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Summary of submissions
Comments on specific interventions
Other interventions
Light vehicle standards
A total of 95 submissions commented on light vehicle standards. Many of these suggested specific areas where they considered standards need improvement. The most frequently mentioned of these were vehicle ages, used imports, speed limiters, bumpers and bullbars, WOF standards, seatbelts, and exhaust emissions. One respondent considered that cars and drivers were the problem, not the road system.
Several submissions advocated banning cars over a certain age, and others wanted stricter limits on used imports. One respondent commented that second-hand imports had greatly benefited the New Zealand vehicle fleet, enabling people to buy better and safer cars, but regulations on imports needed tightening and enforcing. Another recommended that greater restrictions be placed on used imports to ensure safety standards. This respondent also pointed out that it had been stated recently that safety was a low consideration for New Zealanders buying cars. This could be because safety issues receive so little publicity. He suggested that the Ministry of Transport and the AA take the initiative in making available safety information about cars, as the manufacturers were unlikely to do this. The Dunedin City Council also advocated publication of more information about the safety merits of different cars, to put pressure on manufacturers to improve safety standards.
The Motor Industry Association said that the estimated safety gains from importing safer vehicles would not occur, because used imports and the overall fleet were ageing and older vehicles were becoming uneconomic to repair, although they were not being scrapped. It recommended that the LTSA be pro-active with policies to promote the importation of newer vehicles, for example by requiring driver-side airbags or compliance with Japanese frontal impact standards. Future systems should ensure that older vehicles had in-depth inspections to ensure they were safe, and the police should take into account that more unlicensed or unwarranted vehicles would be on the road.
One submission suggested requiring all new cars to have "intelligent" speed-limiting devices, that would allow short bursts of speed for overtaking and incorporate other 'high-tech' features to help drivers. Several submissions also suggested speed limiters or that the power of cars be restricted in future. The Hamilton City Council considered that technology could provide future scope for safety to be designed into vehicles. Another submission suggested that the suppliers of vehicles involved in speed-related crashes should be prosecuted for selling dangerous machinery capable of breaking the speed laws.
EECA submitted that there would be both safety and energy-efficiency benefits if car buyers were encouraged to buy vehicles that provided safety by design rather than by increased mass, because larger cars provided safety for their occupants at the expense of that of smaller vehicle occupants.
The Environment and Conservation Organisations of New Zealand would like to see new cars assessed for their effects on people other than the occupants. They considered that there should be restrictions on bullbars because of their effect on cyclists and pedestrians. Both CAN and Bicycle Nelson Bays agreed with this view.
The National Pedestrian Project questioned whether vehicle design would really improve safety for pedestrians over the next 10 years.
The Ministry of Health's Public Health Directorate considered that insufficient attention was given to characteristics of the old car fleet, and that low socio-economic groups might require financial assistance to improve safety features such as seatbelts.
Beca Carter considered that recreational vehicles constituted a safety risk in themselves because they restrict the visibility of other drivers. They acknowledged that it would be difficult to restrict the sale or use of such vehicles.
Barnardo's pointed out that one issue in the use of child restraints was the use of the upper tether mounting. They recommended a requirement for all Japanese imported vehicles to have at least one anchor bolt fitted before release from the wharf.
The Independent Motor Vehicle Dealers' Association supported the "smorgasbord" approach for recognition of technical standards established under the four main international regulatory systems. It said that it had adopted proactive support of measures to improve vehicle safety in the past and would continue to play a part in all programmes to enhance vehicle safety, while considering the needs of lower-income users who wanted to upgrade their vehicles.
Auckland Healthcare Services raised the issue of vehicle emissions as a public health risk. They considered that educating drivers about vehicle maintenance would help, and that emission testing should be mandatory as part of a WOF check. Another respondent wanted exhaust emissions to be tested as part of WOF and COF tests.
Several respondents thought that WOF tests were not rigorous enough or that there was insufficient enforcement of warrants and licensing. The Gisborne District Council thought that the separate licensing and warrant systems should be combined. The resulting lower costs would encourage more people to license and warrant their vehicles. Another respondent thought the WOF system was a joke, that it was time consuming and costly for companies but still allowed "old junk heaps with bald tyres" on the road. The Kawerau District Council wanted no tolerance for non-compliance with warrant and licence requirements.
