Our Submissions
Our contributions to national and local government policy
Draft Land Transport Rule: Setting of Speed Limits Rule 2024
Date submitted: July 2024
Trafinz submission noted:
the National Party’s promise during and post election that speed limits would not be increased “where it would be unsafe to do so”. However, none of the proposals for reversing speed limit reductions have a safety assessment associated with them. International evidence is very conclusive that increasing speed limits exponentially increases safety risk, and that 100km/h rural and 50km/h urban speed limits are not the Safe and Appropriate Speeds for most rural and urban roads in New Zealand.
extreme disappointment that the new Rule’s focus on undoing supposed ‘blanket speed limits’ and implementing lowest common denominator distances for speed limits outside school gates and times of operation will:
adversely impact good speed management work by local authorities and their reputation with their communities developed over many years;
take away the ability of local authorities to make decisions based on the specific and varied needs of their communities;
increase delays to traffic by over 200%, or over three times, compared to the current, well researched and tested times of operation; and
cost larger local authorities more than $600,000 each to undo recently completed work at a time when local authorities have already set their Long Term Plans for the 2024-25 year and such (unwarranted and wasteful) expenditure has not been provided for
Draft Government Policy Statement on Land Transport 2024-34
Date submitted: April 2024
Trafinz welcomes the opportunity to make a submission to the Ministry of Transport on the Draft Government Policy Statement on Land Transport 2024-34 (GPS 2024).
Trafinz supports aspects of the GPS 2024, however we do have a number of specific issue/concerns which are outlined in more detail in the following document.
Draft Government Policy statement on Land Transport 2024
Date Submitted: September 2023
Trafinz supports the strategic directions of ‘Maintaining and Operating the System’ and ‘Increasing Resilience’. However, Trafinz considers that the Draft GPS 2024 is currently a missed opportunity to strengthen our response to climate change. The Indicative Strategic Priorities Engagement Paper released by Te Manatuu Waka Ministry of Transport in early 2023 had proposed to elevate emissions reduction to become the overarching focus for GPS 2024, so it is disappointing that this Draft GPS 2024 has moved away from this direction, and we would like this to be addressed.
Land Transport Rule Traffic Control Devices (Bilingual Signs) Amendment 2023
Date Submitted: June 2023
Trafinz welcomes the opportunity to make a submission to Waka Kotahi NZ Transport Agency’s Land Transport Rule - Traffic Control Devices (Bilingual Signs) Amendment 2023 - Draft for Consultation.
Trafinz stresses it is generally supportive of the philosophy of bilingual signs in Aotearoa and welcomes their introduction as and where appropriate
Euro 6/VI vehicle emissions standards consultation
Date Submitted: June 2023
Trafinz is supportive of the Ministry of Transport’s Proposed Amendments to the Land Transport Rule: Vehicle Exhaust Emissions 2007, however Trafinz would like to see greater consideration of how the impacts of the Proposed Amendments will affect emissions that are harmful to the climate, and how far the Proposed Amendments will go towards achieving emissions reductions and targets set out in the Emissions Reduction Plan.
Land Transport (Road Safety) Amendment Bill
Date Submitted: May 2023
Trafinz is supportive of the provisions in the Land Transport (Road Safety) Amendment Bill. Trafinz are particularly supportive of ensuring that point-to-point safety cameras can be used as an enforcement tool for speeding offences, particularly as such cameras are internationally recognised as an effective tool for addressing inappropriate speed on the network
Reshaping Streets regulatory changes 2022
Date Submitted: September 2022
Trafinz supports the proposals for a set of regulatory changes to make it easier for local authorities (like councils) to make street changes that support public transport, active travel and placemaking, encouraging emission reduction and road safety
The impact of automated vehicles operating on Aotearoa New Zealand roads
Date Submitted: July 2022
Trafinz notes that without adequate national policy and protocols for the introduction of AVs, the proliferation of private Internal Combustion Engine (ICE) AVs in particular could be counterproductive from economic, efficiency and safety perspectives
Emissions Reduction Plan 2021
Date Submitted: 24 November 2021
Trafinz supports the proposed targets for motor vehicle emissions reduction and argues for faster progress towards a climate resilient future.
