Information on Pseudo Driver Licence PZ109108

Geoff. Waterhouse made this Official Information request to New Zealand Transport Agency

Response to this request is delayed. By law, New Zealand Transport Agency should normally have responded promptly and by (details and exceptions)

From: Geoff. Waterhouse

Dear New Zealand Transport Agency,

On 03 December 2006, Pseudo Driver Licence Number PZ109108 was created for PAIHIA TAXIS & TOURS LIMITED.

Please provide:

1)The name and position of the person(s) who created this licence.

2)The reason and internal process for its creation.

3)The Act, statute, or other legislative authority under which it was created.

4)Was it created as a result of an alleged Speeding ticket?

5What are the details of that ticket?

6If so, what was the date of the offence?

7A list of all offences attributed to PAIHIA TAXIS & TOURS LIMITED under Pseudo Driver Licence number PZ109108 from 3 December 2006 to 20 July 2025.

8 Is a “Pseudo Driver Licence” a legal document under New Zealand law? If so, please specify the legal basis. If not, please explain why it was used for prosecutorial or infringement purposes.

Yours faithfully,

Geoff. Waterhouse
Director
PAIHIA TAXIS & TOURS LIMITED

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From: Geoff. Waterhouse

Dear New Zealand Transport Agency,
One thing I forgot in the original request I require the request to be considered under Section 12 (3)If the person making the request asks that his request be treated as urgent, he shall give his reasons for seeking the information urgently. The information is required for a High Court hearing in November 2025

Yours faithfully,

Geoff. Waterhouse

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From: Official Correspondence
New Zealand Transport Agency


Attachment Re Official Information request Information on Pseudo Driver Licence PZ109108.txt
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Kia ora Geoff

This email acknowledges your below request for information made under the Official Information Act 1982.

Your request has been forwarded to the appropriate section of NZ Transport Agency Waka Kotahi for response. They will contact you if they require clarification of your request, more time to respond, or if your request has been transferred to another organisation to respond to. Unless more time is required, NZ Transport Agency will send a response to you within 20 working days of receiving your request – in this instance on or before 4 November 2025.

If you would like to discuss your request with NZ Transport Agency, please contact us by email at [NZTA request email].

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Ministerial Services
Te Waka Kôtuia | Engagement & Partnerships
NZ Transport Agency Waka Kotahi
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From: Official Correspondence
New Zealand Transport Agency


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Attachment OIA 19836 Geoff Waterhouse response.pdf
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Attachment Attachment 1 Traffic Offence History PZ109018.pdf
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Kia ora Geoff

 

Please find attached the response to your request of 6 October 2025 for
information under the Official Information Act 1982.

 

Ngâ mihi

 

Ministerial Services
Te Waka Kôtuia | Engagement & Partnerships
NZ Transport Agency Waka Kotahi

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From: Geoff. Waterhouse

Dear Official Correspondence,
The link to your reply is not working. I cannot access anything. Is this a deliberate ploy on your part? I wouldn't put it past you

Yours sincerely,

Geoff. Waterhouse

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From: Official Correspondence
New Zealand Transport Agency


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Kia ora Geoff

 

Thank you for getting in touch regarding our response of 20 October 2025
to your request under OIA-19836.

 

For any errors occurring on the FYI website, you will need to contact them
directly via [1][FYI contact email] as NZ Transport Agency does not manage
this website or any of the links provided.

 

In the meantime, if you would like us to send a copy of the response to
your OIA request to a different email address, please let us know.

 

Ngā mihi

 

Ministerial Services
Te Waka Kōtuia | Engagement & Partnerships
NZ Transport Agency Waka Kotahi

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From: Geoff. Waterhouse

Dear Official Correspondence,
You people really do enjoy making life difficult for we the people who pay your wages and whom you are supposed to serve.
I have read your letter of 20 October 2025 reference OIA-19836.
I have also gone back to your previous responses to me in:
OIA-17175, dated 27 January 2025
OIA-17722, dated 14 March 2025
NZT-10383, dated 1 May 2025
NZT-10881, dated 4 August 2025. and I will deal withem in order
1)OIA-17175, dated 27 January 2025
This is the letter from Chris Rodley. He waffles on in typical bureaucrat style failing to give a proper answer, just like a politician