Other vehicle safety issues mentioned were: safety chains for trailers, vehicle colour, the need for visibility stripes on vehicles, tyres, airbags, headlights, anti-glare windscreens, and full-harness safety belts.
The Council of Trade Unions asked that the LTSA seek ways to support people who drove as their job so that they were provided with safer vehicles.
There were very few comments relating to easing standards. One respondent thought that rust restrictions should be less rigid if the rust was not structural. Another thought that New Zealand's WOF testing was too severe, and should be carried out only once a year.
Heavy vehicle standards
A total of 94 submissions commented on heavy vehicle standards. The comments covered a range of issues, and many considered that heavy vehicles needed more regulation of some sort. Driver behaviour was perceived as a problem — trucks exceeded their speed limit, created an obstacle for overtaking by not keeping left, and tailgated other vehicles.
Tighter standards and COF requirements, and better enforcement of these, were frequently recommended. The Rotorua District Council recommended better auditing of COF certifiers to ensure consistency, and more of a focus on safety issues such as brakes, tyres, and lights. Other submissions suggested more monitoring of time, distance, speed and driving hours by means of on-board recorders, and tyre pressure sensors to give warning to the driver of tyre problems. Another suggested establishing a truck speed signage system as used in Europe, whereby trucks displayed their maximum speeds, along with an 0800 number to report violations. A number of other submissions also wanted some way of controlling the speeds of heavy vehicles.
Reduced visibility caused by spray in wet weather was another common concern. One submission suggested using a different design of mudflap to dissipate the spray. The Southland District Council wanted a standard for the use of spray skirts.
The Environment and Conservation Organisations of New Zealand wanted consideration given to requiring trucks to have side shields, to prevent cyclists being sucked under them and to reduce windage. They claimed that this would also improve fuel efficiency for the operators.
The Taranaki Regional Road Safety Co-ordinating Group suggested compulsory installation of seat belts in all vehicles.
The AA also pointed out that most crashes involving a truck resulted in a motorist being killed or injured, and that it therefore supported measures to improve stability and conspicuity. Another submission expressed surprise that New Zealand had not adopted international standards for heavy vehicle conspicuity.
The Road Transport Forum referred to its submissions on truck safety made to the Minister in September 2000, and was pleased to note that most of its recommendations had been accepted.
Several submissions considered that more freight should be forced to use the rail system. Motor Sport New Zealand considered that peak loads of heavy vehicles were wearing out the roads too quickly.
The Hutt City Council was not convinced that heavy vehicle operators were meeting their full road-user costs, especially in relation to maintenance of minor roads. This applied in particular to forestry operations and transport distribution centres.
Overloading of logging trucks was a concern for more than one respondent. Stock truck effluent was another issue mentioned by several respondents.
The Southland District Council mentioned that heavy vehicle owners, including bus companies, sometimes set unrealistic schedules so that drivers had to speed — an example was the Queenstown-Milford daily return trip. Another respondent mentioned the need to restrict the number of hours a driver could be on duty, regardless of whether he was driving for the whole time.
Existing construction
A total of 90 submissions commented on existing road construction. Many of these put forward specific road improvements that they considered should have priority. Among the areas that people thought needed improvement were: signage (in general, and for roadworks), road markings, roundabouts, road surfaces, cambers, medians and shoulders.
Several submissions raised issues about cyclist and pedestrian-friendly construction.
One submission commented that New Zealand's roads were very good, especially in the South Island. Another (from the Canterbury region) considered that the roads were too wide and gave drivers a false sense of safety and security. Another argued that roads did not cause crashes, and there was no such thing as an unsafe road provided drivers used care and attention and took the road condition into account.
One respondent pointed out that, although it was costly, road engineering had to be a continual process or the demands of traffic would force it anyway, regardless of what other measures were put in place. Another recommended never allowing maintenance to slip, even for one year.
Funding issues were raised again, in particular that taxes levied from road users should be used on the roads. Another comment, from Marlborough Health Promotion, was that funding should be based on standards priority, with a minimum standard set for roads, starting with state highways, with priorities set by the community.
