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Submissions

NZ Parliament Land Transport Management (Time of Use Charging) Amendment Bill

To: Transport and Infrastructure Select Committee
Date: April 2025

 

Purpose

This submission’s primary purpose is to advocate for the withdrawal of the Bill, arguing that time-of-use road charging would disproportionately penalise disabled motorists and low-income earners without sufficient complementary investment in public transport. DPA seeks to highlight the significant financial vulnerability of disabled people and the potential negative impact of these charges on their ability to access work, healthcare, and community life.

Summary of DPA submission

DPA strongly recommends the withdrawal of the Land Transport Management (Time of Use Charging) Amendment Bill. A key reason for this opposition is the disproportionate financial penalty it would impose on disabled motorists and vehicle passengers, who are more likely to be low-income earners. DPA cites Statistics New Zealand data indicating that 53% of disabled New Zealanders report having insufficient income to meet basic needs, compared to 31% of non-disabled people. Given that most disabled people drive themselves (54%) or are regular passengers (43%), and 78% drive to work, these charges would significantly impact those least able to afford them.

DPA also expresses concern that introducing user charges would penalise passengers in small passenger service vehicles (e.g., Ubers, taxis, mobility taxis), as providers would likely raise fares to offset the costs. Even with existing subsidies like Total Mobility, increased charges could deter disabled people from accessing essential services, employment, and recreational activities.

DPA notes that the government is heavily promoting the economic growth aspects of time-of-use charging over environmental benefits, and crucially, without any complementary plans for increased central government investment in public transport platforms (buses, ride-share, park and ride schemes) or active transport (cycleways, walkways). DPA points out that the current government is reducing funding for regional public transport, which, coupled with a focus on greater vehicle use, will likely exacerbate, not reduce, vehicular congestion.

DPA argues that ordinary motorists should not be burdened with the cost of road maintenance, especially when research indicates that trucks, due to their weight and axle loads, cause significantly more damage to roads than smaller vehicles. DPA concludes that time-of-use charging, introduced in isolation, primarily benefits freight companies (who can absorb the costs) while disproportionately disadvantaging disabled people and low-income motorists who are already struggling with household expenses. A multi-pronged approach to congestion reduction, which includes significant public transport investment, is needed.

 

Key Recommendation/Finding:

DPA's view is that time of use charging is being introduced in isolation, predominantly as a means of improving economic productivity through lessening travel times for trucks and other business vehicles.

 

Supporting Statement 1:

DPA argues that without complementary investment in public transport, which is needed to encourage a greater "modal shift" from private vehicle use, these charges will inevitably disadvantage disabled people and low-income motorists more than multinational and domestic freight companies.

 

Supporting Statement 2:

Research cited by DPA indicates that encouraging modal shift towards public transport through greater investment is one of the primary ways to reduce congestion, suggesting that time-of-use charging in isolation is an incomplete solution that shifts the burden rather than fundamentally solving congestion.

 
 

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