Speed Limits Rule 2021
Date Submitted: 21 July 2021
Trafinz strongly supports the proposal for a new centralised system for setting and recording road speed limits and makes suggestions for better integration of processes for State Highways and local roads. We suggest better timetabling and ways to reduce any duplication of consultation where area proposals are well advanced.
Accessible Streets Regulatory Package 2020
Date Submitted: 20 May 2020
Trafinz strongly supports the setting of new Rules, especially for the use of our footpaths. We support a National framework with the ability for local choice on speed limits and permitted users.
Road to Zero
Date Submitted: 14 August 2019
We fully support the draft Strategy. Strong action plans will be needed and the role of local government needs greater recognition.
Driver Impaired Driver Testing
Date submitted: 1 July 2019
Trafinz argues for a focus on testing for Driver Impairment and prevention of harm, with prompt referrals to the health system.
Driver Licensing Amendment
Date submitted: 23 April 2019
Due to road safety concerns Trafinz does not support removing the requirement for driver eyesight testing at the 10 yearly renewal of driver licenses
Light Vehicle Brakes Amendment
Date submitted: 23 April 2019
Trafinz strongly supports a requirement for motor cycles to be fitted with ABS, with a few minor exceptions, and argues for faster implementation
NZTA Regulatory Performance and date March 2019
Date submitted: 1 March 2019
Trafinz supports NZ Transport Agency staff in their work with TLA’s on Speed Management and gives examples.
We recognise the urgent need to speed delivering safe speed environments, but this cannot be achieved by NZ Transport Agency alone.
Submission on Traffic control devices manual Part 5: Traffic control devices for general use - between intersections. Part 5
Date submitted: 18 September 2018
Trafinz comments on the need to carefully consider the safety of all users, not just motor vehicle users, when giving guidance on signs and markings, and recommends several changes and additional research
Submission on Land Transport Rule: Regulatory Stewardship (Omnibus) Amendment 2018(the Omnibus Rule)
Date submitted: 28 August 2018
Trafinz supports the amendments which generally tidy up and clarify recent changes to Acts and Rules. We also comment on the need to address problems caused by parking on berms behind the kerbs on our local roads.
GPS18 (2018-28)
Date submitted: 2 May 2018
Trafinz welcomes the new strategic focus, with priority to safety and access and the rebalancing of funding across a more inclusive range of modes. Suggestions are made about ways change should be implemented, to deliver better social, economic and environmental outcomes.
Speed Limits Rule 2017
Date submitted: 16 June 2017
Trafinz strongly supports the new speed limits rule and makes suggestions on its implementation. Such as, the use of Council Resolutions for new speed limits....
Engagement Draft GPS2018
Date submitted: 30 March 2017
Trafinz welcomes the references in the draft to an integrated land transport system approach and evidence based policy development. We make several suggestions...
Submission on Land Transport rule: Operator Licensing 2017
Date submitted: 21 November 2016
Trafinz welcomes the references in the draft to an integrated land transport system approach and evidence...
Vehicle Dimensions and Mass Rule 2016
Date submitted: 12 August 2016
Trafinz is not supporting much of this proposed Rule, in particular extra vehicle mass, width and height for goods vehicles in general use. We are concerned about the extra local road pavement damage. The submission supports new safety equipment on trucks, better monitoring by operators of route and loading and more efficient enforcement.
2016 Omnibus Rules Amendment
Date submitted: 12 August 2016
Trafinz supports almost all of these proposed Rule changes. Some have come from the 2014 Cycling Panel report.
Charging Infrastructure for Electric Vehicles
Date submitted: 8 August 2016
This submission supports RCA's (Councils) being responsible for the siting of charging stations on street.
Submission on the Review of the Vehicle Dimensions and Mass (VDAM) Rule
Date submitted: 17 February 2016
Small Passenger Services Review
Date submitted: 12 February 2016
Click on the link below to view the submission that Trafinz submitted.
GPS2015-Engagement Draft Submission
Date submitted:11 August 2014
Safer Speed Programme Submission
Date submitted: 9 May 2014
Feedback on the safer speed programme presentation.
