Incremento del tamaño del mercado libre

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MTA do not support a change to no inspection period.

– Consumer Research MTA commissioned from Peter Glen research shows:

~ Over 80 percent of motorists freely support an annual inspection for vehicles up to three years.

~ 95 percent freely support an annual inspection for vehicles over three years and up to six years.

~ 67 percent freely support at least a six monthly inspection for vehicles over six years and up to 10. There is even stronger support for a six monthly inspection for vehicles over 10 years.

A full report covering the Peter Glen Research survey into the public attitude to WoF and vehicle safety is attached to this discussion document.

– The discussion document suggests an in-service inspection at the time of change of ownership advising vehicles would be inspected on average at 2–3 year

intervals. MTA disagree. We suggest vehicles would be inspected at just over four year intervals on average.

~ The discussion document advised there are around one million new and used vehicles sold in New Zealand. The relevant transaction is used vehicle change of ownership. Government statistics indicate just over 750,000 light vehicles change ownership in-service.

~ There are approximately 3.2 million light vehicles in New Zealand. ~ On average vehicles change ownership at just over four years.

– MTA research indicates that on average 51 percent of vehicles require safety related work on the day of inspection under the current regime of an annual inspection to six years then six monthly thereafter. Under a regime where these vehicles are inspected at change of ownership these vehicles could on average go on accumulating faults for another 3 to 3.5 years. Some vehicles might not be inspected for 10 or 15 years. This would be an extremely dangerous situation and would clearly be unacceptable to the public of New Zealand.

– Some owners who know their vehicle would not pass a WoF would not sell their vehicle.

– To contemplate this shift would require, before its introduction:

~ A very significant shift of public focus from inspection to voluntary vehicle maintenance. The MTA vehicle servicing survey clearly indentified only 39 percent of motorists that undertook regular vehicle servicing and then these services might not have been comprehensive.

~ A very significant review of the on road vehicle enforcement process. MTA do not believe the government would fund this to a level where enforcement matched the effectiveness of periodic inspection.

These steps would require a prolonged advertising campaign in a similar vein to the drink driving campaign, and enforcement would need to establish itself to the extent the public were not willing to ‘run the gauntlet’ with an unsafe vehicle. There could be no interim period while the public adjusted from one system to another. The resultant fatalities and injuries from crashes would be unacceptable. Inspection costs currently paid by motorists would transfer to government, ie taxpayer, charges to maintain the required advertising and enforcement programme.

– The Oliver Hatton report attached to this submission provides more detail of the advantages of periodic inspection over enforcement systems. An excerpt from this report follows.

‘The WoF and CoF systems are the New Zealand implementation of the type of periodic vehicle inspection schemes that exist in many countries throughout the world. These schemes are seen as having a number of important advantages over roadside inspection schemes, the key ones being;

~ Regular checking of the roadworthiness of the whole fleet (apart from the known proportion of vehicles that don’t comply with the scheme’s

requirements).

~ More comprehensive, effective and efficient inspection unless expensive roadside test equipment is available.

~ Convenient and effective enforcement tool for vehicle licensing ~ Safer environment for the inspection unless expensive, fixed location

inspection sites are available.

~ Inspections are carried out at a time that is convenient to the owner/operator – avoiding the inconvenience, unplanned cost and journey delays caused by roadside inspections.

The main weaknesses of periodic inspection are that it is not a true measure of the roadworthiness of the vehicle fleet - as vehicles can be prepared for test - and the inspection provides no control of, or information on, the roadworthiness of vehicles between tests. However, the only effective way of measuring the roadworthiness of the fleet is by carrying out statistically significant sampling of a random selection of vehicles, which is both expensive and difficult to do in practice. Also, effective and cost/efficient targeting of roadside inspection to risk is difficult to achieve, particularly in a low vehicle density country such as New Zealand.’

In Victoria Australia, if a vehicle is sold without a roadworthy inspection, the number plate needs to be handed into Vic Roads. MTA support this approach and recommend that number plates be handed into NZTA if the vehicle has a WoF more than 30 days old when sold. They should only be returned to the owner once the vehicle has a WoF.

Note that in Victoria the change of ownership inspection mainly related to the Consumer Guarantees Act (not just safety) and typically costs about A$150 – A$250 and take about 11/2 hours.

Victoria also have 750 road enforcement staff split between urban and rural. As a comparison New Zealand currently have around 250 road enforcement staff.

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– Both of these systems already exist in law.

~ A current WoF no older than one month is required at the date of delivery. The purchaser can, however, accept in writing that the vehicle has been certified one month or more previously. For a vehicle with an expired WoF the purchaser must undertake in writing to the seller not to operate the vehicle until it has been inspected and certified.

~ Police can issue a red or green sticker to an unsafe vehicle requiring it to pass an inspection before being allowed back on the road.

The proposal would simply require the current change of ownership requirement to be tightened.

MTA would suggest a more effective way to report unsafe vehicles to the Police be developed that ensured action was taken to red or green sticker them as appropriate. MTA members come into contact with extremely unsafe vehicles on a regular basis. MTA recommendation

A means be established to notify Police of unsafe vehicles that is acted on and the unsafe vehicles taken off the road through issue of a red or green stickered as appropriate

More detail is provided within Appendix B Item 14 to this submission

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As detailed in point 5 above covering Option two, MTA supports ongoing improvement of the WoF test and we have included a number of suggestions within this submission including improvement in inspector training.

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As indicated in the first point above under ‘No periodic inspection’ an information and advice programme would need to parallel the drink drive campaign to bring about the cultural shift necessary to introduce Option four. This would need to occur prior to change to avoid a significant increase in crashes in the interim period.

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As indicated in the first point above under ‘No periodic inspection’ enforcement would need to increase to a point where the public were not willing to ‘run the gauntlet’ with an unsafe vehicle. This would need to occur prior to change to avoid a significant increase in crashes in the interim period.

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In the context of Option four infringements would need to change in line with the

enforcement system designed to ensure owners keep their vehicle in safe condition in the absence of a regular periodic inspections.

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As outlined in point 4 above covering Option one MTA support the introduction of demerit points for operating an unsafe vehicle.

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– The Vehicle Licencing reform interim economic report indicates that this option will result in 8.4 fatalities, 17.9 serious injuries and 88.5 minor injuries. MTA consider this underestimates the annual safety impact. Experts we have spoken to suggest vehicle causal factors contributing to accidents are underreported in this analysis. – The discussion document suggests measures to counter the potential risk of this

change would need to be fully scoped. MTA is very disappointed these measures are not clearly presented in the discussion document and included in the cost benefit analysis. Without this information anyone supporting this Option is doing so with incomplete information.