Submission on Road to Zero - New Zealand Road Safety Strategy 2020 2030 - Trafinz
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Submission on
Road to Zero – New Zealand Road Safety Strategy 2020‐2030
14 August 2019
About TRAFINZ
1. TRAFINZ (The Traffic Institute of New Zealand Inc) represents a wide grouping of NZ local
authorities, covering the majority of the New Zealand population. Its membership includes
regional councils, the major metropolitan cities and smaller provincial authorities as well as
private sector and non‐local government members, including transport oriented NGOs and
transport consultancy firms.
2. TRAFINZ’ Executive is comprised of elected councillors and officers, drawn from a cross section
of the membership, together with senior personnel representing its key government partners
and supported by a number of senior technical staff from transport consultancies that volunteer
their services pro bono. This year TRAFINZ will run our 71st Annual conference, so we have a
long track record of constructive, informed and focused input into the transport sector,
especially road safety.
3. The Institute’s primary focus is on sustainable transportation planning, traffic management and
especially road safety. It provides specialist advice to member authorities on traffic and safety
issues by drawing from the depth of expertise available through its members, and through our
connections to leading international organisations and practitioners. TRAFINZ also acts as a
conduit for local authorities to respond to the NZ Government on new transport policies and
legislation.
SubmissionOverview Comments
4. TRAFINZ welcomes the draft Strategy. TRAFINZ is delighted that safety is the single top priority
for transport under the 2018 Government Policy Statement on Transport.
5. TRAFINZ has already expressed our full support for the Government’s strategic position which
makes safety the most important transport objective.
6. TRAFINZ Executive members have been part of three of the road safety expert reference groups
working on the development of this Strategy. We appreciate that involvement.
7. TRAFINZ was the first organisation in New Zealand to begin publicly and consistently advocating
for a safe system approach, from the early 2000s. We have regular engagement with
international colleagues, particularly in Australia, and Europe. We have also visited leading road
safety countries in Europe.
8. TRAFINZ has long recognized that we are all human, we all make mistakes, and we are all fragile.
We strongly support continuing work to improve road user behaviour. However blaming human
error alone for crashes is doomed to failure. TRAFINZ has consistently advocated for a safe
system approach; safer roads and roadsides, safer speeds, safer vehicles, safer road users, and
the need for a leadership system that drives us to achieve safer outcomes. We agree that the
Strategy should be ‘founded on a position that deaths and serious injuries on our roads are
unacceptable and preventable’.
9. TRAFINZ strongly endorses adopting ‘Vision Zero’ as an ethically based and aspirational
objective which will drive organizational and individual behaviour.
10. We agree that there should be interim targets. This is a very welcome component of the
Strategy. Targets should also drive behaviour.
11. We agree with the draft Strategy’s conclusion that Safer Journeys has not been implemented as
intended, because of insufficient buy‐in, slow and limited safety investment, and lack of
leadership and accountability. We also agree with the comment that the New Zealand public has
not yet bought into the strategy.
12. All system designers – Central and local government politicians, Government agencies, Road
controlling authorities, Police, insurers, car providers, fleet operators (etc) – have a
responsibility to be an active part of the solution.
13. We consider the Strategy needs to more fully recognize the critical role of local government. The
combined annual operating expenditure (opex) of the local government sector into transport
and roading infrastructure for the year ended 30 June 2018 was just under $3 billion. Thisrepresents 28 per cent of total local government opex. It is the largest investment area across all
local government activities. Local councils are responsible for 88 per cent (83,000km) of New
Zealand’s roading network, of which 20 per cent of the network is urban and 80 per cent is rural.
14. TRAFINZ has long considered that there needs to be a comprehensive safe system approach.
15. Strong Actions Plans will be required to achieve the step change needed. Modified business as
usual will not deliver the results we need, and New Zealanders deserve. The intermediate
actions included in the consultation document are good for keeping things moving while we
move from the Safer Journeys Strategy to the Road to Zero Strategy. They are all worthy of
being completed and contributing to the vision – BUT they will not achieve the step change that
will be needed to achieve the new ‘challenging but achievable’ target, let alone a higher ‘stretch’
target. Urgent work following the adoption of the strategy will be needed to get in place the
next action plan within the first 6 months of 2020 to ensure that all of the parties with a role to
play in the safe system are able to work through funding processes and get actions underway.Response to questions asked in the consultation document
To what extent do you support this proposed vision?
