Road to Zero Road Safety Strategy

MSAC Submission on July 2019 Consultation Document

14 Aug 2019

 1. About the Submitter

The Motorcycle Safety Advisory Council (MSAC) was established by the Government in 2011 to promote safe practices across all motorcycle and moped riders, communities and clubs. We are a group of motorcyclists that are passionate about safety and promote this primarily through our work with ACC on the expenditure of the Motorcycle Safety Levy.

MSAC has an important role in leading and promoting motorcycle safety across New Zealand.  We do this by commissioning research, engaging experts and by consulting with motorcyclists and government agencies on how to make motorcycling safer. MSAC also develops specific action plans and initiatives that contribute to motorcycle safety.

 2. Key feedback on the “Road to Zero” initiative

  1. We strongly support the considerably increased emphasis on the impact of policy on motorcyclist’s safety in the Road to Zero initiative. Motorcyclists are vulnerable road users and are over-represented in death and serious injuries (DSI) statistics on a vehicle kilometres travelled (VKT) basis.
  2. MSAC welcomes the opportunity to support and contribute to the development of Road to Zero and the delivery of performance measures and targets, particularly as they relate to motorcycle safety.
  3. The Road to Zero consultation document does not contain sufficient detail in terms of specific initiatives and targets to be delivered, as would be expected at this stage of the policy process. In terms of Action Plan 12 (Support Motorcycle Safety), MSAC is best placed to provide input in the next stage of the policy process, given our mandate; expertise; contacts; and evidence base, and we look forward to providing this contribution.
  4. We believe Action Plan Priority 12 (Support Motorcycle Safety) would be advanced, if not achieved, by by implementing the following factors:
Safety factor Rationale / evidence base
Increased enforcement

Approximately one quarter of Death and serious injury (DSI) crashes involve unlicensed riders, which we understand is significantly higher than for other vehicle types. Motorcycles require a higher level of skill to be operated safely, and this should be enforced.

Speed and impairment are factors in almost a half (48%) of motorcycle crashes.  The inherent vulnerability of motorcyclists is greatly increased when speed and impairment are present.

Enforcement of speed for motorcycles is limited by the inability of cameras to pick up rear licence plates (motorcycles do not front plates).

Investment in safety improvements for vulnerable road users

MSAC has developed a guidance document Making Roads Motorcycle Friendly (MRMF) which incorporates international best practice. Evidence from trials within NZ, including the Coromandel loop, indicated that the widespread adoption of the standards recommended in MRMF will improve safety for all road users, but particularly vulnerable road users such as motorcyclists and cyclists. Improved roads is a high priority for motorcyclists. 

Personal protective equipment

Crash evidence from NZ and overseas and ACC injury data strongly suggests that the use of personal protective equipment (PPE) reduces both risk and severity of injuries in motorcycle crashes.  Unlike similar jurisdictions, NZ lacks a single, mandatory standard for PPE beyond wearing a helmet. Legislation and regulation in this area has not changed in 64 years. While MSAC promotes wearing ‘all the gear all the time’, at a minimum we would recommend an enforced, mandatory standard.

Enhanced emphasis on rider skills

 Evaluation of the Ride Forever training programme, funded by the motorcycle safety levy, demonstrated that training reduces crashes. However, there is no ‘on road’ testing component for motorcyclists and the current licensing regime is confusing. MSAC recommends the immediate adoption of CBTA licensing as the single licensing standard.

Human factors, especially risk taking behaviours

Motorcycling is inherently riskier than other modes of transport.  A focus on interventions that target a reduction in risk taking behaviours by motorcyclists should be a priority. 

Lane filtering / splitting rules

 There is evidence that motorcyclists are being killed or injured while lane filtering/splitting. This is possibly due to a lack of regulation around this. In NSW (Australia) a lane filtering/splitting rule has been implemented allowing motorcyclists to move through traffic at up to 10kmph faster than the speed of the slow traffic. Some structure around this will provide for a safer outcome.

Helmet condition / safety checks

Helmets are a legal requirement. Helmets also have a life expectancy which we believe is date stamped on the inside of the helmet shell. Age and condition of helmets will determine their integrity in the case of an accident- they will or will not perform as expected. An investigation into helmet integrity and how to assess this would be helpful and could save lives or reduce serious head injuries. 

 

3. Specific feedback on the content of the consultation document

In addition to the key feedback above, we make the following submission in respect to the content of the consultation document:

  1. Page 10 This page puts the case for safe roads. Motorcycles and motorcycling are not specifically mentioned on this page. We submit that motorcycling is a legitimate option and that roads should be motorcycle (and other vulnerable users) friendly. Adopting the making Roads Motorcycle Friendly principles will ensure that roads are safer for motorcyclists and other vulnerable road users also (including cyclists).
  2. Page 13 We appreciate acknowledgement of motorcycling as a valid transport option and believe it should be promoted as an efficient alternative to cars.
  3. Page 15 We submit that risk-taking is an issue and we support the deterrence of risk taking while noting that the consequences for vulnerable road users, such as motorcyclists, is more severe.
  4. Page 25 We agree motorcycle numbers are growing and will continue to do so, thus placing even greater importance on the priority of safety of motorcyclists.
  5. Page 35 We submit that it is appropriate to include motorcyclists as vulnerable users and that roads should be “motorcycle friendly”.
  6. Page 51 ”Support motorcycle safety”. We wholly support this as an immediate action. MSAC is well placed to lead this conversation and share the initiatives and research held.
  7. Page 55 Immediate action. This action is to “Strengthen system leadership, support and coordination”. We submit that MSAC is the voice of motorcycling and that we can feature as a sector leader to get actions done. We would appreciate the opportunity to engage in ongoing leadership and co-ordination of motorcycle safety initiatives in partnership with agencies.

