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

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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. 4
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 5
Page 1 and 2: SUBMISSION ________________________
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Page 13: trailers going over 40kph will have

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

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