2014 AA submissions to Government and other agencies
How can government improve results for our most vulnerable (at-risk) children and their families?
The Auckland Chamber of Commerce has identified that the majority of advertised jobs, particularly unskilled entry level jobs for young people, require a driver licence. In stark contrast to levels of licensing in the population, the majority of people on unemployment benefit are unlicensed or hold only a Learner licence.
An unintended consequence of major changes to the driver licensing process to improve road safety is to further disadvantaged vulnerable youth. Unlicensed youth drivers are also at higher crash risk for death and injury, and thereby a focus for enforcement. This results in fines, which many are unable to pay and hence turn into a debt burden and Court record.
The AA says that delivering driver training outside of the family unit for example through schools, marae or mentor programmes to vulnerable youth would circumvent this costly ‘vicious cycle’ and create a virtuous cycle where youth gain employment, remain outside the benefit system, and avoid traffic offences, fines and court sentences for unlicensed driving.
Download the AA submission - 4 December 2014
Safer Journeys for People Who Cycle
As an organisation interested in all forms of mobility for our Members, the AA has taken a strong role in the Cycle Safety Panel work. Our submission on the draft report provided support for a number of the key recommendations but asked questions of others. In line with our usual approach, the AA asked that the Panel focus on recommendations supported by evidence, not emotion. Increasing safety for cyclists on our roading network can bring benefits for all road users. We strongly support the call for well-planned and designed, connected and separated cycle facilities in our major urban centres and we are very pleased that the Government has provided considerable new funds to achieve this. We reiterate our position that the transport system must be looked at as a whole, and that the needs of various users and modes need to be considered.
Download the Safer Journeys for People Who Cycle submission - 28 October 2014
Government Policy Statement on Land Transport Funding 2015/16-2024/25
The proposed GPS is a document issued by the Minister of Transport every three years. It is the Government’s primary tool to communicate to the public what it wants to achieve in land transport, and how funding will be allocated between types of activity (for example, roading, public transport, road safety) across the land transport system.
Overall, we are supportive and view the proposed GPS as being consistent with and carrying on the approach taken with the 2012 GPS with the focus on road safety, value for money and economic growth and productivity. The proposed GPS also aims to spend nearly $39 billion on land transport over 10 years. The AA is particularly pleased that the GPS has five objectives, which provide clear strategic expectations on what land transport t projects should be funded. We also emphasised our support of the GPS taking a more pro-active approach in exploring alternative sources of funding and the greater role that technology can play within the transport sector.
Download the GPS submission - 15 August 2014
Auckland Transport Draft Parking Discussion Document
Auckland Transport is proposing a range of changes to parking regulations in the city, which it believes are necessary given the city’s forecast growth. The goals of the proposed changes are to encourage greater use of public transport, support economic activity in the CBD, relieve congestion, and give greater clarity and consistency to city-wide parking rules.
Key proposed changes include increasing charges for on-street parking in the CBD and metropolitan centres, expanding residential parking schemes, discouraging commuter parking in parking buildings, to free up spaces for short-stay users, removal of parking from some arterial roads, and expanding park and ride facilities.
The AA supports much of what Auckland Transport is trying to achieve in the document, and believes that the majority of the parking management tools it proposes make sense, but we believe the document is too heavily focused on trying to change commuter behaviour by punishing motorists, rather than providing incentives.
Download the Auckland Transport Draft Parking Discussion Document submission - 31 July 2014
ACC 2015-16 Motor Vehicle levy consultation
ACC’s annual consultation on next year’s motor vehicle levies propose to reduce levies for most vehicles by an average of 40%. But for cars under 40 years old, ACC are proposing to introduce ‘risk-rating’ so the size of the reduction in licence fees could range from $73 to $163 depending on its safety rating (derived from the Australasian Used Car Safety Ratings). Alternatively, ACC also propose an option of reducing ACC tax on petrol by 4 cents per litre, in which case licence fees will fall by about $25-$115. The AA’s submission cautiously supports risk-rating but has concerns about the reliability of the data, and suggests new car crash ratings should also be used. We also opposed reducing the petrol tax as it is fairer for motorists to collect more ACC from petrol as those that travel less, pay less in fuel tax and licence fees. We also suggested ACC levies could be collected from alcohol sales to cover the costs of alcohol-related crashes.
