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Summary of submissions

Comments on specific interventions

Open road speed management

This section covers comments on open-road speed management and the safety interventions associated with it. The intervention to attract most comment was the proposal to lower the open road speed limit to 90 km/h. Comments were also recorded on speed cameras, demerit points for speed camera infringements and enhanced surveillance.

90 km|h speed limit

Of the many responses on this subject, only 11% supported this intervention. Around 8% said maybe, while just over 80% opposed it.

One submission commented that the lack of support for the 90 km/h speed limit underlined the immature and irresponsible attitude of many of our drivers and that, in developing the strategy we would need to consider safety and economics, not popularity. Of those who supported the introduction of a 90 km/h open-road speed limit, several felt that an even lower limit of 80 km/h was appropriate. Waitakere City Council and several individuals supported a lower open-road limit but retaining 100 km/h on motorways. The Cycling Advocates Network pointed out that there were non-safety benefits to a lower speed limit, such as energy savings. Some respondents, including TRAFINZ and the Wellington City Council, saw a lower limit as an interim measure until safer roads could be built. One respondent considered that enforcement was working well in all areas except speed, that new options would be necessary, and that upgrading the roads was not an option because it would only encourage more speed.

There was considerable support for a wider range of speed limits, depending on the physical characteristics of the road, and for variable speed limits that took account of weather or other temporarily adverse conditions. The Insurance Council of New Zealand pointed out that any measure that the public did not support was not a practical solution. It supported lower speeds for known blackspots, and variable speed limits that could be changed to take account of the conditions. Where crashes tended to occur in bad weather, lower limits could be set when the road was wet (as in France) and these should be strictly enforced. It was not appropriate to leave such decisions to driver discretion. The Ministry of Agriculture and Forestry also called for speed limits that reflected road conditions rather than a blanket speed reduction. Another submission mentioned that unsealed roads should have lower speed limits. The Ashburton District Council also favoured giving road-controlling authorities the scope to vary speed limits to suit local conditions, within an 80-110 km/h range.

One submission that partially supported lowering the speed limit commented that the current limit was an excellent compromise but was not enforced. Anything over that limit should be an offence and, with strict enforcement, drivers would soon learn. However, the same respondent considered that most rural feeder roads were not safe at 100 km/h and that they should have a limit of 80-90 km/h. Another wanted more maximum speed areas, with 100 km/h on motorways only, and 80 km/h on all other roads except unsealed roads which should have a 70 km/h limit. Speed limits in dangerous areas should be compulsory rather than advisory.

Another submission considered that a lower limit would be acceptable as long as it applied to all vehicles, including those towing other vehicles, and if the need to exceed the limit by at least 20 km/h when overtaking was recognised.

Many respondents who opposed the lower speed limit considered that slower speeds would result in more driver impatience, boredom, frustration and risk taking, resulting in more tailgating and head-on crashes. Many felt that frustration and impatience were already a serious issue, and that enforcement should target slow drivers who did not pull over or drove in the outside lane. Some considered that slow drivers were more dangerous than fast drivers. One individual submitted that minimum and maximum speeds should be enforced in fast lanes. On the other hand, another said that the statements made by some people that slow drivers were the cause of road deaths were ludicrous, and that only a change in road-user behaviour would correct some drivers' need to pass everything in front of them.

One respondent accepted that a lower speed limit would reduce head-on crashes, but considered it too draconian a measure. Another stated that common sense should prevail rather than government dictates.

Some respondents were sceptical that speed was a cause of crashes, and considered that it was more a matter of educating drivers to be able to handle speed. One individual thought that a lower limit could only be justified if there was clear evidence that a significant proportion of crashes involved cars travelling at 100-110 km/h, and that their speed was a factor. A general decrease in the limit would not deal with the minority of drivers who habitually exceeded the limit — greater enforcement was the only way to deal with these drivers. The number of roadside crosses on bends indicated that excessive speed on bends was the problem. This should be targeted with enforcement rather than using only sites where it was easy to operate speed cameras. Another submission asked, "If speed is so dangerous, why aren't all racing drivers dead?"

Other individuals commented that modern cars were very safe and easy to drive at high speeds, and that keeping to a lower limit would be distracting. (i.e. always having to check the speedometer). The Independent Motor Vehicle Dealers' Association submitted that modern vehicles did not cruise easily at 90 km/h.

