2012 AA submissions to Government and other agencies

Land Transport (Admissibility of Evidential Breath Tests) Amendment Bill

This draft Bill proposes to allow an evidential breath test (EBT) to be used for prosecution where a suspect has been unable to provide a blood sample. Currently, a positive EBT is not admissible if a suspect chooses to undertake a blood test. The AA agrees that an obviously intoxicated driver should not escape prosecution because they could not provide blood. However, we believe that the Bill should be more narrowly defined to ensure an EBT is only admissible because a person declined, or their medical condition prevented, blood being taken. The AA is also concerned that, under the draft Bill, there would still be no legal requirement for a driver to undergo an EBT. A suspected drunk driver, knowing they would be unlikely to successfully provide a blood sample, could simply refuse to undergo an EBT. The AA therefore proposes that the Bill should make undergoing an EBT compulsory and/or require suspects, who are unable to successfully complete either an EBT or a blood test for medical reasons, to undertake a compulsory impairment test.

Download the Land Transport (Admissibility of Evidential Breath Tests) Amendment Bill - 17 December 2012

Agricultural Vehicles Omnibus Rule

This draft Rule proposes to relax the road rules around the operation of agricultural vehicles, specifically introducing a 40km/h speed demarcation under which Class 1 licence holders would be permitted to drive an un-warranted heavy agricultural machine on roads (weighing up to 18 tonnes or a combined 25t when towing), and exempt them from complying with the Work Time and Logbooks Rule. While the AA has genuine safety concerns about the proposals, we have proposed amendments to mitigate safety risks. These include monitoring and reviewing the changes post-implementation, and putting emphasis on monitoring the agricultural sectors’ compliance with health and safety regulations and provision of adequate training for unqualified staff driving agricultural machines.

Download the Agricultural Vehicles Omnibus Rule - 30 November 2012

Review of New Zealand’s Oil Security

This paper proposes a range of updated options to mitigate local or international fuel supply disruptions, of which the lowest-cost option would be adding a modest levy on fuel of 0.1cpl to increase stockholdings. The AA’s short submission conditionally supported this, although we suggested it should be funded from the GST take on fuel excise instead of increasing the excise.

Download the Review of NZ's Oil Security - 27 November 2012

Safer Journeys conversation paper

In response to the Ministry of Transport’s conversation paper on the next Safer Journeys Action Plan, the AA’s submission conditionally supports the aim of the National Road Safety Committee that the next action plan focus on achieving transformational change in some key areas of road safety. But we expressed a clear desire that actions that the AA championed through the first Action Plan are not lost. Our submission also stressed the importance of developing an engagement or communications plan with the public so that there was wide public understanding and support for the next action plan.

Download the Safer Journeys conversation paper - 9 November 2012

Vehicle Licensing Reform

The government is investigating reforming New Zealand’s Warrant of Fitness, Certificate of Fitness and annual vehicle licence (‘rego’) systems. Key proposals include reducing the frequency of the WoF and CoF (the most frequent in the world), reviewing rego offences, and other changes which may save motorists millions of dollars in compliance costs. The AA’s submission supports an annual WoF for all vehicles up to the age of 12, and a six-monthly WoF for vehicles older than that. The AA supports the CoF frequency remaining at six months for light and heavy commercial vehicles. Our submission also contains a summary of the AA Member survey results on the government’s proposals.

