Summary of submissions

• Reduced blood alcohol limit
• Driving age
• Education
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Comments on specific interventions

Reduced blood alcohol limit

A total of 158 submissions commented on this proposed intervention to reduce the legal blood alcohol content from 80 mg/100 ml to 50 mg/100 ml. Of these 68% supported a reduced BAC and 27% opposed reducing the limit.

Supporting a reduced BAC

Of the 108 submissions which supported reducing the limit, almost one-third favoured a zero limit. Those supporting reduced alcohol limits generally saw them as providing greater safety improvements, or supporting a community rejection of drink driving.

There was a good awareness of BAC limits in other countries: Norway, Sweden, Belgium and Australia were mentioned as having effective lower BAC levels. There was also acknowledgement that enforcement would have to support the lower limit. Several submissions advocated a limit between zero and 50 mg/100 ml, for example 35 mg/100 ml.

One respondent considered that a zero limit left no room for confusion and would do away with peer pressure to have just one drink. The Opotiki District Council also made this point.

The Auckland City Council suggested progressively decreasing the level until it reached zero. It commented that many younger drivers selected one of their group to act as an alcohol-free driver, and that there was a need to educate older drivers that this was appropriate for them as well.

The Auckland Regional Council (and Roadsafe Auckland) considered that alcohol- related deaths and injuries were still too numerous. Their submissions quoted the statistic that drivers were twice as likely to have a crash at 80 mg/100 ml as they were at 50 mg/100 ml, and that lowering the limit would also reduce the incidence of people driving with a very high BAC. They recommended that the permitted BAC be the level which was the lowest practical, enforceable and acceptable to public opinion, and the most successful in reducing crashes. A lower level would allow drivers to make more rational decisions about when to stop drinking, and whether or not to drive. They also pointed out that standard drink labelling, to be introduced shortly, would have road safety benefits. They also commented on enforcement, quoting the Australian model whereby people caught between 50 and 80 mg/100 ml are fined and given a 12-month grace period.

The ACC said that, while not opposed to the lowering of the legal blood alcohol level it believed that a reduction should not be considered until the current level was enforced adequately by the Police.

CREDD (Alcohol Healthwatch) commented that the S(A)P Review acknowledged that lowering the blood alcohol level was one of the most effective ways to reduce the road toll. If reductions similar to those in NSW were achieved, a reduction of 32 deaths and about 640 injuries could be expected. The 1996 NZ Police Peer Group Review of Traffic Enforcement had recommended lowering the BAC to 50mg/100ml, arguing that the lower level would allow drivers to make more rational decisions about when to stop drinking and whether or not to drive. Other countries cited with the lower level included Austria, Germany, Denmark, France, Holland, Belgium, Spain and Portugal.

The Christchurch Alcohol Action Project recommended dropping the adult breath alcohol limit to 150 mcg, as in Queensland. It commented that recidivist drink drivers were addicted to alcohol and it was difficult to know what to do for them. About half of drink drivers caught in Christchurch had been caught before.

The Cashmere Driving School believed that a zero limit would have a dramatic effect, but that 50mg/100ml was a positive compromise. Communion wine and medications did not justify the present limit.

Hutt Valley Health commented that we could not assume that adult drivers were mature enough to know when they had reached the limit.

Southland District Council believed that specific strategies were needed, including more positive reinforcement advertising.

Both TRAFINZ and Wairarapa Health commented that there would need to be significant education to achieve community understanding of a reduced BAC, and that the public would need to be convinced that research supported the effectiveness of the measure.

The Ministry of Health's Public Health Directorate considered that BAC limits must be adequately supported by appropriate levels of enforcement, penalties, public education and information, along with complementary initiatives (e.g. sufficient breath testing resources). They would not oppose a reduction from 80 to 50mg/100ml if it was backed up with effective levels of such complementary resources and initiatives. Additionally, if any reduction in BAC limits occurred, they recommended pre-reduction and post-reduction research be undertaken with a view to reviewing the New Zealand-specific data in, say, 3-5 years. They would question the justification for any isolated reduction of the limits if the supporting activities could not be guaranteed.

One respondent suggested a trial of a zero BAC, and believed that the results would prove its worth.

Opposing a reduced BAC

Many of those who opposed lowering the BAC limit maintained that those with 50-80mg levels were not causing the problem, and that it was those who drove with levels well over 80mg/100ml who caused crashes. Many also said that we needed to enforce the current limit before, or instead of, lowering it.

The Bailey Partnership stated that this measure would not reduce social costs by the estimated amount, as only 2.2% of drivers killed had a BAC in this range. It also considered that alcohol was probably not a key factor in these crashes.

Several submissions raised the issue of rural people who would have their social activities curtailed if the limit was lowered. One claimed that the local Lions Club would not survive if members could not have a few beers, and that they were very conscious of not exceeding the current limit. Another submission felt that it might cause a "why bother" attitude in rural communities.

The Alcohol Advisory Council recommended that current limits be retained because it was unconvinced either by the strategy document or by its own research that a reduced BAC was of value. It said that the information provided by the NRSC did not give a level of accuracy on which a sound and informed decision about reduced social cost could be made, and that research carried out by ALAC did not support the NRSC's estimates. Based on ALAC's reading of international studies on this issue, it concluded that the estimated reduction in social cost from the proposed reduction in the blood-alcohol limits would be considerably lower than the NRSC's own estimate.

