Submission on Draft Land Transport Rule, Agricultural Vehicles ...

SUBMISSION
___________________________________________________________________________
To: Agricultural Vehicles Omnibus
Rules Team
NZ Transport Agency
Private Bag 6995
Wellington 6141
<strong>Submission</strong> on: Draft Land Transport Rule, Agricultural Vehicles,
Omnibus 2012 Rule 10050
From: Federated Farmers of New Zealand
Date: 30 November 2012
KARA LOK
POLICY ADVISOR
Federated Farmers of New Zealand
PO Box 715, Wellington 6140
P 04 470 2161
F 04 473 1081
E klok@fedfarm.org.nz
www.fedfarm.org.nz
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1. INTRODUCTION
1.1 Federated Farmers welcomes the opportunity to submit to the New Zealand
Transport Agency (NZTA) on the Draft Land Transport Rule, Agricultural Vehicles
Omnibus 2012, Rule 10050.
1.2 The Federation is very supportive of the Agricultural Vehicles Review and we first
submitted on the review in May of this year. The recommendations in this
submission reflect what we initially asked for.
1.3 The agricultural sector is heavily impacted by transport regulation and we agree with
the comment in the draft rules overview that it is vital land transport legislation is fit
for purpose and does not impose undue compliance costs. We strongly support the
‘two-tier’ approach with 40kph speed threshold adopted by the Government and
contained in the draft Rule. We believe it appropriately balances the reduction of
compliance costs with the need to protect road safety.
1.4 We commend the Ministry of Transport, the NZTA and the review team for all the
hard work they have put into this review and for their constructive engagement with
Federated Farmers and other interested parties.
1.5 The Federation would like to remain involved in any further discussions around the
development of the final changes to the Land Transport Rule Agricultural Vehicles
Omnibus 2012.
1.6 Following a summary of recommendations, this submission comments on the
proposals listed in the draft omnibus rule overview.
Section 2 discusses the scope and definition of ‘agricultural
vehicles’;
Section 3 discusses driver licensing and worktime;
Section 4 discusses heavy vehicles;
Section 5 discusses over dimension vehicles;
Section 6 discusses road user and vehicle lighting amendments;
Section 7 discusses vehicle inspection requirements;
1.7 SUMMARY OF RECOMMENDATIONS
1.8 Overall Federated Farmers is very supportive of the majority of the proposed
changes to the Land Transport Rules and we believe it will appropriately balance the
need to reduce compliance costs on the agricultural sector with the need to protect
road safety.
1.9 While supporting the vast majority of changes set out in the draft Omnibus Rule,
Federated Farmers suggests the following amendments be made to the final
Omnibus Rule:
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a. Certain categories of all terrain vehicles (such as ‘quad-bikes’, side
by side utility vehicles.) be included in the definition of an
agricultural vehicle.
b. ‘Agricultural vehicles’ driven on the road at speeds of under 40kph
to be identified by a ‘40kph’ sign.
c. The Vehicle Class ‘EX’ proposed in the Agricultural Vehicles Review
discussion document should be introduced for agricultural vehicles
driven on the road at speeds up to 40kph.
d. Remove the requirement to fit marker lights on or near hazard
panels.
e. Remove the requirement for tractors under three metres in width to
be fitted with hazard panels where the rear tires are the widest
point.
f. Implements that extend beyond the width of the tractor tyres or are
in excess of three metres in width require hazard panels.
g. Remove the requirement for hazard panels to be frangible, as
frangible 1 hazard panels are not durable.
h. The final rule changes align with the definition in the Agricultural
Vehicles Guide. This will mean the guide will have to be amended.
2. COMMENT ON THE SCOPE AND DEFINITION OF ‘AGRICULTURAL VEHICLES’
2.1 The draft omnibus rule proposes that the definition of ‘agricultural motor vehicle’ is
amended in the Land Transport (Driver Licensing) Rule 1999 to a vehicle designed,
constructed or adapted for agricultural purposes 2 .
2.2 This definition includes agricultural tractors 3 and trailers 4 , soil cultivators, planters
and seed drills, harvesters, mowers, toppers, bailers, hay rakes, produce sorters.
On–road 4WD vehicles, utes, trucks, goods trailers operated at more than 40km/h
and all terrain vehicles such as quad bikes are not included in the definition of a
‘agricultural motor vehicle’.
