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

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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