2011 AA submissions to Government and other agencies

In 2011, the AA has made submissions regarding the Government Policy Statement, State Highway Classification proposal, Road User Charges Bill, National Code for Utilities' Access to Transport Corridors, ACC levies and others.  The full submission documents are available for download.

RUC Bill – Vehicle Types and Weight Bands

This Ministry of Transport consultation document outlines the suggested new RUC weights that will apply to different vehicle types under forthcoming amendments to the Road User Charges Act. Under the new Act, RUC charges will no longer vary on a tonne by tonne basis within each vehicle type (according to actual laden weight), instead up to 3 broad weight bands are proposed within each type regardless of actual laden weight. The AA’s submission called for a lower RUC charge for passenger cars to distinguish them from light commercials that carry loads, along with a new bus class within Type 2 to accommodate unladen motorhomes that weigh less than the proposed bands. We also suggested introducing a ‘nominated-weight’ exemption for privately-owned light commercial vehicles which are primarily used for carrying passengers, and a similar exemption for non-commercial heavy vehicles that operate unladen.

Download the RUC Bill - vehicle types and weight bands - 16 December 2011

ACC levy consultation 2012/13

ACC’s consultation for the 2012/13 motor vehicle levies propose no changes for the next financial year (commencing July 2012), meaning the licence fees will remain unchanged for all vehicle classes. However, the AA’s submission proposed that the ACC petrol levy be increased in favour of a lower fixed licence fee as the current regime disadvantages those who travel low mileages or who own multiple vehicles. We also proposed that a similar distance-based ACC levy be introduced for diesel vehicles (on RUC), and that the Goods Service Vehicle class be separated into light and heavy vehicles to better reflect ACC costs.

Download the ACC levy consultation 2012/13 - 16 August 2011

Omnibus Amendment Rule

This Rule contains a number of minor amendments to other Land Transport Rules including Dangerous Goods, Driver Licensing, Vehicle Standards Compliance and Light-Vehicle Brakes. The AA’s submission supports changes to the Driver Licensing Rule, Frontal Impact Rule and Traffic Control Devices Rule, and proposals to remove the requirement for a safety chain to be fitted to a light trailer if a breakaway brake is fitted instead. However, we oppose the proposal to exempt vehicles temporarily imported under the Geneva Convention from meeting New Zealand vehicle safety standards.

Download the Omnibus Amendment Rule submission - 4 July 2011

Road User Amendment Rule

The main proposal in this Rule is to repeal the current give way rules which give priority to right-turning traffic. Under the amendment, which is expected to come into effect in April 2012, a driver turning right at an intersection or T-intersection will have to give way to all oncoming traffic travelling straight ahead or turning left. The AA has lobbied for this change for some time so our submission supports the proposal, which will align New Zealand give way rules with the rest of the world. Other changes include amending the Rule so that drivers approaching a pedestrian crossing controlled by a school patrol do not have to stop if children are obviously waiting to cross but where a school patrol sign is not extended, which the AA also supports.

Download the Road User Rule submission - 24 June 2011

Government Policy Statement on Land Transport Funding 2012-2022

The GPS sets priorities for land transport for the next ten years, and the AA’s submission supports the proposed focus areas: economic growth; productivity; value for money; road safety and Canterbury earthquake recovery. However, the AA challenges the assumption that heavy vehicles contribute more to economic growth and productivity than light vehicles, and contends that the Minister needs to review the cost of getting projects through consent processes if we want better value for money. The AA supports continuing with the Roads of National Significance and proposed increases to public transport funding, but only if at each step there is a strong focus on value for money. Funding for capital improvements against maintenance should be based on a sound trade-off. The AA strongly supports the increased focus on funding ranges for road safety improvements, and calls for an additional $150m on road safety that will have a profound impact on our road toll.

Finally, in an addendum, the AA is calling for GPS to prioritise funding for roading agencies to build utility ducts to reduce how often the roads are dug up and make the roads safer by reducing the need for poles.

