2024 AA submissions to Government and other agencies
ACC Levy rate consultation for 2025-2028
October 2024
The Accident Compensation Corporation (ACC) recently undertook its three-yearly consultation on the Motor Vehicle Levy. Levy rates for 2025-2028 are set to increase, with rate holds in recent years and projected rising injury costs cited.
The AA recognises that the ACC levy does need to rise to meet future injury costs, but we have made suggestions aimed at softening the blow, mindful of the economic climate. Specifically:
- Shifting the higher increases to the latter part of the period when economic conditions have hopefully improved.
- Collecting at least some of the levy increases as part of the fuel pump price for petrol vehicles because it’s the most affordable collection method, hardest for people to avoid, and is least noticed (compared to hiking people’s annual vehicle registration bills). Collecting more at the pump also slightly lessens the issue faced by owners of multiple vehicles who pay a registration fee for each vehicle yet can only drive or ride one at a time.
We agreed with ACC’s proposal to collect the full levy rate from BEV/PHEV owners so they start paying their fair share, particularly given the reduced rate is not considered a meaningful incentive for BEV/PHEV purchases.
We acknowledged ACC’s desire for motorcycles to cover more of the cost of their injuries but noted that the levy rates proposed for high-powered motorcycles are very high, which we think will lead to more riders looking for ways to avoid paying the levy.
Read the AA’s submission on the ACC Levy Rate Consultation 2024
AA submission on proposed tolling schemes
October 2024
NZTA has sought feedback on proposals to toll three new roads: the Takitimu Northern Link in the Bay of Plenty, the Manawatu-Tararua Highway, and Otaki to North of Levin.
The AA recognises that tolling new roads can assist with their delivery and is therefore open to tolling new roads in principle. However, the AA does not support these tolling proposals, on the basis that all (apart from Stage 2 of the Takitimu Northern Link) have full construction funding, meaning revenue from tolling is not needed to enable them to be built. The AA also does not support tolling solely for maintenance and operational costs, as these should be covered by the National Land Transport Fund. Finally, we don’t support charging higher tolls at peak times, as is proposed for the Takitimu Northern Link.
The AA is reviewing its positions on tolling in light of the Government’s expectation that tolling will play a greater role in funding the transport system than it has in the past. The outcome of this work will influence the positions the AA takes on tolling proposals going forward.
Submission on Draft Medical Aspects of Fitness to Drive Guide for Health Practitioners
September 2024
This Guide was last updated in 2014 by the NZ Transport Agency-Waka Kotahi. With New Zealand’s population aging, and our health system under pressure with people less likely to see a GP who knows them well than in the past, it is overdue for an update.
Losing your driver licence at any age is significant because it impacts your freedom to access services and social opportunities. But it’s also critical that the drivers on our roads are safe. Our driver licence testing systems therefore must be thorough and fair.
There is a significant spread of medical conditions that can impact on a person’s ability to drive - it is a complex issue. The AA therefore supports continuing to rely on GPs discretion but would like better guidance for GPs and any testing undertaken to be more robust, relevant and fit for purpose.
We think much better information needs to be provided to both GPs and older drivers to help them navigate this issue, and clearer information about the options for limitations on driver licences (eg. no night driving) could be particularly helpful to mitigate an individual’s particular safety risk.
There can be barriers for older drivers needing occupational therapy or on-road assessment to meet re-licensing requirements and minimising these barriers for older drivers need to be considered in the same way as there are initiatives to assist younger people struggling to get a licence.
Going forward, the system must allow for ongoing review to capture social, technology and transport system changes.
Submission on the Land Transport (Drug Driving) Amendment Bill
August 2024
The focus of the AA on this issue is around the deterrence and removal of drug impaired drivers from the road.
We support the introduction of roadside oral fluid drug testing as a tool available to Police in New Zealand – as is the case in a number of other countries.
We recognise this is a complex issue but we feel the approach set out in the Bill strikes the right balance to enable meaningful enforcement action against drivers who are impaired by drugs while having safeguards in place to ensure individual’s rights and freedoms are protected.
Read the AA’s submission on the Land Transport (Drug Driving) Amendment Bill
Submission on the Draft Second Emissions Reduction Plan (ERP2) for 2026-2030
August 2024
The AA’s submission focused on transport-related policies proposed in the Government’s ERP2. It provides our views on the following topics:
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Support for strong electric vehicle (EV) smart charger standards.
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Concern that insufficient funding is in place to reach the goal of 10,000 public EV chargers by 2030.
