R001248 Appendix A 2.pdf

Regulatory
Respon

se Issue
MFR2025-136
To
Sam Purchas, Senior Ministerial Advisor, Office of Minister Seymour
Title
RRT Bicycle Helmet Regulations
Issue
RRT2025-0742 – Bicycle Helmet
Tracking
MFR2025-136
Regulations
Date
30 May 2025
Priority
Medium
Contact Person  Liam Taylor – Principal Advisor, Regulatory Reviews
Contact Person  Hannah McGlue – Manager, Regulatory Reviews
Attachments
No
Security Level  IN CONFIDENCE
Recommended Action
We recommend that you:
a
note that you requested advice about the benefits of removing
Noted
regulation that requires cycling helmets to be worn in New Zealand
b
note that the Ministry for Regulation has completed desktop
analysis, which has not included consulting with relevant
Noted
government agencies or other stakeholders
c
note that the Ministry for Regulation considers that regulation
requiring cycling helmets to be worn while cycling on roads in New
Noted
Zealand is justified
d
note that the Ministry for Regulation could undertake a
comprehensive cost benefit analysis of the regulatory requirement
Noted
to wear cycling helmet, which would take 12 weeks to complete
and involve engagement with relevant government agencies
e
EITHER
Official Information Act 1982
agree to not undertake a comprehensive cost benefit analysis of
Agree / Disagree
the regulatory requirement to wear a cycling helmet
OR
direct the Ministry for Regulation to undertake a comprehensive
Agree / Disagree
cost benefit analysis of the regulatory requirement to wear a
cycling helmet
IN CONFIDENCE
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Regulatory
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MFR2025-136

Purpose
1.
This briefing provides you with advice requested on 16 May 2025 on the potential risks and
benefits of removing the requirement for helmets to be worn on bicycles.
Key Messages
2.
You asked for advice about “the potential risks and benefits of removing the requirement for
helmets to be worn on bicycles.” Based on the Ministry for Regulation’s (the Ministry’s)
initial analysis we recommend that the risks would outweigh any benefits of removing the
requirement for helmets to be worn on bicycles. The bullet points below summarise our
advice in relation to each of your individual questions.
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a.  The potential that removing the requirement to wear a helmet will increase
cycling uptake. Based on the available evidence, the Ministry does not think that
there would be material increase in the uptake of cycling by removing the helmet
mandate. Cycling has declined since the 1990s but several factors have contributed
to this, including increased car ownership, urban planning, and a lack of cycling
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infrastructure.
b.  The potential health benefits and savings, and effects on traffic congestion of
an increased uptake in cycling. While there would be individual and societal
health and other benefits if cycling uptake were to increase, as well as a decrease
in traffic congestion, the Ministry does not think that any increase in the uptake of
cycling as a result of removing the requirement to wear a helmet would be
significant enough to have a material impact on health outcomes or on traffic
congestion.
c.  Whether the helmet mandate has had a causal effect on head injuries/lives
lost. Bicycle helmets are generally low cost and highly effective at preventing
serious injury and death from cycling accidents. There has been a significant
decline in serious injuries and fatalities since a regulatory helmet mandate was
Information
introduced in New Zealand.
d.  Whether the Peltzman effect is relevant to the behaviour of cyclists. There is
no evidence of the Peltzman Effect applying in practice to cycling. Several studies
have shown that there is very little evidence to support that wearing a helmet
affects the behaviour of cyclists, either towards taking more risks or being more
cautious.
e.  Anything else deemed relevant. The Ministry considers that removing the helmet
Official
mandate would likely lead to an increase in serious injuries and fatalities as a
result of cycling accidents. As well as personal, family and societal costs, this
would lead to increased health care and long-term ACC scheme costs. As outlined
above, we do not think there would be any material benefits.
3.
The Ministry recommends that no further work is undertaken on this issue. However, if you
would like a comprehensive cost-benefit analysis to be completed, this would take 12
weeks and divert resource from other areas of work.

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Background

Cycling helmets are mandatory when cycling on a road in New Zealand
4.
Bicycle helmets have been mandatory in New Zealand since 1994, and across Australia
since the early 1990s. In New Zealand, the Land Transport (Road User) Rule 2004,1 requires
that a person must not ride, or be carried on, a bicycle on a road unless the person is
wearing a safety helmet of an approved standard2 that is securely fastened. Helmet use by
adults in New Zealand rose from 43% in 1993 to 92% in 1994 following the introduction of
the mandate. 3 For teenagers aged 13-18 the rise was from 56% to 97%, and for younger
children from 86% to 98%.4
5.
The fine for not wearing a helmet is $55. The number of fines issued has been steadily
decreasing over time.5 This could be due to a combination of increased compliance and a
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reduced enforcement as police focus resources on other matters. Although there is some
evidence that the approach to enforcement is inconsistent across the country.6
6.
Many countries do not mandate the use of bicycle helmets, including nations with high
rates of cycling and strong safety records7 such as the Netherlands.
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7.
To provide you with advice within the timeframe we have reviewed publicly available
domestic and international data and literature. This means some information is from a
snapshot in time and explains the date ranges for the provided data. We have not engaged
with other government agencies or any stakeholders at this stage.
Initial Analysis
There is rationale for government intervention to mandate cycling helmets
8.
Cycling offers a range of public health and transport benefits, particularly through its
potential to reduce rates of chronic illness such as heart disease, diabetes, and obesity,
and can alleviate traffic congestion in urban areas. At the same time, cycling carries a risk
Information
of serious injury or death, particularly in the event of collisions with motor vehicles. This
risk is more acute in environments like New Zealand, where cycling infrastructure is
inconsistent, and road conditions often force cyclists to share the road with fast-moving
traffic.