17. Strongly Support
What was the reason for your rating? Do you have any other comments?
18. TRAFINZ strongly agrees with the proposed vision. We consider that this is the only ethically
acceptable target. We recognise that it may never be achieved, but that should not be a reason
to reject acceptability of death and serious injury on our roads. Vision Zero should commit all
players in road safety to work constantly and actively towards achieving zero death and serious
injury.
19. Our long international relationships, particularly with our European colleagues, tells us that a
compelling vision has a profoundly motivating impact on behaviour, and can be expected to
drive action. What we saw when we first visited Europe in 2005, particularly in Sweden, was a
culture where all players had an attitude of ‘what can we do to help make our roads safer’. That
included Government, NGOs, Councils, car manufacturers, insurers etc. The slogan ‘Road Safety
– It’s Everyone’s Responsibility’ is exactly on the money. New Zealand’s issue is that at the
moment almost nobody is taking any real responsibility, and the ‘road toll’ is, as the draft
Strategy says, regarded almost as an inevitability.
20. Several of our members have adopted, or are planning to adopt, Vision Zero as their own
aspirational strategy.
To what extent do you support the proposed target for 2030?
21. TRAFINZ strongly supports setting a target, but considers that the target should be more
ambitious and a 50 or even 60 percent reduction should be set.
What was the reason for your rating? Do you have any other comments?
22. The draft Strategy sets a 40% reduction in death and serious injury. It is described as a
‘challenging but achievable’ target. It says the 40% target is based on modelling of a substantial
programme of road safety improvements over the next 10 years – but it provides no detail of
this modelling work, or the assumed action interventions being included, or excluded. One of
the features of the 2000 – 2010 Road Safety Strategy was that it detailed each proposed
intervention, and the number of lives that each intervention was expected to save. Without that
detail it becomes harder to assess the appropriateness of the 40% target. This information isalso particularly valuable for anyone engaging in the subsequent development of action plans,
and in monitoring performance of all parts of the system.
With that rider TRAFINZ considers that a greater reduction target should be set for four reasons.
Firstly several of our members have already set greater reduction targets. The Waikato region
has adopted a 50 % reduction target and Auckland a 60% reduction target.
Secondly a 40% reduction gets us back below the 2013 level, but not by much.
Thirdly we think that in modern educational terms ‘challenging and achievable’ is a sort of
‘merit’ target. We suggest that an additional target should be included; an aspirational, not
unachievable, stretch or ‘excellence’ target.
Finally per capita three times as many people die on New Zealand’s roads as on the roads of
leading road safety nations. Just matching where those leading nations are right now would
entail reducing something like a 2/3rds reduction in deaths and serious injuries.
To what extent do you support the proposed decision making principles?
23. TRAFINZ strongly supports all seven proposed principles. They are the basis of the Vision Zero
philosophy and the Safe System approach.
What was the reason for your rating? Do you have any further comments about the proposed
principles?
Principle One – We plan for people’s mistakes
24. We are human. Roading environments are complex and dynamic, and any road user is having to
make many complex decisions in short periods of time. We will get it wrong from time to time,
sometimes by deliberate choice, sometimes inattention or mis‐judgement. The system needs to
recognize that we will all make mistakes, and compensate for that. The traditional, and still
widely held view, is that crashes are all the fault of a road user(s). It is true that user error is a
component in almost every serious crash. However almost every serious crash also involves
failings in speed or the road environment and sometimes the vehicle. That attitude says that if
only you could fix these ‘inferior’ road users then all would be well. The problem with that is
that while we can, and should, do all we can to improve road user behaviour, we humans are
inevitably going to make mistakes for a whole host of reasons, and unless we focus more widely
on the system we will never make a significant dent in death and serious injury on our roads.