Counterpoint – “Issue / Create / Generate” Inconsistency
In his letter, NZTA official Chris Rodley confirmed that “if a traffic offence is identified as being committed by a vehicle registered to a limited company and the individual operating the vehicle cannot be identified, then a pseudo driver licence record is generated in the limited company’s name.”
This response was given directly to my question as to whether a pseudo driver licence could be issued to a limited company. It is therefore material that Mr Rodley substituted the statutory term “issued” with the administrative term “generated.”
In contrast, other NZTA correspondence states that the pseudo licence PZ109108 assigned to Paihia Taxis & Tours Ltd was “created on 3 December 2006” and has been used in multiple infringement notices between 2008 and 2025.
These statements cannot both be correct. If the record is “generated at the time of the offence,” then it did not pre-exist; yet NZTA simultaneously asserts that the same record was “created” nearly two decades earlier and reused repeatedly.
The inconsistency indicates that the so-called pseudo licence is neither lawfully issued under any statutory authority nor coherently administered under a defined policy or rule. NZTA’s own language reveals an ad hoc internal construct lacking legislative foundation, used to simulate the existence of a driver-licence record where none lawfully exists.
OIA17722 I have read through this from Tracy Moore. It does not say, as far as I can see, if pseudo driver licences are legal. Please show me where it says that they are or are not. I don't propose to go through it in detail, you don't, so just answer the question. “IS A PSEUDO DRIVER LICENCE LEGAL OR NOT?” all IT NEEDDS IS A SIMPLE "YES" OR "NO."
She answered Yes” to the question “ Can a pseudo driver licence be issued to a limited company?” She then waffled on. Yes. If a traffic offence is identified as having been committed by a vehicle registered to a limited company, and the individual operating the vehicle cannot be identified, then a pseudo licence record is generated in the limited company’s name. An example of this occurring would be when a vehicle registered to a limited company commits an offense that is recorded by a speed or safety camera This bit was interesting “ a pseudo licence record is generated in the limited company’s name” The implication here is clear, the “pseudo licence” is created at the time the “alleged” offence is committed. This is clearly untrue since Tracey Moore states in her letter of 1 May 2025 “ The pseudo licence record in the name of Paihia Taxis & Tours Limited is PZ109108. This record was created on 3 December 2006 “ and, by NZTA's own admission, it has been used 17 times between November 2008 and February 2025 so how can it have been generated (created) when the alleged offence was committed?
Ref NZT-10974
“A pseudo driver licence record is a term for a unique identifier created in the driver licensing register system that holds information against it. It is not a licence that is issued to a person or company and does not grant any rights to a person or company to drive. Rather it is an administrative process that is used when an offence is committed and a unique identifier does not already exist or cannot be clearly identified. “ The above clearly states “used when an offence is committed and a unique identifier does not already exist or cannot be clearly identified.' A unique identifier/pseudo DRIVER licence has existed for PAIHIA TAXIS & TOURS LIMITED since 3 Dec 2006 and, as said earlier, has been used 17 times from Nov 2008-Feb 2025 , twice the same day by NZTA which raises a whole load of other questions, like how could it be generated/created twice in the same day if it is created at the time the alleged offence is committed? Interesting eh?
This bit is also doubley interesting “used when an offence is committed and a unique identifier does not already exist or cannot be clearly identified.' Apart from “PZ109108” (unique identifier) existing since 3 Dec. 2006, PAHIIA TAXIS & TOURS LIMITED has at least 2 other “unique identifiers” (1)TSL (Transport Service Licence) 212315 Dated 14 May 2007 which, interestingly, was conspicuous by its absence in both NZTA camera tickets SC00065344 and SC00065396 despite the fact that there is a box on the tickets which says “Transport Service Licence (TSL) Number” which is blank (2) SPSL (Small Passenger Service Licence) number 03001136 (11 Oct 2017)
Finally you have a copy of PAIHIA TAXIS & TOURS LIMITED “Certificate of Incorporation dated 21 November 2002, which was Page 44 of your summons. Another “unique identifier” So you have access to FOUR unique identifiers going back 23 years. Interesting eh?
OK enough
Bottom line
(1)I want to know if pseudo licences are legal, Yes or no and no ifs. ands or buts.
(2)Tracey Moore says in her letter of 1 May 2025 “The pseudo licence record in the name of Pahia Taxis & Tours Limited is PZ109108. This record was created on 3 December 2006.” If she can state that categorically, there must be a record of it. I want a copy of that record.
Geoff. Waterhouse
P.S. I dare say that the justices, who will be deciding this case, will find all your obfuscation, prevarication and failure to provide direct answers to direct questions quite interesting as they will form part of the defence/s evidence. I dare say NZTA's lawyers will also find it interesting as they will receive copies and have to justify them

