50 Victoria Street
Private Bag 6995
Wellington 6141
New Zealand
T 64 4 894 5400
F 64 4 894 6100
www.nzta.govt.nz
5 November 2021
Bevan Woodward
f [email address]
REF: OIA-8834
Dear Bevan
Request made under the Official Information Act 1982
Thank you f or your email
of 23 September 2021 requesting the following information under the Official
Inf ormation Act 1982 (the Act):
1. Please provide a copy of the material (eg: reports, analysis, minutes, resolutions and advice)
that was relied on or pertains to NZTA’s responses to the following information requests:
2. Given the approach taken by the NZTA’s Investment Prioritisation Method approach of rating
for GPS alignment "based on the highest expected contribution to a single GPS strategic priority”,
how is NZTA ensuring the NLTP 2021-24 will meet the requirement of para 7 (and 51) of GPS
2021 that "a reduction in greenhouse gas emissions will be achieved through action across all
priorities, programmes and activity classes”?
3. Given the approach taken by the NZTA’s Investment Prioritisation Method approach of rating
for GPS alignment "based on the highest expected contribution to a single GPS strategic priority”,
how is NZTA ensuring the NLTP 2021-24 will meet the requirement of GPS 2021, para 113: "the
focus of the investment in the activity classes is on improving safety, better travel options,
improved freight connections, and climate change." Please provide three actual examples of how
NZTA is meeting this requirement; one from State Highway Improvements activity class, one from
Walking and Cycling Improvements activity class and one from Local Road Improvements activity
class.
4. How is NZTA ensuring the NLTP 2021-24 has met the requirement of GPS para 89 for each
investment proposal that “Funding applicants need to show that they considered alternatives, and
how they compare in meeting the results set out in Section 2.6. This includes considering whether
there are better ways to operate and maintain the existing land transport system before
considering new improvements.”
5. Please provide three actual examples of how NZTA is giving effect to para 89, one from State
Highway Improvements activity class, one from Walking and Cycling Improvements activity class
and one from Local Road Improvements activity class.
6. In preparing the NLTP 2021, please advise how NZTA has given effect to para 67 of GPS
“Investment decisions will support the rapid transition to a low carbon transport system, and
contribute to a resilient transport sector that reduces harmful emissions, giving effect to the
emissions reduction target the Climate Change Commission recommended to Cabinet until
emissions budgets are released in 2021.”
7. Please advise NZTA’s understanding of the amount and timeframe of emissions reduction
target the Climate Change Commission has recommended to Cabinet per para 67 of the GPS
2021.
8. Can NZTA confirm it will meet the emissions reduction target the Climate Change Commission
has recommended to Cabinet (as required by para 67 of the GPS 2021)? Please provide details
on NZTA’s predicted emissions compared to the Climate Change Commission recommended
target.
9. How is induced traffic is accounted for in NZTA’s GHG emissions models?
10. Please provide the forecast emissions impacts for Penlink (Whangaparāoa) and the Otaki to
north of Levin roading projects.
11. Please advise which investments in the NLTP 2021-24 activity classes of State Highway
Improvements and Local Road Improvements are forecast to increase greenhouse gas emissions.
12. Please advise which investments in the NLTP 2021-24 activity classes of State Highway
Improvements and Local Road Improvements that have not been assessed for greenhouse gas
emissions.
13. How is NZTA ensuring that NLTP 2021-24 is “accelerating mode shift” as required by clause
145 of GPS 2021?
14. Please provide an update of dates and status of activities for NZTA’s “Keeping Cities Moving”
Attachment 1: “Timeline for the National Tactical Plan” published September 2019.
15. Please advise NZTA’s predictions for mode share for the years 2021 – 2031, as compared to
a baseline of 2020.
16. How is NZTA having “a greater role in long-term, integrated planning for the sector” as
required by para 146 of GPS-LT 2021?
17. Please provide evidence of the work done by NZTA to “work closely with MoT and local
government in developing and implementing the NLTP to give effect to the GPS” as required by
para 147 of the GPS 2021.