Several submissions supported higher speed limits and considered that divided motorways in particular should have limits of 110 or 120 km/h. Several also supported no speed limits at all. One submission commented that a re-worked economic analysis would show a net benefit from an increased open-road speed limit of 110 km/h on many roads. Another supported a limit of 115 km/h.

The ACC commented that a lower limit would be extremely unpopular, and instead advocated reducing tolerances of the current limit to 10% rather than 10 km/h. It argued for a national framework to ensure consistency throughout New Zealand, while allowing local authorities the flexibility to set appropriate speed limits for local conditions.

Two submissions referred to the adverse effects of lower speed limits in other countries. One included an article about the repeal of the 55-mph speed limit in the USA, arguing that road deaths decreased as speed limits went up. The other referred to a recent reduction of the speed limit in Iceland by 20 km/h, to which he attributed the increase of its road toll by 20%. One respondent commented that, when New Zealand had an 80 km/h speed limit and 2,500 dedicated traffic personnel, it had the highest number of road casualties in history. Another referred to Germany, which had no speed limit on the autobahn and a lower road toll than New Zealand.

Many respondents supported more rigorous enforcement of the current limits rather than lowering the limit. One respondent commented that, whereas it was unusual to see police or speed cameras (on the Kapiti Coast), it should in fact be unusual to exceed the speed limit without being caught. Environment Southland suggested that enforcement should address the problem of speed creep. Others who advocated more enforcement of current limits were: Hutt Valley Health, Benchmark Building Supplies, New Zealand Labour Party (Cambridge Branch), Cashmere Driving School, Environment Southland, Kapiti Road Safety Consulting Group, Marlborough Health Promotion, Motorsport New Zealand, Road Safe Nelson Bays, Road Safety Community Group Marlborough, the Road Transport Forum, Tauranga and Western Bay of Plenty Road Safety Committee, Waimakariri Road Safety Co-ordinating Committee, and the Ashburton, Clutha, Kawerau, Manawatu, Stratford, Thames-Coromandel, Waikato and Whakatane District Councils.

The Otorohanga District Council called for a 2-year period for testing the effectiveness of the new highway patrols in enforcing the 100 km/h limit before a lower limit was considered.

Benchmark Building Supplies recommended continuing to channel resources into policing and educating drivers about the effectiveness of the current limit. The current advertisements should continue, supplemented by advice on how little travel time was saved by speeding on a given journey, and on the cost per minute saved of the existing fines.

Many also said that a blanket 90 km/h limit was unrealistic or arbitrary.

A number of respondents considered that there would be adverse economic effects of a lower speed limit in terms of travel times and increased transport costs, and some asked for an analysis of this before any decision was made. Respondents putting forward this view included: Environment Southland, Federated Farmers, Napier City Council, the Pavement and Bitumen Contractors' Association, and the New Plymouth, Otorohanga, South Taranaki, Southland, Waikato, Wairoa and Waitaki District Councils.

One submission considered that the cost of replacing all the 100-km/h road signs would be unacceptable.

More respondents favoured than opposed the other proposed open-road speed management measures of demerit points for speed camera offences and enhanced surveillance.

Demerit points for speed camera offences

Of the 77 respondents on demerit points for speed camera offences, 40 supported the proposal.

The ACC strongly advocated demerit points for speed camera offences, and pointed out that demerits should be accrued by all speeders irrespective of the method of detection. The Auckland Regional Council (ARC) and Roadsafe Auckland observed that research in Victoria had found that there was a significant increase in the time between second and third offences, as compared with that between first and second offences, if demerit points were accumulated. The ARC also stated that public support for speed cameras was quite high, even though people thought they were more likely to get tickets from camera surveillance than from police officers. The Invercargill City Council considered that this measure would create a level playing field.

The Cashmere Driving School suggested double demerit points during school holidays.

Another submission suggested demerit points on all road safety offences, and one demerit point for every kilometre in excess of the speed limit.

Some concern was expressed (by the Kawerau District Council and the Taranaki Regional Council) about the ability to assign demerit points to the vehicle's driver, and asked if this would this lead to excessive administration costs, and if it would be possible for the driver to falsely assign the demerit points to someone else.

The AA supported demerit points but believed they should be used for speeds in excess of 20 km/h over the limit because of the administration costs and in order to better target excessive speeds.

The Road Transport Forum submitted that applying demerit points to the current speed camera programme would do nothing to change the current perception of speed cameras as a revenue-gathering mechanism. The Westland and Whakatane District Councils also opposed demerit points for speed camera infringements.