2.3 Under the old rules only ‘special purpose’ vehicles could be classified as all terrain
vehicles. NZTA has proposed to remove this qualification so a wider range of
vehicles such as side-by-side terrain vehicles. This means they will be covered by
the existing specialist regimes and will be subject to helmet-wearing requirements.
1
A ‘frangible’ object is an object of low mass, designed to break, distort or yield on impact, so as to
present the minimum hazard to the vehicle.
2
‘Agricultural purpose’ includes land cultivation, growing and harvesting crops, rearing livestock and
land management operation undertaken in connection with the operation of the farm (includes
cultivation and harvesting).
3
‘Agricultural tractor’ means a vehicle that is designed and constructed principally for the purposes of
towing an agricultural trailer or drawing, or towing an implement ordinarily used for an agricultural
purpose.
4
‘Agricultural trailer’ means a trailer that is used exclusively for agricultural purposes; and includes a
wheeled agricultural implement, the wheels of which are in contact with the road when the implement
is being towed; but does not include a trailer that is designed for carriage of goods; and operated at a
speed exceeding 40kp/h; or a logging trailer.
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Federated Farmers supports the statement in the Yellow Draft that helmets do not
have to be worn in vehicles fitted with roll bars and seat belts.
2.4 We support the inclusion of side-by-side vehicles in the definition of ‘all-terrain
vehicles’ and in the definition of an ‘agricultural motor vehicle’. From the perspective
of farmers the reference to land management connected with growing crops and
rearing livestock etc. (i.e., the business of farming) in the draft omnibus rule will
cover the vast majority of instances.
2.5 As stated in our previous submission, Federated Farmers believes there may be a
case for including certain categories of all terrain vehicles (such as quad-bikes, three
wheelers, mules, etc. but not motorbikes, dune buggies, utes, farm trucks, land
rovers, etc.) in the definition of an agricultural vehicle, especially as these are
generally used only occasionally on the roads.
2.6 Federated Farmers recommends NZTA consider including certain categories
of all-terrain vehicles (such as quad-bikes, three-wheelers, mules etc.) in the
definition of an ‘agricultural motor vehicle’.
3. COMMENT ON DRIVER LICENSING AND WORKTIME REQUIREMENTS
3.1 There are six rule changes proposed by the review team to the Land Transport
(Driver Licensing) Rule 1999 (the Driver Licensing Rule) and Land Transport Rule:
Work Time and Logbooks 2007 ( the Work Time and Logbooks Rule):
a. Increase the maximum speed limit for holders of Class 1 driver licences
driving agricultural motor vehicles from 30kph to 40kph.
b. Allow the holder of a Class 1 Restricted (R) driver licence to operate a tractor.
c. Extend the range of agricultural vehicles that can be operated by the holder
of a Class 1 driver licence and ensure that there is consistency between
vehicles that can be driven with Class 1 and Class 2 licenses.
d. Allow the holder of an overseas agricultural vehicle to operate an equivalent
vehicle in New Zealand.
e. Simplify and improve the alternative fatigue management scheme.
f. Incorporate in the Rule the principal features of the current Work Time
Variation for Critical Agricultural Operations to provide for an agricultural
variation that applies to the sector as a whole.
3.2 Federated Farmers supports these proposals. A brief comment on each proposal
follows below.
3.3 Driver Licensing
3.4 Federated Farmers strongly supports the proposal, as stated in our initial submission
on the Agricultural Vehicles Review, to increase the maximum speed restriction for
Class 1 drivers driving ‘agricultural motor vehicles’ on the road from 30kph to 40kph.
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3.5 A person wanting to drive tractors or a heavy special- type vehicle over 40km/h
would be required to get a class 2 license. Federated Farmers still believes this is a
sensible precaution.
3.6 The Federation supports the proposal to allow restricted licence (Class 1R) holders
to operate a tractor. We agree that the time taken for drivers to obtain a Class 1 full
driver licence can sometimes create a barrier for employers when a restricted
licence holder needs to operate agricultural vehicles to fulfil their tasks.
3.7 We also support the interim solution on the condition that the proposed agricultural
(A) endorsement for Class 1 licences is still being considered. Extending the range
of agricultural vehicles a Class 1 licence holder and a Wheels (W) endorsement can
operate will make it easier for employers to recruit staff. Under the amendment the
person would be able to drive tractors at more than 40kph and other special-type
vehicles (that run on wheels and are not forklifts).