18. Does an updated version of Toitū te Taiao (originally published April 2020) exist? If so, please
provide a copy, or advise whether a date has been set for an update.
In developing the 2021–24 National Land Transport Programme (NLTP) Waka Kotahi NZ Transport
Agency must give effect to the Government Policy Statement on Land Transport 2021. On the Waka
Kotahi website, you can find further details of GPS implications for Waka Kotahi and approved
organisations, including guidance on how the GPS will be applied in the National Land Transport Fund
(NLTF) and NLTP.
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I will answer each of your questions in turn.
1. Please provide a copy of the material (eg: reports, analysis, minutes, resolutions and advice)
that was relied on or pertains to NZTA’s responses to the following information requests:
Relevant material is attached and noted in response to each question in this letter below. In addition,
Waka Kotahi is currently preparing a proactive release of papers relating to the development and
conf irmation of the NLTP 2021-24 on our website and will provide you with a link to our proactive
releases page when the information becomes available.
Questions 2, 3, 4, 5, 6 and 13
We have responded to questions 2, 3, 4, 5, 6 and 13 together. In our view, these questions are in the
nature of requests for explanations rather than existing information held by Waka Kotahi. We note that
we are not required to create new information to respond to requests for explanations. Accordingly, we
respond to your requests to the extent that they apply to information already held by Waka Kotahi.
Analysis of how the NLTP 2021-24 gives effect to the GPS is contained in the NLTP and in Waka
Kotahi Board papers dated 19 and 31 August 2021.
The NLTP is a publicly available document found here: www.nzta.govt.nz/planning-and-
investment/national-land-transport-programme/2021-24-nltp/. Waka Kotahi is currently preparing a
proactive release of papers relating to the development and confirmation of the NLTP 2021-24 on our
website. Therefore, I am ref using this part of your request under section 18(d) of the Act. We will
provide you with a link to our proactive releases page when the information becomes available, which
should be on or before 1 December 2021.
7. Please advise NZTA’s understanding of the amount and timeframe of emissions reduction
target the Climate Change Commission has recommended to Cabinet per para 67 of the GPS
2021.
We decline this request as, in our view, it is a request for an opinion and not a request for information
under the Act.
8. Can NZTA confirm it will meet the emissions reduction target the Climate Change
Commission has recommended to Cabinet (as required by para 67 of the GPS 2021)? Please
provide details on NZTA’s predicted emissions compared to the Climate Change Commission
recommended target.
We decline the f irst part of this request for us to confirm we will meet the emissions reduction target
the Climate Change Commission has recommended to Cabinet as, in our view, it is not a request for
inf ormation under the Act.
The second part of this request relating to predicted emissions compared to the Climate Change
Commission recommended target, is for information not held by Waka Kotahi. Theref ore, I am ref using
your request under section 18(e) on the basis the documents alleged to contain the information do not
exist.
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9. How is induced traffic is accounted for in NZTA’s GHG emissions models?
The Waka Kotahi investment decision making framework requires potential induced traffic impacts that
may arise f rom proposed improvements to the transport system to be assessed in accordance with the
Waka Kotahi Monetised Benefits and Costs Manual (MBCM):
www.nzta.govt.nz/assets/resources/monetised-benefits-and-costs-manual/Monetised-benefits-and-
costs-manual.pdf.
Transport Model Development guidelines provide an industry standard for estimating induced traffic:
www.nzta.govt.nz/assets/resources/transport-model-development-guidelines/docs/tmd.pdf.
To assess the specific greenhouse gas emission impact of induced traffic, Waka Kotahi takes traffic
data outputs from relevant regional or project-specific transport models and applies emission factors to
these that are taken from the Waka Kotahi Vehicle Emission Prediction Model
(www.nzta.govt.nz/roads-and-rail/highways-information-portal/technical-disciplines/air-quality-
climate/planning-and-assessment/vehicle-emissions-prediction-model/), which is aligned to the
Ministry of Transport Vehicle Fleet Emission Model. Waka Kotahi is currently developing guidelines to
f ormalise and support a consistent approach being taken to the assessment of greenhouse gas
emission impacts from proposed land transport infrastructure improvements, including consideration of
induced traffic as and where appropriate.
