1 Accident Compensation Corporation Levy Consultation 2013/14 Levies for motorists Deadline for feedback 5.00pm, 23 October 2012
2 Contents Setting the scene... 3 Our funding policy... 3 Our levy-setting goals... 5 Our levy-setting principles... 5 Motor Vehicle levies 2013/ Proposals at a glance... 6 The combined average Motor Vehicle levy... 6 Residual levy portion... 8 Current levy portion... 8 Recent performance Claim frequency Claim severity or average claim cost month rehabilitation rate Long-term weekly compensation claims Collecting motor vehicle levies Vehicle classes Proposal to introduce GSV sub-classes Introducing a Fleet Safety Incentive Programme The petrol levy Motorcycle Safety Levy Removing the trade plate exemption What do you think?... 17
3 Page 2 Providing feedback Right now, the Accident Compensation Corporation (ACC) is looking for feedback on the proposed Motor Vehicle levies for 2013/14, that is, the money motor vehicle owners and users pay each year that goes to provide insurance for people who are injured in accidents involving moving vehicles on public roads in New Zealand. We welcome your feedback on the proposed levies, whether you agree or disagree with our proposals and if you have any ideas or suggestions for improvement. You can send your submission (which must include your name, address and contact phone number) in the following ways: By post to: By to: Levy Consultation ACC PO Box 242 Wellington 6140 We need to hear from you by 5.00pm on 23 October Please note that ACC is subject to the Official Information Act 1982, so your submission may be available to people seeking information under the Act. For more information If you d like more information, or want to learn more about the advice upon which we ve based the proposed levies, visit call us on or send an with your request to
4 Page 3 Setting the scene The Accident Compensation Corporation (ACC) is the organisation that manages and delivers New Zealand s accident insurance Scheme. Our responsibilities are set out in the Accident Compensation Act Through the ACC Scheme, New Zealanders don t have the right to sue for personal injury (other than exemplary damages). Instead, they receive comprehensive insurance if they re injured in accidents, whether or not they re at fault. In March 2010, Parliament amended the Accident Compensation Act 2001 to make the levy-setting process more flexible. The levy-setting changes now allow for experience rating and risk-sharing options for the Work Account and a greater emphasis on risk-rating in the Motor Vehicle Account. This Account covers claims for all injuries involving moving motor vehicles on public roads in New Zealand. It is funded by a levy included in the price of petrol and the motor vehicle licensing fee. What is the Motor Vehicle Account? The Motor Vehicle Account covers claims for all injuries involving moving motor vehicles on public roads in New Zealand. It is funded by a levy included in the price of petrol and the motor vehicle licensing fee (sometimes called the vehicle registration). What is risk-rating? Risk-rating enables ACC to charge higher or lower levies for different groups of employers and selfemployed people, or different groups of motor vehicles or vehicle owners, to reflect their respective costs to the Scheme. Our funding policy Our legislation requires us to have a funding policy that ensures we have an adequate level of assets to fund the amount of the outstanding claims liability. It guides how we set our levies, as these need to be set to meet today s claims and their associated future costs. Last year ACC reviewed and updated its funding policy so that the risks of over or under-funding were minimised and the stability of ongoing levy rates was strengthened. In the funding policy, the funding ratio target for each Account is expressed as a range with a selected mid-point. Having a range within which to operate provides ACC with more flexibility to absorb changes in the Accounts funding positions without the need to react by changing levies. For the Motor Vehicle Account, the target funding band is 100% to 140% and the selected mid-point is 116%. What is the outstanding claims liability? The outstanding claims liability is the amount ACC needs to set aside now, that together with investment returns, will be sufficient to meet all future payments for existing claims. What is a funding ratio? Funding ratio is defined as the ratio of assets to liabilities as they appear in ACC s financial statements. A percentage below 100% means that the Account is under-funded. You can see our funding policy in the Introduction section at
5 Page 4 About this document This document sets out the changes we propose to recommend to the Minister for ACC for the 2013/14 levy rates for ACC s Motor Vehicle Account. The levies are paid by motor vehicle owners and users when: they purchase petrol when they licence their vehicle (the amount of this funding is lower than that charged for nonpetrol-driven vehicles by an amount equivalent to the average petrol levy). This document covers: the goals we aim to achieve through our levy-setting process and the principles that guide us the proposed changes to the Motor Vehicle levy proposed changes to vehicle classification structure and introduction of a safety incentive programme for motor vehicle fleet owners. For information on how at-work or non-work injuries are funded, please read the Introduction section or the consultation documents for employers/self-employed people and wage earners. These are available at Please note that All the levy rates in this document exclude GST unless it says otherwise. All the levy rates are estimates. This means they might be changed before we make our final recommendations to the Government. We ve rounded some of the numbers (up or down), so if you do your own calculations they might not match ours. In calculating the proposed 2013/14 levies, we ve used estimates based on recent experience and expected trends of the likely number of claims for the year and their costs. It s important to realise that some claims will have costs (in treatment and care) lasting for 60 years or more.