Official
1 See Land Transport (Road User) Rule 2004.
2 See Standards New Zealand AS/NZS 2063:2020.
3  Cycle  helmet  use:  Results  of  national  survey.  (NZTA  February-March  2008).  <www.transport.govt.nz/cycle-helmets-
2008>.
4 Ibid.
5 The number of fines issued fell from 11,310 in 2013/14 to 2,618 in 2017/18 which is a fall of over 75%. Data for more recent
years is not publicly available.
6 New Zealand Police “Poor cycle safety concerns Christchurch  Police” <www.police.govt.nz/news/release/poor-cycle-
safety-concerns-christchurch-police>.
See also Josh Fagan “Cyclists cop $400k in fines” <www.stuff.co.nz/national/10520184/Cyclists-cop-400k-in-fines>.
7 International Transport Forum “Cycling Safety: Summary and Conclusions” (2018) 168 ITFRR at 17.

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Information
Official

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MFR2025-136

12.
The imposition on individuals to wear bicycle helmets is minimal. The data we have
reviewed indicates that only a small proportion of cyclists do not wear helmets, the price
of a helmet is low relative to the price of a bicycle and very low relative to the (personal
and financial) cost of an injury that could occur without a helmet. Therefore, the Ministry
considers that the imposition is outweighed by the (personal and government) benefits of
wearing a helmet.
Cycling helmet mandates do not appear to have stopped people cycling
13.
The Ministry for Regulation (the Ministry) considers that any impact of the cycling mandate
on the uptake of cycling is minimal.
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14.
Countries such as the Netherlands, with higher cycling uptake but no mandate for wearing
helmets, cannot be used as a direct comparison to New Zealand. They invest significantly
in cycling infrastructure and other safety measures (e.g. cycle lanes, bike tracks, shared
paths, bicycle prioritised traffic signals, intersections designed to prioritise bicycles, traffic
Act
calmed streets and strict liability laws that favour cyclists, etc), and foster a strong cycling
culture. In the Netherlands, cycling is treated as everyday transport for people of all ages
rather than a sport or recreational activity. There is also a high degree of motorist
awareness of cyclists.
15.
By comparison, cycling infrastructure in New Zealand is less developed, urban
environments are often more car-centric, and the geography is generally hillier, making
cycling more challenging and less accessible.
16.
There is mixed evidence about the effect of mandatory helmet legislation on cycling
participation. Data suggests that cycling participation has been declining since the 1990s,
with the biggest decline among children cycling to school.11 However, studies discussed in
the following paragraphs have not drawn a definitive link between the 1994 bike helmet
legislation and the decline of cycling. While it is possible that the helmet mandate
Information
contributed to the decline in cycling, it is unlikely to have been the dominant factor.
17.
Several factors contributed to the decline in cycling during this period. Limited investment
in cycling infrastructure made cycling appear comparatively less safe and convenient.
Urban sprawl and low-density development patterns increased the distance between
homes, schools, and workplaces, making cycling a less practical mode of transport for
many people. 12 Rising car ownership further entrenched driving as the dominant form of
mobility. The New Zealand vehicle ownership rate increased by 84% between 1994 and
2024.13 It is likely that the decline of cycling and cycle injuries mirrors the steady increase
Official
of car ownership and cyclists wearing helmets.

11 In 1989-90, 19% of secondary school students and 12% of primary students biked to school. This drastically shifted by
the early to mid-2010s where 3% of secondary school students biked to school and 2% of primary students biked to school.
12 Matthew McLaughlin “Fewer of us are cycling - here's how we can reverse the decline” (1 September 2023) University of
Western Australia <www.uwa.edu.au/news/Article/2023/August/Fewer-of-us-are-cycling-heres-how-we-can-reverse-the-
decline>.
13 Motor Industry Association “Registration Data - 1975 onwards April 2025” (2025) <www.mia.org.nz/Sales-Data/Vehicle-
Sales>.