The Beer, Wine and Spirits Council submitted that many countries had an 80mg/100ml limit, and pointed out that Australia's ratio of alcohol-related deaths to total fatalities was higher than New Zealand's in the late 1990s despite its lower limit. It also mentioned rejection of the lower limit in the UK, the USA and Canada. The Council believed that very drunk and repeat offenders should be targeted. It considered that alcohol was less likely to be the reason for a crash at low BAC levels, and that there was no evidence of public support for a lower BAC. A shift to 50mg/100ml would be difficult to enforce, and police resources would be stretched, with the possibility that drivers well over the limit would be missed. Along with the Distilled Spirits Association, it submitted that a lower limit would criminalise a large number of law-abiding citizens.

The Hospitality Association of New Zealand also quoted John Bailey's research and considered that, while the New Zealand public supported the current regime, a lower limit might antagonise them by penalising the law-abiding majority. It advocated targeting repeat offenders who would be unaffected by a lower limit.

The New Zealand Chartered Clubs submitted that drivers involved in crashes with levels between 50-80mg were not identifiable or quantifiable and that overseas comparisons did not relate to New Zealand conditions. A lower limit might deter people from drinking on licensed premises, risking the economic viability of those premises and encouraging drinking in uncontrolled surroundings. Clubs played an important role in the community. A lower limit would deter responsible people, and have no effect on those who currently drove with alcohol levels over the limit.

The Insurance Council also asked for enforcement of the current limit, and considered that a lower BAC would have limited benefits because most drivers who caused crashes were well over the limit.

The Automobile Association also recommended that drivers with excessive BACs be targeted, and was concerned that a lower BAC would reduce the resources for this. AA Driver Training commented that a lower limit would not be seen as credible by those who practised moderation, and suggested increasing the chances of being caught instead.

Rodney District Council considered that the level should not be changed because current levels were accepted by New Zealanders and represented a fair balance between the rights and responsibilities of each individual.

Blood alcohol level for young drivers

Of the 102 submissions that responded on this subject, 69% agreed with the proposal for a zero BAC for drivers under 20 years of age and 26% opposed it.

The Otago University IPRU commented that there was good evidence that young inexperienced drivers had a higher crash risk at low blood alcohol levels. A zero limit would give a clear message to young drivers as to how much they could drink before driving, reducing the current 'guess-work' component.

Another submission said that inexperience in driving and inexperience with alcohol could be a deadly mix.

Nelson Marlborough Health Services submitted that this would strongly reinforce the 'don't drink and drive' message to young drivers. The effect would then flow through to adulthood and a zero-tolerance attitude be passed on to future generations.

The Tararua District Council submitted that a higher number of young drivers had been caught with levels over the limit since the drinking age was lowered, and suggested raising the drinking age back to 20. The Wairarapa Road Safety Council also submitted that more young drivers had been over the limit since the drinking age was lowered.

Manawatu District Council believed a zero limit should apply to drivers under 25, while the Taranaki District Council would apply the zero limit to drivers under 18.

Some of those who opposed any change considered that the lower limit would not be effective; some wanted the current limit better enforced; and others were concerned that people taking medication would be penalised.

The Automobile Association said that the main benefit of a zero BAC would be in changing the attitudes of young drivers. However, there had been many attitude changes in young drivers over the last 10 years. They should be given some credit for acting more responsibly. Also, there were problems with trying to enforce a zero blood alcohol level because of alcohol traces in other products such as proprietary medicines.

The Taranaki Regional Road Safety Co-ordinating Group considered that young drivers were more likely to organise a sober driver than older drivers, as a result of intensive education about drink driving. It supported an across-the-board limit for everyone.

Compulsory breath testing

A total of 58 submissions commented on compulsory breath testing. Almost all supported intensifying CBT.

ACC submitted that its 'Stop Bus' programme had provided evidence of the potential to make traffic enforcement more effective.

The Alcohol Advisory Council agreed that CBT was highly effective, and supported the proposed increase in police resources. It also recommended that the current testing rate of 0.73 tests per licensee (per year) be increased to the rate recommended following Australian analysis.

The Marlborough District Council pointed out that, while there was a growing community awareness of the severity of the problem, there were sectors within the community who believed they were highly unlikely to be caught while driving under the influence of alcohol. Marlborough Health Promotion supported increased CBT, as long as the police were adequately resourced.

The Ministry of Health's Public Health Directorate also referred to the recommended Australian rate of testing of one per licensee per year, and understood that New Zealand's rate was well below this level. It supported increasing CBT resources, but questioned whether quota targets were currently being met for the existing level. If not, it considered that the increased CBT resources should be applied to the current BAC limit before any reduction in the legal limit was made. In addition, it was concerned that CBT resources might become clogged with lower-risk drivers in the 50-80mg/100ml range while recidivists and those with very high BACs were not reached.

The Coalition to Reduce Drinking and Driving also advocated increasing the number of tests to the levels indicated by Australian research. It believed that the 2010 targets could be met with a relatively small additional effort.

Of those who opposed increased CBT, one respondent considered that CBT should stop because it hassled people needlessly and another that it would cause driver rage and waste police resources. Alan Simms Ltd said that extra speed cameras and breath testing were not the answer, while the DHH Grey Power Association denied that alcohol was the problem. It considered that breath testing should only be used if driver behaviour warranted it, and that better provision of public transport was more important.

Alcohol interlocks

A total of 45 submissions commented on alcohol interlocks, the majority of which supported their use.

The Ministry of Health's Public Health Directorate supported further policy work on the feasibility of this proposal in the New Zealand environment, particularly as a potential option for recidivist drink drivers. It noted that US interlock programmes existed in various forms: judicial or administrative, mandatory or voluntary, and recommended an examination of the pros and cons of each be undertaken as part of any policy work to further this proposal. Additionally, it recommended that data be collected to evaluate the effectiveness of any alcohol interlock intervention that was implemented.