The Wairoa District Council commented that the existing programme was pitifully inadequate to address current deficiencies. The Ashburton District Council asked for an increase in Transfund minor projects allocations. The Stratford District Council called for a review of how road funding was allocated, so projects with a low B/C ratio because of low traffic volumes could get Transfund assistance.
One submission commented that our current road engineering was of a poor standard because of the cost-cutting required in road building. Another called New Zealand's roads the worst designed, built, and maintained in the world, because the Government stole the taxes levied for roading. Another called for a review of the standard of road repair and construction.
Canterbury Highway 2000 was concerned about the proliferation of road signage and other visually-polluting measures, and believed that good design would encourage better behaviour on the roads.
One submission expressed concern that responsibility for planning, design and operation of roads had been fragmented, and that staff had inadequate training and experience.
Transfund commented that investment in the road infrastructure had already made a material impact on road safety. It pointed out that international research demonstrated that road infrastructure contributed to around 20% of crashes, and that engineering improvement could be a cost-effective solution even for crashes to which the infrastructure was not a contributing factor. Current programmes were both reactive (blackspot programmes) and pro-active (safety audit). Transfund had increased expenditure on road safety improvement in recent years from approximately $280m in 1996/97 to approximately $350m in 2000/2001. Transfund estimated that 35-40% of the road-user benefits from the mix of current construction projects were safety-related benefits. In addition, Transfund had increased its allocation for Minor Safety Projects from $11.25m in 1999/2000 to $18.31m in the 2000/01 year. The value of the individual projects allowed in this category was also increased from $50,000 to $75,000.
Vulnerable road users were mentioned a number of times. More than one respondent commented that the rights and safety of cyclists and pedestrians were often ignored by roading engineers, and that there was a lack of safe crossing places. Another respondent pointed out that roundabouts were not cycle friendly and cycle lanes made cycling less safe by speeding up the traffic. Cycling Support New Zealand Inc commented that roading left too much to chance for cyclists, and recommended involving them more in planning and design, or sending engineers out on bicycles to see what problems they caused. The Manukau City Council asked for more flexibility in funding of cycle and pedestrian facilities where traffic volumes, speed and other factors made it unsafe for them to use the road network. If demand was suppressed on these roads, it would not show up in the form of a poorer safety record.
Plunket commented that children were at risk on urban roads as pedestrians, and that the environment should be made safe for them
Blackspots
A total of 54 submissions responded on the subject of blackspots, around a third of which were local authorities. Very few of the responses did not support blackspot treatment. Some which did support it wanted a more proactive approach to funding these improvements, rather than the current B/C method.
The ACC submitted that blackspot programmes in Australia had produced high B/C ratios. It considered that, if the additional funding were allocated to blackspot treatment, it would result in social cost savings in excess of the estimated 2.1%. In particular, the use of skid-resistant road surfaces would offer a relatively low-cost solution.
The Auckland Regional Authority and Roadsafe Auckland recommended that there should be ways of facilitating the sharing of best-practice engineering solutions from the results of safety audits and blackspot studies.
Federated Farmers called for improved identification of blackspots.
The New Plymouth and South Taranaki District Councils and the Taranaki Regional Council supported increasing blackspot treatments but wanted more than just 'retrofitted' safety measures like signs. They also supported more visible enforcement activity in blackspot areas where speed was a problem and the creation of wider roads with more passing lanes to decrease driver frustration.
The Otorohanga District Council considered that improved road quality after blackspots were treated might encourage speeding and require more enforcement.
The Marlborough Road Safety Community Group and Marlborough Health Promotion both advocated a category called "grey spots" for areas where there had been two or more crashes.
The Hastings District Council supported a strategic approach to funding blackspots or problem areas. Funding should not be withheld because of insufficient crashes as occurred with the current B/C system.
Opus International Consultants submitted that engineering treatments should be proactive and applied to sections of highway to ensure consistency. Reactive treatments at blackspots made without consistency with the local network might just shift a crash problem to another location.
Beca Carter also promoted a proactive approach, and recommended upgrading "surprise" alignment elements, rather than responding to fatal crashes. They also support friendlier roadside environments and the installation of crash barriers, particularly in mountainous terrain.
