2023 AA submissions to Government and other agencies

Submission on Draft Government Policy Statement (GPS) on Land Transport 2024

September 2023

The AA’s submission on the draft Government Policy Statement (GPS) on Land Transport 2024 welcomed making maintenance and resilience strategic priorities for investment. We consider these are the two biggest current challenges currently facing the transport system and we were pleased to see they closely match the AA’s two top election calls – “revive essential road maintenance” and “make the road network resilient”. For the same reason, we supported making “maintaining and operating” the transport system the funding priority for GPS 2024.

In our submission, we recommended a change be made to the sustainable urban and regional development strategic investment priority to include the importance of improving connections between and within regions alongside the current focus on towns and cities.

We supported including the Strategic Investment Programme of major projects in GPS 2024 to help guide future investment alongside other priorities and demands for transport funding. We recommended that the final GPS provide a realistic picture about the extent to which progress under the Strategic Investment Programme will be able to be advanced within available funding under the 2024-27 National Land Transport Programme.

We welcomed the substantial funding increase proposed for land transport investment under draft GPS 2024 and noted that significant more investment in road maintenance is vital to catch-up on the backlog of deferred work, start to turnaround the unacceptable state of our road networks and respond to very strong public sentiment that this problem needs to be fixed. We recommended the minimal level of funding available for maintaining state highway and local roads between 2024 and 2027 be increased by $1 billion (19%) to ensure sufficient funding to undertake critical renewals work.

We noted the significant additional funding for state highway improvements but commented that it is unclear how much of this is actually extra funding and how much is just reallocated existing funding for state highway improvements from elsewhere.

We considered that the proposed overall mix of funding under draft GPS 2024 strikes a reasonable balance between motorists’ and general taxpayers’ revenue in line with the priorities for investment. We recommended that the final GPS 2024 state that National Land Transport Fund (NLTF) debt will be reviewed before GPS 2027 to ensure it is not compromising the ability to fund land transport priorities nor adversely affecting the long-term financial sustainability of the NLTF.

We noted that motorists are currently paying approximately $1 billion a year at the pump in Emissions Trading Scheme (ETS) charges. We commented that one of the AA’s Election Calls is that this revenue be targeted to initiatives that will most effectively reduce transport emissions in line with the government’s climate change commitments. We recommended the allocation of ETS transport revenue in GPS 2024 be based on strong evidence of the initiatives that will most effectively reduce transport emissions.

Download the AA's submission on the Draft GPS 2024

Submission on Katoa, Ka Ora, Auckland Transport’s draft speed management plan 2024-27

September 2023

The AA’s submission on Katoa, Ka Ora, Auckland Transport’s draft speed management plan 2024-27, outlines our recognition of the importance of speed management to improve road safety alongside our firm belief that there needs to be consensus amongst the public that speed limits are appropriate for the roads to which they apply. It supports the use of variable speed limits around schools to bring down speeds at school start and finish times. It also urges Auckland Transport to undertake further work to understand how the community feels about different speed limit proposals, and where support is low, explore the reasons for this and seek to address them. It calls for road surface markings, alongside signage, to communicate speed limits to motorists, and signposting of speed cameras to maximise compliance.  

Download the AA's submission on Katoa, Ka Ora - AT draft speed management plan 2024-27

Submission on the Land Transport Rule: Traffic Control Devices (Bilingual signs) Amendment 2023

June 2023

Traffic signs are distinct from general signage and have unique requirements – including that travel speeds mean transport users have briefer windows to observe, interpret and correctly act on the information provided by the signs. 

The focus of our submission is on the safe introduction of bilingual traffic signage and we consider there are some safety issues that need addressing in sign design before they are finalised for a safe introduction. 

In particular we recommend:

  • user testing is required on proposed signs before they are implemented in the roading environment and bilingual advisory signs should be implemented and evaluated before warning and regulatory signage
  • the reconsideration of the ‘one series up’ method to differentiate the two languages as it is not effective 
  • the lines of text on the proposed signs should follow international best practice of a maximum of four lines of text
  • sign placement should be revisited when installing new traffic signs.