The Alcohol Advisory Council also recommended that a further evaluation of the efficacy of interlocks for recidivist drink drivers in a New Zealand setting be undertaken before a significant increase in resources was dedicated to this particular intervention.

The Automobile Association considered that vehicle impoundment was the better alternative, and that alcohol interlocks might not add additional value. Approximately 79% of members supported the use of alcohol interlocks, but they were probably unaware of the recent impact of the impoundment policy. The Association would therefore like to see more research on the effect and impact of alcohol interlocks before it could consider supporting their introduction.

The Waimakariri Road Safety Co-ordinating Committee also thought that recidivist drink drivers should have their vehicles impounded rather than being given another option to use them. One individual submitted that drink-driving fine revenues should cover the cost of having interlocks fitted.

Eastern Bay Road Safety Committee suggested that all new vehicles should be fitted with interlocks in 10 years time. Only fitting them to recidivists' vehicles would be less effective, especially as some of these people would have access to more than one car.

Driving age

A total of 195 submissions commented on the proposal to raise the minimum driving age from 15 to 17 years. The majority (57%) opposed the proposal and 38% were in favour of raising the driving age. Rural people predominantly opposed raising the driving age on the grounds that young people from rural areas did not have alternative means of transport, and that being unable to drive would impact badly on them and their families.

In general those who did not want the driving age raised considered that the risks related to inexperience rather than to age. There was also a view that it was safer for young people to be learning while still under parental control.

Some respondents thought that it was more important to enforce the graduated licence system, or to delay moves to raise the driving age until the effects of the GDLS had been evaluated.

Opposed to raising the driving age

A total of 47 submissions opposing the proposal were from young people on the West Coast who signed a prepared submission form. The submission opposed raising the driving age on the grounds that there was no public transport system on the West Coast, and that the proposal would impact negatively on rural people and put stress on families.

Other submissions also commented that raising the driving age would affect rural communities. Among these was that from the Ashburton District Council, which thought that it would lead to unlicensed and untrained drivers being on the roads because of a lack of alternative means of transport. The Clutha District Council considered it was important that young people be able to drive to school, recreation and social events. Ruapehu District Council said that young people needed to drive, but testing should be more stringent. Southland District Council said that rural communities relied strongly on the independence that driving gave young people, and believed that the problem might migrate to the next higher age group if the driving age was raised. The Taranaki Chamber of Commerce submitted that this would be bad for the employment prospects of young people, especially in the rural sector. The Waimakariri Road Safety Co-ordinating Committee also considered that this proposal would penalise rural families. Waikato Rural Women New Zealand submitted that this measure would only be effective if public transport was improved.

Federated Farmers also pointed out that raising the minimum driving age might lead to an increase in crash risk, as three major risk factors would be concentrated together: legal access to alcohol, driving inexperience, and lack of parental control. They considered that the current GDLS was a surrogate for a minimum driving age and placed the emphasis on skill and experience rather than solely on age. They recommended that the effects of the GDLS be fully evaluated.

Other submissions also said that the graduated licensing system, if properly enforced, would ensure that drivers had sufficient experience before gaining a full licence. The Automobile Association made this point, and also argued that the recent reduction in crashes involving young people demonstrated that education was the key. The Ministry of Agriculture and Forestry supported stricter conditions on young or novice drivers rather than raising the minimum driving age.

The Manawatu City Council and the Porirua City Council both favoured the graduated licence system. Roadsafe Auckland considered that the GDLS needed to operate for longer to see if it was working before any changes to the driving age were considered.

Another point made in relation to young drivers was that it was better for young people to learn while they were under parental control. Cashmere Driving School and the Wanganui District Council also commented that students had more time and opportunity to gain driving skills when they were in a controlled environment.

The Otago University IPRU believed that the low driving age in New Zealand undoubtedly contributed to the poor crash record for 15-24 year olds, and that raising the age would bring safety benefits, but the GDLS had to be taken into account. It mentioned overseas experience indicating that, the older drivers were, the more difficult it was to impose restrictions on their driving. Because of this, it supported a driving age of 16 but said it might be necessary to allow exemptions to the night-time curfew for young restricted licence holders who needed to drive at night for work purposes.

The National Council of YMCAs commented that 18-year-old males were the group with the highest rate of crashes, and that the proposed change would not affect them.

Support raising the driving age

Many of those who supported raising the driving age did not give details of the reasons for their views. Ages between 16 and 20 were put forward as being more suitable ones to gain a full licence. Several respondents considered that 15-year-olds were too immature to drive, one pointing out that they were very susceptible to peer pressure.

Some people considered that, as students were tending to stay longer at school, it was unnecessary for them to drive so young. One thought that being unable to get a licence might keep some potentially dangerous young male drivers at school.

Two responses thought that the driving age should be raised, but low-powered motor scooters could be allowable for 15 year olds.

TRAFINZ submitted that, while there was a variety of evidence about the relationship between safety and driving age, as opposed to risk and driving experience, it believed that raising the driving age would reduce the number of crashes by taking a particularly high-risk group off the roads. This would also help to reduce overall risk and support other transport objectives by reducing overall traffic volumes.

The Wellington Regional Council strongly supported raising the driving age, while the Otorohanga District Council believed that this low-cost enforcement measure should be included in the mixed option.

Rotorua Grey Power suggested that people could learn to drive on simulators.