Theref ore, I am ref using your request under section 18(d) as the information requested is publicly
available.
10. Please provide the forecast emissions impacts for Penlink (Whangaparāoa) and the Otaki to
north of Levin roading projects.
As per our response to you on 1 October 2021 to OIA-8752, Waka Kotahi is working with the Ministry
of Transport and Ministry for the Environment on a proactive release of the CIPAs and related
documents for publishing, and Waka Kotahi will contact you when these have been published, which
should be before or on 1 December 2021. Theref ore, I am refusing your request under section 18(d)
as the inf ormation requested will soon be publicly available.
11. Please advise which investments in the NLTP 2021-24 activity classes of State Highway
Improvements and Local Road Improvements are forecast to increase greenhouse gas
emissions.
An assessment of the NLTP was undertaken using the Waka Kotahi Climate Assessment Tool for
Investment (CATI). This was completed on 30 August 2021. CATI is a new tool and remains in
development. It’s application, therefore, comes with some important caveats. In particular, CATI
provides:
• a qualitative not quantitative profile of an investment programme in terms of its potential to
increase or reduce emissions
• in the case of the NLTP, a three-year snapshot focused on the potential of investment to
increase or reduce enabled emissions (i.e. vehicle use) not construction or operating
emissions
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• an assessment of activities included in the NLTP across three categories:
o potential to increase emissions (e.g. increasing road capacity for vehicles)
o potential to maintain emissions (e.g. operations, maintenance, and business cases)
o potential to reduce emissions (e.g. public transport and active modes)
Attachment - Q11 - list of investments is a list of activities included in the NLTP State Highway
Improvements and Local Road Improvements activity classes that were assessed as having the
potential to increase emissions.
It is worth noting that due to the high-level nature of the CATI assessment, some projects with initial
phases categorised as “potential to increase emissions” may be precursors to investments that have
the potential to reduce emissions in the long-term. Similarly, such projects may also contain project
elements that have the potential to decrease emissions (e.g. the provision of a walking and cycling
path in conjunction with a state highway roading project).
12. Please advise which investments in the NLTP 2021-24 activity classes of State Highway
Improvements and Local Road Improvements that have not been assessed for greenhouse gas
emissions.
As per our response to you on 4 October 2021 to OIA-8764, the CATI assessment noted above
covered all activities included in the NLTP.
14. Please provide an update of dates and status of activities for NZTA’s “Keeping Cities
Moving” Attachment 1: “Timeline for the National Tactical Plan” published September 2019.
See Attachment – Q14 – Mode Shift National Action Plan Tracking Sept 21 for information within
scope of this request. Certain information has been removed as it is not in scope of your request.
15. Please advise NZTA’s predictions for mode share for the years 2021 – 2031, as compared to
a baseline of 2020.
There are no documents Waka Kotahi holds in response to this request. Theref ore, I am refusing this
request under section 18(e) as the document alleged to contain the information requested does not
exist.
You may wish to contact the Climate Change Commission or the Ministry of Transport who have
undertaken work to predict future mode share.
16. How is NZTA having “a greater role in long-term, integrated planning for the sector” as
required by para 146 of GPS-LT 2021?
Ref er to pages 22-24 of the NLTP setting out our role as system leader and in system planning, spatial
planning and urban design, found here: www.nzta.govt.nz/planning-and-investment/national-land-
transport-programme/2021-24-nltp/.
Ref er also to
Arataki, our 10-year view and long-term objectives for the land transport system, found
here: www.nzta.govt.nz/planning-and-investment/planning/arataki/arataki-version-2/.