4. Responses to the questions posed in the consultation document

We have provided these via the online survey tool. For the sake of completeness, they are included below:

Consultation question MSAC response

To what extent do you support the proposed vision?  - What was the reason for your rating? Do you have any further comments about the proposed vision?

Strongly support

To what extent do you support the proposed target for 2030? - What was the reason for your rating? Do you have any further comments about the proposed target?

That target is not high enough

We support a strengthening of the target or sharing of the evidence as to why this target was chosen

Because motorcyclists are over-represented in death and serious injury (DSI) statistics, we would propose a higher target for this group of road users unless evidence suggests this is not achievable.

To what extent to you support Principle 1 ‘We plan for people’s mistakes’? - What was the reason for your rating? Do you have any further comments about this principle?

Strongly support

To what extent to you support Principle 2 ‘We design for human vulnerability’? - What was the reason for your rating? Do you have any further comments about this principle?

Strongly support

We note that motorcyclists are a vulnerable road user and this principle is of high importance to them.

To what extent to you support Principle 3 ‘We strengthen all parts of the road transport system’? - What was the reason for your rating? Do you have any further comments about this principle?

Strongly support

We consider shared accountability by central and local government to be critical to the successful delivery of this principle.

To what extent to you support Principle 4 ‘We have a shared responsibility for improving road safety’? - What was the reason for your rating? Do you have any further comments about this principle?

Strongly support

We recognise that for road safety to improve all road users will need to change their behaviours. This will only be achieved through partnership and a culture change on our roads.

To what extent to you support Principle 5 ‘Our actions are grounded in evidence and evaluated’? - What was the reason for your rating? Do you have any further comments about this principle?

Strongly support

We would like all evidence to be shared.

To what extent to you support Principle 6 ‘Our road safety actions support health, wellbeing and liveable places’? - What was the reason for your rating? Do you have any further comments about this principle?

Strongly support

We note that motorcycling should be encouraged as it has positive impacts on congestion, the environment and mental wellbeing. It is a popular recreation and increasingly popular as a commuting option.

To what extent to you support Principle 7 ‘We make safety a critical decision-making priority’? - What was the reason for your rating? Do you have any further comments about this principle?

Strongly support

Do you have any further comments about the proposed principles?

 

To what extent do you support Focus Area 2 ‘Vehicle safety’? - What was the reason for your rating? Do you have any further comments about this principle?

Strongly support

We support the recent mandating of ABS on motorcycles, and note the safety effectiveness of other motorcycle technologies. However, technology also presents challenges and the issue of driver distraction is a great concern to motorcyclists.

To what extent do you support Focus Area 3 ‘Work related safety’? - What was the reason for your rating? Do you have any further comments about this principle?

Strongly support

We note that there is an apparent growth in the use of motorcycles and scooters in the workplace (e.g. food couriers and ride sharing) that is likely to continue to increase.

To what extent do you support Focus Area 4 ‘Road user choices’? - What was the reason for your rating? Do you have any further comments about this principle?

Strongly support

We note that approximately a quarter of motorcycle accidents involve unlicensed riders, and a further significant portion involve impairment, speed or other errors of judgement. MSAC has plans for further research on Human Factors.

To what extent do you support Focus Area 5 ‘System management’? - What was the reason for your rating? Do you have any further comments about this principle?

Strongly support

We note that we consider joint and shared accountability of central and local government (and their contractual partners) to be a critical element to successful delivery of the Road to Zero vision.

Do you have any further comments about the focus areas?

MSAC shares the view that strong leadership is key to improving road safety in New Zealand.

What are your top priorities for the first action plan? - Do you have any further comments about these priority actions?

  1. Support motorcycle safety
  2. Invest in safety treatment and infrastructure improvements
  3. Review Infrastructure standards and guidelines.

Do you have any comments about these priority actions?

Infrastructure standards: The integration of MSAC’s guideline document Making Roads Motorcycle Friendly which proposes standards for road design and maintenance should be applied to all NZTA high risk routes.

Support motorcycle safety: MSAC would welcome the opportunity to be a partner in taking this work forward.

Do you have any suggestions about other actions we could consider for future action plans?

Maintain a watching brief on emerging trends for motorcycle technology (including personal protective equipment).

Consider the classification and applicability of safety regulations to emerging powered vehicle types, such as scooters, e-bikes, and in particular how these vehicles share (or are separated from) roadways.

Do you have comments about the way that we intend to monitor our performance?

The intention to monitor performance is admirable, but it difficult to see how this can be achieved, given there are no clear accountabilities for government departments and/or other agencies in the draft Strategy.