Cycling Action Network – Submission, 8 October 2021
CAN (Cycling Action Network) is New Zealand's national network of cycling advocates. We work with government, local authorities, businesses and the community on behalf of cyclists, for a better cycling environment. We've been around a long time. We speak for more than a million people in New Zealand who love riding bikes.
Key points of our submission
Extending the validity of learner and restricted licences will put other road users at risk, particularly people on foot and on bikes.
The cost of learning to drive is regressive, but it is not acceptable to sacrifice the safety of vulnerable road users to address this issue.
Trading safety against other benefits is at odds with Vision Zero.
Extending the validity of learner and restricted licences will put other road users at risk
Allowing drivers to remain on learners and restricted licenses for longer will reduce progression through the graduated driver licensing system.
Learner drivers are allowed to operate vehicles on the road with only a theory test. 35 multiple choice questions and accompaniment by a responsible passenger are not sufficient qualification to ensure the safe operation of motor vehicles on public roads for a period of 10 years.
Learner drivers need accompaniment, but over a longer period of driving it’s unreasonable to expect family members or other ‘responsible passengers’ to remain vigilant and constantly provide oversight and guidance. In practice, non-professional passengers will relax and reduce their guidance over time.
A long period of driving as a learner without requiring any professional feedback also risks embedding bad habits or attitudes. Lessons by professional instructors and practical tests are the most reliable way to improve the skills of NZ drivers. There should be emphasis on increasing these requirements much earlier in a driver’s progression towards their full licence.
Compliance with requirements imposed by learners and restricted licences is low, and this proposed change will likely lead to an increase in drivers breaching their license conditions. Low fines and lack of adequate enforcement has contributed to this issue. We believe that changes to driving offences and penalties need to happen before this proposal is considered.
The cost of learning to drive is regressive, but this issue should be addressed in other ways. It is not acceptable to sacrifice the safety of vulnerable road users to address this issue.
Lack of transport options to attend tests is a key obstacle to drivers progressing through the graduated driver licensing system.
Reducing the cost of progressing to a full licence should not outweigh safety. The government should take other approaches to assist drivers to progress through the graduated driver licensing system.
Other options exist to reduce licensing costs or assist with financing for people on low-incomes. Once a driver achieves their full license that level of licence will last them for the rest of their lifetime. It is in everyone's best interest to encourage drivers to achieve their full license.
Improving marginalised communities access to the drivers licensing system by reducing requirements will increase the number of drivers operating vehicles without adequate training. This will likely lead to an increase in injuries and deaths in their communities. This is counter to the action identified in the Road to Zero policy of improving road safety outcomes for Māori.
The best thing we can do to help families out of transport poverty is give them alternatives to driving.
Trading safety against other benefits is at odds with Vision Zero
Vision Zero says we should integrate human failings in the systems approach. This means recognising that learner drivers are not perfect, and identifying and correcting their problems with professional guidance and testing as soon as possible.
Vision Zero says we should not trade off safety against other benefits such as mobility. Safety must be the number one priority. Increasing acceptance for under-qualified drivers clearly trades off safety against other outcomes.
The consultation document identifies that there is no data available to demonstrate the time-limited licence policy has had any impact on land transport safety. We don’t think this is the case, and the suggested absence of evidence supporting the current policy is not sufficient evidence for a proposed change to the current policy.
It is inappropriate to make such a change without a sufficient body of evidence to show that the change will not result in an increase in deaths on our roads.
Research done by the ministry of transport concluded that: “the increased appearance of learner licenses ... could point to a systemic failure” and that "successful road safety strategies can be undermined by failing to maintain levels of enforcement and an unexpected outcome from license regulations.”
At the very least, plans should properly identify the risks of the change and put in place measures to manage them.
Reducing testing, requirements and costs will further incentivise driving over other modes of transport. It is clear that the current licensing system does not adequately train drivers in the safe operation of motor vehicles. Cycle Action Network would like to see action taken to improve the drivers licensing system, and opposes actions to weaken it such as this proposal.
Walton, D., Jenkins, D., Thoreau, R., Kingham, S., & Keall, M. (2020). Why is the rate of annual road fatalities increasing? A unit record analysis of New Zealand data (2010–2017). Journal of safety research, 72, 67-74.
CAN – Cycling Action Network
Tel 027-563-4733, skype: patrick.morgan.can twitter: @patrickmorgan @CyclingActionNZ
PO Box 25-424, 2 Forresters Lane, opposite Tory St Bunnings, Wellington
Join us: http://can.org.nz/ Find us on Facebook More people on bikes, more often