Every child deserves the freedom to walk and bike to school safely in Aotearoa. 

Make sure the government hears your voice on their planned changes to the Land Transport Rule. The Government’s changes to speed limits will result in more people being killed or seriously injured, make our streets unsafe, and strip power from local councils.  

Creating a submission is your opportunity to share your perspective with decision makers, and you can do this within minutes. Below we’ve created a quick explainer, with instructions on how to create a submission on the planned amendments to the Land Transport Rule. 

Why does this matter? 

We all want our tamariki to be able to walk and cycle to school and sport, and for our whānau to come home safely from mahi. We can have cities and towns where it’s safe for all of us to get to school, work, and return home safely. Councils and communities have worked together over the last three years to introduce safer speeds on some of our roads, reducing deaths and serious injuries, and making our towns and cities a better place to be.  

The OECD reports that speed is the biggest contributor to the number of deaths and serious injuries on our roads, and official advice to the Minister said that 87 percent of our current speed limits are unsafe. Forcing speed limit increases in places that are inappropriate in our cities, towns, and on highways will disproportionately affect Māori, young people, and low-income communities, who experience higher rates of road injury and death. 

This decision to force higher  speed limits will prevent our kids being able to walk and bike freely and independently to their schools, to the playground, to sports and other activities. 

 What is the Government trying to do? 

The Government is proposing to force communities to put in speed limits that are dangerous, especially for children walking and cycling, and change how they are set, through the Land Transport Rule: Setting of Speed Limits (the draft Rule). 

This draft Rule, out for consultation: 

1. Bans the evidence-based safe speed of 30kph in most urban places, including most of the day near schools, and blanket state highway increases to 100km/h, so communities cannot make their own decisions on appropriate speeds 
2. Forces councils to use variable speed limits next to schools, of 30km/h right before pick up and drop off times, even though children are in school areas at all times of day throughout the week 
3. Requires councils to undertake expensive cost-benefit analysis if they want to change speed limits, with minimal exceptions, if they wish to reduce speeds from 50km/h in urban areas, and 100km/h on arterial roads 

 The evidence is overwhelming that moderate reductions in speed saves lives – we’ve seen this in early evaluations of speed limit changes made since 2020. These are the kinds of speed limit changes the Government is applying a blanket reversal to. 

What can I do about it? 

The Minister has said this blanket reversal of sensible speeds won’t be applied where there is support to retain them – make your voice heard by submitting on the draft Rule now! 

• We have created the below guide to help you understand the Bill and draft your own submission.
• You can choose to make a quick submission, or spend a bit more time and use our prompts to create a strong submission of your own.
• Once you have done your submission, consider sharing this with friends and whanau. You could include your stories of why this is so important.   

What could my submission say? 

This guide sets out prompts to help you understand the draft Rule and draft your own submission. This could be a quick submission, using the arguments drafted below against this Rule, or a more detailed submission you write in your own words.  

Make a quick submission: 

You can submit an email, or document, with the text below. Send this to [email protected] before Midnight on Thursday 11 July 2024. 

Copy this text into a document/email:

I do not support the draft Land Transport Rule: Setting of Speed Limits. This is because it:  

Applies blanket speed limit increases and settings that are not appropriate for all local, rural, and state highway roads, which will result in more deaths and serious injuries 

Overrides local decision-making by communities who have already implemented safe speed limits 

Applies variable, instead of static speed limits outside schools, which are less effective and do not result in significant time savings 

This Rule overrides the wishes of communities who want slower, safer, residential streets. It will be less safe for children to walk and bike to school independently and contradicts international and domestic evidence which clearly shows that higher speeds lead to more crashes, injuries and deaths.  

When speeds are lowered in our communities, there is a massive uptake in walking and cycling. Making these options attractive and safe for people makes our cities and towns better places to live – it decreases congestion, noise pollution, and makes our streets more pleasant.  

Councils have consulted with local communities and spent ratepayer money on implementing sensible speeds that help to make our streets safer for children, pedestrians, cyclists and motorists alike. Overriding these decisions and making it more difficult, and more expensive, for these communities to retain their changes is an ideological overreach from central Government. 

The Land Transport Rule also reverses years of work that Road Controlling Authorities and communities have already done to implement safe speeds – changes which have avoided crashes and helped to save lives. This is an overreach by central Government that attempts to force communities to bend to an ideological opposition to sensible speeds, and to accept more deaths and injuries in our neighbourhoods and communities. 

Do you have a local street that has had its speed changed? You could write about your personal experience of the speed limit changing, for example, whether you find the street safer to walk or cycle on now.  

Make a detailed submission 

Either submit directly through the survey on the Ministry of Transport’s website, or submit a document prepared separately to [email protected]. Submissions are due by midnight on Thursday 11 July, 2024. 

For a submission done by survey, or through email, start your submission with your overall position on the draft Rule. We recommend you say: 

• I strongly oppose the draft Rule.  
• I request that the Ministry of Transport recommend it does not proceed through further stages. 

For the survey, answer the questions section by section for the seven total proposals the Rule changes. You do not have to comment on every proposal. See our breakdown of the proposals below. 

Use the proposal-based prompts provided below to guide your submission with any (or all) of the key issues identified that you are interested in.  

The more you put your submission into your own words the better. Submissions that are exactly the same are grouped together, rather than being read individually. Use the ideas below to prompt your own response you will submit. 

Proposal one – require cost benefit analysis for speed limit changes 

The draft Rule requires road controlling authorities (councils and Waka Kotahi) to undertake cost benefit analysis when consulting on proposed speed limit changes.  