Download the GPS 2012-2022 submission - 31 May 2011

High-risk Rural Roads Guide

The AA made a submission on the NZTA’s draft High-risk Rural Roads Guide. Crashes on rural open roads accounted for 53 percent of all New Zealand fatal and serious road crashes in the five year period to 2009, and high-risk rural roads are a priority of the government's Safer Journeys strategy to 2020. The Guide provides advice to road controlling authorities on how to identify which rural roads are ‘high risk’ and provides best practice guidance on choosing effective countermeasures. The AA believes the guide is major step forward in road safety and a key deliverable of the Safer Journeys strategy to target high-risk rural roads. Whilst the submission is generally supportive of the guide and its approach, the AA does have some concerns over the amount of funding that will be available to support engineering treatments for the high-risk roads that will be identified, and also the potential for practitioners to see lowering speed limits as the ‘easy solution’ to a address a high-risk route.

Download the High-risk rural roads guide - 31 May 2011

State Highway Classification

The AA made a submission on NZTA proposals to develop a State Highway classification system or roading hierarchy. After classifying the state highways into one of four categories based on their function, over time the goal is to have a consistent level of service for the highways in each category. The implications for motorists of the categorisation approach are likely to be quite significant and the AA submission supports a top-down assessment which considers the purpose of each highway and how this may change in future, but believes the measurement criteria needs to be more forward-looking. In addition the AA would like periodic reviews of the classifications in order to keep them current.

Download the State Highway Classification submission - 31 March 2011

Road User Charges Bill

This Bill aims to simplify the Road User Charges (RUC) system. The key proposal is to change the definition of vehicle weight that the charges apply to. Currently owners have to estimate the actual gross weight they will carry, and Police have to physically weigh the laden vehicle. The Bill proposes to use the maximum weight the vehicle can carry (the vehicle manufacturer’s gross vehicle mass or the maximum allowable mass, whichever is lower). This will have not much effect on light diesel vehicles; while some light vehicles will shift up a RUC class this will not significantly increase the amount they pay because the light weights have very similar charging rates. The Bill also proposes to remove the time licence system, and replace the cumbersome and unfair process for calculating RUC infringements with a flat $200 fine for vehicles that don’t have a current RUC licence (the same fine as having no WoF or registration).

Download the Road User Charges Bill submission - 24 March 2011

National Code for Utilities' Access to Transport Corridors

The NZ Utilities Advisory Group is proposing to make mandatory the currently voluntary Code for utility companies (e.g. telephone and power) who access the road network to repair or install infrastructure. The AA’s submission said the Code favours utilities’ access to the road network at the expense of road users in terms of safety, frustration and cost. We said the code needs to be reviewed to provide greater co-ordination of utility work, reduce disruption, and to require utilities to undertake a proper assessment of the costs to road users of the delays imposed by works. The Code should require Road Controlling Authorities to consult with road user representatives about the reasonable conditions that road users consider should be imposed on managing utility road works. We said that utilities should be responsible for assessing the level of hazard they are placing in a public place and for moving those that are hazardous or mitigating them. The Code should also align with the Government’s Safer Journey’s strategy to achieve safer roads and roadsides.

Download the National Code for Utilities' Access to Transport Corridors submission - 18 March 2011

Engine Fuel Specification Regulations

This review proposes minor amendments to fuel specifications which will better align New Zealand standards with global standards, thereby improving source options and possibly lowering fuel costs. The AA submission supported these amendments, and other proposals to reduce impediments to the supply of biofuels.

Download the Engine Fuel Specification Regulations submission - 14 March 2011

National Infrastructure Plan

Submission on the Ministry of Transport’s long-term National Infrastructure Plan in which the AA discusses the fiscal benefits of infrastructure investment, measures of costs or delays caused by consents and compliances, a national strategic overview of infrastructure, and the Treasury discount rate which favours low-durability road materials with higher maintenance costs.

Download the National Infrastructure Plan submission - 4 March 2011

Alcohol Reform Bill

The Alcohol Reform Bill, which replaces the Sale of Liquor Act, contains measures to reduce wider alcohol related harm and these are likely to also improve road safety. The AA’s submission called for greater funding for alcohol and drug assessments, treatment and rehabilitation, and hypothecation of alcohol fines to fund this, and also for a ban on open alcohol containers in cars. We also recommended that licensing authorities should include road safety considerations in decisions on whether to grant or renew a liquor licence, and licensees should have greater responsibility to assist intoxicated patrons find safe transport home. The AA also submitted that alcohol taxes should in principle, over time, fully recover the cost to taxpayers of alcohol related harm including policing, ACC and health costs.

Download the Alcohol Reform Bill submission - 9 February 2011

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