Enhanced surveillance

About 82% of the respondents on enhanced surveillance supported it. The majority favoured a more visible police presence, and many supported having dedicated traffic police. The increased use of speed cameras and improved testing and measuring devices were also mentioned.

The ACC's view was that speed tolerances must be rigidly enforced if road safety was to improve in the short term. Federated Farmers praised the new highway patrol as a step in the right direction. Rodney District Council also applauded the introduction of the highway patrol, believing that the public perception of the likelihood of being caught must increase if there was to be significant progress on reducing speeds.

The Marlborough District Council wanted more enforcement on rural roads, where drivers tended to think they could get away with speeding. The South Taranaki District Council wanted rural intersections targeted for enhanced surveillance. The Otorohanga District Council believed that the need for surveillance would increase if the roads were improved, this would encourage people to speed.

The Invercargill City Council expressed concern that the Government had seen the need for dedicated traffic police, but was reducing funding for the police overall.

The Road Transport Forum suggested that, rather than penalising the average motorist, the individuals causing the major risk should be targeted. Another submission, which opposed enhanced surveillance, also recommended targeting recidivist drink drivers and 'louts with a bad attitude' instead of trapping the other 90% of motorists.

One submission commented that the police were heavy handed, with an emphasis on punishment rather than assistance and education. Hence they were regarded as revenue gatherers whereas they should emphasise prevention rather than punishment.

The Pavement and Bitumen Contractors' Association wanted to see the issue of road safety at road works sites included in the Strategy because the crash rate on these sites was three times the national average. Its particular concern was with speed enforcement at these sites and the associated safety issues.

The New Zealand Chartered Clubs commented that the Strategy lacked incentives for good drivers and contained merely punitive measures for bad drivers.

One person complained that the police closed roads for too long after a crash.

Speed cameras

Although this was not proposed as an option, 23 people commented on hidden speed cameras, of whom more than half said that they agreed with their use. Around a quarter were opposed to hidden speed cameras. Two respondents said that the Waikato hidden camera trial had not worked. Several said that the cameras needed to be visible as a deterrent.

In support of hidden speed cameras, one respondent said that the introduction of nation-wide and numerous hidden speed cameras would go a long way towards reducing the road toll. This view was supported by other respondents. The ACC advocated the national implementation of hidden speed cameras. The Selwyn and Banks Peninsula Road Safety Trust favoured covert sites for research even if they were politically unacceptable for operational use. It also supported the removal of all warning signs, and prosecution of drivers of all vehicle types, not just car drivers.

The Road Transport Forum stated that a review of the speed camera programme would illustrate its serious shortcomings and failure to target areas of risk. It maintained that the public believed speed cameras were being used simply to gather revenue. If both the location of cameras and the penalties were seen to be targeting offenders committing serious speeding offences, the initiative's credibility and effectiveness would rise. Rotorua Grey Power also considered that speed cameras served no purpose other than revenue gathering.

One respondent pointed out that privacy concerns about being photographed while breaking the law did not exist in other first world countries, and restrictions on the use of speed cameras were not in accordance with the "anytime, anywhere" philosophy.

Another suggested removing speed camera zones so the cameras could be used anywhere.

Other comments on open road speed management

The Automobile Association commented that, while the Strategy was proposing to manage speed by targeting a reduction in the mean speed, it believed that speed management should be targeted at those motorists travelling at excessive speeds. The AA supported the 10-km/h tolerance. It also urged that the government introduce, without further delay, the Speed Limit Setting Rule supporting variable speed limits.

Ross Vincent Consultant submitted that, if substandard lengths of road were posted with lower speed limits, the poor condition of these roads would become more obvious and the public would be more accepting of higher road-user costs to make the improvements.

TRAFINZ proposed a formula to be used in setting speed limits which would be linked to the social cost of individual roads. Doing this would allow the 2010 targets to be reached more easily or earlier, when combined with an ambitious engineering programme. TRAFINZ also supported consideration of a clear, understandable variable speed limit regime for different types of vehicle.

Waimakariri Road Safety Co-ordinating Committee wanted speedometer checks to be part of the WOF check. It also supported finalising the draft speed limit Rule, and suggested reviewing speed camera sites more often.

A number of submissions considered that there was a need to target heavy vehicles that tailgated other vehicles and exceeded speed limits. One submitted that logging trucks often sped around corners, another thought that priority should be given to reducing speed differentials between vehicles.