6 Page 5 Our levy-setting goals The levy-setting process for the ACC Scheme includes a focus on achieving five key goals over the next three to four years: 1. Each levy payer contributes their fair share to the Scheme costs Where practical, levy rates should match different levels of risk so that levies paid by low-risk people and businesses are lower than those paid by high-risk people and businesses. 2. Levy rates reward injury prevention Levy rates should provide financial incentives for safe behaviour (which prevents injuries). This supports ACC s work in encouraging people to be aware of the risks associated with activities and preventing injuries. 3. Levy rates reward good injury management Levy rates should provide financial incentives for getting injured people back to work or living independent lives. By encouraging levy-payers to get involved with injured people s rehabilitation, ACC is helping to reduce the social impacts of injuries (i.e. the impacts on their lives and those of their families and communities, and ultimately on New Zealand s economic wellbeing). 4. Levy-payers are informed Levy-payers should understand the cover that ACC provides, the costs involved in providing that cover and any options that might be available. 5. The Scheme is cost-effective ACC must ensure that the Scheme is financially strong and represents value for money for levy-payers. What is risk? Risk is the likelihood of an injury happening - at home, at work, in sport or play and on the roads. The greater the likelihood, the greater the risk. Our levy-setting principles We ve used three key levy-setting principles to guide the setting of levy rates and to make sure that the Motor Vehicle Account has enough funds to cover the full lifetime costs of all the claims that people make (i.e. ensuring the Account is fully funded ). 1. Do not anticipate future improvements ACC does not consider it financially sensible to include estimated impacts of any initiatives to improve future rehabilitation outcomes until they actually demonstrate consistent and sustainable performance. 2. Do not over-react to short-term trends and outcomes While rehabilitation performance has been improving, it is important to be financially prudent in the approach taken to including the impacts in levy-setting. As ACC gets more confidence in the durability and consistency of these trends, this will be reflected in levy-setting. 3. Do not allow ACC s financial position to deteriorate Given the Scheme is still on the path to full funding, it would be irresponsible to deliberately allow reserves to decline from the current level.
7 Page 6 Motor Vehicle levies 2013/14 In this section you ll find our proposed 2013/14 Motor Vehicle levies, and information on how we ve calculated them. The Motor Vehicle levy has two parts: the residual levy portion, which covers injuries to road users prior to 1 July 1999 the current levy portion that funds the costs of motor vehicle injuries that are expected to occur during the 2013/14 year and any adjustments to funding requirements for claims that occurred in prior years. Proposals at a glance maintaining the current (2012/13) combined average Motor Vehicle levy of $ introducing sub-classes for Goods Service Vehicle (GSV) classifications, based on vehicle weight introducing four additional sub-classes to support the introduction of a Fleet Safety Incentive Programme (FSIP) keeping the petrol levy at 9.90 cents per litre keeping the Motorcycle Safety Levy at $30 per year per licensed motorcycle removing the trade plate exemption. The combined average Motor Vehicle levy The combined average Motor Vehicle levy is the amount of the total levy required averaged across every licensed vehicle in New Zealand. ACC proposes to maintain the current (2012/13) combined average vehicle levy of $ for 2013/14, to allow continued build-up of reserves to ensure the Account is fully funded. The graph on the next page shows the proposed 2013/14 average levy rate and the projected average levy rates for the Motor Vehicle Account out to 2020/21.