Download the ACC 2015-16 levy consultation - 17 June 2016
Driver Licensing Amendment Rule
This Rule proposes changes to overcome concerns about the large numbers of people not progressing through the graduated driver licence system.
The AA’s submission supported proposals to reduce the renewal period from 10 years to five years for Learner and Restricted stages of Class 1 (car) and Class 6 (motorcycle) licences as an encouragement to progress to the next licence stage.
We supported automatically removing the R licence restrictions after 5 years (or sooner), and recommended automatically progressing to a Full licence, as occurs in some states in Australia, provided the R licence carries no current demerit points. Failing that, require an attempt on the Full licence test before they can renew their Restricted licence. Our submission also supported mandatory R plates for Restricted drivers, and printing the licence conditions on the inside so passengers and parents are aware of the conditions. It also supports renaming the Learner licence a Learner permit, so that it is not misinterpreted as a licence to drive solo.
Download the Driver Licensing Amendment Rule submission - 6 June 2014
Health and Safety Reform BIll
The AA’s submission has concerns around some potentially unintended consequences for motorists on public roads and so have asked officials to ensure that some potential outcomes, which may or may not arise, have been taken into consideration. These include:
- Lengthy road closures due to the requirement to protect the site of a workplace injury until investigations are complete
- Increased risk to first responders and crash victims from secondary incidents (protecting the crash site is at odds with moving vehicles quickly to a safe place; Quick Clearance laws are international best practice to enable quickly clearing the worksite off the road)
- Potential duplication of existing road safety and crash investigation systems; we suggest the Bill delegate WorkSafe inspector’s on-site crash investigations to Police.
- Roading agencies may be liable if the road environment does not meet safety standards or has failed to undertake adequate inspections, which may have implications on transport budgets and thereby petrol tax, road user charges and rates. Utilities may also be liable for placing hazardous objects (poles etc) of unsafe design into the public road corridor.
Download the Health and Safety Reform Bill - 9 May 2014
Light-Vehicle Brakes Amendment Rule
This Rule amendment proposes to introduce changes that require light vehicles entering the fleet to be fitted with ESC. The Rule proposes to introduce the changes from July 2015 for new vehicles, and phase-in requirements for used vehicles from 2016-20. The AA’s submission broadly supports the proposed Rule, especially the proposed dates for used vehicles which strike a fair balance between introducing the changes as soon as possible without substantially affecting vehicle choice or price. However, we proposed that NZTA investigate whether verifying the ESC system is operational during the WoF check can be more reliably checked by means of a generic diagnostic scan tool.
Download the Light-vehicle Brakes Amendment Rule submission - 22 April 2014
Energy (Fuels, Levies and References) Amendment Bill
This Bill proposes a small increase in the Petroleum or Engine Fuel Monitoring Levy to cover the cost of meeting NZ's oil stockholding treaty obligation.
Download the Energy (Fuels, Levies and References) Amendment Bill - 16 April 2014
Auckland Council Low Carbon Strategic Action Plan
Our submission offers tepid support for the Plan. The AA’s main concerns are that we believe central government and not local government should drive programmes to reduce the carbon footprint. We are concerned that Auckland Council had not provided information regarding the financial impacts of the Plan and furthermore, they appear to have set arbitrary and incomplete targets. The second part of our submission focuses on the Plan's transport action points. We supported some of the action points, but we were concerned that the Plan was unfairly targeting motorists. Lastly, we suggested that Auckland Council should create robust and efficient investment criteria that clearly outlines how and why they intend to make decisions that seek to lower the carbon footprint of Auckland.