Other individual comments on open-road speed management favoured increased enforcement — for example, that high-technology options should be considered, or that vehicles should have speed limiters fitted. One person thought that speeding penalties should be comparable to those for drink driving.

Others considered that current enforcement was ineffective — for example, that the police should concentrate on traffic flow rather than speed, and that rigid enforcement of posted speed limits was not helpful but should target inappropriate speeds, whether too fast or too slow.

One respondent believed there should be regional speed limits because faster speeds were safe in the uncrowded South Island. Another considered that speed limits on motorways were just revenue-gathering measures.

A number of submissions commented that rural roads were often unsafe at 100 km/h, and one suggested that lower speeds on unsealed roads might reduce the number of tourist crashes.

Expanded construction

A total of 244 submissions commented on the expanded construction programme. The majority of these (71%) were in favour, 10% were opposed and 19% said 'maybe'.

There were a number of submissions that reflected a feeling that New Zealand had a poor standard of roads, commenting, for example, that road design was at about the level of Europe in the 1950s, with basic safety features ignored.

A number of submissions recognised that engineering improvements would go a long way to achieving the goal.

Several submissions gave specific examples of stretches of road that needed engineering work — three mentioned Transmission Gully. One said that Transmission Gully was an example of regional thinking, but that it should be a national project as it had greater implications than for Wellington alone. Similarly, the Rimutaka Hill Road was poor and dangerous, but should be treated as a national asset. Gully Alternatives Information Network said that engineering safety solutions should not be used as an opportunity to increase road capacity.

One submission recommended that a standardisation board be formed with an overview of the whole country, to ensure road-controlling authorities adhered to a set of standard road markings and signage throughout New Zealand. The submission also gave details of recommended improvements to signs and road markings.

The New Zealand Contractors' Federation fully supported the engineering option, and believed the public would be prepared to pay because of the other benefits from an improved road system. The Pavement and Bitumen Contractors' Association agreed with this view.

The Road Transport Forum supported increased funding for roads, for a range of economic, social, environmental and road safety reasons. It was firmly of the view that road safety would be significantly improved if roading expenditure was lifted to the level of that in comparable countries throughout the world.

Transit New Zealand commented in some detail about the potentially negative aspects of implementing an extensive programme of road engineering. There were several issues that might affect or delay the timing of roading projects. Firstly, if an extra $200 million per year was allocated to general roading improvements, this would cause tender prices to rise, reflecting the market saturation that would result. Secondly, there was already a shortfall of roading engineers in New Zealand, and it would take time to recruit additional resources. Thirdly, the development of engineering projects could take up to 6 years, particularly for large urban projects, because of the need to refer them to the Environment Court (which was already overloaded with resource consent hearings for roading projects).

In order to minimise these effects, there would need to be a staged introduction for general roading projects:

  • An early allocation of funds would have to be made for the cost of professional engineering services for general engineering projects. These costs were usually of the order of 12-15% for scheme development and design.
  • The increase in physical works contracts would have to be increased gradually to allow contractors time to increase their resources.
  • Flexibility in the funding programme would have to be allowed so projects could be deferred for a short period if the market became saturated.
  • Retrofitting of corridor deficiencies could be done, as these could be more rapidly developed and constructed with minimal impacts on resources, thereby achieving early results for the 2010 Strategy.

Transit believed that there were few remaining locations requiring blackspot work, and that there might be benefit in retrofitting parts of the state highway network with safety barriers, clear zones, bridge and shoulder widening, intersection lighting and removal of land drains, among other things. Transit submitted that the high number of loss-of-control crashes on straight sections of road raised the issue of whether the benefits of such retrofit projects were fully reflected in the Transfund Project Evaluation manual. A preliminary review of retrofit improvements indicated a safety B/C ratio of 1 to 2.5, for a total of up to $0.5 billion dollars of improvements, based on current evaluation criteria and construction costs. Tender prices for such projects could be extremely competitive as work could be carried out during the winter months, a traditionally quiet time for contractors. The low level of design required for many of the retrofitting projects was expected to result in professional engineering costs being about half of those for general roading projects.

The Southland District Council also questioned the availability of suitably-qualified engineers to undertake the work if the engineering option was chosen. It considered that, to be successful, engineering approaches would have to be quantum leaps rather than incremental.

Among those who did not agree with expanded road construction, some considered it to be too expensive, some doubted the benefits and thought it would promote speeding, and others thought the money would be better spent on education of drivers to enable them to cope with existing road conditions.