Download the AA's submission on the Land Transport Rule: Traffic Control Devices (Bilingual signs) Amendment 2023

Submission on the Climate Change Commission's Draft Second Emissions Reduction Plan

June 2023

The AA's submission to the Climate Change Commission on its advice for NZ's second Emissions Reduction Plan is largely fact based.  There are three main parts:

  1. A summary of the AA’s latest Member survey on climate change issues (May 2023);
  2. References to research by other parties;
  3. Analysis of potential benefits of working from home and the importance of not making private vehicle emissions worse through conditions that make them run in fuel inefficient ways.


(1) Findings from an AA Member survey

The overall findings of our third AA Member survey on climate change issues found that unlike the previous two surveys (in 2017 and 2020), Member enthusiasm for shouldering climate costs has been reduced by the effects of the cost-of-living crisis.

Members remain supporters of environmentalism, and are concerned about climate change, but their ability to absorb new price increases through the Emissions Trading Scheme is much less than in previous surveys, averaging $11 per month.  This ranges between those who are well off and committed who say they could part with $24 per month on average and those at the other end of the spectrum who would find $5 a month difficult. This should provide the Climate Change Commission with information for sensitivity testing of responses to ETS prices.

Another finding from our AA Member survey is the low credibility climate change action has with AA Members, with most people feeling dubious that NZ (or the world in general) will meet its targets, or that the targets set in the first Emissions Reduction Plan for reducing car-based transport are feasible. Certainly, aside from improving public transport, any climate change policies which make parking, or use of cars more difficult or expensive, were not viewed as effective by many people.

(2) Research comparing NZ transport emissions with overseas examples

Research referenced by the AA reinforces the view that the first Emissions Reduction Plan target of reducing national kilometers travelled per year by 20% is not practical. The research points out that while New Zealanders make many short trips, collectively these don’t amount to a very significant share of total emissions from transport. It is the longer trips which count the most, but which are also the most difficult to substitute. The AA submission also references intriguing international research which shows that the carbon footprint of Auckland is significantly better than Amsterdam, Copenhagen or a number of other European cities for total emissions. This is probably due to the fact that these cities rely on gas for heating, and that private land transport only actually accounts for around 12% of New Zealand’s total greenhouse gas emissions (including agricultural methane) or 25% of our carbon emissions.

(3) Potential benefits of working from home and other congestion reduction initiatives

The final point the AA submission makes is based on Tomtom data, which compares not only congestion but also carbon emissions between the world’s cities. The Tomtom data shows that congestion has a role to play in increasing transport emissions and shows that, were Auckland as poor a performer as Dublin, New Zealand’s emissions would be much worse. That said, Wellington’s emissions per vehicle are very high by world standards already, while Christchurch’s are reasonably good. The AA makes the point that if Auckland achieved Christchurch’s per vehicle emissions it would be the equivalent of 120,000 Aucklanders foregoing their cars for bicycles every day of the year. To that end, the AA points out that Tomtom data also shows that working from home can have a significant double benefit in both removing emissions directly and removing emissions indirectly by reducing congestion. The conclusion is that we should not solely focus on reducing emissions via alternatives to the car, but also investigate changes that enable more efficient car use, which can come from small changes (like encouraging more working from home and other actions that reduce peak congestion) but impact how millions of cars are used by New Zealanders every day so collectively could offer significant transport emissions reduction.

Download the AA submission on the Climate Change Commission's Draft Second Emissions Reduction Plan

Submission on the Land Transport Rule: Vehicle Exhaust Emissions 2007

June 2023

In general, the NZAA is supportive of the introduction of more stringent exhaust emission standards for new and used vehicles. The proposed standards will lead to a significant long-term reduction in nitrogen oxides, exhaust particulates and carbon monoxide in both the light and heavy fleet. It also will prevent older used vehicles from being imported into New Zealand, which has additional safety benefits.