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18.
Social and cultural attitudes have also contributed to this decline. Cycling has become
associated more with sport and recreation than with everyday commuting, and parents
are more reluctant to allow children to cycle to school alone.14
19.
There is also a cost barrier to cycling. A bicycle can cost between several hundred and
several thousands of dollars, depending on the type and brand. An adult bicycle helmet
can be bought for as low as $45.15 There are also charitable organisations in New Zealand
that offer free helmets and bicycles to communities that cannot afford them.16  The cost of
a helmet is relatively small compared to the overall cost of a bike. Given this, we consider
that the main cost barrier for cycling is the bike itself.
20.
There is some evidence that helmet mandates can reduce the use of public bike-share
schemes. The requirement to wear a helmet limits spontaneous use, since potential riders
may not have a helmet with them.
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17 This has been documented in cities like Melbourne
and Brisbane, where helmet laws have been linked to low uptake of bike-share
programmes. However, the market could offer practical solutions, such as integrating
helmets with bike-share bikes (as many of these schemes have done).
Act
21.
Based on the evidence reviewed to prepare this advice, we do not consider that the helmet
mandate has a significant impact on the uptake of cycling – and therefore do not consider
its removal would increase cycling uptake. Removing the helmet mandate is likely to result
in higher costs to the government. Based on the evidence reviewed, we think it is likely to
increase the number of serious injuries and fatalities, which would increase costs on the
public health system and ACC. The long-term costs are likely to significantly outweigh any
benefit from an increase in cycling.
There is no evidence that the Peltzman effect applies to cycling
22.
You asked for advice about the Peltzman Effect. According to the Peltzman Effect, when
safety measures are implemented, people’s perception of risk decreases, and so people
may feel that they can now afford to make riskier decisions.18 This effect would mean that
safety measures provide a lower than expected benefit as the safety benefits are offset to
Information
some extent by increased risky behaviour. In the context of cycling, this could mean that
riders wearing helmets might feel more protected and therefore ride faster or less
cautiously, potentially offsetting the benefits of the helmet itself.
23.
However, there is no evidence of the Peltzman Effect applying in practice in cycling.
Several studies have shown that there is very little evidence to support that wearing a
Official
14 Melody Smith et al “Children’s Transport Built Environments: A Mixed Methods Study of Associations between Perceived
and Objective Measures and Relationships with Parent Licence for Independent Mobility in Auckland, New Zealand” (16
April 2019) 16 IJERPH 13 at 14.
15  99  Bikes  <www.99bikes.co.nz/collections/helmets>  Torpedo7  <www.torpedo7.co.nz/bike/helmets>  EVO  cycles
<www.evocycles.co.nz/HELMETS>.
16 For example, Sustainability Trust Wellington <www.sustaintrust.org.nz/our-recycling-programmes/bicyclerecycling>.
17 Elliot Fishman et al “Barriers to bikesharing: an analysis from Melbourne and Brisbane” (2024) 41 JTG at 12.
18 Sam Peltzman “The Effects of  Automobile Safety Regulation” (1975) 83 JPE  677-726. See also The Peltzman Effect.
<https://thedecisionlab.com/reference-guide/psychology/the-peltzman-effect>.

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helmet affects the behaviour of cyclists, either towards taking more risks or being more
cautious.19
The Ministry for Regulation considers that further work on this issue carries risks
24.
Based on this initial analysis, the Ministry considers that further work on this issue carries
risks.
25.
While the Ministry could undertake a comprehensive cost benefit analysis which would
look at actual costs to the health and ACC systems and access data held by the New
Zealand Transport Agency, this would take 12 weeks to complete and divert resource from
other priorities (Sector Reviews, Red Tape Portal investigations and Economics team). We
expect that this analysis would show that the benefits of mandating helmets outweigh the
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costs.
26.
s 9(2)(g)(i)

Act
Information
Official

19 Jake Olivier and Frances Terlich “The Use of Propensity Score Stratification and Synthetic Data to Address Allocation
Bias when Assessing Bicycle Helmet Effectiveness” (2016) at 190.
See also Mahsa Esmaeilikia et al “Bicycle helmets and risky behaviour: A systematic review” (2019) 60 TRPFTPB 302 at 305.

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Information
Official

Outside of scope
From:
Lucy Pritchard
Sent:
Friday, 23 May 2025 8:36 am
To:
Liam Taylor; Grace Chang
Cc:
Hannah McGlue; Sachi Herath
Subject:
RE: Noting: RRT Commission on bicycle helmet regulations- requested by COB 30 May
(A2025-173)
Thanks Liam – yes please reach out to Kevin in the first instance and see what support they can
provide. They are used to supporting on urgent RRT isues.
Ngā mihi,
Lucy Pritchard (she/her)
Principal Advisor/Acting Lead - Regulatory Response Team
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Ministry for Regulation
īmēra: [email address] |
Act
www.regulation.govt.nz
From: Liam Taylor <[email address]>
Sent: Thursday, 22 May 2025 5:45 pm
To: Lucy Pritchard <[email address]>; Grace Chang <[email address]>
Cc: Hannah McGlue <[email address]>; Sachi Herath <[email address]>
Subject: RE: Noting: RRT Commission on bicycle helmet regulations- requested by COB 30 May (A2025-173)
Information
Hi Lucy, Hannah,
One question I have, which we can discuss tomorrow, is whether we can get any analytical support
from Kevin / Izi’s team.
I think it would probably be possible to calculate a cost-benefit analysis for the helmet mandate – but
it’s probably not possible by the end of next week.
Official
s 9(2)(g)(i)
it might be worth having a chat with
Kevin / Izi to see what would be feasible?
Thanks,
Liam
Liam Taylor
Principal Advisor, Regulatory Reviews
Ministry for Regulation

