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

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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 12
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. 13
Page 1 and 2: SUBMISSION ________________________
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Submission on Draft Land Transport Rule, Agricultural Vehicles ...

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