3.8 In our previous submission on the Agricultural Vehicles Review, we welcomed the
proposal to recognise agricultural vehicle licenses from UK and Ireland, but felt that
clarification was needed to recognise all appropriate jurisdictions (e.g., Europe, USA,
Canada, Australia etc.).
3.9 The Federation is pleased to see this recommendation has been included in the
proposed changes to the omnibus rule and we commend NZTA for this.
3.10 The revised proposal will make it much easier for the agricultural sector to recruit
seasonal workers from countries like Ireland and the UK. Under the current rules, the
time taken to obtain a New Zealand Class 1 License creates a barrier to employ an
overseas seasonal worker.
3.11 Work time requirements
3.12 Federated Farmers supports the proposed changes to the Work Time Rule.
Simplifying the existing rules and improving the alternative fatigue management
scheme will have a positive impact on farming business while not compromising
workplace health and safety or road safety.
3.13 Many farmers will be excluded from the Work Time requirements, due to the
proposed 40kph threshold speed limit for Class 1 licence holders driving tractors and
agricultural ‘motor vehicles’. This is supported as it will reduce compliance costs and
allow farmers to keep working during seasonal harvesting operations.
3.14 Agricultural work is seasonal and weather dependent, for example for grain and
seed farmers stopping harvesting is not an option. This is also the case for other
farming activities such as calving lambing and planting. Another instance where
farming contractors work long hours is during bailing which can usually only be done
at dusk as there tends to be very little wind. This means the contractors employed to
do this task will often work through the night. Allowing a farmer or agricultural
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contractor conducting a ‘critical agricultural operation’ 5 to apply for a variation to the
work time rules will address this issue.
3.15 Federated Farmers supports the general obligations on employers and the selfemployed
to take all practicable steps to ensure health and safety in the workplace.
An improved alternative fatigue management scheme will also protect and improve
safety. The ‘Work Time Variation of Critical Agricultural Operations’ application
process must be user friendly and flexible enough to recognise the needs of the
agricultural industry.
4. COMMENT ON REQUIREMENTS FOR HEAVY AND OVER-DIMENSION
VEHICILES
4.1 There are several changes proposed for heavy and over-dimension vehicles:
a. Update the Rule to reflect the current practice for towing
connections between heavy agricultural motor vehicles.
b. Increase the front overhang for an agricultural motor vehicle to a
maximum of four metres measured from the front edge of the
driver’s seat.
c. Introduce rule that provides for flexibility of alternative hazard
panels. Allow parts of an agricultural motor vehicle to be painted in
high visibility paint as an alternative to displaying hazard panels.
d. Relax the requirements for agricultural motor vehicles travelling in a
convoy to be accompanied by pilot vehicles.
e. Clarify that forks and other equipment fitted to the front of an
agricultural motor vehicle do not have to be removed when the
vehicle is being operated on the road, provided the operator
complies with Land Transport Rule: External Projections 2001.
4.2 Federated Farmers supports these proposals. A brief comment on each of the
proposal follows below.
4.3 Towing connections
4.4 Federated Farmers supports the proposed change to the Land Transport Rule:
Heavy Vehicles 2004 to update the current rules around towing connections.
4.5 The present rule, which is in line with the Agricultural Vehicles Guide, has a
minimum requirement of a single safety chain. There are no further specifications for
the weight, other than that two crossed safety chains should be used if the coupling
fails as it will improve the directional control of the trailer.
4.6 The Federation believes making the amendments to Land Transport Rule listed
below will provide some much needed clarification and will make it easier for farmers
to be compliant when towing agricultural trailers and implements.
5 ‘Critical agricultural operation’ means work that is required for an agricultural purpose that must be
completed urgently to avoid the adverse impact of a biological event, including a natural phonological
process, or change in weather conditions.
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Towing connection components must be fit for purpose and in
sound condition;
A coupling pin must:
a) be of a diameter that is appropriate for the diameter of the tractor
or trailer coupling, whichever has the smaller diameter hole; and b)
have a diameter that is less than 75% of the diameter of the larger
of the coupling holes; and
c) have a retaining mechanism
Tow-eyes must not be worn at any point more than the lesser of:
a) 10% of the original diameter; or
b) the manufacturer’s wear tolerance
An Agricultural trailer fitted with a towing connection other than a
two-point or three-point linkage must have a safety chain
permanently attached to it and that chain must:
a) have a breaking strength of a least the gross mass towed; and
b) have its breaking strength identified; and
c) be attached to the trailer by means other than by welding of the
chain itself; and
d) be adjustable in length to eliminate a tight or loose chain.