Education

A total of 315 submissions commented on education. Many comments were unspecific about what road safety education should comprise, but there was a widespread perception that education had a small or no part in the strategy as proposed. Many respondents obviously felt that the proposed strategy lacked detail about educational measures that could be used in support of specific interventions, or believed that education should be an intervention in itself. The view was expressed a number of times that education should not be disregarded just because the results were difficult to measure and quantify. Many also assumed that education was an easier and cheaper option than enforcement, engineering, or any combination of the two.

There were a wide range of interpretations of what road safety education should consist of, and how it should be improved. Broadly, these fell into the areas of community-based education, driver training, advertising, and school education. There were also a substantial number of comments about education for, and about, cyclists and modes of transport other than cars.

ACC said it was strongly committed to an enforcement and education emphasis, and was concerned that no attempt had been made to quantify the benefits of public education and health promotion interventions. It did not consider that education was pervasive, as stated in the proposed Strategy, and believed that omitting mention of it suggested that educational interventions were of no value. The success of the 1995 Supplementary Road Safety Package was noted in the draft Strategy, but this type of intervention deserved to be included in social cost reduction targets.

The Ashburton District Council thought that education had become an afterthought rather than a stand-alone component of the strategy. The Napier City Council believed that education needed to be an integral part of any future road safety strategy.

Christchurch City Council submitted that education was a key factor in developing heightened awareness of road safety issues, and that it could be used as an intervention equal to enforcement and engineering.

The Christchurch Co-ordinating Committee for Traffic Safety considered that there was not enough emphasis in the strategy documents about education and developing a safety culture. It also argued that education should be an option equivalent to enforcement and engineering. Only with education would people accept the proposed changes and costs. We needed to teach the community that driving was a privilege and not a right, and to sell the financial savings aspect of reducing road trauma.

The Hamilton City Council (HCC) also wanted education given a similar profile to enforcement and engineering. It wanted educational initiatives defined and expenditure levels quantified. HCC also submitted that education was not always associated with enforcement. Often valuable education initiatives might lead to "best- practice" road-user behaviour or responsible attitudes without reference to any particular rule. Examples were defensive driving, "Share the Road" campaigns, and the "Down With Speed" initiative.

AA Driver Training asked why there were no stated educational interventions or goals, and commented that leaving education to mass TV campaigns and relying on engineering and enforcement would do little to gain public support and compliance.

The National Council of YMCAs considered the section on education in the strategy document to be extremely vague, and to contain no targets or estimates of impacts.

The Bikers' Rights Organisation of New Zealand said that education, which was more than just an advertising campaign, was the most effective method of improving road safety.

The Rotorua District Council considered that education should play a larger role, and was a large potential source of cost reduction. It should be one of the 'Big Four' not just part of everything we do. It needed to start with toddlers in car seats and the instilling of safe driving — gains would be exponential as the population went through the process from childhood onwards. The Council considered that the whole system of education delivered by the range of agencies needed review, re-invention and reinvestment because potentially the biggest gains would come from this area.

The Dunedin City Council advocated comprehensive education about road safety, and made the following comments: education was the key to modifying driving culture and would lead to long-term safety gains. It should be part of the core curriculum as soon as children started school, and should deal with road rules, defensive road use, personal safety, and optimal speeds for the environment, safety and efficiency. It should also include how safety, economy and the environment could be improved with the use of other transport modes — the safety advantages of public transport. Education was needed to keep all road users up to date with road rules and changes arising from new engineering practices. Education was also needed on the increasing likelihood of serious injury with advancing age, to encourage older people to adopt different travel strategies to eliminate unnecessary risk. Incentives should be provided for the transition to other modes of transport.

The Hurunui District Road Safety Co-ordinating Committee submitted that an important function of education was to prepare the public to pay for the engineering and to accept the enforcement.

The Kaipara District Council commented that, although education in safety issues ran through everything, it often took a long time to work.

The Thames/Coromandel District Council pointed out that education was only effective when backed up by consistent enforcement. The Waitakere City Council supported increased road safety education and enforcement because of the low levels of driver licensing and vehicle roadworthiness in the area.

The Wellington City Council commented that the strategy implied that road user education was relegated to a lesser role. It submitted that there remained an important need for innovative education across the social spectrum, to use the media to reinforce driving skills and good road user behaviour, and especially to reinforce the link between deaths/injury and excessive speed, so that long-term attitudinal change occurred.

The New Zealand Automobile Association commented that the role of education should be an essential part of the Strategy. It considered that early road safety education was vital because research had shown that developing skills was not enough on its own: drivers had to be motivated to change their risk-taking behaviours. These changes to attitudes needed to occur before a person reached driving age (as in Victoria's RAW programme). The Association recommended two driver education interventions: driver education as an integral part of the school curriculum, and hazard perception tests as part of the driver licensing process. It strongly recommended that driver education be part of the curriculum at all school levels. New Zealand had recognised some of the deficiencies in novice drivers' skills by developing a graduated driver licensing scheme. NSW and the UK were proposing to introduce a hazard perception test. It also strongly suggested that a similar test should be considered for New Zealand.

A number of submissions considered that attitudes required changing before behaviour would improve, and that education would achieve this. One respondent asked how to educate road users about the difference between the roads and competitive environments at work or on the sports field. Another said that education campaigns to change driver attitudes were very important, but very difficult. Campaigns should be aimed primarily at the sections of society that caused the most crashes because of bad attitudes. Another attributed the lack of courtesy of New Zealand drivers to the 'macho' New Zealand attitude.

One person submitted that displaying crashed vehicles beside the road was a good way of making people consider their driving habits and take extra care.

