2015 AA submissions to Government and other agencies
ACC 2016-17 motor vehicle levy consultation
ACC’s annual levy consultation proposes a 33% reduction in average motor vehicle levies, and seeks feedback on whether all of this should on the annual rego or some of it via a 1.2 cent per litre reduction in petrol tax, along with changes to the methodology used to risk-rate cars. The AA recommended no change in petrol tax as the reduction is too small to be noticeable, and we supported a number of changes to the risk-rating methodology, including giving more weight to NCAP ratings. ACC also sought feedback on adding some ACC to RUC, which the AA supports as it would mean diesel licence fees would be the same as equivalent petrol vehicles, and we also recommended changes to the funding policy which means levies could unchanged over a 2-3 year period rather than have small fluctuations each year.
Download the AA submission - 30 October 2015
Engine Fuel Specifications Regulations
The Ministry of Innovation, Business and Innovation are proposing to amend NZ’s specifications for fuel quality. Amongst the proposals were reducing sulphur content in petrol from 50 parts per million (ppm) to 10ppm, which the AA supports but with a deferred timetable that ensures security of supply. The AA opposed the increase in biodiesel limits to 7% as most engine manufactures only endorse up to 5%, while we did not support permitting the use of methanol until more analysis on compatibility is undertaken.
Download the AA submission - 30 October 2015
Z Energy purchase of Chevron NZ
Z Energy is seeking Commerce Commission approval to purchase Chevron NZ which includes Chevrons terminal infrastructure and supply contracts to Caltex service stations, but not the actual service stations which are already independently-owned. The AA’s submission comments on a number of issues that we think currently constrain competition, potential risks for reducing competition under the merger, and suggestions on how these risks might be mitigated.
Download the AA submission - 9 September 2015
Petroleum or Engine Fuel Monitoring levy
The Ministry of Business Innovation & Employment sought feedback on how the levy to cover the cost of NZ’s 90-day oil stockholding requirements be applied. The NZAA supported it applying to petrol, diesel and biofuels, and for the levy rate to be reviewed every 3 years.
Download the AA submission - 24 August 2015
Omnibus Amendment 2015
The annual Omnibus Rule amendment proposes a number of minor changes to various Land Transport Rules, including the Traffic Control Devices (TCD) Rule and Vehicle Lighting Rule. In particular, the AA opposed a change to the TCD that would allow road controlling authorities to install non-regulatory warning or advisory road markings. We suggested this could lead to confusing or distracting markings. The AA also opposed a suggestion to permit some reserved parking spaces to be painted white instead of yellow as currently required, as this may confuse motorists and result in more infringements.
Download the AA submission - 10 July 2015
Accident Compensation (Financial Responsibility and Transparency) Amendment Bill
The primary purpose of this Bill is for the Government to set the funding policy for how ACC calculates its annual levies. Previously the ACC Board set the funding policy. The Bill will also enable the Government to bring forward the date from which residual levies are fully-funded so that ACC does not over-collect. The AA supports the overall objectives of the Bill, but suggested the funding policy statement should have a fixed term, and permit ACC to consult on levies for more than one year at a time. We also suggested the Bill should require ACC to report on the impact that variations in the funding policy statement would have on the long-term sustainability of the scheme for each Account.
Download the AA submission - 2 July 2015
Auckland Transport Regional Public Transport Plan Amendments
Auckland Transport has sought public submissions on amending the 2013 Regional Public Transport Plan. The amendments seek to include changes to the public transport fare structure, include light rail as a possible future transport option and the focus on improving the existing ferry services and infrastructure.
The NZAA supports the moves to simplify the public transport fare structure by charging public transport users based on the length of their journey and not the mode of transport that they use. We also support Auckland Transport focussing on improving existing ferry services and infrastructure before looking at expanding the ferry network. We have concerns about whether light rail is a serious option considering the proposed land zoning provisions along the suggested routes.
Notwithstanding our concerns about light rail, the NZAA generally supports the proposed amendments to the Regional Public Transport Plan.
Download the AA Submission-3 June 2015
Auckland Council Long Term Plan and Auckland Transport Regional Land Transport Plan
Auckland Council and Auckland Transport have sought public submissions on their 10-year strategic documents, the Long Term Plan and Regional Land Transport Plan.
In developing our submission, we undertook the largest ever Auckland Member survey and established the Auckland Panel, which provided additional qualitative data. We placed a great deal of emphasis on the findings from the surveys, so they also form the basis of our submission.
For the AA and our Auckland Members the Basic Transport Network, with its smaller funding envelope for transport capital investments and project delays, is a non-starter. However, we do not support the Auckland Plan Transport Network as an alternative. We believe the Auckland Plan Transport Network delivers limited network benefits, particularly in terms of congestion relief, and the feedback of our Auckland Members clearly suggests that it will struggle to generate meaningful public support.
In our submission, we proposed a next steps approach for Auckland Council. One that focuses on developing a stronger alignment between Central and Local Government, an independent strategic review of the Auckland transport programme and considers new consultation mechanisms so that more Aucklanders feel comfortable that their say is being heard.
Download the AA submission-16 March 2015
Ordering Vehicles off the Road Notice
In January the NZ Transport Agency issued a short consultation document on changing the Land Transport (ordering a Vehicle off the Road Notice). This is also known as the ‘pink’ or ‘green’ stickers which the police can issue for unroadworthy vehicles. The NZTA are reviewing the notice because of changes to the Certificate of Fitness system, and NZTA concerns that these changes (which are expanding the range of CoF providers) may mean that the existing inspecting agents which are only permitted to remove stickers (AA, VTNZ, VINZ) might withdraw services from less populated areas, meaning it might be harder for vehicle owners to find an inspection organisation able to remove a sticker. At the same time, NZTA propose tougher penalties to mitigate an increased likelihood of “incorrect” removal of stickers by the expanded pool of inspectors. However, the AA’s submission suggested that the NZTA had not made a case that the notice needed to be reviewed at this time. Instead, we suggested the impact of changes to the CoF service delivery model needed to be monitored to see if these concerns are realised. If they are, we suggested that rather than permitting any inspection agent anywhere in NZ to remove stickers, that a local inspection agent be authorised to do so, on a case-by-case basis, but that otherwise the existing agents remain the only organisations permitted to remove green or pink stickers.