8 Page 7 Average levy rate for motorists $500 $450 Actual Projected $400 Rate per vehicle $350 $300 $250 $200 $ $ $ $ $ $ $ $ $ $ $ $ $ $ $150 $100 $50 $ Levy year ending 30 June Current Portion Residual Portion Levies are assessed each year on a full funded basis. You can see our funding policy in the Introduction section at The target full funding band for the Motor Vehicle Account is 100% to 140% with a selected mid-point target of 116%. The graph below shows the path to reach the target funding mid-point of 116% by 2019/20, based on current performance trends. At present ACC expects the Motor Vehicle Account to be very close to 100% funded by 30 June After this date, the funding adjustment component of the current levy rates may be reduced, to allow a slower path to the final target mid-point of 116%. Indicated Motor Vehicle Account Funding Path 150% Funding Ratio 125% 100% 86% 95% 102% 107% 111% 115% 117% 119% 75% 68% 77% 50% A Funding Position as at levy year ending 30 June
9 Page 8 Here s how the proposed average Motor Vehicle levy compares with the current levy: The Motorcycle Safety Levy (MSL) is included in the average amount but is only paid by the owners of motorcycles and mopeds (refer page 17). Current 2012/13 levy rate Proposed 2013/14 levy rate % change (current to proposed) Average levy for current year claims (including MSL) $ $ No change Average levy for the residual portion $77.07 $77.07 No change Combined average Motor Vehicle levy $ $ No change Further details on these levy rate components are provided on the following pages. Residual levy portion The Accident Compensation Amendment Act 2010 changed the way the residual portion of the Motor Vehicle Account levy was calculated: 30 June 2019 was set as the final date for paying off the estimated unfunded outstanding liability associated with residual claims the final amount to be funded by the residual levy portion as at 30 June 2009 was calculated and has been locked in. It is not recalculated each year, as was done previously. The residual levy portion for 2013/14 remains at $77.07 per vehicle, as this is the rate required to collect the remaining residual amount by 2019 Current levy portion The table below shows the comparison between the current average Motor Vehicle levy and the 2013/14 proposed average Motor Vehicle levy. The current levy of $ was calculated last year, however, the breakdown as shown below was reassessed this year when determining the calculation for the 2013/14 proposed levy: The breakdown is described in more detail below. This illustrates that increased levies to fund and manage new claims is offset by a lower funding adjustment. To fund the cost of new claims during the levy year Current 2012/13 (per vehicle) Proposed 2013/14(per vehicle) % change (current to proposed) $ $ % To fund Scheme costs $15.19 $ % Funding adjustment $ $ % The Motorcycle Safety Levy $1.10 $1.10 0% Average current year levy $ $ No change
10 Page 9 Cost of new claims The table below shows the estimated costs of the 2013/14 claims compared with those of 2012/13 and the impact on the average Motor Vehicle levy: Current 2012/12 Proposed 2013/14 % change (current to proposed) A. Expected number of full-year equivalent vehicles 1 3,159,446 3,205, % B. Entitlement claim frequency (the number of entitlement claims per 100 vehicles) 0.19% 0.19% 0.0% C. Expected number of entitlement claims (A x B) 6,044 6, % D. Average lifetime claim cost discounted to the beginning of the levy year (how much ACC has to collect now to pay for the lifetime cost of an injury) E. Estimated cost of claims discounted to the beginning of the year (C x D) F. Levy rate per vehicle to fund the cost of claims (E / A) $60,764 $62, % $367.27m $385.35m 4.9% $ $ % The increased costs have been partially offset by an expected increase in vehicles licensed for the full year. The difference, which increases the levy, is due to the increases in cost of treatment and rehabilitation being greater than the expected increase in vehicles numbers. Also refer to the Recent performance section below for further details on changes to key claim cost drivers in recent years. Scheme costs Scheme costs Current 2012/13 Proposed 2013/14 Levy collection costs $1.3 m $1.4 m Injury prevention costs $7.5 m $7.8 m Operating costs $39.2 m $41.3 m H. Estimated Scheme costs $48.0 m $50.5m I. Number of full-year equivalent licensed vehicles 3,159,446 3,205,523 J. Average claims levy to fund Scheme costs (= H / I) $15.19 $15.76 The largest component of the Scheme Costs is the cost of managing claims (included in operating costs ). This is expected to increase each year due to more claims arising because of a higher number of registered vehicles, and with wage inflation. The increase in cost per vehicle is small as this is partly offset by the increase in the number of registered vehicles. Funding adjustment A funding adjustment is included in levy assessments to allow for any shortfall or surplus in the full funding requirements to meet the estimated ongoing costs of injuries from prior levy years. The proposed funding adjustment in the 2013/14 levy assessment is reduced slightly to offset the increased funding requirements for new claims and the management of these claims. 1 A full-year equivalent vehicle is a vehicle licensed for the full year. Vehicles licensed for part of the year are counted as equivalent fractions. So if a vehicle is licensed for six months, it s counted as a 0.5 full-year equivalent vehicle.