The Disabled Persons' Assembly saw the need for a move from a competitive to a more considerate and co-operative approach.

The Hurunui District Road Safety Co-ordinating Committee considered the proposed Strategy to be quite inadequate in the area of education and changing attitudes. Simply ignoring such an important issue because it was difficult to measure the benefits was futile. There had been a successful change with drink driving — we now needed to focus on safe and considerate driving.

The Pacific Island Safety and Prevention Project submitted that education was a priority issue. It believed that higher penalties and fines would not change attitudes. Education and services needed to be delivered in a culturally-appropriate way.

TRAFINZ considered that the Strategy should include a greater emphasis on continuing to improve educational initiatives. The key was continuing to change the road safety culture. Sustained efforts had successfully changed the ingrained drink-drive culture, but there was still some way to go in changing attitudes to other key road crash causes, notably speed. Too often people did not understand the reason behind rules, or did not agree with rules because they were insufficiently informed. TRAFINZ considered that the Strategy should not assume that there was little room for improvement through education, though it acknowledged that the larger quantum of improvement was likely to come from other areas. However, without completing the shift in road safety culture there was little chance of achieving a long-term goal of a 'vision-zero' target.

The Waikato District Council said that New Zealand drivers had appalling attitudes and lack patience. There was a need to increase drivers' awareness of this, to encourage them to be more consistent with international standards. There was already sufficient publicity to inform the public. Drivers not responding to this would not be reached by spending more on advertising and consultation.

The Waimakariri Road Safety Co-ordinating Committee believed that changing road user behaviour would need a strong focus on education, which should have an equal share with enforcement and engineering. Education and advertising needed to be more focused. It might be more effective to focus on the innocent victims of crashes because the public still accepted dying on the roads as part of the cost of driving.

One respondent considered that there was not enough information available about the proposed Strategy, and that there should be leaflets in every petrol station.

In sharp contrast to the majority, Alan Simms Ltd recommended no extra funding for education over the next 10 years because too much had already been spent on it, with an inadequate return. It considered that there would never be a measurable road safety result from trying to teach safety because it would never target the right group.

Community focus

There was very strong support for community programmes, particularly from local authorities.

The Auckland Regional Council's submission (also Roadsafe Auckland) covered a range of issues, focusing on community education. ARC pointed out that community road safety promotions or projects had been a feature of the NZ Road Safety Programme since its inception and had grown as communities increasingly wanted to get involved in road safety. Funding criteria based on proven or promising projects should be established to better target resources and promote best practice. To assist this the Council recommended a review of community projects to provide an evaluation of what was effective and why.

The ARC also sought greater efforts to address the emerging problem of serious repeat offenders. Current community-run alcohol assessments were generally run on an ad-hoc basis, did not specifically target drinking and driving, and there was little evaluation of their effectiveness. Repeat offenders had difficulty gaining access to mainstream alcohol and drug treatment providers because they were Justice clients. Incentives (e.g. sentence reduction) should be introduced for disqualified drivers to complete road safety/driver training programmes.

The ARC considered recent LTSA funding to be an important first step for Maori and Pacific Island communities which had long been overlooked in road safety initiatives. Projects and infrastructure needed to be supported and encouraged as a long-term solution. Effective programmes within these communities would benefit this region in particular. Pacific Island initiatives should be strongly focused in this region and driven by local Pacific Island communities. Asian people were also an emerging road safety issue in the Auckland area.

Local Government New Zealand also saw education as having a very wide scope. As well as addressing driver training matters, it advocated more funding for road safety co-ordinators and community projects, as well as training to address a possible skills shortage among RCA staff and others. Community initiatives might include: visiting groups that were over-represented in road trauma statistics to offer advice and educate them; providing more funding for road safety co-ordinators and community projects; and developing campaigns that informed road users and members of the public of the reasons behind road safety laws and regulations, so they understood why they were necessary.

The Manukau City Council also supported continuation of national funding for community-based education and awareness projects delivered through road safety co-ordinators. Marlborough Health Promotion also recommended continuing support and funding for community projects.

Opus International Consultants also believed that community ownership was necessary to achieve road safety targets, and that road safety co-ordinators and community agencies working in an educational role were going to have the greatest responsibility.

The Coalition to Reduce Drinking and Driving submitted that it was important for the 2010 strategy to ensure the support of groups involved in advocacy and community- based initiatives, which could play a key role in putting road safety issues on the public agenda. CREDD believed that emphasis needed to be retained on community initiatives as they could be highly successful. This included supporting such groups as SADD and community-based and legal initiatives to deal with recidivist drink drivers. They pointed out that New Zealand had been a world leader in promoting community-based road safety initiatives. The establishment of road safety co-ordinators and the introduction of culturally and ethnically-based road safety initiatives had been significant in changing attitudes towards drink driving in particular.

The Ministry of Health's Public Health Directorate strongly supported a mix of health promotional approaches to support road safety education. It recommended that road safety education campaigns seek the input of public health providers who were able to mobilise communities to work together on solutions and promote ownership of safety messages.

The Rotorua District Council submitted that current community projects, training and programmes were good but more were needed. Expansion would require direction and adequate funding. It supported recent moves to co-ordinate delivery and resources across TLAs.

The Selwyn and Banks Peninsula Road Safety Trust wanted to continue to encourage communities to accept ownership of the road safety problem. It advocated stimulating and supporting innovative community projects and campaigns that complemented LTSA/Police campaigns.

The South Taranaki District Council would also like to see increased funding for community groups to carry out local road safety campaigns.