Yours faithfully

Geoff. Waterhouse

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From: Official Correspondence
New Zealand Transport Agency


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Attachment Attachment 1 Driver Licence Record PZ109108.pdf
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Kia ora Geoff

 

Thank you for your email. We feel we have answered your questions about
pseudo licences as thoroughly as can be and have nothing further to add to
our previous responses.

 

For your reference we have a screen shot of when the licence was created.
Please find this attached.

 

If you are not satisfied with NZTA’s response, you have the right to
complain to the Ombudsman. The contact details for the Ombudsman can be
located at [1]www.ombudsman.parliament.nz.

 

Ngâ mihi

Ministerial Services
Te Waka Kôtuia | Engagement & Partnerships
NZ Transport Agency Waka Kotahi

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From: Geoff. Waterhouse

Dear NZTA OIA Team,

I am in receipt of your latest OIA response. The attached “Transaction Log” (Page 2/2) and reply (Page 8/9) raise substantially more questions than they answer. I intend to address these, page by page and in numerical order.

1) Page 8/9:
You state, “We FEEL we have answered your questions about pseudo licences as thoroughly as can be and have nothing further to add to our previous responses.”
I respectfully point out that this is offered as an opinion, not a fact. There remain many questions still to be answered.
You also state, “For your reference we have a screen shot of when the licence was created. Please find this attached.”

2) Page 2/2 – The Transaction Log:
This document contains critical information which, in my view, should have been disclosed at a MUCH earlier stage. It raises the following queries:

a) What is the source of the Transaction Log? Where is it stored? Is there a URL or database reference to access the full record?
b) What do the abbreviations “DLPRO”, “DL Register”, and “6.20v31” represent?
c) It appears DRIVER LICENCE NUMBER PZ109108/000 was “ISSUED” on 03/12/2003 and has been on the DL Register since that date.
- How do you account for the expiry date “99/99/9999”?
- The log states “DRIVER LICENCE” was “ISSUED”, then “PSEUDO”, then “status inactive”. If “inactive,” how was it possible to issue seventeen infringement notices using PZ109108 between November 2008 and February 2025?
- Why does the log refer to “Licence Number” rather than “Pseudo Licence Number”?

d) Please clarify all abbreviations across the white log box, beginning with “Appl.” and including “User code”, “REPORT”, and “SUPPORT”. Who inputted these records, and what do highlighted codes refer to? Does the creation time of 02:45am indicate standard practice?

e) Most critical:
- The entry “000000 IADDR 06/01/2003 14:17 W98AK042 AUCKLD GORDONC” records an event a month before I even arrived in New Zealand. Please explain this anomaly, as it seriously calls into question the authenticity of the record.

These points appear to contradict statements by Chris Rodley and Tracey Moore on pages 6/9 and 7/9.

Your prompt clarification on these issues is requested in the interests of accuracy, transparency, and lawful administration.

Regards,
Geoff. Waterhouse
P.S. I just noticed that you still have not answered ANY of the questions on your page1/9

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From: Official Correspondence
New Zealand Transport Agency


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Kia ora Geoff

 

This email acknowledges your below request for information made under the
Official Information Act 1982.

 

Your request has been forwarded to the appropriate section of NZ Transport
Agency Waka Kotahi for response. They will contact you if they require
clarification of your request, more time to respond, or if your request
has been transferred to another organisation to respond to. Unless more
time is required, NZ Transport Agency will send a response to you within
20 working days of receiving your request – in this instance on or before
5 December 2025.

 

If you would like to discuss your request with NZ Transport Agency, please
contact us by email at [1][NZTA request email].

 

Ngā mihi

 

Ministerial Services
Te Waka Kōtuia | Engagement & Partnerships
NZ Transport Agency Waka Kotahi

[2]Connect with us on Social Media

 

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