The proposed new Rule “Setting of Speed Limits 2024” requires reduced speeds to be reversed and the public consultation process to be repeated even though there was obvious support and sound accident and risk factor logic for making the previous reductions.
It seems ludicrous that the section of SH30 around the shore of East Rotoiti should be subject to a rule which could require a blanket reversal of the speed reductions introduced. The high accident rate, supporting submissions and safe speed warning signs that existed on the section of road all indicated that the safer speeds were appropriate.
With the demonstrated public support for the speed reductions for this section of SH30 it should not be necessary to go through public consultation again - this would certainly not be efficient use of limited government resources let alone the cost to the community of repeating the process again.
Overwhelming support was received from both from the community and respected community organisations. This was reinforced by Whaka Kotahi commenting in their report that: "the decision came after favourable submissions for the 60kph speed limit from: Treaty Partners: Ngāti Pikiao Koeke, (70 people attended their hui), Ngāti Pikiao and Te Whaekura o Ngāti Rongomai and key Stake Holders: the Ministry of Education, the Log Transport Safety Council, the Whakatane District Council, the Automobile Association, LRCA and the lake side community."
Cost Benefit Analysis
The Cost benefit analysis should also include a valuation of the damage caused to roads by acceleration, deceleration, cornering and higher speeds, associated with lower and higher speed limits. Especially if the road is used by heavy commercial transport.
To what extent do the above speeds impact the $0.5 billion pothole nightmare the government currently faces and the widespread road repairs which are continually taking place which add more to trip time than any reduction in speed limits?
Strengthen Consultation Requirements
Requiring the consultation process to be repeated
Repeating the already thorough Consultation Process: Our observation was that the consultation process used to set the safer speed limits for our section of SH30 was very thorough.
Repeating this process to reverse speed limits is definitely a waste of money - just refer back to the consultation which has already taken place. Only consult where the decisions taken are not backed by the consultation which took place.
Update the Director’s criteria for assessing speed management plans
The Director’s review criteria should include an accident analysis!
The following requirement should be added:
Provided an analysis of accident statistics for the road highlighting sections of the road which have high accident rates and the speed limits and or other actions designed to mitigate these high rates.
Reverse Recent Speed Limit Reductions since January 2019
Repeating the Consultation Process:
Where NZTA can demonstrate public support, (from the previous speed review consultation process), for the lower speed limit on all or part of a route the lower speed limit should be able to be retained for that section.
It is ridiculous to state that NZTA must undertake an additional new consultation in line with the requirements of proposal 2 when they can demonstrate based on the original consultation that there is widespread public support for the lower speed on part or all of a state highway.
Surely this would be creating the very red tape and duplication that the new government is endeavouring to remove.
Information to be provided to the Public before they make their submissions:
As a Cost Benefit Analysis is a fundamental required pillar of the new governments process for reversing, setting and reviewing speed limits, it should be mandatory for NZTA to present economic and safety analysis to inform the Public’s understanding when making their submissions.
You can read the LRCA Submission on the new Rule here.
You can find out more about the new Rule and the implementation process here.