The Waitakere City Council said that it presumed education included community safety promotions as well as driver training and school programmes — there was a need for extra resources for licensing programmes targeting disadvantaged drivers, and for school-based programmes to ensure everyone received a minimum level of instruction. Projects using the new funding for Maori and Pacific communities should be owned and driven in a culturally-appropriate way by road safety workers of that ethnicity. There were emerging road safety issues for migrants also. There should be an increased financial commitment to community driver licensing projects for unlicensed drivers and those most at risk.

One respondent commented that the Marae was a very important and effective location for training, and that oral rather than written tests would produce better results.

The Wellington Regional Council wanted to give greater emphasis to community road safety measures and divert police funds to local authorities for road safety education. It recommended ensuring every local authority employed a road safety co-ordinator with funding from existing Police funds to provide the educational functions formerly provided by MOT officers.

Driver training

There was a widespread perception expressed in submissions that New Zealanders were bad drivers, lacked driving skills, and that there was insufficient training before a licence was granted as well as during the time that a licence was held. A number of submissions recommended compulsory professional driving instruction, pointing out that bad driving habits were handed on when instruction was given by relatives or friends. There was also support for on-going retraining or retesting every 10 years, and concern that currently no 'upskilling' was required for a period of many decades during a person's driving career.

Some people believed that defensive driving courses should be compulsory, especially for people with road safety infringements. One felt that re-testing should be compulsory after a certain number of demerit points were accumulated. Another felt that 'upskilling' would be more effective than increasing fines or demerit points.

One respondent advocated establishing "Best in the World" driving schools, where every type of road condition could be replicated. It could also include vehicle knowledge and first-aid training. Courts could recommend re-training at these schools, and there should be opportunities to voluntarily retrain at a reasonable cost.

Several respondents considered that driver education was the answer to improving road safety, rather than reducing the speed limit. Others advocated skid and hazard training or advanced driving courses.

The AA Driver Education Foundation commented that the lack of emphasis on driver education in the strategy was a concern. Its view was that driver knowledge and awareness impacted on all areas of motor vehicle operation, and that measures to improve road user behaviour should be among the major interventions. The Foundation believed driver education to be the most significant influencing factor in crashes and the use of the motor vehicle, but that it was not specifically targeted. Improvement in this would have both a direct and an indirect effect on the three stated safety interventions and it should be regarded as the fourth. It recommended interventions such as a national co-ordinated driver awareness programme, an older driver programme, a recognised driver awareness/improvement programme for adult drivers, an awareness programme for court-referred drivers, and linking driving standards to national qualifications.

Age Concern Wellington advocated advice for older drivers, as their reaction times slowed down. Motoring groups such as the AA and car salespeople should take responsibility for providing advice and issue brochures referring people to courses for updating their skills.

Benchmark Building Supplies' submission recommended on-going driver training, focusing on trucks, and suggested a Master Driver level of driver education. Drivers should be educated to handle road conditions, not just to learn the road rules. The insurance industry could offer incentives such as a lower level of premiums for master drivers.

Professional driver trainers such as the Cashmere Driving School considered that there should be increased incentives for professional driver training. Although there was no statistical evidence to prove that driver training made any difference to the road crash exposure of young drivers, this was only because there was no facility to record the data. It was equally true that there was no evidence to the contrary. There was however, plenty of anecdotal evidence that professional training produced better-prepared and better-skilled drivers. The most effective method of ensuring that drivers continued to update their skills was by offering incentives, and making driver training more accessible to a larger proportion of novice drivers, and this would provide major cost savings.

The New Zealand Institute of Driving Instructors advocated a system for reviewing drivers throughout their driving lives, in order to maintain the standard of driving desired of the experienced driver. This system would supplement the GDLS, and would possibly make the separate test for older drivers unnecessary. The NZIDI submission set out a plan for introducing this type of driver review system, to be delivered by a separate stand-alone organisation.

The Cashmere Driving School also recommended that drivers should sit a practical test when renewing their licences. The standard of driving for mature experienced drivers should be addressed. A ten-yearly renewal test would educate New Zealand drivers to change lifetime bad habits and demonstrate up-to-date knowledge of road rules. The cost could be less than $100 for 10 years — $10 per year, the cost of a light lunch.

The Corrigan Driving School also stressed the need for professional driver training. It said that the public needed to be made more aware of any changes in, or interpretations of, road rules — for example, signalling when exiting from a roundabout.

The Independent Motor Vehicle Dealers' Association wanted to see defensive driving courses for offending drivers reintroduced.

The National Council of Women wanted affordable material targeted at specific groups (elderly, visitors, ethnic groups), and education and skill checks for drivers other than novices and older drivers.

The New Plymouth District Council recommended greater investment in driver training to avoid additional costs on drivers — for example free compulsory driver education courses before getting a restricted licence.

The New Zealand Roadshow Trust was concerned that training received very little attention in the Strategy, and would like to see a focus on increasing the number of hours of supervised experience for novice drivers, as currently occurred in Australia. It reported on Swedish research indicating that, when novice drivers in the learner phase obtained at least 120 hours of experience, their crash rates reduced by 30%. The Trust had surveyed 324 novice drivers and 146 of their parents and found that around half were getting only 6-24 hours' driving experience in the learner phase. They commented that a lot of parents were not comfortable as passengers with their children — the involvement of parents in the licensing process as supervisors in the learning phase needed promotion.

