Cycling Action Network submission
Key points
- CAN strongly opposes the draft Land Transport Rule: Setting of Speed Limits 2024
- Lower speed limits reduce the number and severity of traffic crashes.
- Traffic crashes in New Zealand disproportionately affect pedestrians and cyclists.
- Greater perceived (and actual) safety conditions including from lower speed limits can increase the amount of cycling uptake.
- A large proportion of New Zealanders would choose to cycle for more of their journeys if conditions on our streets and roads were safer.
- The proposed rule disempowers local communities to have a voice in either (a) speed limit reversals or (b) setting safe speeds in the future.
- Cost benefit analysis processes are poor mechanisms for gauging the value of a transport project, especially when explicitly ignoring wider costs and impacts on health, environment, and ongoing user costs.
- Compared to the proposals in the draft Rule, the current approach to speed settings in use is up to 45x better for the economy in urban areas around schools, rendering arguments that time savings from faster speeds result in a net positive for productivity objectives misleading at best.
- Emissions: the current Emissions Reduction Plan reduces transport emissions via mode shift. If leveraging mode shift is deprioritised further, the Government must explain how other sectors will make up the difference.
- The draft Rule undermines decades of work on road safety and other positive transport objectives being pursued, like inclusive access, public health, environmental sustainability, and economic productivity.
Recommendations
- Discard this draft Rule in its entirety. It is very poorly prepared and ill-informed. Return the process of setting speeds for road transport to a methodology that leverages and respects experts tasked with providing safe transport.
- Reinstate the coalition agreement to only raise speed limits where it is safe to do so for all road users.
- Make the lower limit of the allowable speed limit for each road at most equal to the safe and appropriate speed limit for that road, so that local communities have the freedom to choose this if they wish to do so.
- Reinstate an ambitious target of reducing death and serious injuries on our roads by 40% (or more) by 2030.
- Enact our international commitment under the Stockholm Declaration for max 30 km/h where vehicles & vulnerable road users share road space.
- The transport strategy for Aotearoa should permanently integrate health concerns and objectives, both individual and public.
Re: Overview of the Draft Rule
Speed limit management involves many goals including reducing fuel consumption, improving air quality, frequency and severity of crashes traffic flow and travel time, mode share, physical activity, and public health. There is a great wealth of expertise in these matters both in New Zealand and globally (see References); the draft Rule will certainly cause many deaths and injuries that under the continued operation of the existing Rule would not have occurred.
CAN supports more widespread use of vehicle speeds that are proven to deliver better livability, safety and health outcomes on our streets and roads. The narrative that this work is reversing ‘blanket speed reductions’ introduced by the previous Government seriously misrepresents recent history. Under the existing Rule, no RCA was compelled to change any speed limits at all (except outside schools, which remains in the draft Rule albeit with less choice). The changes that were made were small in number, carefully targeted, and subject to extensive community consultation.
CAN could welcome a more accelerated and broadly delivered application of speed limits across the country – if such changes started with lower, safer speeds across the board. We support the reduction of speeds across the country to levels that are proven to be safer for all road users, and the raising or retention of higher speeds where the infrastructure design is demonstrably and effectively safe to do so according to scientifically supported evidence.
The Speed Rule 2024 proposals prepared by the Minister can be far more fairly described as a ‘blanket rules’ approach – as the broad stroke, dictatorial nature of the changes will return speed limits via a far less targeted, nuanced, locally informed, and locally supported process across the country. The draft Rule will remove existing powers of communities to enact safe speeds where they wish to do so. It is shameful and contradictory.
Re: Proposal 1 – require cost benefit analysis for speed limit changes
Cost benefit analysis processes (CBAs) are poor mechanisms for gauging the value of a proposed transport project.
The proposal implies that ‘economic impacts’ are primarily represented by benefits from reductions in travel times. This is a minor and problematic consideration.
