“Faster. Faster. Faster… OK, pull over, and we’ll discuss that. Back there, if you go at that speed in your test, you’ll fail. It’s a critical error. That road is where four of my students have failed their test for driving too slowly.”

Sitting in the back seat during the driving lessons this year was an educational experience for me.

“Back there” was a narrow residential road lined with parked cars, where to go at the speed necessary to get a license, these requirements of the road code could not be met:

Be careful when driving past parked vehicles. Pedestrians may walk out without warning.

Speed reduces peripheral vision, as shown in this graphic by the organisation 8 80:



This learner driver was being taught to focus more on the road ahead of him, and less on anything happening between the parked cars or on the footpath. Coupled with his inexperience, he was having to drive at a speed that could easily result in a nasty crash with a pedestrian.

Checking the AA’s Driving Test Ezy guide, I found:

If you over-emphasise safety by travelling more than 5 kph under the speed limit when unnecessary, you may cause other road users to become impatient with you. They may take an unnecessary risk in order to pass…

I knew this was a myth. Driving at faster speeds increases risk. If driving at slower speeds increases risk, there is insufficient research to show it. The US National Transportation Board looked at the available evidence in 2017 about speed variance (ie people driving at a wider range of speeds):

Although speed variance within a traffic flow exists and is often cited as a concern, the degree to which speed variance contributes to crash involvement is inconclusive. However, the link between speed and injury severity in a crash is consistent and direct.

In an evidence-based system, slower speeds should be supported rather than faster speeds. So I asked NZTA if it was legal for the examiners to follow a guide like this. They replied:

Travelling too slow is considered a critical error during the practical driving test. The test guide has more detail: www.nzta.govt.nz/assets/Driver-Licences/docs/full-test-guide.pdf

The Driver License Test Guide states a critical error of driving too slowly is:

If ‘road and traffic conditions’ include parked cars hiding children, or people made invisible by reduced peripheral vision, that was certainly not how the instructor and examiners were interpreting it. I wondered how speeds that keep people safe could be compromised for someone else’s ‘convenience’.

In contrast to the Driver License Test Guide, the Road Code says:

[your speed is low enough to follow the safe speed guidelines.] There are no requirements to drive close to the speed limit.

The Road Code does give some tips for how to be considerate:

To my mind, there is a huge discrepancy between:

being allowed to drive at any speed under the limit, with tips for how to do so safely and considerately, and

receiving a critical error for travelling 10 km/hr below the speed limit.

These are simply not equivalent. So I asked NZTA, and they informed me:

the practical test guide and NZ Road Code are two separate documents. The test guide is information on the tasks you will be assessed on and what you need to do to pass the practical test. The Road Code provides recommendations on safe driving practices, this is general information to help you learn to drive and to ensure you drive with due care and consideration of other road users. The practical test guide then goes into further detail to explain, how in the context of the test, these recommendations should be put into practice.

How does the requirement to drive close to the speed limit give “further detail” to not having to drive close to the speed limit?

I pondered on the situation, and thought of the streets in my suburb, where there are children playing and climbing street trees, people walking, running, cycling and scootering, and elderly residents struggling around illegally parked cars. I thought about how absolutely wrong the 50 km/hr speed limit is. These are little dead end residential roads where 20 or 30 km/hr is suitable. And I wondered about what a young driver practising for the test would do here…

“Faster. Faster. Faster.”

I cringed when I thought about rural roads I knew where you’d be mad to drive near the speed limit. And I asked NZTA:

As successful driver applicants are required to drive within a narrow band around the posted speed limit, it is important that the posted speed limit is safe and appropriate. Are you able to tell me what percentage of NZ roads have posted speed limits that align with NZTA’s safe and appropriate speeds, according to whatever measure the NZTA does use?

NZTA’s reply consisted of facts that didn’t answer my question, so I asked again on the 19th October, and suspect at this stage that I won’t get a reply. According to the Ministry of Transport’s information to the Road Safety Strategy Speed Reference Group:

87% of NZ’s roads have speed limits that do not align with the safe and appropriate speed for the road

Remember, too, that the “safe and appropriate speeds” were set by NZTA before the current government’s interest in Vision Zero; they’re almost certainly too high. Driving 10 km/hr or more below the speed limit may in fact be far closer to a safe speed on most of our roads. Yet, to gain a driving license, learners must drive within a narrow band of speed around a limit that NZTA know is not safe, and not appropriate, on at least 87% of our roads.

NZTA say:

Drivers on a restricted licence are seven times more likely to be involved in a fatal or serious injury crash than other drivers. Data also shows that young restricted drivers are more at risk of having a serious crash in the first six to 12 months of driving solo on their restricted licence than at any other time in their lives. This increased risk is partly due to driving inexperience.

A society that values human life would find a way to mitigate this increased risk. Requiring and supporting lower speeds would be a way to scaffold learning to drive in a way that keeps a focus on developing good awareness of vulnerable road users and on what’s happening in the peripheral vision.

Younger people agree more than older people with the statement that ‘Fewer crashes would happen if drivers slowed down’. NZTA interpret this by saying,

It might be that advertising campaigns have been effective on the younger group and a generational acceptance of slower speeds is occurring.

Instead of building on youngsters’ higher awareness around speed, the Driver License Test Guide seems to be designed to make drivers override that awareness.

I believe the guide has contributed to a culture of speed and disregard for vulnerable road users. It has resulted in instructors training drivers to drive faster than is safe, and to ignore activity in their reduced peripheral vision at higher speeds. There is no basis for the guide to make driving too slowly a critical error.

The reason behind discouraging slower speeds is probably the arrogant cultural value that delaying traffic is worse than endangering lives. The new Government Policy Statement on Transport changes all this:

In the past, the design of both urban and rural roads has often prioritised the faster movement of vehicles over the safety of people, particularly vulnerable road users like people walking and cycling… Reversing New Zealand’s current trauma trends requires a transport system that is designed for people, and one that considers their safety as the top priority… GPS 2018 supports investment in initiatives to improve road user behaviour and community understanding of road safety… GPS 2018 supports policy development in key areas, including: ensuring safer and appropriate speeds…

Now this change needs to be reflected in driver training and licensing.

The NZTA is currently under review:

The laissez faire regime has been overturned – Transport Minister Phil Twyford says the review covers everything the agency is in charge of, including driver testing, licenses… It comes after agency chief executive Fergus Gammie publicly confessed a raft of public safety failures in recent weeks and months… It will consider if new laws are necessary and cover governance, leadership, operational policy and practice, regulatory intelligence, people capability and capacity, and the balance of education, engagement and enforcement.

Government: There are a number of ways drivers could be required to develop more awareness and care of vulnerable road users; this error around speed in the Driver License Test Guide being just one of several. Between the work being done by the Road Safety Strategy Reference Groups, and the review of the NZTA, I hope this change to the test guide can be accommodated.

NZTA: Change your Driver License Test Guide. Instruct examiners to change their testing protocol. And (because instructors teach to the test):

Allow learner drivers to drive at slower speeds, as per the Road Code, as per Vision Zero principles, and in line with the GPS, when they’re being tested for their licenses.

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