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In regard to the work Waka Kotahi intends to carry out this year towards this objective, refer to the
2021-22 Statement of Performance Expectations: www.nzta.govt.nz/assets/resources/statement-of-
perf ormance-expectations/2021-2022/spe-2021-2022.pdf. In particular, refer to the section “Partnering
on integrated transport system and spatial planning” on page 50.
As this information is publicly available, I am declining your request under section 18(d).
17. Please provide evidence of the work done by NZTA to “work closely with MoT and local
government in developing and implementing the NLTP to give effect to the GPS” as required
by para 147 of the GPS 2021.
Thank you f or clarifying this part of your request for us on 26 October 2021, as below:
Regarding clarification of question 17:
Particular topics of interest: The development and implementation of NZTA's process for assessing
investments for inclusion in NLTP 2021 to give effect to GPS 2021.
Category of documents of interest: Guidance materials issued by NZTA to local Government. NZTA's
dialogue with MoT and the Climate Change Commission.
Date range for the information: 1 November 2020 - 6 September 2021.
The f ollowing documents fall within the scope of this request and are enclosed:
• Attachment Q17a - 002 - NLTP Moderation Approved Organisation Overview and
Milestones.pdf
• Attachment Q17b - 002 - NLTP Moderation Waka Kotahi Overview and Milestones.pdf
• Attachment Q17c - Approach to the Final Moderation for Improvement Activities.pdf
• Attachment Q17d - Preparation for the Assessment Prioritisation Workshop.pdf
The guidance materials Waka Kotahi provided regarding the application of the Investment
Prioritisation Method can be found on our website here: www.nzta.govt.nz/planning-and-
investment/planning/investment-decision-making-framework-review/investment-prioritisation-method/.
There were also “NLTP Bulletins” provided by Waka Kotahi to local government from September 2019
to October 2021 and can be found on our website here: www.nzta.govt.nz/planning-and-
investment/national-land-transport-programme/news-updates?start=0.
Regarding the part of this request for dialogue between Waka Kotahi and the Ministry of Transport and
the Climate Change Commission. I can confirm that there are some emails between Waka Kotahi and
the Ministry of Transport that are in scope, and we are working towards providing this information to
you before or on 26 November 2021. This is because of the consultations necessary to make a
decision on the request are such that a proper response to the request cannot reasonably be made
within the original time limit.
18. Does an updated version of Toitū te Taiao (originally published April 2020) exist? If so,
please provide a copy, or advise whether a date has been set for an update.
Toitū te Taiao has not been updated since it was originally published in April 2020. The latest version
can be accessed via the following link: www.nzta.govt.nz/assets/About-us/docs/sustainability-action-
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plan-april-2020.pdf. As this information is publicly available, I am declining your request under section
18(d).
With respect to the information that has been withheld, I do not consider there are any other factors
which would render it desirable, in the public interest, to make the information available.
Under section 28 of the Act, you have the right to ask the Ombudsman to review my decision to
withhold this information and refuse parts of your request. The contact details for the Ombudsman can
be located at www.ombudsman.parliament.nz.
If you would like to discuss this reply with the Waka Kotahi NZ Transport Agency, please contact
Ministerial Services by email to [email address].
Yours sincerely
Howard Cattermole
Chief Financial Officer
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OIA-8834 Document Schedule
Ref
Document
Date
Description
1.
Attachment – Q11 – list of investments.xlsx
N/A
Release in full.
2.
Attachment - Q14 -
September
Certain information being
Mode_Shift_National_Action_Plan_Tracking_Sept_21.pdf 2021
withheld as being out of
scope.
3.
Attachment Q17a - 002 - NLTP Moderation Approved
N/A
Release in full.
Organisation Overview and Milestones.pdf
4.
Attachment Q17b - 002 - NLTP Moderation Waka Kotahi
N/A
Release in full.
Overview and Milestones.pdf
5.
Attachment Q17c - Approach to the Final Moderation for
17 May
Release in full.
Improvement Activities.pdf
2021
6.
Attachment Q17d - Preparation for the Assessment
N/A
Release in full.
Prioritisation Workshop.pdf
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