State highways

Many people supported construction of a four-lane highway with median barriers, either over the full length of SH1 or for parts of it (e.g. Auckland to Wellington, or Auckland to Christchurch). One respondent specified a dual carriageway with central barrier from Whangarei to Dunedin as a priority for SH1, and more passing lanes on 2-lane roads.

Increased provision of passing lanes was frequently mentioned (by around 50 respondents) as a very desirable improvement. More hard shoulders were also supported in several submissions. One said that roads were too narrow, and lacked shoulder space for cars to travel slowly. Another pointed out that in Sweden, all 2-lane highways had an extra tarsealed strip on each side for slow traffic, cycles, and emergencies. This was a much cheaper solution than four lanes, and very effective.

One respondent said that more median barriers were required, and not mere grass strips. All unsafe areas needed to be re-engineered by people with a good understanding of traffic principles and effective road design. Cheap options, such as erecting 80 km/h road signs in dangerous areas or building bridges without cycle lanes, should not be considered because they clearly did not work. Another respondent also supported median barriers, commenting that one could never control drivers who wanted to overtake, so should at least stop them from hitting oncoming traffic.

Upgrading of one-lane bridges was important for the Cycling Advocates Network, Marlborough Health Promotion, Opus International Consultants, Roadsafe Nelson Bays, Selwyn and Banks Peninsula Road Safety Trust, and the Ashburton, Kaikoura, and South Taranaki District Councils.

There was a widely-held view among respondents that New Zealand roads were substandard and poorly maintained. Many considered State Highway One to be dangerous. This was expressed in such comments as: "We are the only country in the western world that funnels such a huge volume of traffic up and down a two-lane death-trap like SH1."

The Automobile Association supported more four-lane highways, more passing lanes, a more forgiving roadside environment, and an enhanced blackspot programme.

The Gisborne District Council commented that there was very little latitude for correction when something went wrong, particularly on state highways with high traffic volumes and accident rates.

Marlborough Health Promotion considered that priorities should be set on the basis of standards rather than B/C ratios, and that minimum standards should include such items as passing lanes every 5-15 kms, elimination of one-lane bridges, minimum road widths, improved shoulder seal programmes, rumble strips, separation of high volume carriageways, and continuous guard rails.

MotorSport New Zealand put forward some safety suggestions, including run-off areas or gravel traps to capture vehicles safely when they were out of control, rather than the prevalent deep drainage ditches and uneven ground which made this very difficult. It also recommended pruning and clearing roadside vegetation to improve visibility.

Canterbury Highway 2000 suggested using plants to define road features and improve the highway environment, and asked for a strategy to achieve higher standards of environmental design and construction in the highway system.

Rural|urban

Auckland Regional Council and Beca Carter Hollings and Ferner both recommended developing an implementation strategy setting out a coherent plan for new roads and road improvements to decrease the road toll. The ARC also had concerns that urban areas might not get their share of road improvements because of the relatively greater disruption caused by road works in built up areas. It considered that safety-targeted roading improvements would therefore progress much faster in rural areas.

Beca also commented on the construction of multi-lane roads — they were concerned that crashes caused by lane changing and weaving did not feature in the strategy document, and suggested that these problems be targeted by having minimum distances between interchanges and avoiding on-ramps feeding into the fast lane.

The Christchurch Co-ordinating Committee on Road Safety commented that speed zoning on open roads, as is done in New South Wales, would tell drivers what kind of speed environment to expect. It considered that many of our roads were not engineered for 90 km/h and that there were places where safe speeds were well below this level. More reminder speed limit signs would be helpful. A number of other specific comments were also made.

Federated Farmers advocated a minimum standard for all roads, including rural roads. They believed that the higher rate of crashes on rural roads could not be attributed to lower driving standards. There were many instances where rural roads had an inherent safety risk but, because the cost of upgrading was considered too high in relation to the use of the road, the risk remained. They strongly urged that consistency of design be incorporated into New Zealand's roading system, and wanted changes in the way roads are funded. They remained unconvinced that expanded construction would achieve the predicted 18% reduction in social cost.

MAF Policy supported investment in minor open roads because they were integral to the primary production that contributes to New Zealand's exports. Rural network problems should be identified by listening to road users rather than by crash history. Anecdotal evidence from truck drivers indicated that there were areas where road design caused problems without actually resulting in crashes.

TRAFINZ said it make more sense for the road safety emphasis to be on improving rural state highways in the first instance.