Therefore we must plan for people’s mistakes.Principle Two – We design for human vulnerability
25. TRAFINZ has long supported this principle. Roads and roadsides, vehicles and speeds, and crash
response should all be designed around human vulnerability. This means that when a crash
happens it should not kill or main those involved. Speed is key. There are internationally
accepted speeds to achieve this. Austroads Safe System Assessment Framework (SSAF) and
compendium of the Safe System refers to survivable impact speed curves. 30km/hr is deemed
appropriate in areas with vulnerable road users – pedestrians and cyclists, 50km/hr where side
impacts between vehicles are likely and 70km/hr where head‐on crashes are likely. At these
levels there is a roughly 10% chance of death, but as speeds get higher the chance of death and
serious injury climbs very rapidly.
26. NZTA’s assessment is that 87% of our country’s roads have inappropriate speeds. That is 87%
are too high, and do not meet internationally recognised standards.
27. Merely setting appropriate speed limits will not of itself achieve a system designed for human
vulnerability. It is essential that the roading environment supports the appropriate speeds. That
might mean engineering to slow vehicles down in areas where there are vulnerable pedestrians
or cyclists, separation of modes (eg by providing footpaths or cycleways) or separation of
oncoming traffic (by median barriers) where speeds are higher than those safe levels.
28. One emerging issue in designing our roads for the human body is the proliferation of micro
mobility options and the contest for space which had hitherto been solely pedestrian space.
There is a need for resolution on this, working with local authorities and other key stakeholders,
especially disability groups. TRAFINZ has good connections to many of the relevant NGO sector,
and would be very pleased to help in this work.
Principle Three – We strengthen all parts of the road transport system
29. We agree with this principle as noted throughout this submission.
Principle Four – We have a shared responsibility for improving road safety
30. TRAFINZ strongly agrees with this principle. We want to see that responsibility actually have
some muscle behind it. At the moment there are no consequences for wrong action, or for
inaction. We have for several years advocated that all the ‘system owners’ should be required to
have a ‘safe system plan.’ That doesn’t mean their road network, their Policing operation, their
fleet operation etc will be safe on day one, but it does mean that they should have a meaningfuland active safe system plan which is specifically aiming to move them from their current
performance towards a Vision Zero state. These Safe System Plans should be regularly
monitored both by the entity and externally.
31. There is also no body – a ‘champion for road safety’ ‐ with the resource capability and single
focus to hold ‘system owners’ to account. Central Government’s existing agencies cannot really
do that – to each other, or to Ministers where they make decisions which do not advance, or in
fact reduce safety.
Principle Five – Our actions are grounded in evidence and evaluated
32. TRAFINZ considers that a strong evidence base is critical. Too many decisions have been made,
and equally have not been made, by previous governments of all stripes on the basis of
predilections and political considerations rather than evidence. It is not good enough for
decision makers to think that because we are road users we are therefore experts. Upskilling all
players in the system is very important.
33. There are two riders we would make to this:
34. The first is that at times getting evidence has been used as a refuge from actually making
decisions. This is particularly when international evidence, physics, and human physiology tell us
clearly whether an intervention is a good idea or not, and decision makers instead say we need
‘New Zealand based evidence.’ The lowering of blood alcohol levels was a case in point.
35. The second is that evidence and evaluation can be taken to the extreme. TRAFINZ considers it
important to undertake benefit – cost analyses, but when this goes from analysing a programme
of work to the individual works themselves it often becomes onerous, time consuming and
expensive and prevents safety works from being undertaken. Funding micro‐management is
widely seen as an issue by local government. We know that for example roundabouts work in
improving intersection safety at high speed rural intersections. Do they all need to be analysed
in such detail?
36. Finally in terms of evidence and evaluation, we consider that developing a centre of excellence
should be considered. It would be worth considering allying evidence and research capability
with the concept of a road safety champion organisation as recommended in our comments on
Principle Four.Principle Six – Our road safety actions support health, wellbeing and liveable places
37. TRAFINZ welcomes this principle and was delighted to see it incorporated into the Government
Policy Statement. TRAFINZ has long advocated for this kind of integrated approach between
transport and urban planning. Good urban planning can reduce the need for journeys by car,
make freight easier to distribute, allow greater use of public transport, walking and cycling.