A tractor used to tow an agricultural trailer must have an attachment
point which a safety chain can be securely connected.
4.7 Over-dimension vehicles
4.8 As Federated Farmers previously stated in its submission on the Agriculture Vehicle
Review, we welcome the proposal to increase the current three metre forward
overhang threshold to four metres. However, many large modern tractors with front
end loaders, or front mounted implements fitted will still be unable to comply. Despite
this, Federated Farmers understands and shares concern about the potential safety
risk of increasing the maximum threshold beyond four metres and we agree it is
important to manage the safety risk.
4.9 We would like to reiterate the point we made in our previous submission that road
controlling authorities and property owners should ensure there is a clear five metres
between the entrance to a property and the road free from trees or other vegetation
do there is clear visibility in both directions at intersections and access ways.
4.10 Hazard warnings
4.11 Federated Farmers welcomes the proposals to introduce alternative hazard panels
and to allow parts of an agricultural vehicle which overhang the front of the vehicle to
be painted in high visibility paint.
4.12 The Federation continues to believe that European panels should be allowed to be
used, but we do commend NZTA for allowing alternative configurations.
4.13 The Federation also continues to recommend that officials consider increasing the
vehicle width before hazard panels are required be increased from 2.5 to three
metres.
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4.14 Federated Farmers acknowledges that the alternative hazard panel configuration will
still have to consistent with the standard set by the rule and that they can be no
smaller than 1200 square mm in size. Also Proposal B the ‘painting of a vehicle
overhang’ greater than four metres provides an alternative to displaying hazard
panels.
4.15 However, the Federation believes some further amendments need to be made to
Clause 6.7 (3) of Vehicle Mass and Dimension Rule 2002 (VDAM) and the
provisions of the Vehicle Lighting Rule 2004.
4.16 Presently these rules require vehicles over 2.5 meters in width to be fitted at the
widest point with flags during the day or to be fitted with retro-reflective hazard
panels at night. These vehicles must also be fitted with a white or amber marker
light forward facing and red rearward facing at each corner of the vehicle closest to
the widest point, i.e. on the hazard panel.
4.17 To require the fitment of marker lights in addition to standard tail lights on all vehicles
and implements and provide a power source would impose significant compliance
costs on our members and would not be durable, practical or provide tangible road
safety benefits.
4.18 The majority of the tractors in New Zealand have a width of 2.5 - 2.8 meters across
the outside of the rear tyres and the bulk of those tractors are not fitted with either
hazard panels or outline marker lighting. The safety of these vehicles on the road is
a factor of their speed differential, rather than width and compliance with this rule is
currently very low (see Pic 1).
4.19 When a tractor is fitted with hazard panels, they are then made redundant when an
implement is fitted that is wider than the tractor; which must in turn be fitted with
hazard panels at its widest point, thereby creating a duplication of panels. This point
is illustrated in two of the photographs below (Pic 2-3) provided by one of the
Federation’s members.
Pic 1 - A tractor where a hazard panel is legally required, but has little benefit.
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Pic 2 - Oncoming traffic clearly warned by hazard panels.
Pic 3 - Protruding implement clearly identified by hazard panels.
4.20 Any implement protruding beyond the outside line of the tractor tyres is the real risk
posed to other road users and Federated Farmers supports the use of Hazard
Panels on these implements.
4.21 Federated Farmers recommends officials consider making the following
amendments to the VDAM and the provisions of the vehicle lighting rules:
a. Remove the requirement to fit marker lights on or near hazard
panels.
b. Tractors under three metres in width to not require hazard panels
where the rear tires are the widest point.
c. Implements that extend beyond the width of the tractor tyres or are
in excess of three metres in width require hazard panels.
d. Remove the requirement for hazard panels to be frangible, as
frangible hazard panels are not durable.
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4.22 Pilot vehicle requirements
4.23 Federated Farmers supports the proposal to relax the requirements for agricultural
motor vehicles travelling in a convoy to be accompanied by a Class 2 pilot vehicle.