Increasing speed limits along a given journey does not equate to a corresponding decrease in time for that journey as many journeys involve negotiating traffic congestion and delays at intersections. The evidence suggests lower speed limits typically incur very small increases in travel times.
If the goal of this work is to lift productivity, there are much more effective ways of doing so that don’t involve speeding up heavy private vehicles. Given that research suggests people do not make productive use of time savings from faster car journeys, it calls into question how any reduced time of driving can be even counted as a benefit towards any CBA business cases.
Also, by making it more attractive to drive faster this will lead to more people expecting to be able to travel longer distances by car, and in turn meaning more traffic on the road, increasing congestion issues, and less overall time savings.
Higher speed limits could actually end up costing motorists more due to greater fuel costs from driving faster and more often as well. More fuel is required at highway speeds above 80 km/h. Induced demand means more fuel costs going overseas that harms our economic competitiveness from greater amounts of driving.
If CBAs are used in determining the economic viability of transport projects, we recommend they should account for benefits and disbenefits beyond safety, travel time, and implementation costs. We know that different forms of transport incur varying broader impacts on human health, the environment, and economic productivity.
Climate emissions, health complications due to inactivity, air and noise pollution, microplastics, chemical runoff, materials disposal, and more are only some of the impacts that should factor into any analysis if CBAs are going to give decision makers any meaningful information.
Re: Proposal 2 – strengthen consultation requirements
Consultation processes on changes to our transport system are cumbersome, especially when it comes to Road Controlling Authorities making minor changes to specific locations.
For a government that campaigned on ‘cutting red tape’ it is surprising to see a move to further burden the process for local authorities to be able to deliver the changes their residents and ratepayers are calling for.
We understand that there is also an urgent needs to transform a lot of our urban built environment to enable meaningful climate action in the transport space. Making the processes to enable this more onerous will slow that work, leading to slower and undelivered opportunities to lower transport emissions.
CAN holds that there are other effective ways of reducing climate emissions from transport in urban areas than relying on the electrification of the existing vehicle fleet. By empowering RCAs with faster means of making change, while ensuring residents are kept informed, we could enable more right-sized vehicles that harm people, infrastructure, and the environment less. This is the point of the ‘Shift’ component of the Avoid, Shift, Improve strategy.
The Shift is already taking place on our city streets around the country. Many people and businesses recognise the unbeatable economy of eBikes and cargo bikes when compared to many journeys made by cars, vans, utes, and trucks in cities. If RCAs are not enabled to follow more efficient processes to transform city streets, more people will be placed in more dangerous situations as large and small road users cross paths more often on poorly designed infrastructure.
Re: Proposal 3 – require variable speed limits outside school gates
CAN considers that the proposal of variable timing of traffic speeds on school streets ignores evidence about the timing of traffic harm near schools and the fact that many schools operate as community hubs / destinations at all hours.
The catchment size for active journeys around schools is a performative gesture, at best. Children who walk, bike and scoot to school are exposed to the danger of cars, vans, and trucks for the whole journey between their homes and schools, not just as they enter some nominally determined forcefield a few metres either side of the school gate
Children (and the community at large) deserve safe streets around schools and in their neighbourhoods at all times – not just for the tiny window in time and space when they're being marched through the school gate on weekdays.
And then there's the horrendous inequality built into this approach for rural children, who get slightly lower but still reliably fatal speeds of 60 km/h at “drop off and pick up times”. Why? Does the government think rural school children are worth less? Or that their communities are more comfortable with sacrificing children to some made-up economic imperative?
As well as being practically unenforceable using today’s approaches to policing speeds, a variable speed limit approach would put everyone, including children, in more danger outside those times. 85% deaths and serious injuries immediately outside of schools in Auckland occur outside of pick up and drop off time. Children still travel around schools throughout the whole day for many reasons and scenarios. School properties can be split by a street with students crossing often throughout the day.
Variable speeds are also hard to remember and comply with, relying on more demanding information and signage that drivers may overlook. Permanent speed limits are much more understandable and intuitive, and provide greater safety for people of all ages using the street not in vehicles at all times of the day.