Good urban form is the single most important transport behaviour determinant.
38. Urban transport safety needs to be given a strong mandate. Urban road safety involves
managing multi‐modal, complex combinations in busy places and therefore requires a different
approach to that of rural road safety. Almost half of all New Zealand deaths and serious injuries
are urban (48% for 2014 ‐2018).
39. There is a lack of discussion of the role that land use planning and mode shift to public transport
play in reducing exposure to risk. As public transport is the safest mode, quality service and
access to stations and stops will increase the number of low‐risk trips. Both land use planning
and public transport reduce exposure for everyone by reducing VKT on the network.
40. Inclusion of health, wellbeing and liveable places as a principle does not adequately link to
urban road safety in the Immediate Actions part of the draft Strategy. Increasing safe and
sustainable trips as a high level measure links climate change goals to Vision Zero goals for an
integrated policy approach to all harms from transport ‐ thus achieving the well beings.
Principle Seven – We make safety a critical decision – making priority
41. TRAFINZ strongly agrees with this principle. This means that projects need to be designed with
safety at their core. Safety should not be traded off for often very small travel time savings for
individual vehicles. For example is saving a few seconds for a lot of people more important than
saving a life? TRAFINZ supports reviewing the value of life to assist in this analysis.
42. Funding to support safety is vital. We saw the uptake of cycling projects when the previous
Government significantly increased cycling funding. Road to Zero needs to ensure changes to
funding levels and processes a made to incentivise safety works and that the process to access
funding is not excessively onerous.
43. Systems and processes need to be reviewed to expedite decision making where possible. This
includes ensuring consistent decision making from leaders within approving agencies. This will
allow for a plan to be implemented which will result in actual improved road safety outcomes on
the road network, leading to a reduction in harm on our roads. This is a priority as it was
identified as one of the key weaknesses of Safer Journeys. This should apply to all transport
network programmes not just road safety.The Five Focus Areas
To what extent do you support the proposed focus areas?
44. TRAFINZ strongly supports all five focus areas, particularly One, Two, Four and Five. They are the
basis of the Safe System approach.
What was the reason for your rating? Do you have any further comments about the proposed
focus areas?
Focus Area One – Improve the safety of our cities and regions though infrastructure
improvements and speed management
45. This focus area picks up two of the four traditional pillars of the Safe System approach, safer
roads and roadsides and safer speeds. TRAFINZ considers that they should be two separate
Focus Areas. Both are essential, and major focus areas in their own rights.
46. Increased investment levels will be necessary to support the achievement of the targets set out.
47. In determining safe and appropriate speeds, the Speed Management Guide and Mega Maps
have already completed the hard work. Streamlining the speed limit setting process is the next
key to unlock the benefits. Many Road Controlling Authorities have not changed any speed
limits since the updated Speed Limit Setting Rule came out in 2017.
48. We recommend a move away from the bylaw process. This process and the associated Local
Government Act consultation requirements that apply to most road controlling authorities make
it a very time consuming and onerous process to change speed limits via bylaw change. It is also
very inflexible.
49. We also question the level of consultation required. Given that the speed management
guide/rule drive quite deterministic technical processes for identifying the appropriate speed
limits and there is a desire to achieve national consistency of outcomes there is very limited
scope for “consultation” to actually change the outcomes of specific speed changes. It is
appropriate for councils/RCAs to consult widely on their strategic approach to speed
management, and to engage and educate on the benefits of speed management but we would
like to reduce the engagement on the detail of specific speed changes within that wider
strategic approach down to an ‘inform only’ level.
50. Safer speed limits alone will not suffice. Speeds should ideally be self‐explaining and appropriate
to the environment. Often the target speed will be considerably lower than the prevailing
speeds, and engineering or urban design features (such as threshold treatments) will be
necessary. These also support Principle Six, creating more liveable and attractive places for
people.51. Safer speeds will need at least initially to be supported by extra enforcement. We realise this
will put pressure on Police resources. TRAFINZ considers that the road safety contract between
NZTA as funder and the Police needs to be clearer and able to be better monitored at a national
and RCA level.