4.24 It is proposed that over-dimension category 1 and 2 agricultural motor vehicles
travelling in a convoy of three or less vehicles would not be required to have a pilot
for each agricultural vehicle. This is provided there is a pilot vehicle positioned at the
front and at the rear of the convoy.
4.25 This amendment would only apply to areas where adequate visibility is maintained,
where there is not adequate visibility on the roads a pilot vehicle would still be
required for every over-sized agricultural vehicle.
4.26 We agree that removing the piloting requirement altogether for oversized agricultural
vehicles would raise too many concerns about safety.
4.27 Removal of forks and other equipment fitted to the front
4.28 Federated Farmers supports the proposal to clarify that operators do not have to
remove forks and other mounted implements fitted to the front arms of agricultural
vehicles.
4.29 Under the External Projections Rule an operator of an agricultural vehicle has to
show they are following best practice and meeting the requirements set out in the
Agricultural Vehicles Guide 2009. Federated Farmers believes this is a sensible
safety precaution.
5. COMMENT ON ROAD USER AND VEHICLE LIGHTING AMENDMENTS
5.1 Although some concern has been expressed to us about an ‘over saturation’ of
flashing lights, Federated Farmers supports the proposal that slow moving
agricultural vehicles registered from May 2013 require to be fitted with and to use
amber beacons. We will also be encouraging farmers to use them even if their
vehicles were registered before that date.
5.2 The value of the beacon is when there is a large difference between speed of the
vehicle and the speed of the traffic. Concern has been expressed to us that they
could be a distraction for drivers in built up areas moving at much the same speed
as the agricultural vehicle. On the other hand, the large size of agricultural vehicles
and their density relative to other road users makes it important that warning is
provided to motorists who do not regularly come into proximity of such large
vehicles.
5.3 Federated Farmers accepts that the amber flashing beacon must be visible for at
least 100m. Where a towed vehicle obscures the amber flashing beacon another
beacon may be fitted on to the towed vehicle.
6. VEHICLE INSPECTION (AND LICENSING) REQUIREMENTS
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6.1 There are several changes proposed for vehicle inspection requirements:
a. The removal of periodic (warrant of fitness/certificate of fitness
(WoF/CoF)) inspection requirement for agricultural motor vehicles
that are operated at speeds not exceeding 40kph.
b. A revised and simplified WoF inspection for agricultural motor
vehicles that are operated at speeds exceeding 40kph, with no CoF
requirement.
c. Annual vehicle inspections for vehicles that are operated at speeds
exceeding 40kph, rather that six monthly.
6.2 Federated Farmers supports these proposals. A brief comment on these proposals
follows below. We have also provided comment on agricultural vehicle licensing.
6.3 Agricultural Vehicle Inspection Regime
6.4 Federated Farmers supports the proposal that there be no periodic inspection for
agricultural vehicles that only travel up to 40kph, a revised and simplified annual
WoF for agricultural vehicles operating above 40kph, and an expanded mobile
service network to enable WoF inspections to be carried out on-farm. These are all
very sensible and helpful proposals.
6.5 We note that the operators of farm vehicles will still be subject to a duty of care to
keep their vehicles in a road worthy condition when operating on road. Federated
Farmers supports the development of an annual safety check list for all agricultural
vehicles used on the roads.
6.6 The Federation has also made this recommendation the Vehicle Licensing Reform’s
review team. We would be happy to work with NZTA to develop such a safety
checklist.
6.7 Agricultural trailers and towed implements
6.8 Federated Farmers is pleased that NZTA has decided not to change the current
licensing regime for agricultural trailers and towed implements.
6.9 Towed agricultural vehicles pose very little safety risk to other road users when
towed at speeds in conformity with manufacturers specifications for axle loadings
and tyre speed and weight ratings. As stated above Federated Farmers supports the
development of an annual safety check list for all agricultural vehicles used on the
roads.
6.10 As stated in section 6, the Federation believes developing a series of agricultural
vehicle specific safety checklists explaining what is needed to ensure the vehicle is
well maintained would make it easier for operators to meet the minimum safety
standards.
6.11 Agricultural Vehicle Licensing
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6.12 Federated Farmers continues to support the initial proposal contained in the
Agricultural Vehicle Review’s discussion document to permit all agricultural vehicles
operated up to 40kph on the road to be registered under license class ‘EX’.