11 Page 10 Recent performance This table shows the difference between the initial 2012/13 levy assessment when the levy was calculated in June 2011 and the current assessment with nine months actual experience. This illustrates that the anticipated cost to fund new claims and the cost to fund the Motor Vehicle Account were both over-estimated. The difference is reflected through the funding adjustment. This means an additional $11.66 of the $ current portion of the average Motor Vehicle levy is invested to achieve full funding earlier. To fund the cost of new claims during the new accident year Initial 2012/13 assessment (per vehicle) Current 2012/13 assessment (per vehicle) Change (initial to current) $ $ $5.69 To fund Scheme costs $21.16 $ $5.97 Funding adjustment $ $ $11.66 The Motorcycle Safety Levy $1.10 $1.10 No change Average current claims $ $ No change Claim costs are essentially the product of the following equation: = (claim numbers) x (average cost of entitlements & rehabilitation) x (claim duration) The following graphs show the recent performance in each of these variables that have enabled ACC to maintain the proposed 2013/14 levy at the same overall level as 2012/13. Claim frequency has remained at the same level as in last year s projection; most of the improvement has come from lower average claim cost (i.e. claim severity). Claim frequency 2.50 Motor Vehicle Account Estimated entitlement claim frequency Frequency per 1,000 motor vehicles Accident Year Ending 30 June This year's estimate Last year's estimate
12 Page 11 Claim severity or average claim cost 400,000 Motor Vehicle Account Estimated entitlement claim severity Average Claim Size (Undiscounted) 350, , , , , ,000 50, Accident Year Ending 30 June This year's estimate Last year's estimate The projected average claim cost is lower than expected last year, driven by both improved rehabilitation service provision and case management. This continued improvement to date has now been incorporated into the ongoing levy assessments. The claim duration can also be illustrated by the following graphs of the 12-month rehabilitation rate and numbers of claims being managed that are more than 12 months in duration. 12-month rehabilitation rate The rehabilitation rate measures the percentage of injured people who have been successfully rehabilitated after 12 months from the date of injury. A higher percentage means more people are rehabilitated earlier. 100% Motor Vehicle Account 12-month rehabilitation rate 98% Claimants rehabilitated after 12 months 96% 94% 92% 90% 88% 86% 84% 82% 80% Year ending 30 June
13 Page 12 Long-term weekly compensation claims 3,400 Motor Vehicle Account Long-term weekly compensation claims 3,200 Number of long-term weekly compensation claims 3,000 2,800 2,600 2,400 2,200 2, Year ending June 30 The number of long-term weekly compensation claims (i.e. more than 12 months duration) has reduced in recent years.
14 Page 13 Collecting motor vehicle levies Vehicle classes ACC does not charge a standard or flat levy for each vehicle on the road because we believe it is fairer to ensure the groups of vehicles that contribute a greater risk of injury are contributing a larger share of the total levy ACC needs to collect to pay for injuries that occur in road crashes. ACC sets the Motor Vehicle levies according to classes of vehicle. The existing risk-based vehicle classes have been developed over time based on the information ACC has available and the information on the Motor Vehicle Register. There are nine different classes set in legislation, covering every type of vehicle on the road from everyday motorcars to vintage vehicles, caravans, tractors, motorcycles, ambulances, fire engines, trucks, trailers and more. Each year ACC reviews the relative amount each class should contribute to fund the cost of injuries that occur in road crashes. Most vehicle classes have maintained their expected relative levels of injuries and costs over the past year. However the Goods Service Vehicle (GSV) classification have reduced the number of injuries from crashes at a greater rate than other classes of vehicles and so ACC has lowered the level of contribution required from owners of these vehicles for the 2013/14 levy year. This does not impact the overall amount of levy that needs to be collected but will result in slight increases of contribution from other classes of vehicles. Proposal to introduce GSV sub-classes ACC is proposing to split the existing GSV classifications for Motor Vehicle Account levies by vehicle weight into the following two sub-classes: light GSVs (vehicles with a gross vehicle mass of 3,500 kg and under) heavy GSVs (vehicles with a gross vehicle mass of 3,501 kg and over) The GSV split proposal will more accurately reflect the respective ACC costs resulting in an injury from light and heavy GSVs. How are they currently classified? GSVs are defined as motor vehicles designed exclusively or principally for the carriage of goods (including animals and mail), but not including tractors.. It includes vans, utes, and trucks that are used for both personal and commercial activities. There are currently two GSV vehicle classes for levy-setting purposes - class 5 is for petrol-driven GSVs and class 9 is for non-petrol-driven GSVs.