2013 Achievement Report
Date submitted: 4 April 2014
Land Transport Amendment Bill
Date submitted:13 February 2014
TRAFINZ's submission on the Land Transport Amendment Bill. Trafinz supported the proposed reduction in allowable blood alcohol for drivers from 0.8 to 0.5 and suggested other future initiatives to support the change.
Draft ITS Action Plan
Date submitted: 20 January 2014
See below to read about Trafinz’ submission on the Draft ITS Action Plan. Trafinz strongly support the proposed actions, in particular those that relate to improving the safety and productivity of the land transport system. They have specifically commented on Clauses 5.6; 5.9 and 5.10.
Safer Journeys for Rural Schools Guide
Date submitted: 16 October 2013
A submission from Trafinz on safer journeys for rural schools that involves several recommendations.
Palmerston North Speed Limits Review
Date submitted: 26 July 2013
A submission that focuses on the use of 40kph speed zones around school areas.
Omnibus Amendment Rule
Date submitted: 21 July 2013
Trafinz supports the rule change, but had some suggestions to make regarding School Patrol Signs and School Bus signage and parking.
Vehicle Licensing Reform Submission
Date submitted: 31 October 2012
Submission from Trafinz to the Ministry of Transport on vehicle licensing reform.
Land Transport Management Amendment Bill
Date submitted: 26 October 2012
A submission to the Transport and Industrial Relations Select Committee suggesting that the reading be changed "to contribute to an economically efficient, safe, accessible, socially inclusive and environmentally sustainable transport system."
FAR Review
Date submitted: 21 July 2011
A submission on proposals for targeted changes to the 2012 National Land Transport Programme co‐investment ratios (funding assistance rates).
Submission Government Policy Statement (GPS)
Date submitted: 27 May 2011
A submission on the Government Policy Statement 2011.
Land Transport Driver Licensing Amendment Bill
Date submitted: 21 October 2010
A submission on the Land Transport Driver Licencing Amendment Bill. TRAFINZ supports the Bill, though would like to see it go further.
Land Transport Road Safety & other matters amendment Bill
Date submitted: 21 October 2010
A submission on the Land Transport Road Safety and Other Matters Amendment Bill. Trafinz supports the Bill as including a valuable set of initiatives to promote road safety and under ‘other matters’ assist in the management of Council owned land.
Proposal for the 2020 Road Safety
Date submitted: 02 October 2009
Our proposals to assist in the development of a Road Safety Strategy for the upcoming decade to 2020.
BAC Letter - May 2009
Date submitted: 07 May 2009
It is submitted that a national blood alcohol content (BAC) limit should give clear formal guidance to drivers to promote safe driving practices. TRAFINZ believes that New Zealand’s current legal adult limit of 0.08, does not do this.
Amending the Government Policy Statement
Date submitted: 16 March 2009
This paper is to provide some experience responses on the GPS discussion document to help facilitate the development of a local government sector response.
Guidelines for Facilities for Blind and Vision-Impaired Pedestrians
Date submitted: 13 December 2007
Trafinz has a strong interest in pedestrian safety as part of its wider interest in transport safety in New Zealand.
Level Crossing Guideline Nov 07
Date submitted: 16 November 2007
Trafinz has a strong interest in rail safety as part of its wider interest in transport safety in New Zealand, and we recognize the important role that rail plays in the wider community and national economy.
Omnibus Amendment Sept 2007
Date submitted: 14 September 2007
A submission on the yellow draft of Land Transport Rule : Omnibus Amendment (Rule 10003)
Police Act Review
Date submitted: 31 July 2007
Trafinz has focused its submission on transport activity as from scientific research virtually every criminal act within our society has a transport component and hence policing and transportation are inexplicably linked.
Guideline Parking Control (Volume 13)
Date submitted: 27 July 2007
Our comments on the Parking Control (Volume 13) draft document July 2007.
MoT Review of the Transport Act 1962
Date submitted: 08 July 2007
New Zealand Traffic Institute submissions on the Ministry of Transport review of the Transport Act 1962.
Land Transport (Road User) Amendment Rule
Date submitted: ???
In developing this submission we have discussed the proposed Rule changes at a meeting of our Executive.