6.13 Under the rule changes proposed in the Omnibus Rule all agricultural vehicles
(regardless of whether they are operating under or over 40kph) will be licensed G.
This means there is no way to classify those agricultural vehicles operating under
40kph and therefore able to take advantage of the concessions available in this
Rule.
6.14 Federated Farmers continues to believe that the EX license class is necessary. This
is particularly so as the Government grapples with how to ensure that tractors
operating over 40kph pay their share of RUC, as required under the Road User
Charges Act 2012. Hubodometers for tractors are impractical and we understand
that the Government is currently considering a higher annual license fee for these
tractors. This will obviously require a different license class for those operating over
as opposed to under 40kph.
6.15 As well as the need to classify vehicles operating under as opposed to over 40kph,
these vehicles need to be easily identifiable both for enforcement purposes and as a
warning to other road users about their slow speed (this is because most accidents
involving agricultural vehicles are caused by faster vehicles running into slow-moving
vehicles). Federated Farmers continues to support a ‘40’ sticker as proposed in the
discussion document and we note that the Agricultural Transport Forum is
considering whether to provide farmers and contractors with ‘40’ stickers they can
place on their vehicles.
6.16 Some people have suggested that the signage should be on those vehicles
operating over 40kph (as a ‘40+’ in a circle). This is because these vehicles are a
small minority of the total fleet and they will be the exceptions as opposed to the
rule. However, on the other hand there is concern that using a ‘40+’ sign would
generate confusion in the minds of motorists, which are used to seeing speed signs
as a limit. Federated Farmers strongly supports the use of ‘40’ sign only on
agricultural vehicles travelling on the road at less than 40km/hr.
6.17 It has also been suggested to us that the speed signage also has a purpose of
warning motorists of the speeds these vehicles actually travel and that there should
be signs reflecting those speeds (e.g., 20kph, 30kph, 40kph, 50kph, etc.). We also
consider this to have the potential to generate confusion and it would depart from the
purpose of the proposal to use a 40kph sign, which is to identify those vehicles
registered EX as opposed to G.
6.18 Federated Farmers recommends that vehicles operating up to 40kph be
licensed as EX and required to display a ‘40’ sticker.
6.19 Applying RUC to tractors and trailers over 40kph
6.20 Under the Road User Chargers Act 2012, tractors going over 40kph have to pay
Road User Chargers (RUC). The Ministry of Transport is now also proposing that
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trailers going over 40kph will have to pay RUC in response to concerns raised by the
Road Transport Forum.
6.21 The Federation has been involved in discussions with the Ministry of Transport,
NZTA and a number of other interested parties over how RUC should be applied to
trailers and tractors going over 40kph.
6.22 Federated Farmers supports the proposal that tractors registered to go over 40kph
on roads pay an additional flat annual charge of $600 that is collected as part of
annual vehicle licensing process.
6.23 We also support the proposal for agricultural trailers travelling above 40kph to be
registered and for a combination RUC rate to be applied based of the gross laden
weight (GLW) of the vehicle and the trailer.
6.24 However, the Federation does not support the proposal to apply RUC to all
agricultural motor vehicles and trailers going under 40kph. Federated Farmers
believes given that the majority of these tractors will only use the road incidentally,
the contribution farmers make to the Land Transport Fund for the up keep of rural
roads through their council property rates should be sufficient.
7. AGRICULTURAL VEHICLES GUIDE
7.1 Federated Farmers recommends that when the rules are adopted into law that the
Agricultural Vehicles Guide 2009 is amended to reflect the rule changes. The guide
has proven to be an invaluable resource for both the Federation’s members and the
agricultural sector as a whole.
7.2 Federated Farmers would welcome the opportunity to be involved in updating the
guide and recommends that the Agricultural Transport Forum works with the Ministry
of Transport (MOT) and NZTA to do this.
8. ABOUT FEDERATED FARMERS
8.1 Federated Farmers is a member based organisation that represents farmers and
other rural businesses. Federated Farmers has a long and proud history of
representing the needs and interests of New Zealand’s farmers.
8.2 The Federation aims to add value to its members’ business. Our key strategic
outcomes include the need for New Zealand to provide an economic and social
environment within which:
Our members may operate their business in a fair and flexible commercial
environment;
Our members’ families and their staff have access to services essential to the
needs of the rural community; and
Our members adopt responsible management and environmental practices.
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