Southland District Council advocated a more holistic approach, arguing that rural roads did not have black or grey spots but "black causes" — similar types of crash happened randomly across the rural network. Funding should be made available to address these "black causes", for emergency services, local education campaigns and targeted enforcement.
The Waimakariri Road Safety Co-ordinating Committee considered that blackspot treatments should be 100% government funded.
One submission considered that driver factors and vehicle maintenance were more important, given that millions of dollars had already been spent on known blackspots such as the Mercer Straight, Rangiriri, and the Waihi-Tauranga road, but crashes still happened there.
Stricter licensing conditions
The majority of those who responded about stricter licensing conditions for young and novice drivers, supported stricter licensing conditions generally without particular reference to the GDLS. There was a perception that it was currently too easy to get a driving licence and to get away with breaching the conditions.
Federated Farmers commented that the effect of the GDLS needed to be fully evaluated. New Plymouth District Council agreed that the full effect of the recently-tightened conditions had yet to be felt, but suggested that the licence conditions should emphasise experience rather than age.
Many submissions considered that defensive driving or other professional driving courses should be compulsory for learners. Some thought these courses should be subsidised or free.
The Ministry of Agriculture and Forestry submitted that stricter licensing was preferable to raising the driving age. Roadsafe Nelson Bays had a similar view.
The Waimakariri Road Safety Co-ordinating Group asked for stricter enforcement of restricted licences and more education of parents and teenagers on the implications of breaching licence conditions.
Two driving schools made specific comments on the GDLS. The Cashmere Driving School recommended that there should be no minimum time on a learner licence before being able to gain a restricted licence, because most learner licence applicants began to drive closer to the time when they were eligible to sit the restricted test. If they did begin to drive immediately after passing the learner licence, the time delay was detrimental to learning and interrupted progressive teaching methods. Learner drivers were not at risk but restricted drivers were, while gaining experience unsupervised. To encourage drivers to move through the GDLS, graduated licences should have an expiry date — learner licences should expire two years after the day they were issued, and restricted licences four years after the issue date. The "automatic-only" endorsement should apply to the full licence as well as the restricted licence, if the driving test was passed in an automatic vehicle. It also commented that, if a licence was easily obtained it had little respect and no credibility.
The Corrigan Driving School thought that there should be a minimum 6-month period for learners, to allow more development of practical and perceptual; skills. It believed that a comprehensive test of driver competency was essential, but the restricted test was a waste of time and the full licence test had become diluted and too easy to pass. It also supported expiry dates on licences to encourage people to progress through the system.
The Insurance Council of New Zealand Ltd considered that the licence system was weak, because learners could stay on restricted licences indefinitely. It believed there should be a 24-month maximum period before having to do an exit test and recommended a maximum term of 12 months on a learner licence.
The Wellington Regional Council and the Marlborough Road Safety Community Group advocated keeping the GDLS under review, and changing it as necessary.
Restraint wearing
Most of the submissions that responded on restraint wearing supported the option of intensifying police enforcement to eliminate regional differences in wearing rates and to bring all regions up to the standard of the best. Some advocated random checks and instant fines, although Roadsafe Nelson Bays suggested that the effectiveness of fines in areas of low socio-economic conditions should be carefully considered. It believed that education and one-on-one work with families rather than increased penalties would be more effective in reducing regional variations in restraint wearing.
The Kaikoura District Council considered that cars leaving schools and supermarkets could be targeted.
The New Plymouth District Council suggested a programme to target restraint wearing by all passengers in heavy vehicles, particularly children.
The Waimakariri Road Safety Co-ordinating Committee recommended targeting enforcement at specific times, and suggested that it would be more effective to target shoppers than commuters.
Barnardo's wanted to see a target of 100% compliance with the child restraint law, and suggested that this could be achieved by increasing funding for rental and purchase of restraints, with clear and correct information provided to educators, and enforcement and advertising. They also raised the issue of the correct use of child restraints, and wanted to see the joint Australia/New Zealand Standard imposed, rather than the four different standards that currently existed.
Those who disagreed with the proposal considered that wearing restraints should be a decision for the individual, and not compulsory. The Nelson City Council recommended addressing regional differences in wearing rates by education rather than by enforcement.
One respondent was sceptical such a measure could be enforced, if implemented.