52. A sustained and significant safety engineering programme will also be required. This includes
treatment of urban areas. This also includes median and edge barriers, rumble strips,
roundabouts, road shoulder treatment etc. All these interventions work. They are a response to
at least Principles One, Two and Five. Again a huge amount of work has been done to identify
higher priority areas for intervention. Money has been allocated to start in earnest on this work.
Again streamlining the funding process to increase the level of work on the ground is necessary.
We welcome the provision of $1.3 billion specifically for road safety engineering projects
through the GPS.
53. TRAFINZ has been a consistent strong advocate for widespread installation of median and edge
barriers. They work. So do roundabouts at high speed intersections. A lot of excellent work has
been done on determining priority locations. As the draft Strategy notes just over 25% of all
fatalities in the last decade were the result of head on crashes, while a third more were the
result of road run offs. Over 10% were at intersections. We are however frustrated that despite
the best of Government intentions, roll out of these lifesaving interventions remains far too
slow. People are literally dying as a result, and there are no apparent consequences for the
‘system owners.’
54. The one other caution we would make is that there should be careful consideration of the
impact on environment. Many important roads run through very significant natural areas
including reserves and National Parks. This is a different trade off to the trade off with travel
time, so safety management in these areas must be done with the utmost care.
Focus Area Two – Significantly improve the safety performance of the vehicle fleet
55. TRAFINZ agrees with focusing on safer vehicles.
56. We agree with the need to provide better information about the difference in vehicle
performances in crashes. We applaud the NZTA advertisement series focused on buying cars for
young drivers. We therefore consider it a problem that at the same time ACC has removed the
differential levy between safer and less safe vehicles.
57. TRAFINZ also encourages thinking more laterally about road safety related to freight. The draft
Strategy notes that 20% of fatal crashes involve a heavy vehicle. Clearly this is vastly
disproportionate to their numbers in the vehicle fleet. TRAFINZ notes that the annual social cost
of crashes is actually higher than the entire investment being made in the roading network. Thatsocial cost is not worn by the transport system but by the health and welfare systems and by the
victims, their families, friends, employers etc. We would therefore encourage Government to
continue to work on increasing the level of freight movement by rail and sea for safety and
sustainability reasons.
Focus Area Three – Treat road safety as a critical health and safety at work issue
58. TRAFINZ supports this, but considers that the H and S responsibility should be widened. This is
particularly for Road Controlling Authorities, but also for other players in road safety such as the
Police and relevant Government agencies, insurers etc. At the moment we take H and S really
seriously because it has real liability consequences, but on road safety there are no
consequences for the ‘system owners.’
Focus Area Four – Encourage safer choices and safer behaviour on roads
59. TRAFINZ has a long and close relationship with SASTA. Locally based Road Safety Co‐ordinators
play a really valuable role in encouraging safer behaviour and ‘winning hearts and minds’. Road
Safety Co‐ordinators have developed deep relationships with their local communities all around
New Zealand, and have developed a remarkable array of innovative programmes targeted at the
risks and needs of their local communities. That particularly includes relationships with
vulnerable parts of our community, particularly youth and Maori and Pacifica communities. The
Strategy should explicitly recognize this work and upcoming Action Plans should support it
further.
Focus Area Five – Drive action through effective system management
60. An effectively structured and effectively run ‘System’ is essential in getting actions and results,
and in keeping those actions and results going. Getting the ‘System’ right will allow us to embed
safety into our culture, as it is embedded in leading safety nations. At the moment road safety is
only truly bought into by an active minority, so we have much to do.
61. We all recognize that leadership is lacking and sporadic. Some of that is about people, some
about structure, some about incentives and understanding.
62. The current ‘System’ is not performing to the level required. At the highest management level,
the NRSC has only met sporadically in recent times. We know that some of the key Government
agencies have had some governance and management challenges. A leadership body needs to
be both appropriate in its membership, and connected and effective in what it does.63. We note the draft Strategy says ‘We will continue to embed and strengthen the role of the
National Road Safety Committee, which brings together central government agencies to
coordinate road safety policy,’ before then talking almost separately about the importance of
local government.