Prompt: This is an added layer of bureaucracy and cost for councils who have already implemented sensible speed limits in their cities, towns, and near their schools. Domestic and international evidence is already very clear that reducing speed limits results in more benefits than costs. Area wide changes to speed limits should undertake consultation and cost benefit analysis, but small local road speed limit changes that save lives should not be required to absorb this extra cost.  

Are there areas where speed limits have reduced in areas where you live? You could write about the value you’ve seen from these speed reductions.   

Proposal two – additional consultation requirements 

The draft Rule proposes that all road controlling authorities follow the same consultation requirements, and expands on the consultation requirements already in the Local Government Act. This means Waka Kotahi, along with local councils must do the following: 

• Use reasonable efforts to consult with persons that use the road for which a speed limit change is proposed, freight users, local communities, businesses and schools surrounding the impacted area, and local government  
• Publish the draft speed management plan and cost benefit analysis on a website and give at least four weeks for any interested party to make a submission 
• Following consultation, publish a summary of submissions and include an explanation of how feedback was taken into account in the final speed limit changes 
• Proposed speed limit changes on each road must be presented separately in consultation to allow for consultation feedback on each road that is changing. 

The draft Rule also removes the requirement for Māori to contribute to speed management plans, unless it specifically is likely to affect Māori land, land subject to any Māori claims settlement Act, or specific historical, cultural or spiritual interests.  

Prompt: I support requiring all Road Controlling Authorities, including Waka Kotahi, to consult with locally affected communities when undertaking speed management plans. I do not support the removal of the requirement to provide processes to provide for Māori to contribute to the preparation of the plan. This is against principles of Te Tiriti o Waitangi, especially when Māori experience disproportionate rates of deaths and serious injuries on our roads. 

Proposal three – variable speed limits outside school gates  

The draft Rule proposes variable speed limits variable speed limits outside school gates during school travel periods, using static or electronic signs to show speed. The previous rule required speed limits of 30km/h around schools at all times, or 60km/h at all times, depending on the location of the school. 

Variable speed limits are speed limits that change depending on the time of day to protect certain road users.  

Prompt: I do not support proposal three. This is because children travel near and around schools at different times of the day, including evenings and weekends for sports and other co-curricular activities. The time savings from variable speed limits are not worth the increased risk to children, as vulnerable road users. We should be reducing speeds around schools at all times to ensure children are able to travel to school safely and independently. Static speed signs should not be allowed, because evidence shows drivers tend to ignore the lower speed.  

Are you attending school, or have children who have attended a school? You could write about times you were there past the proposed hours.  

Proposal four – introduce a Ministerial speed objective  

The draft Rule introduces a ‘Ministerial speed objective’ which signals the pace, scale and focus of speed changes they expect road controlling authorities to work to. 

Prompt: I do not support proposal four. Road controlling authorities should set speed limits according to evidence, not according to the whim of a Minister. 

Proposal five – schedule of speed limits classifications  

The draft Rule proposes to introduce a binding schedule of speed limit classifications that specify speed limits available for each road type. All changes Road Controlling Authorities make to speeds must follow these classifications, with limited exceptions. This includes standardised speed limits in urban areas (50 km/h) and interregional connectors (100 km/h). 

Prompt: I do not support proposal 5. Blanket speed increases for all roads in Aotearoa, without the ability for Road Controlling Authorities to determine appropriate speed settings will lead to increased risk of crashes. Road Controlling Authorities should be able to retain the speed settings they have implemented and not spend time and revenue reverting to higher speeds from this binding classification. Blanket speeds of 50km/h in urban areas will reduce the number of people who feel safe to walk and cycle, which will worsen congestion, climate pollution, and health outcomes. Blanket speeds of 100km/h on state highways, including less safe highways where speeds have been reduced will lead to more deaths on our roads. 

You could write about how it feels unsafe to walk or cycle alongside roads at the higher speed limits.  

Proposal six – new criteria for speed management plans 

The draft Rule requires additional criteria Road Controlling Authorities need to meet before submitting a speed management plan for certification: 

• consultation requirements (including publishing a summary of submissions and how that feedback was taken into account) 
• cost benefit analysis requirements 
• speed limits have been set in accordance with the speed limit classifications 
• speed limit requirements outside schools in accordance with the new Rule 
• has regard to any Ministerial Speed Objective 

Prompt: I do not support proposal 6. I do not support Road Controlling Authorities needing to have regard to the Ministerial Speed Objective because I do not support Ministers setting a ‘speed objective’, as there are risks this objective will be based in ideology and not evidence. I also do not support requiring councils to do cost-benefit analysis for minor speed changes. I also do not support the speed limit classifications which restrict councils ability to set safe speed limits of 30 km/h in urban areas. 

You could write about how unsafe it feels to walk or cycle in urban areas when speeds are at the higher speed limits, or how urban areas are more pleasant to be around with reduced speeds. 

Proposal 7 – reverse recent speed limit reductions 

The draft Rule requires speed limit reductions put in place by Road Controlling Authorities, such as councils and Waka Kotahi, be reversed. Widespread speed limit reductions had been put in place for areas around schools of 30km/h and 40-60km/h, depending on the category of school. Some speed limit reductions were also put in place in areas of the state highway with high, unsafe speeds. 

Prompt: I do not support proposal seven. Road Controlling Authorities have already made assessments of speeds in their areas and have determined safe speeds, and blanket increases, or blanket variable speeds outside schools will lead to more deaths and injuries on our roads. This proposal also undermines councils and communities who have already made decisions on speed limits in their areas.  

Do you have a local street that has had its speed changed? You could write about how much safer the street is to walk or cycle on now. 

Are you ready to submit? Click the button below to go through to the survey. Please make your submission before Thursday 11th July.