The Ruapehu District Council had a high percentage of rural roads with low usage and considered that the blanket application of mandatory standards for edgeline treatment, centreline delineation and advisory speed signs would be unjustified. A minimum average number of road vehicles per day should be applied to such standards if they became mandatory.

One respondent asked for an alternative to the Auckland motorway to be built, using urban arterials.

Funding

Gisborne District Council asked for full central government funding or an increased subsidy, as it had very limited ability to raise funding locally.

The Marlborough District Council fully supported additional funding for roads, but wanted a bias towards safety because the current BC ratios only resulted in one-third of total projects giving safety benefits.

The Automobile Association submitted that engineering options needed to be carefully targeted to safety, and the funding should be ring-fenced to ensure the money was not diverted to other government purposes.

Tararua District Council said it was difficult to achieve the BC cut-off for safety projects when many crashes on its spread-out network were unreported. The Government should increase the allocation for minor safety projects by raising the percentage to 5% of basic maintenance programmes. The maximum value of $75,000 should be increased to $100,000 to enable geometric realignment works to be undertaken to ease sharp corners. The subsidy on major works should be increased to base rate plus 5%.

Rotorua District Council did not consider that a reduced BC ratio was required yet and that the current 3-4 range was appropriate.

Transfund New Zealand submitted that the current benefit/cost framework was still the best way to allocate resources for road safety — other methods of allocating resources might be counter-productive. Road safety benefits comprised a significant, and the largest single, proportion of total benefits arising from road construction projects. Replacing the benefit/cost ratio (BCR) approach with more visible, targeted safety investment programmes would have the risk of directing funds towards projects that actually achieved a lesser safety benefit for each dollar spent than integrated improvement projects that met the prevailing benefit/cost ratio. Transfund cautioned against the wholesale adoption of "retrofitting", "safety proofing", or "generic" programmes as there was a risk of wasting resources which could be better spent on an integrated road reconstruction project, for instance. However, certain types of "generic" safety projects could be identified and given a high priority, provided that appropriate analysis demonstrated their cost effectiveness in given localities or circumstances.

Transfund outlined further complementary measures that might be needed to refine the existing BCR methodology, and to better target investments towards areas of greatest risk and/or potential improvement.

The Invercargill City Council submitted that the national main road system fell well below the standard of that in the other developed countries mentioned in the document because funding has been restricted for years. Adequate funding would have assured that we had divided highways by now, but engineering alone was unaffordable in New Zealand.

Vulnerable road users

There were a large number of comments relating to the effects of expanded construction on vulnerable road users. Submissions from many vulnerable road user organisations emphasised safe-access issues (rather than simply reducing death and injury statistics), and the likelihood that, unless construction was planned and undertaken with vulnerable road users in mind, 'safety' would be achieved by excluding them from the roads. Opinions were mixed about the merits of separating cyclists and pedestrians from vehicles.

The Christchurch Co-ordinating Committee for Road Safety made some suggestions on behalf of vulnerable road users. It criticised the pedestrian and cyclist safety measures in the Overview, saying that it was not satisfactory to eliminate unsignalised pedestrian crossings on major urban roads without replacing them with a safe alternative. To provide cycle lanes "where space permits" would be to give cyclists the lowest priority. It stated that the safety solution for major urban roads, of separating vehicles and pedestrians would not work in Christchurch, where many major arterials contained shopping strips and schools, as well as elderly pedestrians and cyclists. They believed it was preferable to promote the safety and mobility of vulnerable road users by using traffic management tools to slow the traffic.

Kerry Wood's submission pointed out that engineering solutions had the potential to increase speeds and might reduce safety for pedestrians and cyclists. Poor-quality cycle lanes could be dangerous and worse than no lane at all. Pedestrian safety measures such as median refuges, narrowed crossings and guardrails could be dangerous for cyclists. Roundabouts were very cycle-unfriendly. He also believed there should be a commitment to signalising crossings on four-lane roads. Another respondent on cycling issues agreed that measures needed to be safe for both pedestrians and cyclists, and that roundabouts should be introduced as a last resort, from the point of view of cycle safety.

The Cycling Advocates Network made the same points, and would also like to see cycle-friendly designs for traffic signals, such as cycle phases and advance waiting boxes. They, and other cycling advocates, recommended the adoption of Austroads standards and wanted to see a set of criteria to help determine whether segregated cycling facilities were appropriate.