15 Page 14 Reasons for the change In response to concerns raised by private and small business owners of utility vehicles and vans to the levy increase in 2010, ACC has investigated the drivers of cost (or risk) in the GSV class of vehicles. As there is no definition of a truck in New Zealand law, ACC has selected the 3,500 kg weight threshold as a proxy for determining a vehicle is a truck. This approach is supported by the following: the Ministry of Transport uses this definition to differentiate trucks when reporting on the performance of the vehicle fleet the threshold aligns with existing vehicle classification factors in the Motor Vehicle Register and so will minimise the cost of implementation of the proposal The analysis showed that the cost of injuries arising from occupants of trucks (GSVs with a gross vehicle mass of 3,501 kg and over) is substantially more than those arising from occupants of lighter GSVs such as vans and utes. This means that there is a significant cross-subsidy between higher-risk trucks and lower-risk lighter GSVs such as vans and utes. The trends from claims experience over the last five years show that: the average cost of claims for trucks is 80-90% higher than vans or utes claims experience is volatile but there are indications that there has been a greater improvement in claim numbers and costs for GSVs compared to other vehicle classes trucks with a gross vehicle mass of 3,501 kg and over account for 3% of the total registered vehicles but contribute to 15-20% of total costs in the Motor Vehicle Account per year. What the new classification will look like To resolve these issues, ACC proposes that two sub-classes of GSVs be created within classes 5 and 9 to group like vehicles together to better reflect the actual risk and to reduce cross-subsidies. These are shown below. Proposed changes to total levy rate (includes licence and petrol levies): Current class 2012/13 total levy Petrol-powered vehicles 5 Goods service vehicles $ Non-petrol-powered vehicles 9 Goods service vehicles $ Proposed class 2013/14 5L GSVs with a gross vehicle mass 3,500 kg and under 5H GSVs with a gross vehicle mass of 3,501 kg and over 9L GSVs with a gross vehicle mass 3,500 kg and under 9H GSVs with a gross vehicle mass of 3,501 kg and over Indicative total levy 2013/14 $ $ $ $643.18
16 Page 15 Proposed changes to licence fees (the amount you pay each year for the vehicle s registration ): Current class 2012/13 licence levy Petrol-powered vehicles 5 Goods service vehicles $ Non-petrol-powered vehicles 9 Goods service vehicles $ Proposed class 2013/14 5L GSVs with a gross vehicle mass 3,500 kg and under 5H GSVs with a gross vehicle mass of 3,501 kg and over 9L GSVs with a gross vehicle mass 3,500 kg and under 9H GSVs with a gross vehicle mass of 3,501 kg and over Indicative licence levy 2013/14 $ $ $ $ There are approximately 452,000 vehicles in the GSV class. Implementation of the proposal would result in: levy reductions for about 341,000 light GSVs. a significant proportion of these light vehicles are used for private purposes or used by small businesses levy increases for 111,000 heavy, mainly non-petrol, GSVs ACC has used information from the Road Transport Forum to assess the impact of the proposed changes on a median sized road transport fleet consisting of three trucks. The increase in heavy GSV levies adds less than 0.1% to the annual operating cost of 3-truck business, as shown in the table below: Estimated 2012 Operating Costs ($) Additional ACC levy ($) New Operating Cost ($) Wages and salaries 203, ,865 Fuel 110, ,428 Ownership costs 84,944 84,944 Road User Charges (RUC) 76,462 76,462 Maintenance 67,955 67,955 Tyres 16,958 16,958 Insurance 16,989 16,989 Other Costs 220, ,044 Total 798, ,983
17 Page 16 Introducing a Fleet Safety Incentive Programme Road crashes involving trucks represent a significant cost to ACC each year. ACC figures show that the cost of injuries from truck-involved crashes equate to about $60 million to $80 million, which is 15-20% of the total costs of the Motor Vehicle Account per year. The New Zealand Transport Agency s (NZTA) Crash Analysis System (CAS) data shows that for every truck-involved crash, an average of 2.4 other motorists are either injured or killed in the same crash. ACC proposes to introduce a Fleet Safety Incentive Programme (FSIP) from 1 July The programme is voluntary and seeks to support operators of heavy vehicle fleets to move from compliance with regulations to implementing best practice fleet management. The FSIP will be audit based and provide fleet owners and ACC with an objective assessment of the safety practices within the fleet. Fleets that meet the audit standards will benefit from lower ACC levy charges when the vehicles are licensed each year. As a fleet attains higher levels of assessed