E-mail: [email address]
From: Liam Taylor <[email address]>
Sent: Thursday, 22 May 2025 2:52 pm
To: Lucy Pritchard <[email address]>; Grace Chang <[email address]>
Cc: Hannah McGlue <[email address]>; Sachi Herath <[email address]>
Subject: Re: Noting: RRT Commission on bicycle helmet regulations- requested by COB 30 May (A2025-173)
Hi Lucy,
Sorry, yes I’ve got it and have started working on it. I’ll schedule some time to catch up with you and
Hannah tomorrow.
Thanks,
Liam
1982
From: Lucy Pritchard <[email address]>
Sent: Thursday, May 22, 2025 2:23:27 PM
To: Liam Taylor <[email address]>; Grace Chang <[email address]>
Cc: Hannah McGlue <[email address]>; Sachi Herath <[email address]>
Act
Subject: RE: Noting: RRT Commission on bicycle helmet regulations- requested by COB 30 May (A2025-173)
Kia ora Liam
Can you please confirm receipt of this urgent commission and let me know if you have any questions
on it today?
Ngā mihi,
Lucy Pritchard (she/her)
Principal Advisor/Acting Lead - Regulatory Response Team
Ministry for Regulation
Information
īmēra: [email address] |
Official
www.regulation.govt.nz
From: Lucy Pritchard
Sent: Thursday, 22 May 2025 8:41 am
To: Liam Taylor <[email address]>; Grace Chang <[email address]>
Cc: Hannah McGlue <[email address]>; Sachi Herath <[email address]>
Subject: FW: Noting: RRT Commission on bicycle helmet regulations- requested by COB 30 May (A2025-173)
Kia ora kōrua

We have received the below commission on Tuesday this week and it was discussed at the RRT
advisors meeting yesterday.
We have agreed to prepare some initial/high level advice on the issue to provide to the office by COP
Friday 30 May.
Below is one article that Hannah located on the issue yesterday:
https://www.stuff.co.nz/national/102177384/renewed-push-for-review-of-cycle-helmet-law-starts-
with-protest-ride-in-wellington
Hannah and I would like you both to support on this please and work out between you how you are
going to approach the commission. Liam I will forward you a separate email with some RRT
investigators material that will be useful. Grace has done a few RRT investigations so will be a great
support.
Ideally I would like us to work to these initial timeframes:
1982
Friday 23 May – Liam and Grace to meet with Hannah or Lucy to outline their plan/approach for the
advice and to get a steer on approach. Please have undertaken some initial fact finding and evidence
gathering on the issue before then – taking into account the specific aspects indicated from the office
Act
in the email below.
COP Monday 26 May – initial outline advice provided
Tuesday/Wednesday – refining advice/review and sign out by Hannah/Lucy
Wednesday COP – to Paul for review by COP Thursday
Friday 30 May – provision to the office
I have allowed some flex in the above timeline and we can discuss today or tomorrow whether that is
feasible/what adjustments you might need.
Information
Please drop some time into my calendar/Hannah’s calendar tomorrow to discuss – it won’t look good
as we have the away morning and other things already scheduled but we will work it out!
Sachi – please can you support with getting this added to the Sharepoint List and an RRT # allocated
(and also advise Mins of that).
Thanks so much both – please reach out today if needed.
Official
Ngā mihi nunui,
Lucy Pritchard (she/her)
Principal Advisor/Acting Lead - Regulatory Response Team
Ministry for Regulation
īmēra: [email address] |

www.regulation.govt.nz
From: Lucy Pritchard
Sent: Thursday, 22 May 2025 8:23 am
To: Hello <[email address]>; Nikki Bidlake <[email address]>; Aisling Risdon
<[email address]>
Cc: Hannah McGlue <[email address]>; Sachi Herath <[email address]>
Subject: Noting: RRT Commission on bicycle helmet regulations- requested by COB 30 May (A2025-173)
Kia ora
1982
We have not yet had a formal commission from hello@ on this issue but I can confirm following the
discussion at advisors yesterday that RRT are progressing this with a view to providing high level
information as requested by COP 30 May.
Act
If you have any further information or instructions for us on the commission please reach out. We will
advise when we have an RRT #.
Ngā mihi,
Lucy Pritchard (she/her)
Principal Advisor/Acting Lead - Regulatory Response Team
Ministry for Regulation
īmēra: [email address] |
Information
www.regulation.govt.nz
Official
From: Aisling Risdon <[email address]>
Sent: Monday, 19 May 2025 12:34 pm
To: Paul Delahunty <[email address]>; Grainne Moss <[email address]>
Subject: FW: RRT Commission on bicycle helmet regulations- requested by COB 30 May (A2025-173)
FYI only – in case it comes up today.
Ash

From: Tim McGiven <[email address]>
Sent: Monday, 19 May 2025 10:19 am
To: Hello <[email address]>
Cc: Aisling Risdon <[email address]>
Subject: RE: RRT Commission on bicycle helmet regulations- requested by COB 30 May (A2025-173)
Advisors say it’s brand new and happy to discuss further at a future RRT meeting
From: Hello <[email address]>
Sent: Friday, 16 May 2025 5:08 PM
To: Tim McGiven <[email address]>
Cc: Hello <[email address]>; Aisling Risdon <[email address]>
Subject: RE: RRT Commission on bicycle helmet regulations- requested by COB 30 May (A2025-173)
Confirming receipt. Please use reference A2025-173 in any future correspondence about this.
Are you aware of any discussion of this (either at RRT this week) or verbally or is this brand new? Just
1982
for my information before I commission out.
Thanks
Nikki
Act
Nikki Bidlake (she/her)
Senior Advisor, Ministerial Services
Ministry for Regulation
From: Tim McGiven <[email address]>
Sent: Friday, 16 May 2025 4:24 pm
To: Hello <[email address]>
Subject: RRT Commission on bicycle helmet regulations- requested by COB 30 May
Hello,
The office would like to commission work from RRT. Please see below and let me know if any
Information
questions.
Cheers
Bicycle helmet regulations
Please investigate and prepare a report on the potential risks and benefits of removing the
Official
requirement for helmets to be worn on bicycles. This report could consider:
•
potential increased uptake of cycling,
•
the potential health benefits and savings of this uptake,
•
the potential effects on traffic congestion of this increased uptake
•
Whether the helmet mandate has had a causal effect on head injuries/lives lost
•
The Peltzman effect
•
Anything else deemed relevant
If possible by COB Friday May 30th.

