OIA24-408
C Robertson
[FYI request #27571 email]
Dear C Robertson,
I refer to your email of 10 October 2024 requesting the following under the Official
Information Act 1982 (the Act):
“I note that you refer me to the RIS in relation to parts 1 and 2 of my request. What I was
requesting was any analyses used to support the statements made in the RIS, not the
statements themselves. Referring me to those statements therefore does not supply me with
the information requested.
The RIS does not contain the evidentiary basis for the statements it contains about
economic benefit (and the similar statements made in the interview I referred to in my initial
request), so parts 1 and 2 of my request are not answered by a refusal on the basis that the
RIS is publicly available.
I reiterate my request: please supply me with the evidentiary basis (such as any
analysis undertaken of detailed or quantified costs and benefits, and/or based on
established CBA methodology, including information about the methodology used) for the
statements made in the RIS about economic benefit. If no such evidentiary basis exists,
please confirm that.
The RIS also does not contain detailed information about 'any safety analysis undertaken
relating to the proposed Rule, such as modelling of the expected change in deaths and
serious injuries (DSI), or analysis of historical DSI data'. The RIS contains a number of
statements about safety, such as 'The new proposed speed limit classifications are based on
safety' (page 13). I am requesting any information or analysis used to support or inform
those statements. In particular, I am requesting any analysis of safety impacts undertaken
before the release of the draft Rule (especially given the Minister's campaign promise that
speed limits would be reduced 'where it is safe to do so', and the absence of similar
language in the draft or final Rule). I therefore reiterate my request for any such safety
analysis. If none was undertaken, please confirm that.
Finally, since the new Rule is now published, please supply me with the documents refused
in your previous reply on the grounds that the Rule was under active consideration
(numbered as 3, OC231067; 4, OC240067; 5,Cabinet paper: update on our 100day
commitment to stop blanket speed limit reductions and start work on a new rule for setting
speed limits; 6, OC240201; 7, OC240312; and 8, Draft results of the localised approach 14
June 2024).”
The Regulatory Impact Statement (RIS) drew on research on the safety impacts of speed
limits and the general assumption that increased speed limits would result in higher
operating speeds. The RIS notes that the Ministry of Transport could not assess the specific
costs and benefits of the Land Transport Rule: Setting of Speed Limits 2024 (the Rule) at an
individual road or national level. The Ministry advises it did investigate the feasibility of
modelling the number of deaths and serious injuries resulting from speed limit changes on
some corridors. However, I am advised that the Ministry considered that such analysis could
not be developed due to a range of issues, including data availability and not knowing which
roads would have their speed limits changed.
When road controlling authorities propose changes to individual road speed limits, they will
have to prepare cost benefit disclosure statements for those changes as set out in section 3
of the Rule. This must describe the estimated safety impacts, the estimated travel time
impacts, and the estimated implementation costs of the proposed speed limit change.
There are six documents in scope of the final part of your request. These are listed in the
attached document schedule. Documents one to five will soon be available on the Ministry of
Transport website:
www.transport.govt.nz. I am therefore refusing these under the following
section of the Act:
18(d)
the information requested is or will soon be publicly available
The Ministry has advised the sixth document
Draft results of the localised approach 14 June
2024 is a draft document and it
was not used in the development of the Rule. I am
withholding this document in full under the following section of the Act:
9(2)(g)(i)
to maintain the effective conduct of public affairs through the free and
frank expression of opinions by or between or to Ministers of the Crown
or members of an organisation or officers and employees of any public
service agency or organisation in the course of their duty
With regard to the information that has been withheld under section 9 of the Act, I am
satisfied that the reasons for withholding the information at this time are not outweighed by
public interest considerations that would make it desirable to make the information available.
You have the right to seek an investigation and review of this response by the Ombudsman,
in accordance with section 28(3) of the Act. The relevant details can be found on the
Ombudsman’s websit
e www.ombudsman.parliament.nz
Thank you again for writing.
Yours sincerely,
Hon Simeon Brown
Minister of Transport
Annex 1 - Document Schedule
Doc# Date
Document
Decision on release
1
20/12/2024
OC231067 Setting of
Refused in full under Section
speed limits rule review –
18(d).
terms of reference
2
7/2/2024
OC240067 New setting of
Refused in full under Section
speed limits rule timeline
18(d).
and policy confirmation
3
15/2/2024
Cabinet paper: update on
Refused in full under Section
our 100-day commitment to 18(d).
stop blanket speed limit
reductions and start work
on a new rule for setting
speed limits
4
13/3/2024
OC240201 Approach to the Refused in full under Section
new speed rule
18(d).
5
10/4/2024
OC240312 The new setting Refused in full under Section
of speed limits rule: public
18(d).
consultation
6
Draft results of the
Withheld in full under section
localised approach 14 June 9(2)(g)(i)
2024