CAN is particularly concerned that people on bikes will be put in more danger by faster traffic speeds outside these variable times and discouraged from riding more often. We know that the perceived danger of heavy vehicles has a significant impact on people’s choice to ride their bikes. If mums and dads, grandmothers and grandfathers, workers, and customers in a local area know that cars near where they live are going generally faster, they will add that multiplying factor to their assessment to ride or not.
More people may decide that faster cars moving around their neighbourhoods and in front of schools makes choosing to ride their bikes not worth the extra danger, leading to more traffic and frustration from more driving and congestion.
Re: Proposal 4 – introduce a Ministerial Speed Objective
CAN has concerns about ministerial overreach that would lead to worse outcomes, especially given that the objectives of the other proposals in this speed rule will create more dangerous roads and streets across New Zealand.
Re: Proposal 5 – changes to speed limits classifications
CAN does not support the majority of these speed limit classification changes. They are not based on widely available evidence and fail to respect the agreed principle of only keeping speeds higher where safe to do so.
There is significant amounts of peer reviewed evidence that explains how collisions involving vehicle speeds above 30 kmph get more harmful and deadly.
CAN is particularly concerned by the direction of this Speed Rule given that people riding bikes are at more risk from fast vehicles. The majority of roads in New Zealand do not have well designed separated space for cycling. Many urban roads will struggle to find extra space that would provide for safe separated cycling at different speeds. Where people on bikes are expected to share space with cars, vans, and trucks, it therefore remains critical that safe speeds are observed.
Along with the technical risks of higher traffic speeds, the signal they send to motorists can lead to frustration and unnecessary conflict. Many cyclists will be travelling well below 50 km/h (generally closer to, and below 30 km/h), and some motorists can take risks to overtake or act aggressively toward the person on the bike. This conflict can add to the perceived danger of choice to cycle.
CAN recommends that the Minister leave the setting of speed categories up to experts who understand the health and safety considerations when it comes to traffic.
Re: Proposal 6 – update the Director’s criteria for assessing speed management plans for certification
CAN is concerned that these changes, in combination with the other stricter processes involved in the Rule, risk reducing the decision making powers of RCAs to deliver for their local communities.
Re: Proposal 7 – reverse recent speed limit reductions
CAN strongly opposes this proposal in its entirety. Reversing speeds set by RCAs around the country to higher limits will put more people in danger and result in more deaths and serious injuries. The large amount of locally held engagement and decision making undertaken over the timeframe listed will be in effect, thrown on the trash heap.
This disregard for community consultation would signal an enormously insulting contempt for public input to these kinds of projects. This disrespect for civic engagement will leave more people disillusioned with public engagement even more than they are now. This proposal is completely at odds with a government that has spoken and campaigned on greater local decision making.
30 km/h zones surrounding schools
CAN strongly opposes discarding recent speed reduction work near schools. CAN understands the value of this work to enhance the safety of kids getting to and from school, as well as the benefit for entire communities around schools at all times of the day.
Increasing speeds in the wider zones around schools will result in more dead children. We wonder under what scenario that a Minister of Transport could be challenged legally following the death of a child following the raising of speed limits – knowing that such risk is established by widespread evidence.
Arterial roads
CAN strongly opposes discarding recent speed reduction work on arterial roads. Most arterial roads in New Zealand are ill-equipped to support high speeds of traffic, especially when it comes to the safety of people walking and on bikes. With the historical omission of separated, protected cycleways, it is critical to keep vehicle speeds lower to help reduce the likelihood of crashes and help reduce the severity of crashes that will happen.
CAN advises that arterial roads need speed limits to be set based on evidence that supports keeping people on bikes safer. We would welcome the opportunity to contribute our input into designs for arterial roads that can accommodate faster general traffic that would keep people on bikes and those walking safe.
