans are confirmed by the Climate Change Commission and the government, we do not expect emissions impacts to be expressed in traditional terms of tonnes of CO2e.” We note that Toitū Te Taiao, Waka Kotahi's sustainability action plan and GPS 2021 refer to desired emissions reductions in terms of “tonnes of greenhouse gases emitted”.
- We note that Waka Kotahi’s Climate change mitigation is an Environmental Plan published by Transit in June 2008. We cannot understand why Waka Kotahi is not referring to Toitū Te Taiao and instead is relying on a 15 year old document.
- Waka Kotahi claim that the 78% of NLTP’s $24.3 billion investment having the potential to increase emissions is high because of the ‘committed' activities approved under previous GPS. However the previous GPS (2018) also required Waka Kotahi to reduce emissions.