Timothy McGiven
Acting Private Secretary (Regulation) | Office of Hon David Seymour MP
Deputy Prime Minister (from 31 May 2025)
Minister for Regulation
Associate Minister of Education
Associate Minister of Justice (Treaty Principles Bill)
Associate Minister of Finance
Associate Minister of Health
Email: [email address] Website: www.Beehive,govt.nz
Private Bag 18041, Parliament Buildings, Wellington 6160, New Zealand
Phone: s (9)(2)(a)
1982
..........................................................................................................................................
Confidentiality notice: This email may be confidential or legally privileged. If you have received it by mistake, please tell the
sender immediately by reply, remove this email and the reply from your system, and don’t act on it in any other way. Ngā mihi.
Act
Information
Official

Outside of scope
From:
Liam Taylor
Sent:
Friday, 23 May 2025 1:41 pm
To:
Kevin Counsell
Cc:
Grace Chang
Subject:
FW: Noting: RRT Commission on bicycle helmet regulations- requested by COB 30 May
(A2025-173)
Hi Kevin,
Hope you’re well.
Grace and I are picking up this urgent commission come through from the Minister’s o ice for RRT on
the regulation of cycle helmets (see the e-mail below).
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From doing some initial research it feels like it might be possible to do some quantitative cost-benefit
analysis on the impact of the helmet mandate (e.g. on reduced injuries/fatalities, uptake of cycling
etc) but we’d need help from your team to do it.
Act
So, I wanted to check if your team has any capacity to help this work?
Are you free this afternoon or Monday for a quick chat?
Thanks,
Liam
Liam Taylor
Principal Advisor, Regulatory Reviews
Ministry for Regulation
E-mail: [email address]
Information
From: Lucy Pritchard <[email address]>
Sent: Thursday, 22 May 2025 8:41 am
To: Liam Taylor <[email address]>; Grace Chang <[email address]>
Cc: Hannah McGlue <[email address]>; Sachi Herath <[email address]>
Subject: FW: Noting: RRT Commission on bicycle helmet regulations- requested by COB 30 May (A2025-173)
Kia ora kōrua
Official
We have received the below commission on Tuesday this week and it was discussed at the RRT
advisors meeting yesterday.
We have agreed to prepare some initial/high level advice on the issue to provide to the o ice by COP
Friday 30 May.
Below is one article that Hannah located on the issue yesterday:
https://www.stu .co.nz/national/102177384/renewed-push-for-review-of-cycle-helmet-law-starts-
with-protest-ride-in-wellington
1

Hannah and I would like you both to support on this please and work out between you how you are
going to approach the commission. Liam I will forward you a separate email with some RRT
investigators material that will be useful. Grace has done a few RRT investigations so will be a great
support.
Ideally I would like us to work to these initial timeframes:
Friday 23 May – Liam and Grace to meet with Hannah or Lucy to outline their plan/approach for the
advice and to get a steer on approach. Please have undertaken some initial fact finding and evidence
gathering on the issue before then – taking into account the specific aspects indicated from the o ice
in the email below.
COP Monday 26 May – initial outline advice provided
Tuesday/Wednesday – refining advice/review and sign out by Hannah/Lucy
1982
Wednesday COP – to Paul for review by COP Thursday
Friday 30 May – provision to the o ice
Act
I have allowed some flex in the above timeline and we can discuss today or tomorrow whether that is
feasible/what adjustments you might need.
Please drop some time into my calendar/Hannah’s calendar tomorrow to discuss – it won’t look good
as we have the away morning and other things already scheduled but we will work it out!
Sachi – please can you support with getting this added to the Sharepoint List and an RRT # allocated
(and also advise Mins of that).
Thanks so much both – please reach out today if needed.
Ngā mihi nunui,
Information
Lucy Pritchard (she/her)
Principal Advisor/Acting Lead - Regulatory Response Team
Ministry for Regulation
īmēra: [email address] |
Official
www.regulation.govt.nz
From: Lucy Pritchard
Sent: Thursday, 22 May 2025 8:23 am
To: Hello <[email address]>; Nikki Bidlake <[email address]>; Aisling Risdon
<[email address]>
2