However, another submission made the point that Austroads standards were appropriate for rural roads and major urban arterials, but their use on other roads in urban areas led to higher operating speeds and more intersection crashes. There was a conflict between the Austroads standards and traffic calming which aimed to achieve lower traffic speeds and easier decision making through appropriate design. Traffic calming was also more pedestrian friendly. A simplistic application of standards could lead to quite unsatisfactory and even unsafe outcomes in many cases.

DHH Grey Power Association also submitted some ideas on behalf of vulnerable road users — for example, money should be spent on public transport instead of motorways, although urban roads and state highways needed to be made safer also. Pedestrians and cyclists needed off-road lanes, and intersections need to be engineered with consideration for pedestrians and cyclists.

A submission pointed out that cycle lanes were needed in central city areas because cyclists were forced out into the main traffic lanes by traffic calming structures.

The Environment and Conservation Organisations of New Zealand also asked for networks of cycleways parallel to the motorway network, and for a consistent national approach to making cycling safer.

The Kapiti Road Safety Consulting Group supported expanded construction in its region, especially provision for walking and cycling. Marlborough Health Promotion asked that the roading programme include a better cycle/pedestrian environment.

The Disabled Persons' Assembly submitted that more usable and safe pedestrian environments for people with disabilities were needed, particularly at street crossings in city and town central business districts. The DPA did not accept that the complete separation of vehicle and pedestrian environments necessarily provided the best solutions for pedestrian safety. However, it believed the traffic calming principle to be a good one provided it was co-ordinated with appropriate detailing and construction of a usable pedestrian environment. Co-ordination of the visual, tactile, audible and mobility needs of people with disabilities at kerbsides was important — use of good signage, colour contrasts, changes in surface texture and adequate widths and gradients were fundamental to safety provision.

The DPA also recommended that more financial resources be directed into improving pedestrian environments. It was concerned that the social cost of pedestrian injuries appeared to be increasing while the volume of pedestrian journeys was decreasing, and commented that the real cost of pedestrian injury was difficult to quantify because much of it was unreported. Hospitalisation costs for injured pedestrians were twice those of vehicle occupants, but pedestrian injury did not have the same high media profile as speeding or drink driving.

Nelson Marlborough Health Services stressed the need for safe road environments for children as non-drivers — these included safe and accessible crossing points and measures to reduce speed. The Public Health Directorate of the Ministry of Health echoed these suggestions, and stated that both minor open and urban roads and major urban roads should be designed to protect people who walked, ran and cycled, and that this required specific targets and interventions. Safekids also wanted the education of children on road safety to be linked with the creation of a safe and accessible roading environment.

The Street Skills Cycle Unit in Porirua submitted that improved cycleways and cycle stands were needed in and around Porirua, and lock-up shelters at railway stations.

The Rotorua District Council considered that additional funds would be needed for pedestrian/cycle facilities.

The National Pedestrian Project submitted that many of the suggested engineering initiatives for increasing pedestrian safety in the proposed Strategy showed poor understanding of New Zealand's pedestrian injury picture, and of international best-practice for pedestrian safety. For example, it suggested that minor roads were not a key safety issue for pedestrians and that the critical issue was the acceptance of the right of pedestrians to cross relatively main roads in a timely and safe manner. Facilities that might be safe but not time efficient for pedestrians were unlikely to be used.

The University of Otago Injury Prevention Research Unit believed in the need for strong initiatives to turn urban roads back into streets where positive activities such as walking, cycling and play could occur in safety.

Negative effects

Several people were concerned about the potential for better roads to cause higher speeds, therefore making more enforcement necessary to achieve the safety benefits. Some of these comments also suggested that education of drivers would be more effective than improved roads.

The Clutha District Council acknowledged that the benefits would last longer than the enforcement approach provided that speeds did not creep up.

One respondent believed that increased spending on roads would be an expensive and regrettable option. We should not waste money building motorways and therefore encouraging more traffic in urban areas. A better way to go was to put the money into funding public transport.

Another considered that straightening roads was not a useful safety strategy, as it made the roads more boring and people killed themselves on long straight roads. The Central Hawke's Bay District Council also had the concern that less demanding roads would lead to more drivers falling asleep at the wheel.

The ACC also expressed concern that improved roading would contribute to increased speeds, and that the amount of road construction needed to improve New Zealand's roads to a level equivalent to the world's best would be unsustainable. It further stated that outcomes such as reduced travel times had no place in a road safety strategy.