Download the Vehicle Licensing Reform submission - 31 October 2012

Land Transport Management Bill

The Land Transport Management Bill proposes changes in the planning and funding arrangements, tolling and public-private partnership requirements and public transport operations. The AA supports most of the changes but areas where we consider amendments should be made include:

• add a focus on value for money, network resilience and customer focus as objectives and to influence funding priorities
• add checks and balances to the GPS process to retain certainty, and to minimise unintended consequences of changes in funding direction
• add road user representation into planning and funding decision making
• add a requirement to consult at the national level on the GPS and NLTP
• include road user representatives on RTCs; limit TLA representation to be proportionate to their share of funding through an electoral college process
• add a tougher test for debt funding than is used for NLTF expenditure to ensure debt funding does not tie the hands of future generations
• defer consideration of removing regional fuel tax until the Auckland consensus building group has completed its deliberations
• use Crown funds, not road user funds, to protect the integrity of Crown revenue systems, and fund the work of Crown entities
• make non-compliant users pay the costs they impose, not compliant users

Download the Land Transport Management Bill submission - 26 October 2012

ACC motor vehicle levies 2013-14

ACC is proposing no substantial changes to next year’s ACC levies for motor vehicles. However, the main proposals is to reclassify the ‘goods service vehicle’ category, which will lead to a $112 reduction in the annual levy for diesel utes/vans vans, and a $32 reduction for petrol utes/vans. The AA submission supports the change for utes and vans, which our previous submissions have called for, but we also restated that ACC’s must introduce an ACC levy on RUC equivalent to the 9.9 cents per litre ACC tax on petrol. We also said that financial improvements in the scheme allow for a moderate reduction in levies for other vehicle classes.

Download the ACC levy consultation submission - 23 October 2012

Road Maintenance Task Force

The AA’s submission on the Road Maintenance Task Force’s report: Review of Road Maintenance Regime supports recommendations to improve value for money in maintenance contracting, provided the effect on safety is monitored, network resilience is factored in (detour routes) and minimum standards are maintained.

The AA considers the Task Force has a role to develop resources to provide guidance to road controlling authorities on how to communicate contentious expenditure priorities and trade-offs; objective triggers for maintenance interventions; and technology advances that can reduce costs.

The Task Force should also undertake further work to consider ways to reduce the impact of the RMA and consent process on maintenance costs; the potential for greater use of standard products; the most cost effective ways to maintain isolated roads; and ways to reduce the need for utilities to dig up roads.

Download the Road Maintenance Task Force submission - 14 August 2012

Vehicle Exhaust Emissions Amendment Rule

This Rule proposes to extend the current emissions standards for imported used vehicles beyond the end of this year, and confirms the adoption dates of Euro 5 and equivalent Australian, Japanese and US emissions standards for new vehicles, as well as clarifying the means by which a vehicle may be assessed as complying with an approved emissions standard. The AA submission supports the proposals, as without extending the used-import emissions standard, it’s possible no used vehicles could be imported from 2013, or older used vehicles of any emissions standard could be imported which would not be desirable for improving air quality or vehicle safety.

Download the Vehicle Exhaust Emissions Rule submission - 10 August 2012

Network Access and Use Strategy

The Network Access and Use Strategy (NeXUS) outlines NZTA’s intended approach to managing how people (and vehicles) access and use the transport network (including State Highways, local roads and other modes) over the next 10 years. The NeXUS strategy represents a revolutionary shift in NZTA’s approach away from a compliance and regulatory framework to a much more holistic system and customer-focused approach.

The AA commended the draft NeXUS Strategy as a welcome breakthrough piece of thinking from NZTA and supported moving NZTA platforms to a much more customer-focussed approach; integrating information among agencies to deliver better outcomes to customers and for road safety; incentivising behaviour above the regulatory minimum; changing the safety conversation and embedding Safer Journeys and the Safe Systems approach; seeking opportunities to get better value from existing assets and services; and smart uptake of technology.

The AA has concerns about other issues including lack of funding for the strategy’s initiatives; the need for a multi-modal plan including integration with rail, sea and air transport developments; seeking integration between urban development processes so they support the transport hierarchies; and public opposition to road pricing and network charging for roads they have already paid for.

We also suggested adding a sixth objective to include national and regional network resilience and reliability.

