2022 AA submissions to Government and other agencies

Reshaping Streets regulatory changes

October 2022

With the government having set key goals to around higher density living, public health, and emissions reduction, Waka Kotahi has proposed a range of powers that would enable Road Controlling Authorities (RCAs) to support these outcomes. It suggests regulatory changes allowing RCAs to more nimbly modify streetscapes to support public transport, and active transport modes. While the AA considered some proposals to be pragmatic, its had significant concerns around the degree of power that would be given to RCAs to act without a clear public mandate and the lack of clarity around some of the proposals.

Download the AA submission on Reshaping Streets

Improving the performance of electric vehicle chargers

August 2022

The electrification of our light vehicle fleet will bring many benefits to society and the environment. Smart charging can make charging EVs significantly cheaper and safer for EV owners and will help to manage increasing electricity demand. The AA supports the adoption of EV smart chargers that are subject to regulated standards and supported by time-of-use pricing and demand response capability. Further, the AA encourages an Emissions Trading Scheme-funded largescale investment in private and public EV charger infrastructure via the Low Emissions Transport Fund. Such an initiative could be co-funded by electricity suppliers with a contribution from the householder. This model has been successfully used by EECA in its Warm-Up New Zealand home insulation programme.

Download the AA submission on EECA's consultation: "Improving the performance of electric vehicle chargers"

Auckland's Draft Parking Strategy

May 2022

Auckland’s draft Parking Strategy focuses on:

  • reallocating on-street parking space on the city’s busiest roads to enable more people to be moved by all modes
  • increased use of parking charges and other restrictions across more of Auckland’s urban area to encourage a shift to public transport, walking and cycling

The AA’s submission supports some aspects of the draft Strategy but also expressed concern that the wrong changes in the wrong places may result in perverse consequences for access, congestion, and emissions. The submission sets out the changes the AA considers needs to be made to ensure the final Strategy achieves the most critical objectives of improving access and moving more people, more sustainably.

Download the AA submission on Auckland's Draft Parking Strategy

Review of the Road User Charges System

April 2022

Te huringa taraiwa: Te arotake I te punaha utu kaiwhakamahi rori | Driving Change: Reviewing the Road User Charges System explores proposals in three areas:

  • Using the RUC Act to do more than recover road costs
  • Improving the RUC system for end users
  • Technical amendments to the RUC Act

The AA has only addressed questions considered to be of most relevant to our Members.

The AA strongly supports the continued policy of using RUC as a mechanism to allocate charges for the use of our roads based on the costs each vehicle causes. The simplicity of the scheme is a reason it has been recognised as world leading. Therefore, the AA is opposed to proposals that would damage this simplicity – for example by adding in externalities that in most cases are already subject to some other policy intervention. Accident costs and greenhouse gas (GHG) emission costs are two clear examples of where drivers are already paying for them through other fees.

The AA is strongly opposed to the introduction of any additional charges which cannot be directly and accurately linked to the costs of individual vehicle use as this is inconsistent with the founding principles of the RUC system.

The AA does support improving the RUC system for easier use and to attain administrative cost savings. It welcomes the proposals to remove the requirement to physically display RUC and registration labels on vehicle windscreens.

Download the AA submission on the Review of the Road User Charges System

Proposed changes to land transport regulatory fees, charges and funding – consultation document

March 2022

Proposed fees and charges are set at a level so that Waka Kotahi can repay the loan it took out in 2018 to address its regulatory failures. The NZAA strongly opposes this approach. The other main concern the NZAA has with the proposals is the use of FED and RUC revenue to fund Waka Kotahi’s regulatory work, given the significant pressure the NLTF is under, and the opportunity cost of redirecting further revenue.

The AA generally supports the proposed fees for driver licencing (provided the loan repayment component is removed), including the policy intent behind “free” resits to encourage people to move through the licencing system. However, we have identified three potential unintended consequence of these changes – less preparation and training being undertaken, more “no shows” for tests, and increasing driving instructor shortages – and propose measures to mitigate these adverse consequences.

Download the AA submission on proposed changes to land transport regulatory fees, charges and funding

Penlink tolling proposal

February 2022

The AA opposed Waka Kotahi’s Penlink tolling proposal. The proposal involved tolling Penlink to pay for maintenance and operation of the road and signalled future new State Highways could also be tolled to fund these activities. The National Land Transport Fund is a user pays system and the AA’s strong view is that maintenance must be one of the first calls on these funds. Waka Kotahi also proposed tolling Penlink to address ‘travel time reliability’. In our submission, we noted that Waka Kotahi’s Tolling Policy states that the Land Transport Management Act does not provide for tolling for demand management or congestion management purposes. Further, we noted that congestion at the western end of Penlink appears to be largely due to growth in the surrounding area rather than demand for travel on Penlink itself, and should be addressed through the earlier provision of a full diamond motorway interchange.

Download the AA submission on Penlink Tolling Proposal

Auckland Transport’s Discussion Document ‘Parking in Auckland’

January 2022

‘Parking in Auckland’ sets out Auckland Transport’s proposed approach to managing on-street parking in Auckland. It signals plans to prioritise the movement of people over parking on roads on the ‘Strategic Transport Network’; to reduce on-street parking and increase parking charges and restrictions to reduce private vehicle use in major centres (such as the CBD and Albany); to increase charges and restrictions to reduce private vehicle use for commuter trips in other centres with good access to public transport, and; respond to parking issues as they arise in all other areas. The AA’s submission supports the removal of parking where needed to maximise the movement of people along a corridor, and signalled comfort with increased restrictions on parking in major centres within walking distance of rapid transit. However we also said that in other areas, the approach signalled in the discussion document appears out of step with Auckland’s land use and trip patterns, the ability of our current public transport system to effectively meet these needs, and a realistic role for active modes. We noted that pragmatic decisions will be needed to attract community buy-in.

Download the AA submission on 'Parking in Auckland'

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