64. TRAFINZ advocated for several years that it was essential that local government should be a
member of the NRSC. It was clear that excluding the owners of 83,000 km of the nation’s 94,000
km of road was not going to assist in ‘making road safety everyone’s responsibility.’
Consequently LGNZ has represented local government on the NRSC. TRAFINZ has an MOU under
which we represent local government on matters of road safety. We have had discussions with
LGNZ and various NRSC chief executives from time to time about whether TRAFINZ could better
perform that role. We remain willing to assist in that way, and/or in support of LGNZ. We would
also appreciate TRAFINZ being added to the sentence: ‘This should include sharing knowledge
and best practice through forums such as Regional Transport Committees and the Road
Controlling Authorities Forum – and TRAFINZ.’
65. We are glad to see the Ministry of Transport wanting to take responsibility as the lead agency
for transport strategy across New Zealand. MOT has an overview of the whole system, and as
the lead agency for transport have a wide ability to review and predict system failure and take
steps to prevent it. However MOT will have limitations, particularly when it comes to holding
other Government agencies, and the Government itself to account.
66. We strongly agree that there needs to be leadership and that we need ‘leaders that have
effectively made the case for change, and commitment to bringing communities with them’. At
the Parliamentary level we have tended to see road safety given to a relatively junior Minister,
usually outside of Cabinet. That is not usually an effective formula. Pleasingly in this term of
Government road safety has been made the number one transport priority and even though the
Minister of Transport Safety is outside of Cabinet there is currently a very pleasing commitment
to transport safety. We do recommend though that the Strategy finds a structural way to deal
with this. We would like to hope for a multi‐partisan standing committee on road safety as
recently established by the Australian Federal Parliament.
67. We also continue to advocate that there needs to be some form of adequately resourced safety
champion organisation. Central Government agencies cannot hold Government to account, and
most organisations with an interest in road safety have other often conflicting roles. We
consider that Government could resource such an organisation to advocate for safety without
fear or favour, and possibly to conduct research and disseminate best practice. These things are
essentially the mandate of TRAFINZ, but we do not have the resources to do this on the scale
needed. Another model would be the Parliamentary Commissioner model. When one considers
that road trauma costs the nation in the order of $4.5 billion annually, not to mention theemotional and physical cost to victims and their loved ones, we consider that some form of
structural response would be a very good investment.
68. TRAFINZ considers it critical that all key players in the ‘System’ should be legally required to
develop, maintain and monitor their own Safe System Plans showing the approach and actions
they are taking to reduce risk of death and injury on our roading system and materially
improving transport safety. The Road Safety Champion could monitor performance.
69. Another element of an effective system will be good access to information and ongoing
research. We suggest that this would fit well with a Road Safety Champion organisation.
70. The System needs to provide funding at a level that incentivises investment in safety, and a
process that is not overly onerous to access that funding.
71. TRAFINZ has long advocated for the inclusion of a specific road safety engineering activity class
in the NLTP to avoid trade‐off of safety for other objectives. There are existing specific GPS
categories for road safety enforcement and road safety education. We acknowledge that there
are often safety elements in other road works, but a specific category resourced at a level
appropriate to safety being the highest transport priority in the Government Policy Statement
would clearly drive behaviour.
72. We consider that the Funding Assistance Rate (FAR) should be changed to 75% for safety
programmes. Requirements for trading off safety benefits with travel time dis‐benefits in crash
reduction projects should be removed. A higher level of subsidy for safety work would send a
clear message about its importance, and incentivise investment by RCAs. That should of course
not be on the basis of substituting NLTF funding for local share, but about doing more.
73. Safety camera income should be used to fund road safety. One aspect could be to support FENZ’
or ambulance services.
74. TRAFINZ also considers that there are more circumstances where enforcement of some mobile
offences should be allowed to be taken over by local road controlling authorities to reduce the
pressure on Police and increase the responsiveness to local community needs. RCAs could take a
role in installation of safety cameras and processing of offences.