Vehicle impoundment
A total of 53 submissions commented on the recently-introduced law allowing the impoundment of vehicles in some circumstances if their drivers were found to be unlicensed or disqualified. Most of those who commented supported the impoundment regime. A number wanted the scheme extended to cover, for example, excessive speeding and other serious traffic offences. Marlborough Health Promotion wanted to see the provision extended to include those driving with twice the legal BAC, and those exceeding the speed limit by 50 km/h or more.
The Bailey Partnership considered that the new legislation was working well in reducing the number of convicted drinking drivers who were also disqualified, and recommended that the scheme be evaluated.
The Hospitality Association of New Zealand commented that this measure and the photo driver licence were already having a significant impact and targeting those who caused the problems, without unduly affecting the majority of citizens.
Wairarapa Health commented that this policy should improve vehicle standards, with disqualified and recidivist drink drivers removed from the road.
Kaipara District Council, however, stated that the vehicle impoundment scheme seemed to have turned into an abandoned vehicle programme, with 50% of vehicles impounded in Northland not being reclaimed. The Taranaki Regional Road Safety Co-ordinating Group wanted to see tow truck drivers compensated for unclaimed vehicles.
Licence suspension
A total of 47 submissions commented on the recently-introduced measure of roadside licence suspension, for driving with twice the legal BAC, refusing to take a blood test or exceeding the speed limit by more than 50 km/h. Similar comments were made for this proposal to those for vehicle impoundment — people supported the measure, but considered that it could be extended to cover a wider range of offences.
Several commented that drivers who had had their licences suspended should have to re-sit their licence tests and do defensive driving courses. Others considered that licence suspension should be accompanied by education. One respondent thought that people who caused crashes should have their licences suspended. The need for increased patrols to enforce this was also mentioned.
Legal hours of darkness
A total of 83 submissions commented on the proposal to extend the legal hours of darkness so that drivers would have to use their headlights for a longer period of the day. The proposal was to extend the legal definition of "hours of darkness" by one hour at each end of the day. The current hours of darkness are from half an hour after sunset until half an hour before sunrise.
Most of those who supported increasing the legal hours of darkness in fact favoured compulsory daytime running lights. There was a perception that any vehicle modifications which might be necessary to make headlights switch on automatically with the ignition would be cheap and easy to install. Several submissions mentioned European and US experience of road safety gains when daytime running lights were introduced. The South Taranaki District Council recommended the compulsory installation of daytime running lights in new vehicles. Several submissions also mentioned that motorcycles used headlights voluntarily during the day to reduce their crash risk.
A smaller number of respondents agreed with the proposal, or some variation of it. One recommended the use of headlights from two hours before sunset, and in fog or heavy rain. Roadsafe Auckland thought that headlights should be wired to switch on with the windscreen wipers. Other respondents recommended that the proposal be extended to include all periods of low visibility, or whenever the sun was not visible or it was raining. The Ruapehu District Council recommended the use of headlights by all light vehicles on motorways and state highways.
The AA commented that the problem was not just dawn and dusk hours but at all times of low visibility. The general problem was that people did not realise how difficult it was to see their vehicles in such conditions. Therefore they recommended more education and publicity to encourage the voluntary use of headlights at times of low visibility. The Waimakariri Road Safety Co-ordinating Committee also considered that an education campaign would be preferable to a legal requirement.
Two submissions commented that hours of darkness were inconsistent between various pieces of legislation, and that this should be remedied. Another called for clearer definition of the rules.
One respondent vehemently opposed daytime running lights, but did not comment on the proposal. Two submissions considered that the use of headlights during twilight could reduce visibility. One of these was referring to pedestrians and cyclists, who might become less visible as drivers focused on headlights. The other considered that flashes of light would add to the hazards, and that in rain the refraction of light would cause confusion whereas in fog the light bounced back and caused a form of whiteout. This submission considered that the use of sidelights was preferable, although others thought the use of parking lights while driving should be banned. One respondent thought that using lights on high beam in the daytime and wearing dark glasses in poor light conditions should be a traffic offence.
Trauma management
A total of 25 submissions commented on trauma management, which is the response by emergency, medical, and rehabilitation services to road crashes.