Rotorua GreyPower commented that training helped people to accept responsibility for their driving. The Rotorua District Council submitted that training for adults throughout their driving career was lacking — we should have driver training at 5-yearly intervals. It could be voluntary but more punitive penalties could be applied if an offence was committed and the driver had not attended training within the previous five years. The Council also submitted that little use was made of defensive driving and similar courses during the prosecution process — even just reviewing the Road Code requirements would benefit offenders. Demerit points could be used as an incentive for the education programme — with points and infringements being made public to increase awareness and create embarrassment.

The Selwyn and Banks Peninsula Road Safety Trust wanted mandatory fleet safe- driving policies and training programmes for company drivers.

The Stratford District Council believed that many drivers did not understand the significance of road signs, and needed training specifically for this. The Traffic Control Materials Division of 3M Ltd made the same point, and recommended that a Signs Advisory Committee be set up to assist with education about road signs and changes to road rules. There should be a 5-yearly theory test of road users.

Transfund New Zealand also considered that the proposed Strategy paid insufficient attention to the education of all road users. This should have a higher profile in the Strategy and more resources should be applied to the on-going education of all road users. Road users should be competent to use the transport system. Features in the road infrastructure, like signs and road markings, provided guidance for road users. However, road users received very little education as to what these features meant, and there was very little knowledge of what users understood by them.

The Wellington Regional Council wanted all drivers to complete a defensive driving course within 30 months of getting their first full licence. Canterbury Highway 2000 suggested developing defensive driving programmes to help younger drivers to 'read' the road.

AA Driver Training wanted goals to be written for the professional development of road safety workers, driving instructors, and driver testers, and for the continuing development of the learner driver syllabus and driver testing systems.

Advertising

A small number of submissions doubted the value of the advertising programme in changing bad driving habits. One respondent said that the advertising campaign was insulting and should be stopped. Another commented that television advertisements were a waste of time and money.

Several submissions favoured changing from shock tactics to a positive message, as in the new advertisement with the sober driver. On the same theme, one respondent asked whether graphic road crash advertisements really helped the road toll, and whether a series of programmes highlighting common driving errors would be more beneficial because we could all relate to them.

Other submissions supported the advertising programme. One commented that the advertising programme was very good but should address why New Zealanders did such stupid things on the roads, suggesting that issues relating to individualism, self-identification, resentment of authority and being a small country, were to blame.

Some respondents put forward suggestions for campaign topics. One asked for a campaign about the benefits of daytime running lights, another for one about keeping left. A further submission considered that driver education programmes on rules of the road and merging, overtaking, etc would be better than the current style of advertising. Another respondent wanted the seat-belt campaign to continue.

The Alcohol Advisory Council (ALAC) recommended that current and past drink-driving advertisement campaigns be evaluated to establish their effectiveness as deterrents and which advertisements were the most effective in deterring drink-driving related behaviours and attitudes. It suggested a comparison of those advertisements showing road deaths and injury through drink driving with those showing drink drivers being tested or prosecuted. ALAC recommended that the LTSA review the consistency of its advertising campaigns and campaign messages regarding drink driving, in order to provide the public with a clear and accurate message about drink driving and drivers' legal obligations. Not all messages advertised the legal BAC limits, for example.

Opus International Consultants suggested continuing and monitoring the current campaigns; new campaigns based on understanding road conditions, traffic signs and markings and research into these areas; rewriting the Road Code to include all modes and ensure better understanding by new drivers; research on driver behaviour; and more positive messages like the current one on designated drivers.

Rodney District Council commended the recent TV advertisements with the positive message and the 'Down with Speed' campaign.

The Hutt City Council supported more emphasis on education and advertising. The Porirua City Council submitted that extensive educational measures would be needed to create an effective change in culture, similar to the drink-drive campaign but much more intensive. The Hawke's Bay Regional Council considered education as probably the most important factor and cited the success of the drink-drive campaign.

The Window Association of New Zealand submitted that there should be more emphasis on road rules and practical driving tips in the advertising. It suggested using a news reporter and camera team rather than an expensive agency.

School education programmes

The Auckland Regional Council strongly supported initiatives to increase road safety education resources in schools and commented that urgent action was needed, either to increase the numbers of trained police educators or to develop another means of delivering road safety education in schools. It recommended setting minimum benchmarks for the type and level of road safety education delivered by teachers and external agencies, to be audited by an agency such as the Education Review Office.

The ARC's view was that road safety education would only be effective alongside safe and accessible roading environments, so it must be developed in conjunction with the creation of safe environments — the Ministry of Education should be more actively involved in road safety, particularly in dealing with issues around school boundaries and the demands increasing rolls placed on local infrastructure. There should be accountability and responsibility for these issues so that the Ministry of Education collaborated with RCAs, communities and others affected. There appeared to be no guidelines for ensuring schools had effective road safety policies and practices to make road safety education compulsory at all levels. The Ministry of Education should provide incentives to adults to supervise school pedestrian crossings.

Barnardo's New Zealand wanted to see more child-focused resources developed to assist parents and educators to reinforce road safety messages. There should also be programmes to educate adults about keeping children safe on the roads.

Bicycle Nelson Bays recommended accelerating the "Safe Routes To School" programme, and believed that school children should receive practical as well as theoretical training.

CAN also supported the promotion of "Safe Routes to School". Environment Southland wanted the national curriculum changed to include road safety education.

Fischer and Associates also wanted long-term strategies in the schools and other educational institutions, starting in early childhood, as part of the curriculum. Kingsway School suggested integrating driving courses into schools to free up the police.

Motorsport New Zealand submitted that sports people excelled because they were constantly coached and drivers should be too. It would welcome an in-depth analysis of its "Prodrive" training programme for college pupils with driving licences. Checking on the driving histories of former students would show that more of this was needed.

