2025 AA submissions to Government and other agencies

Submission on the Land Transport (Time of Use Charging) Amendment Bill

April 2025

The Land Transport (Time of Use Charging) Amendment Bill proposes a framework for the implementation of time of use charging – directly charging motorists for using roads at busy times.

Time of use charging is the only realistic tool capable of addressing congestion in our biggest and fastest growing cities. But it’s by no means an easy or straightforward option, and it’s far from clear if it can be made to work in cities like ours which have literally developed around the mobility that cars provide and as a result where most people rely on cars to meet their travel needs.

The AA’s view is that time of use charging should be seriously considered and investigated, but it’s not yet clear to us whether it should be implemented here. For this reason, we support legislation to enable time of use charging, and our submission sets out what changes we think are needed to help make it work in the New Zealand context.

Our view on whether it should be implemented in any New Zealand city will ultimately depend on the content of any proposal that’s put forward, which won’t be until sometime after the legislation has passed. We will carefully scrutinise any proposals that are developed and will be particularly focused on the basis for proposing charges on specific roads, what the charges would be and when they would apply, what travel times savings people will get in return for paying the charge, whether there are realistic public transport alternatives, and how the proposal will impact traffic on nearby roads.

> Read the AA's submission on the Land Transport (Time of Use Charging) Amendment Bill

Vehicle Standards Compliance Amendment 2025 Consultation

April 2025

The AA fully supports the proposal to extend the period for Warrant of Fitness (WoF) tests for vintage and veteran vehicles from 6 months to 12 months. We believe this will not compromise road safety while saving the owners of these vehicles unnecessary expense.

We support the extension of the period for Certificate of Fitness (CoF) tests for privately owned motorhomes, with some reservations. We are concerned about motorhomes that are parked for sustained periods in harsh environments that could cause corrosion to the brakes or critical safety structures. We recommend that an evaluation of CoF test failures be made after three years to determine if the failure rates have increased.

We also recommend that the Ministry of Transport and NZTA begin exploration of moving the WoF and CoF regimes to one that is based on distant travelled. We believe that distance travelled by a vehicle is a better indicator of wear and tear than the age of a vehicle. A distance-based system would also align with the proposed changes to the Road User Charges regime that is targeted to commence in 2027.

> Read the AA's submission on NZTA's Vehicle Standards Compliance Amendment 2025 Consultation

EECA 2025-2026 Levy Consultation

January 2025

The AA’s submission relates to the funding from the Petroleum or Engine Fuel Monitoring (PEFM) Levy only.

The AA is pleased with new, additional  funding to encourage the rollout of the EV charging network ahead of EV vehicle adoption rates. We strongly support funding of public EV chargers in remote areas or locations with seasonal population variances.

We also continue to support other initiatives encouraging transition to cleaner transport options across the whole vehicle sector, and the provision of high-quality information to help customers make vehicle choices.

We cannot however see a clear business case to increase the PEFM levy from $13.5m to the proposed $14.62m, an increase of 8.3%. This increase is above the rate of inflation.

We are also concerned about the tenuous link between the PEFM and some demonstration projects that were funded in the past and appear to be proposed for future funding. 

> Read the AA's submission on the EECA 2025-06 levy funding proposal