Urban speed management

A total of 101 submissions commented on this issue. The majority (65%) was in favour of implementing urban speed management measures. Around a quarter had some reservations or wanted variations to the proposed measures. The safety of vulnerable road users was often raised as a reason for urban speed management. A few submissions were opposed to any further measures to control urban speed.

While the majority of those who supported urban speed management agreed with strict enforcement of the 50 km/h speed limit, several recommended lower speed limits, such as 30 or 40 km/h, in school zones or near shopping centres.

Among those who had reservations about the proposed measures, many favoured a 60 km/h urban speed limit, sometimes with lower school-zone limits, but still supported strict enforcement of urban speeds.

Those who disagreed with urban speed management wanted a 60 km/h speed limit, or felt that speed management was a waste of money and resources or purely a revenue gathering exercise. One thought that the increase in police work would be too expensive.

Many of the submissions on this issue raised the subject of vulnerable road users. There was considerable support for lower speed limits around schools, as in parts of Australia.

Auckland Healthcare Services supported making the roads safer for cyclists and pedestrians, including children. They recommended that priority be given to diverting traffic away from residential areas, and introducing traffic calming and speed management measures. Safe Waitakere expressed concern that the strategy did not address road safety issues in land-use planning. It was necessary to ensure that the development of new subdivisions on major urban roads did not conflict with road safety.

The ACC made the point that a significant proportion of speed-related crashes occurred in urban areas, and believed that experience in Victoria of integrated enforcement and publicity campaigns indicated that this relatively low-cost intervention could not be overlooked, and suggested that the estimated 5.3% reduction in social cost for this intervention in the draft strategy was conservative.

Auckland Regional Council and Roadsafe Auckland saw urban speed management as a means to promote pedestrian and cyclist safety. They also wished to see lower speed zones around schools, clearly marked with flashing yellow signals and strictly enforced. They advocated traffic calming measures and the installation of pedestrian-friendly road facilities adjacent to shops and community facilities on arterial roads.

Bicycle Nelson Bays submitted that there had not been enough consideration of speed as a contributor to pedestrian and cyclist deaths and injuries in urban areas. It considered that police surveillance should be intensified and that some police should ride bicycles so that they would appreciate the cyclist's perspective.

CAN considered that reducing urban speeds to 30 km/h was important and also wished to see a lower target for urban speeds than 51 km/h. The Environment and Conservation Organisations of New Zealand recommended lower urban speeds in areas where there were a large number of pedestrians and cyclists, and along cycle routes. EECA supported the strategy's speed reduction measures in principle, but believed traffic calming should be given more prominence.

Healthcare Hawke's Bay submitted that the provision of safe and accessible crossing points, and the design of roads to reduce speeds, were effective in reducing pedestrian injuries. It pointed out that a major strength of modifications to the environment was that it helped people regardless of their behaviour and with or without their co-operation.

The Otago University IPRU considered that urban speed reduction might be more acceptable to communities if measures were framed in terms of protecting children. It considered that an average urban speed of 51 km/h was still far too high to ensure much-needed reductions in child injury and mortality. Safekids also pointed out the increased risk for children on urban roads. Health Waikato commented that children were at increased risk as pedestrians on major urban roads, particularly going to and from school.

The National Pedestrian Project submitted that, on any urban roads, vehicle speeds that impinged on the safety of other road users were unacceptable, and that the Strategy should not assume the primary right of motor vehicles. It considered that the 10 km/h tolerance for speeding on urban roads was too high, given that it allowed drivers to travel at 20% over the limit before being ticketed.

The Waitakere City Council wished to emphasise urban speed management as a means to improving pedestrian and cyclist safety. It would like to see 30-40 km/h speed zones around schools and during pre-school journey hours, and local authorities having more authority to set local speed limits.

Road Safe Nelson Bays supported extra police surveillance, demerit points, traffic calming and the adoption of reduced speed zones around schools. AA Driver Training also advocated targeting specific areas for speed control, especially school zones and areas where children played.

Taranaki Regional Council, and the New Plymouth and South Taranaki District Councils emphasised the need for increased enforcement and better road design around intersections, and for higher penalties for speeds in excess of 10 km/h above the limit.

There were a number of calls for more variation of speed limits in urban areas, but one respondent said that the current multiplicity of limits was confusing and that there should be just one.

Federated Farmers commented that urban speed management should concentrate on reducing the incidence of significant variations outside the standards set, rather than seeking to reduce the average speed.

Page created: 16 September 2002