Rural State highways
CAN strongly opposes discarding recent speed reduction work on state highways. We believe many New Zealanders consider that much of the regional roading network in this country is unsuitable for higher speeds.
The process for setting speeds on our roads for much of recent history has not been based on a method that puts all road users' safety as the central concern. The 85th percentile methodology for setting speeds for road traffic was simply a derivative of user behaviour following the opening of a road design and aligning the final speed limit to that which was closest to the average speed of 85% of road traffic.
The 85th percentile approach pays little regard to people on bikes on rural state highways. CAN has been encouraged to see recent work undertaken to reduce speed limits on these roads for the proven safety enhancement for people driving vehicles. We are grateful that the speed reductions also deliver slightly improved safety conditions for people on bikes.
The majority of rural state highways across New Zealand have very little safe accommodation for people on bikes, relying largely on space on the shoulder, and driver awareness and safe overtaking behaviour. Slower speeds of traffic allows drivers more opportunity to see a person cycling up ahead, and manoeuvre past them without incident.
Summary
The draft Rule does not offer any promise of positive outcomes for New Zealanders. Even the supposed primary objective of these changes, economic productivity, will likely be worse off. There are many, many more negative consequences that will result in net harm for the New Zealand economy, as well as leaving more people of all ages killed or seriously harmed in future. Such recklessness by a Minister is unbelievable.
CAN struggles to understand the motivation of the Minister to propose such detrimental developments. We hope that he will reconsider this work and return it in its entirety to more capable experts at his disposal who understand these issues and can put forward genuinely helpful ways of improving the safety and performance of our transport system.
Sincerely -
Alex Dyer
Chair
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References
Aldred, R., Goodman, A., Gulliver, J., & Woodcock, J. (2018). Cycling injury risk in London: A case-control study exploring the impact of cycle volumes, motor vehicle volumes, and road characteristics including speed limits. Accident Analysis & Prevention, 117, 75-84.
Isaksson-Hellman, I., & Töreki, J. (2019). The effect of speed limit reductions in urban areas on cyclists’ injuries in collisions with cars. Traffic injury prevention, 20(sup3), 39-44.
Ekmekci, M., Dadashzadeh, N., & Woods, L. (2024). Assessing the impact of low-speed limit zones' policy implications on cyclist safety: evidence from the UK. Transport policy, 152, 29-39.
Moll, S., López, G., & Garcia, A. (2024). Speed limit management on two-lane rural roads shared by drivers and cyclists to improve safety and traffic operation. Transport policy, 147, 1-11.
Beek, M. C. (2022). Effects of speed limit reduction on safety, job accessibility and equity: Case study: Amsterdam, speed limit reduction of 50km/h to 30km/h (Master's thesis, University of Twente).
Kamruzzaman, M., Debnath, A. K., & Bourdaniotis, V. (2019, January). An exploratory study on the safety effects of speed limit reduction policy in Brisbane and Melbourne CBDs. In Proceedings of the 2019 Australasian Transport Research Forum (pp. 1-12). [car-bicycle crashes halved after speed limit in central city reduced from 50 to 40 km/h in Melbourne; particular decrease in severe injuries and fatalities (to zero)]
Mertens, Lieze, Sofie Compernolle, Benedicte Deforche, Joreintje D. Mackenbach, Jeroen Lakerveld, Johannes Brug, Célina Roda et al. "Built environmental correlates of cycling for transport across Europe." Health & place 44 (2017): 35-42. [Lowering speed limit increases cycling.]
Yannis, G., & Michelaraki, E. (2024). Review of City-Wide 30 km/h Speed Limit Benefits in Europe. Sustainability, 16(11), 4382. [A study of 30 km/h limits in forty cities which finds that they reduce crash numbers, severity, injuries, lead to safer, healthier, greener, more liveable streets, decreases congestion, improves traffic flow, reduces travel times, reduces fuel consumption, emissions, and noise, reduces car dependency, and reduces nitrous oxide and particulate emissions especially from diesel vehicles.]