Dear New Zealand Transport Agency,

SECTION 1: DEVICE VALIDATION AND ACCURACY

(a) All validation studies, accuracy assessments, and independent testing results for the Securetec DrugWipe 3S considered during procurement

(b) The false positive rate and false negative rate for each tested substance when compared to confirmatory blood testing (real and estimated)

(c) Whether you were aware of international accuracy concerns, specifically:

Finnish National Institute for Health and Welfare data on false positive rates
University of Sydney Lambert Initiative findings on sensitivity and accuracy
UK and Swiss police field testing results

(d) The evidential basis for concluding the DrugWipe 3S is fit for purpose given documented international performance issues
SECTION 2: STATISTICAL BASIS AND METHODOLOGY

(e) All analysis, reports, or calculations distinguishing between:

Road fatalities where drugs were present in the deceased driver's system
Road fatalities where drugs were determined to have caused or contributed to the crash

(f) Specific breakdown of the widely cited "30% of road deaths involve drugs" statistic, including:

How many involved THC alone vs. THC combined with alcohol or other drugs
Causality analysis (presence vs. impairment vs. crash causation)
Source data and methodology

SECTION 3: POPULATION IMPACT ESTIMATES

(g) Estimates or calculations of:

Number and percentage of New Zealanders who regularly take Schedule 5 medications (by drug category)
Number of medicinal cannabis prescription holders
Geographic distribution (urban vs. regional/rural)

(h) Assessment of health and safety risks to Schedule 5 medication users who may:

Cease taking prescribed medications to avoid testing positive (health deterioration, pain-related impairment while driving)
Cease driving entirely (social isolation, delayed healthcare access, unemployment)

SECTION 4: FINANCIAL COSTS

(i) Itemized programme costs, including:

Cost per DrugWipe 3S unit
Cost per oral fluid collection kit for laboratory analysis
Annual procurement budget (devices and consumables)
Laboratory confirmatory testing costs per sample
Officer training costs (development and delivery)
IT systems development and maintenance
Administrative processing costs
Total first-year cost and projected ongoing annual costs

(j) Disposal costs:

Cost per test for biohazardous waste disposal
Annual waste management budget
Environmental impact assessment of 50,000+ single-use devices annually

(k) Enforcement resource allocation:

Average officer time per test (including administration and paperwork)
Officer hours diverted from other policing activities annually
Cost-benefit comparison: drug testing vs. alternative policing priorities

(l) Long-term cost projections:

Expected legal challenge defense costs
Ombudsman and Human Rights Commission complaint processing costs
Mandated 3-year independent review budget
Contingency budget for programme modifications or discontinuation

SECTION 5: EXPECTED BENEFITS AND COST-EFFECTIVENESS

(m) Quantified expected benefits:

Expected reduction in road crashes per year (number)
Expected reduction in fatalities per year (number)
Expected reduction in serious injuries per year (number)
Methodology and data sources used to calculate these projections

(n) Cost-effectiveness analysis:

Cost per life saved (or expected to be saved)
Cost per serious injury prevented
Break-even point: minimum crashes/fatalities that must be prevented to justify programme cost

(o) Comparative analysis with alternative road safety interventions:

Cost-effectiveness comparison with: increased alcohol testing, road safety campaigns, fatigue detection systems, infrastructure improvements, vehicle safety standards
Evidential basis for prioritizing drug testing over alternatives

(p) Net benefit calculation:

Overall cost-benefit ratio
Whether a formal Regulatory Impact Assessment was completed (if so, please provide)

SECTION 6: PROCUREMENT PROCESS

(q) Tender and device selection documentation:

Tender process records
Alternative devices and manufacturers considered
Evaluation criteria and scoring matrix
Whether independent (non-manufacturer) validation was required
Conflicts of interest declarations from decision-makers

SECTION 7: FALSE POSITIVE AND MEDICAL DEFENSE IMPACTS

(r) False positive management:

Expected number of false positive tests annually based on device accuracy data
Estimated economic cost to drivers wrongly subjected to 12-hour bans (lost wages, stranded, missed appointments)
Compensation mechanism for confirmed false positives
Administrative cost of processing medical defence applications

(s) Revenue projections:

Expected annual revenue from infringement fines
Comparison: fine revenue vs. total programme cost

SECTION 8: MOBILITY AND ACCESSIBILITY IMPACTS

(t) Whether assessments were conducted on:

Public transport availability in regions where testing will occur
How Schedule 5 medication users in areas with inadequate public transport are expected to maintain employment and access essential services if unable to drive
Employment impacts for workers who drive professionally and take prescribed Schedule 5 medications

(u) Alternative transport considerations:

Estimated financial burden on affected individuals relying on taxis/rideshare
Whether subsidies or transport assistance were considered
Comparison with existing disability transport schemes

SECTION 9: EQUITY AND HUMAN RIGHTS

(v) Whether analysis was conducted on:

Geographic equity (urban vs. rural/regional impacts)
Demographic equity by income, age, ethnicity, and disability status
Disproportionate impacts on Māori and Pacific peoples
Treaty of Waitangi obligations

(w) Whether the regime was assessed for compliance with:

New Zealand Bill of Rights Act 1990 (specific legal advice received)
Human Rights Act 1993 (disability discrimination, indirect racial discrimination)
Convention on the Rights of Persons with Disabilities (Article 20: Personal mobility)

(i have read the JUDITH COLLINS' NZBORA REPORT and it seems like you guys are violating the bill of rights implementing this but im not a lawyer but this is devastating language from the Attorney-General. She's not just saying "there are concerns" — she's saying the Bill violates fundamental rights and the violation cannot be justified. https://bills.parliament.nz/download/Pap...)

apparently the lawyers agree
(https://www.lawsociety.org.nz/assets/Law...)

(w.2) The Attorney-General's report states that requiring officers to have reason to suspect drug consumption before testing would make the regime less likely to be inconsistent with s 22. Please provide:

All advice on why this recommendation was not adopted
Policy analysis weighing rights protection vs. enforcement convenience
Whether any modelling was done on how requiring suspicion would affect testing numbers or road safety outcomes

(x) Legal advice on whether restricting driving for people taking legally prescribed medications constitutes unlawful discrimination

(y) Whether alternatives to blanket restrictions were considered (impairment-based testing, functional assessments, conditional licenses)

SECTION 10: CONSULTATION

(z) List of organizations consulted during policy development, including:

Patient advocacy groups
Disability rights organizations
Chronic pain associations
Medicinal cannabis clinics and prescribers
Māori health providers
Employment/labour organizations

(aa) Copies of submissions or feedback received, particularly regarding:

Mobility and accessibility concerns
Impacts on medicinal cannabis patients and Schedule 5 prescription users
How concerns were addressed or reasons for dismissal

SECTION 11: INTERNATIONAL COMPARISONS

(ab) Evidence from comparable jurisdictions:

Cost-benefit data from Australian states with roadside drug testing
Measured crash reduction outcomes in jurisdictions with vs. without drug testing
Any evidence of jurisdictions discontinuing programmes due to cost-ineffectiveness or accuracy concerns
How other countries addressed medicinal cannabis and prescription medication exemptions

Yours faithfully,

Hayden