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Concern that without other policy interventions, the pace of transitioning our fleet to EVs will be slower than previous assumptions.
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Support for major public transport projects currently underway and a desire to see clear future plans for public transport through to at least 2030.
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Desire for clear public information on how ETS levies on fuel contribute to reducing transport emissions and providing more sustainable transport options for people.
Overall, the AA has expressed our concern that the policies in ERP2 are insufficient to achieve the emissions reductions needed to meet New Zealand’s commitments under the Paris Agreement and the country’s goal of carbon neutrality by 2050.
Read the AA’s submission on the Draft Second Emissions Reduction Plan (ERP2) for 2026-2030
Submission on 2024 Draft Land Transport Rule (Setting of Speed Limits)
July 2024
The AA’s submission provided feedback on the proposed new Rule, including that we:
- Support cost-benefit analysis being undertaken for speed limit changes
- Would like to see further improvements to public consultation, including longer consultation periods
- Agree with the principle of lower speed limits around schools, and generally consider variable speed limits along with flashing electronic signage to be the most appropriate approach
- Do not consider designing and building roads to a 120km/h standard is the best use of investment
Download the AA's submission on the 2024 Draft Land Transport Rule (Setting of Speed Limits)
Submission on NZTA-Waka Kotahi Emergency Works Policies Review
June 2024
Along with local authorities, the AA was invited to submit on proposals that would make some changes to funding available for recovery from significant events that damage transport infrastructure.
The proposals include changes to funding application processes as well as changes to Funding Assistance Rates (FAR). The aim is to encourage better local planning for future damaging events.
The AA’s key concern with some of the proposals is that they would shift, at short notice, more burden for recovery to local authorities. The new approach wouldn’t address the underlying funding shortfall for maintenance and resilience work, so ultimately Kiwis won’t see any tangible improvements to their transport network maintenance or resilience.
The AA suggests that central government should instead lead consultation on how funding shortfalls can be met, rather than simply shifting more responsibility to local government.
Download the AA’s submission on NZTA’s emergency works policies review
Submission on Road User Charges (RUC) for PHEVs and BEVs
February 2024
From 1 April 2024, PHEVs (plug-in hybrid electric vehicles) and BEVs (battery electric vehicles) will be included in the road tax system. Until then, they have been exempted in an incentive to encourage their uptake. The exemption was introduced with the intent of removing it once these vehicles reached 2% of the light vehicle fleet, effectively becoming more ‘normalised’.
The AA has always supported this plan. We think the technology is now common enough that these vehicles should start contributing to transport network upkeep and improvements like all other light vehicles. However, we did join with a number of other organisations in the motor vehicle industry in a submission to the Government delivered in February 2024 with our thoughts on what RUC rates should be for these vehicles to make them as fair as possible compared to vehicles running on other fuel types. This submission assisted in getting a lower RUC rate for PHEVs than originally proposed to half that of BEV. BEV now pay $76 per 1000 km in RUC, while PHEV pay $38 in RUC (original proposal was for $53/1000km) as they also use petrol so pay fuel excise duty (FED) at the pump too. Our industry group suggested that BEVs should have a lower rate than proposed. We proposed $60/1000km, based on the fact that at $76/1000km BEVs pay more in road tax than very efficient petrol and petrol hybrid vehicles, but this was not successful – from 1 April this year, EVs pay exactly the same RUC rate as diesel vehicles.
Download the AA's motor vehicle industry submission on RUC rates for PHEVs and BEVs
Submission on the March 2024 Draft Government Policy Statement (GPS) on Land Transport
2 April 2024
The AA agrees with the focus on reforming the transport funding system in this GPS. The existing system wasn’t designed for the scale and range of investment it’s now trying to cover. In addition, we don’t think the current three-year National Land Transport Programme (NLTP) timeframe works well for long-term infrastructure planning.
We welcome the priority being given to maintenance and resilience of the road network. We want to see adequate pavement restoration and value-for-money.
We also support the other strategic priorities but note there’s a very ambitious work programme which will require robust and realistic setting of priorities.
The AA supports investment in public transport, including some subsidisation from road users reflecting the benefits in terms of reduced road congestion, but investment has to go into affordable and deliverable initiatives.
The AA agrees that a new strategic approach is needed to road safety that has more recognition of the role of safe drivers, in addition to road and vehicle conditions and appropriate speeds. As part of this we welcome the renewed interest in improving policing of drunk and drugged drivers.
Download the AA’s submission on the March 2024 Draft GPS on Land Transport