Download the Network Access & Use Strategy submission - 1 June 2012

Agricultural Transport Legislation

This Ministry of Transport discussion paper proposes amendments to various Land Transport Rules affecting on-road agricultural vehicle use, which are designed to reduce compliance costs for agricultural vehicle operators and the farming sector. These include developing an ‘Agricultural’ endorsement that will permit Class 1 licence holders to drive an agricultural vehicles weighing up to 18 tonnes or 25 tonnes in combination (as is currently the case with tractors), raising the speed limit for agricultural vehicles that can be driven on a Class 1 or 1A licence from 30km/h to 40km/h, and exempting such vehicles from licensing or WoF requirements.

Our submission raised concerns about many of the proposals which we said were contrary to the Safe System and the MoT’s own Safer Journey’s strategy, and we are concerned that safety of road users could be compromised. However, we supported developing the ‘Agricultural’ endorsement, and improved daytime lighting for large and slow agricultural machinery.

Download the Agricultural Vehicles Review submission - 25 May 2012

High Risk Intersection Guide

The NZTA Guide follows the release of two other Guides – one for high-risk rural roads and another focused on safer journeys for motorcyclists. Whilst the AA submission was generally in favour of the content of the draft guide, there were some concerns. We said the Guide does not go far enough in terms of limiting access points onto the highway and the option of promoting alternative access points where they will be safer; speed is also mentioned often as a solution for high risk intersections and our concern is that engineering treatments should be the priority with reducing speed limits as the last resort.

Download the High-risk Intersection Guide - 14 May 2012

State Highway Construction Noise Guide

The AA supports a balanced approach to managing and mitigating the effects of road construction noise, and the NZTA’s draft Construction Noise Guide provides some excellent examples and suggestions (e.g. temporary noise barriers, silent vehicle reversing alarms, advance warning of dates, event tickets for residents). However the AA is concerned that reducing hours of operation significantly increases construction costs and delays completion of critical projects. When there are noise curfews at night, it forces construction into the daytime when there is more traffic, increasing stress and delays for motorists. The AA submission suggests that NZTA undertake an analysis of the cost effectiveness of the proposals to manage noise during construction to ensure that all needs are being balanced and to inform the NZTA Board on decisions about value for money in noise management.

Download the State Highway Construction Noise Guide - 1 May 2012

Consumer Law Reform Bill

This Bill modernises various consumer laws to accommodate internet auctions and online sales, the main change from the motorists’ perspective being the inclusion of cars or parts sold by dealers via online TradeMe-style auctions under the Consumer Guarantees Act (auctions are presently exempt, but under the amendment the definition is narrowed to only apply to live physical auctions). The CGA includes guarantees that goods sold must be of ‘acceptable quality’, and provides for legal redress. The AA’s submission supports moves to preserve the rights of consumers buying off dealers via online auctions, as they would have an expectation of being able to obtain a warranty or return defective goods shortly after purchase just as if they had bought the car or parts off the yard. However we recommended the Ministry of Consumer Affairs develop clear, consistent guidelines for the Motor Vehicle Disputes Tribunal as to what constitutes ‘acceptable quality’ in respect of a used car under the Act to exclude vehicles that cannot be reasonably guaranteed.

Download the Consumer Law Reform Bill - 29 March 2012

Review of motor vehicle registration and licensing and RUC administration fees

This submission comments on proposals to amend some vehicle licence and Road User Charge administration fees, and introduce new fees. The AA broadly supported lowering the cost of internet transactions but opposed a new fee for reassigning the RUC vehicle type.

Download the Review of registration, licensing and RUC fees - 16 March 2012

Safer Journeys for Motorcycling on NZ roads

This draft guide for road controlling authorities, engineers and planners, policy makers and funders, and motorcyclists, is intended to help reduce the numbers of fatal and serious injury crashes involving motorcyclists and moped riders. The document reflects the Safe System approach, with a particular emphasis on safe roads and roadsides. The AA’s comments focus on amending the guide to identify and improve road surface treatment for motorcyclists, investigating alternative pavement markings, and greater analysis of alternative barrier treatments.

Download the Safer Journeys for Motorcycling - 26 January 2012

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