The Ashburton District Council commented on the inadequate funding of emergency response units in rural areas, and sought more scope for addressing this. Marlborough Health Promotion and the Marlborough Road Safety Community Group also asked for these services to be properly resourced. The Southland District Council submitted that funding needed to be made available for emergency services in rural areas.
One respondent praised the use of helicopters and the opportunity they provided to save lives.
Auckland Healthcare Services wanted protocols developed for the treatment of chemically-contaminated road crash victims.
Safety management systems
Of the 50 submissions that commented on safety management systems, most were positive, though to varying degrees.
The Manukau City Council commented quite extensively. It suggested that the regime should focus on the fostering of best practice and continuous improvement, rather than a heavy-handed compliance approach, and that it should be administratively efficient and effective and not impose an undue burden on RCAs. Compliance should be audited at a systems/network level and the auditing body should not get involved in operational aspects best managed by the RCA.
The Council considered more work to be necessary to identify relevant and measurable safety indicators related to road conditions, because this was only one of many contributors to crashes and the others were mostly beyond the control of RCAs. It was also necessary to give careful consideration to the culture and expertise of the national body responsible for establishing the safety regime and monitoring RCAs safety performance — a flexible and partnering approach was important.
Transfund believed that comprehensive deployment of safety management systems by road-controlling authorities was needed to provide the appropriate framework within which the benefits of pro-active accident risk identification and pro-active identification of safety improvement projects could be maximised. Safety management systems ensured that all opportunities to improve road safety were identified, considered, implemented and evaluated in all phases of road planning, design, construction, operation and maintenance.
The Ashburton District Council suggested that having a safety management system in place could become a prerequisite for obtaining Transfund funding. TRAFINZ also considered that this could be the basis for funding safety works. The Contractors' Federation also submitted that increased financial assistance could be an incentive to road-controlling authorities which performed well.
MAF Policy questioned the rationale of implementing safety management systems at local authority level, and believed that they should operate at a regional level instead. They suggested a further narrowing of the parameters for such a system, by establishing a national standard that would result in one system being developed for the entire country that would operate at a regional scale through modification of minor parameters.
The National Pedestrian Project considered that, for safety management systems to be effective in addressing pedestrian safety, road-controlling authorities would need to be clearly accountable for the safety of all types of road user, including pedestrians. Safety management systems would also need to set clear safety objectives for all road- user groups (including pedestrians); and to set safety objectives along with the levels of activity desired for pedestrians, and for monitoring of pedestrian activity rates to occur alongside pedestrian injury rates. They would also need to audit, monitor, and report in relation to pedestrian policies and activities; monitor transport-related hospital injury data for their areas; and have in place risk identification and management systems which addressed injuries due to poorly-designed or maintained footpaths.
CAN recommended that road-controlling authorities be required to include a target for increasing cycling in their safety management systems, and that they set out clear expectations that cyclists' needs would be considered in all roading work. Staff training in cyclist issues should also be required. The Otaki Cycling Environment and Access Network thought that safety management systems could lead to a perverse result of "safety = less cycling". If the target was to reduce the number of cycle crashes, road-controlling authorities might be tempted to achieve this by reducing the number of people cycling.
The Franklin Kidsafe Coalition considered that road-controlling authorities should be accountable for identifying impacts on all road users, including children as motor vehicle passengers, as pedestrians, and as cyclists.
Waimakariri Road Safety Co-ordinating Committee considered that safety management systems should be encouraged, but not compulsory.
The Central Hawke's Bay District Council expressed interest in the concept and asked for more information.
The Gore District Council was concerned about the likely difficulty of obtaining staff with expertise in safety management systems.
Efficiency gain
There were very few comments about the road safety benefits of increased efficiency in the delivery of existing interventions.
The New Zealand Contractors' Federation expressed concern that increased expenditure was being proposed when it was unclear whether the existing expenditure was being used efficiently. It submitted that road safety expenditure should be benchmarked against overseas jurisdictions and not just given the rubber stamp by peer reviewers.
The Road Transport Forum recommended that there be a rigorous review of all existing road safety programmes, with a view to optimising the benefits obtained from the existing expenditure. It also recommended benchmarking against comparable overseas countries.
The Hastings District Council commented that the emphasis should be on support for police enforcement — without it, the other aspects were a waste of money.
Page created: 16 September 2002