75. Upskilling the sector is essential. TRAFINZ strongly supports a focus on developing greater
leadership, capability and capacity. Inadequate leadership and priority for road safety in policy
and decision making was identified through the 2015 independent review of Safer Journeys as a
key factor that prevented the full delivery of a safe system. We have seen too often that most
local or central government politicians lack the knowledge needed to champion road safety,
especially when faced with opposition, or are inclined to populist actions that sacrifice road
safety. Success in this area will require strong, and informed, leadership by MOT, and we believea Safety Champion organisation, to ensure key partners including NZ Transport Agency, NZ
Police and Local Authorities are held accountable to national targets and maintain operational
focus on keeping people safe.
76. We fully support the draft Strategy’s aim of building community understanding of road safety.
77. Crash response doesn’t fit easily into the Strategic responses above and might warrant its own
focus area. TRAFINZ supports work to enhance crash response.
78. We suggest that FENZ might well be included in the revamped NRSC. FENZ funding is important
too. There is a clear public good in much of what FENZ does, education, crash response, general
health work – just as much as Police who are publicly funded. If Government has difficulty with
tax funding – we suggest that at least the use of revenue from safety fines should be seriously
contemplated.
79. The Strategy includes useful commentary on emergency response and treatment post crashes.
TRAFINZ supports this commentary. We propose that another angle be added. We consider that
post‐crash investigations should routinely involve more parties than the Police. Our objective
should be to determine what caused the crash from a safe systems perspective, and what needs
to be done to avoid repetition. We also consider that such investigations should consider
whether there are other locations in the nearby network which have the same risk profile.
What are your top priorities for the first action plan?
80. We question why this choice is presented in this way.
Nevertheless TRAFINZ considers that the top three are:
Safety treatments and infrastructure improvements and
Introducing a new approach to tackling unsafe speeds and
Strengthening system leadership, support and coordination
81. With as the next priorities:
Enhance safety and accessibility of footpaths, bike lanes and cycleways
Raise safety standards for vehicles entering the fleet and
Prioritise Road Safety PolicingDo you have any further comments about these priority actions?
82. Most of our comments have been made earlier in this submission.
83. At this point it is worth making the observation that the Immediate Action List is missing any
reference to urban form (important in Principle Six)
84. Under the other action points, TRAFINZ supports a comprehensive review of penalties to better
reflect risk arising from the behaviour in question. We consider this review should include
aligning penalties to risk, and to the ‘thought’ that goes into an infringement of the rules. We
also consider that the review should cover whether the proceeds from infringements should be
dedicated to safety investment.
85. We recommend including a lower tolerance for speeding infringements and demerit points to
apply regardless of whether officer or camera detection. The speed tolerance makes setting
appropriate speed limits difficult. We also support the review including the way we respond to
blood alcohol levels that are between the current and previous limit, to strengthen the new
limit, and support enhanced drug driver detection such as saliva testing (BIR), and support
ongoing enforcement of use of safety restraints.
Measuring success.
Do you have any comments about the way we intend to monitor our performance?
Additional indicators for monitoring performance that could be included:
data on post‐crash response in order to understand the opportunities for improvement from a
system management perspective
number of deaths and serious injuries where fatigue was a factor in travelling to and from a
workplace
purchasing of new safer vehicles into the fleet by workplaces (businesses, local and central
government agencies) and the role this plays in improving the second‐hand fleet.
Understanding impact of legalising marijuana (if and when this is passed) to ensure that it is not
lost in a more generic ‘drugs’ category and to understand Road User Choices
both technical and attitudinal data to enable a greater focus on what people say versus what
people do. This will also assist in the targeting of educational activities to influence Road User
Choices
TRAFINZ again welcomes the opportunity to make a submission. We would welcome the opportunity to
further engage with you as the Strategy evolves, and as Action Plans are developed.For further information please contact: Councillor Andy Foster President New Zealand Traffic Institute (TRAFINZ) andy.foster@wcc.govt.nz 021 227 8537
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