Download the Low Carbon Strategic Action Plan submission 7 April 2014
Funding Assistance Rate
The NZ Transport Agency is proposing several options for changing the way costs are shared between road users and ratepayers (the Funding Assistance Rate or FAR). The various options result in differences of millions of dollars for individual local councils. The AA considers some of the changes have value but that the proposed options will not improve national consistency, value for money or new investment. The AA suggests some alternative options based on the gap between the current standard of transport services and the ideal level.
Download the Funding Assistance Rate - options for discussion submission - 31 March 2014
Auckland Council draft Unitary Plan
The AA’s submission utilises our earlier Auckland Transport Funding Survey. The intention of doing this was to help inform the development of the Unitary Plan by providing insights into the views of our Auckland members on transport, intensification and housing affordability. We emphasised in the submission that the survey provided a snapshot into how our members viewed “big ticket” items like the Central Rail Link and an additional Waitamata Harbour Crossing as well as their expectations and assumptions for funding these projects. Furthermore, the survey drew a number of conclusions about intensification and housing affordability that the submission stressed. While these two issues are outside the work of the AA, they do have an impact on the development of a safe and reliable multi-modal transport network.
Download the Unitary Plan Submission 27 February 2014
Auckland Council draft Annual Plan 2014/2015
Auckland Council sought public consultation on their draft Annual Plan for 2014/2015. The AA’s submission focussed on the $1.9 billion intended investment in transport capital infrastructure and the associated operating expenditure. Overall, the AA was pleased to see Auckland Council planning to invest nearly $900 million into transport capital projects. However, we did emphasise our concerns that Auckland Council was lacking strategic clarity around the planned investment. The AA also supported the $1 billion investment into operating expenditure. Lastly, we were supportive about the emphasis that Auckland Council placed on improving safety in the transport system.
Download the Annual Plan submission-24 February 2014
RUC Administration and Vehicle Certification Fees review
NZTA are proposing changes to RUC admin fees and various vehicle certification fees to better reflect costs. In most cases, the cost of purchasing RUC licences, including via the internet, will fall. The AA supports the changes but would also like to see NZTA introduce a separate surcharge for credit card fees instead of amortising and recovering the cost in the admin fee. We also oppose proposals to introduce a new fee for applications for exemptions from vehicle-related Land Transport Rules due to a lack of data and analysis to justify imposing a minimum $160 fee for some 4,600 vehicle owners a year.
Download the RUC Administration & Vehicle Certification Fees submission - 11 February 2014
Land Transport Amendment Bill 2013
This Bill proposes to lower the adult legal alcohol limit from 400 to 250 micrograms of alcohol per litre of breath (and from 80 to 50 milligrams of alcohol per 100 millilitres of blood). The AA supports the proposed lower drink driving limit and the $200 fine and 50 demerits penalty for driving between the new and current limit. The AA does not believe however that the lower limit will significantly reduce serious and repeat drink driving. Therefore we also called for:
- mandatory alcohol interlocks for serious and repeat offenders to be installed in vehicles immediately
- serious and repeat drink drivers to be assessed for alcohol issues and have rehabilitative treatment included in their sentence
- net revenue from the new $200 infringement fine to be used to fund more alcohol interlocks, alcohol assessment and rehabilitation
Download the Land Transport Amendment Bill - 11 February 2014
Intelligent Transport Systems Action Plan
The Ministry of Transport has drafted an Intelligent Transport Systems (ITS) Action Plan that takes a multimodal multi-agency approach to the introduction of ITS in New Zealand over the next four years. ITS is more of an umbrella concept than a specific product or proposal. ITS refers to the embedding of computer and communications technology into vehicles and roads, and the use of it by drivers and passengers. ITS is still very much in the early stages of implementation by technology manufacturers and infrastructure providers. The AA’s submission recommends that the action plan begins by defining its objectives and the principles by which ITS will operate in New Zealand.
Download the Intelligent Transport Systems Action Plan submission - 17 January 2014