safety practices the annual levy charged by ACC will further reduce. This will provide a more accurate representation of the respective ACC levy rates that heavy GSVs should pay based on the relativity of risk that they represent on New Zealand roads. The programme focuses on fleet practices that improve road safety, reduce workplace injuries and improve fuel efficiency. Fuel efficiency is included because of the strong evidence-based links between safe driving and fuel efficient driving. Both behaviours require drivers to observe and anticipate the situations ahead, manage speeds, and maintain their vehicles in good condition. The type of fleet management practices required to improve safety, injury prevention, and fuel efficiency are essentially the same. Fleets who have implemented fuel efficiency measures in New Zealand have typically saved between 10% and 18% of their fuel bills and have reported 50% reductions in incidents 2. A 10% fuel saving typically results in an increase in fleet profit of up to 30% because profit margins are small and fuel is a relative large expense. Similar schemes in other countries have shown decreases in crashes, improved productivity and significant savings beyond the insurance costs to the fleets involved in the programme. The FSIP is modelled on the ACC Workplace Safety Management Practices (WSMP) programme that encourages employers to create and maintain safer workplaces and recognises/rewards employers who have established health and safety systems and good practices in injury prevention. The FSIP is tailored for heavy vehicle fleet management. It includes workplace injuries, road safety and fuel efficiency. Each fleet will be audited on site at least once every three years, with telephone-based audits undertaken in the years when an on-site audit is not carried out. In addition, ACC will be monitoring crash, injury and infringement data associated with the fleet to ensure ongoing improvements in safety are being made. Demonstration of good safety management systems and improvements in safety outcomes are required to maintain membership in the programme. Levy classification and rate changes to support FSIP ACC proposes to introduce the following four heavy GSV sub-classes. Class code 5Ha or 9Ha 5Hb or 9Hb 5Hc or 9Hc 5Hd or 9Hd Description Heavy GSVs not in the Fleet Safety Inventive Programme (FSIP) Heavy GSVs with a silver FSIP audit rating Heavy GSVs with a gold FSIP audit rating Heavy GSVs with a platinum FSIP audit rating 2 Baas P.H., Fleet Management Commitment to Fuel Efficiency, NZTA Research Report 482, 2012.
18 Page 17 The following sub-class relativities would apply: Class code Sub-class relativity (compared to the aggregate heavy vehicle levy) Total levy without proposed GSV split Total levy with proposed GSV split 5Ha and 9Ha 104% $ $ Hb and 9Hb 93% $ $ Hc and 9Hc 78% $ $ Hd and 9Hd 62% $ $ For fuller details about the FSIP, including the audit standards, refer to the supplementary document Additional Information about the Motor Vehicle Account. This is available at The petrol levy Owners and users of petrol-driven vehicles pay their Motor Vehicle levy when they license their vehicles and when they purchase petrol. The current petrol levy is 9.90 cents per litre. ACC is proposing there be no change to the petrol levy. Motorcycle Safety Levy The Motorcycle Safety Levy (MSL) funds initiatives aimed specifically at motorcycle, scooter and moped riders, to reduce the number and severity of injuries and fatalities on New Zealand s roads. The current annual levy is $30. ACC is proposing there be no change to the Motorcycle Safety Levy. An advisory council ensures that proposals to use the levy meet ACC legislative requirements and will have a positive impact on motorcycle, scooter and moped safety. For more information on the advisory council and how you can contribute ideas toward developing safety initiatives for motorcyclists visit the advisory council s website at Removing the trade plate exemption It is proposed to remove the trade plate exemption from Motor Vehicle levies for dealers of agricultural vehicles, heavy motor vehicles, caravans and boat trailers. This exemption was introduced because the Motor Vehicle Sales Act 2003 unintentionally removed the eligibility of these dealers in using trade plates to transport unregistered vehicles. Under the Land Transport (Trade Plates) Notice 2011 these dealers are once again eligible and required to use trade plates. It is more appropriate to remove the exemption for these dealers so that they pay for their share of road injury costs every time they renew their trade plate licence. What do you think? ACC are interested in your thoughts on the proposed changes covered in this document. The ways that you can send us your comments are listed on page two of this document.