The National Pedestrian Project commented that education of school-aged children was less likely to be important for improving pedestrian safety than, for example, the development of a more 'forgiving' road environment for those who walked, including children. There was much debate in the international community as to the effectiveness of child education for reducing injury. Current education programmes and tools could contribute to safety, but the reality was that these were not effectively used in schools.

Safekids considered that education was a primary component of any intervention, but should be linked with the provision of safe road environments — for example safe parking, pick-up and drop-off facilities at schools. The ARC had made a similar comment (see above).

Nelson Marlborough Health Services recommended an independent evaluation of current road safety programmes targeting children, in order to guide decisions on future programme development.

The National Council of YMCAs of New Zealand submitted that the Street Talk programme showed that safe driving involved attitudinal change, and doubted that this could be achieved by a TV advertisement. It recommended that Street Talk and other educational initiatives be evaluated.

The Ministry of Health's Public Health Directorate noted the need to improve road safety education in schools. It recommended the establishment of minimum benchmarks for the type and level of road safety education delivered in schools by teachers and external agencies.

The Rotorua District Council recommended that there be limited support from uniformed staff in schools and community areas — additional dedicated staff were needed to provide an information/community role and counteract strict enforcement/penalty provisions, as well as to provide role models and guidance to young children.

The Selwyn and Banks Peninsula Road Safety Trust considered that education should have equal status with enforcement and engineering, and that we should consider integrating traffic education into the school curriculum and including professional driver education at high school. AA Driver Education Foundation funding could be used by high schools for this purpose.

TRAFINZ considered there was room in the longer term to improve road safety education by including this subject as part of the compulsory school curriculum.

The Waitakere City Council wanted more police educators in schools (see also the ARC comment above).

The Wanganui City Council believed that pre-driver education as part of the school curriculum would lead to improved habits as drivers, and also influence parents.

Education and alternative modes

The Cycling Advocates Network believed that education should be central to the Strategy. It suggested another round of consultation to give people a chance to look at the balance of education with enforcement and engineering. CAN suggested adopting the Australian "Share the Road" campaign and including cyclist examples in the Road Code.

The Christchurch City Council's Cycle Steering Group wanted research done into the long-term benefits of cycle training, training in co-operative road behaviour, and professional training for cycle infrastructure engineering. A number of other cycling groups also asked for better training of drivers on sharing the road with cyclists, and for education about the benefits of cycling.

The University of Otago IPRU recommended advertising campaigns that targeted motorists on cycle safety issues, and encouraged the LTSA to purchase and adapt commercials currently showing in Australia on safe road sharing. However, it questioned the allocation of scarce resources to pedestrian education, given the lack of its effectiveness in modifying behaviour. Traffic-calming measures should be the preferred strategy.

The Otaki Cycling Environment and Access Network suggested that the Road Code be revised to reinforce the bicycle's status as a vehicle. Kiwi Cycling was an important course for children. Training for road safety and transport professionals needed to treat cycling as a mainstream transport mode, with adequate consideration given to cyclist issues. Defensive driving courses also needed to include cyclist issues.

The New Zealand Cycling Strategy Foundation Project submitted that there were large gaps in cycle education — for example, training was available only for adolescents, not adults; motorist education did not cover interaction with cyclists; the Safe Cycling book was directed at young people, with the implication that cycling was something people grew out of. There was no definition of good practice in cycling, or in motorists' interaction with cyclists.

The EECA wanted to see energy-efficiency messages included in driver education, and was interested in working with the LTSA on safer driving educational materials that included energy-efficiency driving tips. It would like to see road safety education promote the wider aspects of public health, community safety, and the economic and environmental benefits of encouraging more walking, cycling and public transport use.

Street Skills/ Kiwi Cycling submitted that there needed to be education catering for cyclists, both children and adults, in the Strategy, and asked to be included in the list of groups which were current educators in cycle training (Appendix 2 of the Strategy document). It also supported training for drivers about cyclists, with Road Code references as well as practical training.

The National Pedestrian Project submitted that education of motorists was critical to pedestrian safety, but this would require more emphasis to be placed on: increased recognition of the needs and rights of pedestrians; developing a culture that encouraged a 'share the road' mentality; and clarifying the role that drivers played in keeping pedestrians safe. Education for road safety professionals was also required to encourage expertise in pedestrian issues.

Other education ideas

The Motor Trade Association supported training initiatives to raise the competency of motor vehicle technicians in the vehicle repair industry. It also wanted owner responsibility for vehicle maintenance highlighted.

Several submissions recommended that the Road Code should be provided free of charge, or subsidised, or made available on the Internet.

The New Zealand Contractors' Federation submitted that fines gathered from traffic offences should be applied to driver education rather than added to the Crown Account.

Local Government New Zealand was concerned that a lack of skills might become a problem in some parts of the country, especially in rural and provincial areas (enforcement, education and engineering-related skills). Funding was needed for the LTSA to stage and develop training programmes for staff in RCAs, as part of the implementation process. Targeted funding or incentive programmes should be made available to ensure that young road safety engineers continued to be available.

TRAFINZ submitted that there was a need for skilled personnel in the educational, and particularly the engineering, fields. The LTSA should facilitate the provision of expert advice to road controlling authorities on best practice, and play a lead role in the development of training programmes for staff engaged in the planning and implementation of safety projects.

A number of other submissions were also concerned about a shortage of traffic engineering expertise in New Zealand.

The Wellington Regional Council suggested providing targeted funding for young engineers to study safety engineering, and introducing measures to improve the standard of driving instructors.

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Page created: 16 September 2002