Cc: Hannah McGlue <[email address]>; Sachi Herath <[email address]>
Subject: Noting: RRT Commission on bicycle helmet regulations- requested by COB 30 May (A2025-173)
Kia ora
We have not yet had a formal commission from hello@ on this issue but I can confirm following the
discussion at advisors yesterday that RRT are progressing this with a view to providing high level
information as requested by COP 30 May.
If you have any further information or instructions for us on the commission please reach out. We will
advise when we have an RRT #.
Ngā mihi,
Lucy Pritchard (she/her)
Principal Advisor/Acting Lead - Regulatory Response Team
Ministry for Regulation
1982
īmēra: [email address] |
Act
www.regulation.govt.nz
From: Aisling Risdon <[email address]>
Sent: Monday, 19 May 2025 12:34 pm
To: Paul Delahunty <[email address]>; Grainne Moss <[email address]>
Subject: FW: RRT Commission on bicycle helmet regulations- requested by COB 30 May (A2025-173)
Information
FYI only – in case it comes up today.
Ash
From: Tim McGiven <[email address]>
Sent: Monday, 19 May 2025 10:19 am
To: Hello <[email address]>
Official
Cc: Aisling Risdon <[email address]>
Subject: RE: RRT Commission on bicycle helmet regulations- requested by COB 30 May (A2025-173)
Advisors say it’s brand new and happy to discuss further at a future RRT meeting
From: Hello <[email address]>
Sent: Friday, 16 May 2025 5:08 PM
To: Tim McGiven <[email address]>
Cc: Hello <[email address]>; Aisling Risdon <[email address]>
Subject: RE: RRT Commission on bicycle helmet regulations- requested by COB 30 May (A2025-173)
3

Confirming receipt. Please use reference A2025-173 in any future correspondence about this.

Are you aware of any discussion of this (either at RRT this week) or verbally or is this brand new? Just
for my information before I commission out.

Thanks
Nikki

Nikki Bidlake (she/her)
Senior Advisor, Ministerial Services
Ministry for Regulation

From: Tim McGiven <[email address]>
Sent: Friday, 16 May 2025 4:24 pm
To: Hello <[email address]>
Subject: RRT Commission on bicycle helmet regulations- requested by COB 30 May

1982
Hello,

The o ice would like to commission work from RRT. Please see below and let me know if any
questions.
Act

Cheers

Bicycle helmet regulations

Please investigate and prepare a report on the potential risks and benefits of removing the
requirement for helmets to be worn on bicycles. This report could consider:

•  potential increased uptake of cycling,
•  the potential health benefits and savings of this uptake,
•  the potential e ects on tra ic congestion of this increased uptake
•  Whether the helmet mandate has had a causal e ect on head injuries/lives lost
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•  The Peltzman e ect
•  Anything else deemed relevant

If possible by COB Friday May 30th.

Official
Timothy McGiven
Acting Private Secretary (Regulation) | Office of Hon David Seymour MP
Deputy Prime Minister (from 31 May 2025)
Minister for Regulation
Associate Minister of Education
Associate Minister of Justice (Treaty Principles Bill)
Associate Minister of Finance
Associate Minister of Health
4

Email: [email address] Website: www.Beehive,govt.nz
Private Bag 18041, Parliament Buildings, Wellington 6160, New Zealand
Phone: s (9)(2)(a)

..........................................................................................................................................
Confidentiality notice: This email may be confidential or legally privileged. If you have received it by mistake, please tell the
sender immediately by reply, remove this email and the reply from your system, and don’t act on it in any other way. Ngā mihi.
1982
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Information
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Outside of scope
From:
Lucy Pritchard
Sent:
Monday, 26 May 2025 8:59 am
To:
Hannah McGlue; Liam Taylor
Cc:
Grace Chang; Kevin Counsell
Subject:
RE: RRT Cycle Helmet Regulations - draft outline
Thanks Liam and Hannah.

In our initial discussions we had also covered thes 9(2)(g)(i)

s 9(2)(g)(i)
– we
normally signal in our RRT briefings what engagement we have had with lead agencies on the issue by
the time we provide our advice (none, some etc.,).
1982

Ngā mihi,

Lucy Pritchard (she/her)
Act
Principal Advisor/Acting Lead - Regulatory Response Team
Ministry for Regulation
īmēra: [email address] |

www.regulation.govt.nz

Information
From: Hannah McGlue
Sent: Monday, 26 May 2025 6:30 am
To: Liam Taylor ; Lucy Pritchard
Cc: Grace Chang ; Kevin Counsell
Subject: Re: RRT Cycle Helmet Regulations - draft outline

Thanks for sending this though Liam - I think it is looking really good as an outline for advice to respond to the
request from the Office - covers all of the key points, and we are being clear that this is initial advice and more
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can be provided if requested.

s 9(2)(g)(i)

1

s 9(2)(g)(i)

On the CBA, which we can talk about me if needed - as well as QALYs and ACC costs, I think that public health
system costs could also be factored in. s 9(2)(g)(i)

From: Liam Taylor <[email address]>
Sent: Friday, May 23, 2025 4:23 PM
1982
To: Hannah McGlue <[email address]>; Lucy Pritchard
<[email address]>
Cc: Grace Chang <[email address]>; Kevin Counsell <[email address]>
Subject: RRT Cycle Helmet Regulations - draft outline
Act

Hi Hannah, Lucy,

Just to follow up from our chat earlier, below is a draft outline for the advice. The [yellow square
brackets] is information we think we can probably find for this commission based on publicly
available information.