The proposals will:

  • Rapidly shift the minimum requirement on used imports from Euro 4/IV to Euro 5/V.
  • Phase in the shift from Euro 5/V to Euro 6/VI on used imports and new vehicles in several steps, between late 2024 and the start of 2028.
  • Introduce an emissions requirement for mopeds and motorcycles.

The AA does however believe that the Euro 6d standards for new vehicles need to be introduced at the same time as they will be in Australia to avoid additional costs for NZ buyers. The AA has also highlighted that the proposed standards for motorcycles could have negative consequences on the niche industry here that restores classic motorcycles if it is not carefully thought through.

Download the AA’s submission on the Land Transport Rule: Vehicle Exhaust Emissions 2007

Justice Committee - Land Transport (Road Safety) Amendment Bill

June 2023

This submission concentrates on three matters the AA believes if addressed will result in better safety outcomes which is a main objective of this bill.

The NZAA has concerns about the draft wording of clause 10 that seeks to amend S96 of the Land Transport Act 1998. Some wording is confusing, open to interpretation and in its current form could lead to unintended perverse outcomes.

The NZAA supports the introduction of point-to-point average speed cameras to reduce speeding. We believe the cameras will be more effective if they are used in conjunctions with warning signs alerting drivers to their presence as they approach them.

Our view is that warning drivers, so they have every opportunity to modify their behaviour immediately would mean these devices truly achieve their purpose – that being to increase safety on a particular section of road.

The NZAA also has concerns about the release process for vehicles that have been impounded which currently allows them to be driven away from the storage yard and onto the road regardless of their condition. The NZAA would like to see more rigorous requirements introduced that would prevent this from occurring and ensure that only road-worthy vehicles are permitted to be driven away after being impounded.

Download the AA submission on the Land Transport (Road Safety) Amendment Bill

Ministry of Transport - Charging Our Future consultation

May 2023

The AA submitted on the Ministry of Transport discussion paper, Charging Our Future, which proposes a long-term strategic vision for Aotearoa New Zealand’s national electric vehicle charging infrastructure.

The AA has long been calling for greater investment in both public and private electric vehicle charging infrastructure in our submissions on the annual EECA levy funding.

The AA supports large scale investment in public and private electric vehicle (EV) smart chargers that are subject to regulated standards and supported by time-of-use pricing and demand response capability.

The AA believes that greater investment in EV charging infrastructure will accelerate the uptake of low/zero emission transport options. We believe additional funding should come from a mixture of sources including appropriated funds, Electricity Industry Levy, and hypothecated Emission Trading Scheme revenue.

Download the AA submission on Charging Our Future

Submission on the Waitematā Harbour Connections consultation

May 2023 

The AA’s submission highlighted the challenges in drawing conclusions with significant information gaps, but concluded that based on the available information, the optimal way forward would be a new road connection in a tunnel between the lower North Shore and the central motorway junction, and a light rail, walking and cycling connection on a bridge between Wynyard Quarter and just north of the northern-end of the Harbour Bridge (ie. Waka Kotahi’s ‘Option 5’).

The AA believes a road tunnel would provide the best outcomes for general traffic, by separating trips to/from the city centre with those continuing on the motorway network. It is also the only option that would address the significant resilience problem with the Harbour Bridge’s ability to operate in high winds. And it was the only one to avoid unacceptable levels of disruption when the Northern Motorway is raised to protect it against flooding and sea level rise, because much of the traffic using the corridor could be shifted into the new tunnel before these works are carried out.

The AA’s preferred bridge alignment for light rail, walking and cycling is the most direct and most efficient route, with the shortest travel times – this will be crucial to achieve mode shift.

The AA’s submission also pointed out that it needs to be made clear to the public that the project will not address congestion. There is likely to be widespread expectation that the project will have a significant impact on congestion. Cross-harbour congestion is generally the result of congestion on the motorway connections either side of the Bridge, but given the project is only concerned with a cross-harbour connection, it won’t alleviate congestion.

Download the AA’s submission on Waka Kotahi’s Waitematā Harbour Connections consultation

New! Our navigation has changed.

Use this button to access the site content.

 |  Learn more