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Below the outline is some further analytical questions that Kevin we’d need your help with if we’re
asked to do a cost-benefit analysis.

If we are required to do a cost-benefit analysis we’d probably also need to engage with other agencies
to get better data (e.g. it looks like Ministry of Transport have been collecting data on cycling since
1989 but only some of it is published and publicly available).
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Anyway, grateful for any views on the structure or if there’s anything we’ve missed?

In the meantime, Grace and I will start populating the placeholders and turning the outline into a full
draft.

2

Happy to chat more if helpful.

Thanks,
Liam

Advice Outline

s 9(2)(g)(i)
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s 9(2)(g)(i)
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s 9(2)(g)(i)
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Further questions for a cost benefit analysis:
•  Is there any evidence of a causal relationship between the introduction of the helmet mandate
and a reduction in cycling?
o
If so, how strong is it?
•  What is the impact of changes of cycling uptake on:
o
Health (e.g. chronic illness)
o
Traffic congestion
•  What is value in reduced injuries / fatalities from the helmet mandate
o
Direct cost to government savings from ACC
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o
Quality adjusted life years (QALY) saved

Liam Taylor
Principal Advisor, Regulatory Reviews
Ministry for Regulation
1982
E-mail: [email address]

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No problem. Good points, I’ll weave them in.

Thanks,
Liam

Liam Taylor
Principal Advisor, Regulatory Reviews
Ministry for Regulation
E-mail: [email address]
1982

From: Kevin Counsell <[email address]>
Act
Sent: Monday, 26 May 2025 4:15 pm
To: Liam Taylor <[email address]>; Lucy Pritchard <[email address]>; Hannah
McGlue <[email address]>
Cc: Grace Chang <[email address]>
Subject: RE: RRT Cycle Helmet Regulations - draft outline

Hi Liam

Two quick things from me (and sorry I realise this comes late when your draft is already done – I’ve
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been drafting these points since 9am this morning but kept getting pulled into other things!):

s 9(2)(g)(i)
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s 9(2)(g)(i)

Hope that’s helpful in some way, despite being late! I’m also happy to review the draft from an
economics perspective, if that would be useful.

Cheers,
Kevin
1982


Act
From: Liam Taylor <[email address]>
Sent: Monday, 26 May 2025 4:09 pm
To: Lucy Pritchard <[email address]>; Hannah McGlue <[email address]>
Cc: Grace Chang <[email address]>; Kevin Counsell <[email address]>
Subject: RE: RRT Cycle Helmet Regulations - draft outline

Hi both,

Information
Just to give you a quick update we’ve got a draft of the advice mostly ready.

We’re still doing a bit of fact checking/hunting down some stats and need to give it a proofread etc.
We’re aiming to share a draft with you for review tomorrow morning.

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Hannah – Grace has booked some time your diary at 2pm to review it, and in Paul’s diary for 10am
Wednesday.

Thanks,
Liam
3

Liam Taylor
Principal Advisor, Regulatory Reviews
Ministry for Regulation
E-mail: [email address]

From: Lucy Pritchard <[email address]>
Sent: Monday, 26 May 2025 8:59 am
To: Hannah McGlue <[email address]>; Liam Taylor <[email address]>
Cc: Grace Chang <[email address]>; Kevin Counsell <[email address]>
Subject: RE: RRT Cycle Helmet Regulations - draft outline
1982

Thanks Liam and Hannah.
Act

In our initial discussions s 9(2)(g)(i)


s 9(2)(g)(i)
– we
normally signal in our RRT briefings what engagement we have had with lead agencies on the issue by
the time we provide our advice (none, some etc.,).

Information
Ngā mihi,

Lucy Pritchard (she/her)
Principal Advisor/Acting Lead - Regulatory Response Team
Official
Ministry for Regulation
īmēra: [email address] |


4

www.regulation.govt.nz

From: Hannah McGlue <[email address]>
Sent: Monday, 26 May 2025 6:30 am
To: Liam Taylor <[email address]>; Lucy Pritchard <[email address]>
Cc: Grace Chang <[email address]>; Kevin Counsell <[email address]>
Subject: Re: RRT Cycle Helmet Regulations - draft outline

Thanks for sending this though Liam - I think it is looking really good as an outline for advice to respond to the
request from the Office - covers all of the key points, and we are being clear that this is initial advice and more
can be provided if requested.

1982
s 9(2)(g)(i)
Act
Information

s 9(2)(g)(i)


Official

From: Liam Taylor <[email address]>
Sent: Friday, May 23, 2025 4:23 PM
To: Hannah McGlue <[email address]>; Lucy Pritchard
<[email address]>
Cc: Grace Chang <[email address]>; Kevin Counsell <[email address]>
Subject: RRT Cycle Helmet Regulations - draft outline
5

Outside of scope
From:
Lucy Pritchard
Sent:
Wednesday, 28 May 2025 4:42 pm
To:
Liam Taylor
Subject:
FW: Bike Helmet Regulations
We normally do the Mins Cover sheet for RRT issues briefings - not sure if you have done that for this
one? Can go to Larissa/Mins when ready/approved to go out – prior to having a Hannah sign out
option RRT briefings went straight to Paul 놴
놲
놵
놶
놷
놳

Any questions let me know.

Lucy Pritchard (she/her)
Principal Advisor/Acting Lead - Regulatory Response Team
1982
Ministry for Regulation
īmēra: [email address] |
Act

www.regulation.govt.nz

From: Hannah McGlue
Sent: Wednesday, 28 May 2025 12:43 pm
To: Lucy Pritchard ; Kevin Counsell ; Grace Chang
Cc: Liam Taylor
Subject: Re: Bike Helmet Regulations

Information
Thanks Grace and Liam.

I have made some edits and it is good to go, bar...Kevin are you OK with us saying this:

1.  While the Ministry could undertake a comprehensive cost benefit analysis which
would look at actual costs to the health and ACC systems and access data held
by the New Zealand Transport Agency, this would take 12 weeks to complete and
Official
divert resource from other priorities (both Sector Reviews and Red Tape Portal
investigations). We also expect that this analysis would show a very high benefit
to very low-cost ratio.

From: Lucy Pritchard <[email address]>
Sent: Wednesday, May 28, 2025 11:57 AM
To: Kevin Counsell <[email address]>; Grace Chang <[email address]>; Hannah
McGlue <[email address]>
1

1982
Act
Information
Official

Grace Chang (張家瑜)
Advisor, Reviews and System Capability
Ministry for Regulation
īmēra: [email address]

www.regulation.govt.nz

Outside of
scope
1982
Act
Information
Official
3

Outside of scope
From:
Kevin Counsell
Sent:
Wednesday, 28 May 2025 12:55 pm
To:
Hannah McGlue; Lucy Pritchard; Grace Chang
Cc:
Liam Taylor
Subject:
RE: Bike Helmet Regulations
Categories:
TO SAVE
I’m fine with it, although have suggested (in red below) we also refer to diversion of Economics
resources.

s 9(2)(g)(i)

1982

From: Hannah McGlue <[email address]>
Sent: Wednesday, 28 May 2025 12:43 pm
To: Lucy Pritchard <[email address]>; Kevin Counsell <[email address]>; Grace
Act
Chang <[email address]>
Cc: Liam Taylor <[email address]>
Subject: Re: Bike Helmet Regulations

Thanks Grace and Liam.

I have made some edits and it is good to go, bar...Kevin are you OK with us saying this:

1.  While the Ministry could undertake a comprehensive cost benefit analysis which
would look at actual costs to the health and ACC systems and access data held
by the New Zealand Transport Agency, this would take 12 weeks to complete and
divert resource from other priorities (both Sector Reviews and Red Tape Portal
Information
investigations, and the Economics team). We also expect that this analysis
would show a very high benefit to very low-cost ratio.

From: Lucy Pritchard <[email address]>
Sent: Wednesday, May 28, 2025 11:57 AM
Official
To: Kevin Counsell <[email address]>; Grace Chang <[email address]>; Hannah
McGlue <[email address]>
Cc: Liam Taylor <[email address]>
Subject: RE: Bike Helmet Regulations

I have also reviewed and it looks great. Some small changes tracked and discussed with Hannah.

Lucy Pritchard (she/her)
Principal Advisor/Acting Lead - Regulatory Response Team
1

1982
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www.regulation.govt.nz

Outside of
  scope
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Outside of scope
From:
Hello
Sent:
Friday, 30 May 2025 2:47 pm
To:
Hannah McGlue; Hello
Cc:
Lucy Pritchard; Paul Delahunty; Grace Chang; Liam Taylor
Subject:
RE: MFR2025-136 Bike Helmet Regulations
Thanks – this has been sent.

Nikki Bidlake (she/her)
Senior Advisor, Ministerial Services
Ministry for Regulation

From: Hannah McGlue <[email address]>
Sent: Friday, 30 May 2025 12:03 pm
1982
To: Hello <[email address]>
Cc: Lucy Pritchard <[email address]>; Paul Delahunty <[email address]>;
Grace Chang <[email address]>; Liam Taylor <[email address]>
Subject: MFR2025-136 Bike Helmet Regulations
Act

Kia ora,

Please find advice requested by the Minister's advisors attached to this email - due today (Friday 30
May).

Apologies, I've not signed the cover sheet. Please consider this my signature.

Ngā mihi nui,
Hannah
Information
Official
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Outside of scope
From:
Paul Delahunty
Sent:
Wednesday, 4 June 2025 6:14 pm
To:
Lucy Pritchard; Liam Taylor; Hannah McGlue; Grace Chang
Subject:
RE: Bicycle Helmets
Categories:
TO SAVE
Well done all,s 9(2)(g)(i)

Great job

Ngā mihi

Paul

1982
From: Lucy Pritchard
Sent: Wednesday, 4 June 2025 5:39 pm
To: Liam Taylor ; Hannah McGlue
Cc: Paul Delahunty
Act
Subject: Bicycle Helmets

Kia ora Liam me Hannah hoki

We discussed the bicycle helmets advice at RRT Advisors today and the o ice confirmed no further
work is required and they will not be taking any further action in relation to this issue.

Ngā mihi,

Lucy Pritchard (she/her)
Principal Advisor/Acting Lead - Regulatory Response Team
Ministry for Regulation
Information
īmēra: [email address] |

Official
www.regulation.govt.nz

1