Letter to Auckland Transport: Speed Limit Reversals 2025

In the ongoing saga that is the ex-Transport Minister’s Speed Rule, it appears that Auckland Transport is offering to raise speeds on roads that they don’t legally have to raise them on. In response, All Aboard, Bike Auckland, Brake, and Living Streets Aotearoa have sent the below letter to Auckland Transport CEO Dean Kimpton to raise concerns about Auckland Transport’s proposed approach to implementing the Rule, and to encourage Auckland Transport to take a more proactive approach to defending its (award winning) safe speeds programme. Brake, Movement and Greater Auckland were all denied the right to speak about these serious concerns to the Council at the most recent Transport, Resilience and Infrastructure Committee Meeting.

You can see which streets Auckland Transport has offered to raise speeds for in response to the Speed Rule on this map here. Feeling motivated (or horrified)? Check out Greater Auckland’s awesome guide for ideas for how you can help! At Bike Auckland, we also have some ideas for how we could use our ghost bikes to increase public awareness and support the retention of safe speeds – but we need more people with the capacity to make it happen! Sign up as a volunteer or contact us if you are keen to help!

Letter to Auckland Transport: Speed Limit Reversals 2025

To:

Dean Kimpton, CEO

Cc: 

Richard Leggat, AT Board Chair and AT Board members
Mayor Wayne Brown 
Cr Andy Baker, Chair Transport, Infrastructure and Resilience Committee
Houkura Members Pongarauhine Renata and Billy Brown
Local Board Chairs and Councillors 

Speed Limit Reversals 2025

1. We are writing in relation to the Land Transport Rule: Setting of Speed Limits 2024 (“the Rule”) and Auckland Transport’s assessment of the roads for which speed limit changes will be reversed
2. We represent organisations that have all worked with Auckland Transport and Auckland Council to make our roads safer and have supported the award winning world-class safe speeds programme which has resulted in fewer deaths and serious injuries.
3. The purpose of our letter is twofold:
   1. to raise concerns about Auckland Transport’s proposed approach to implementing the Rule, and in particular the incorrect inclusion of roads in Freemans Bay, Ponsonby and Manurewa; and
   2. to seek for Auckland Transport to take a more proactive approach to defending its safe speeds programme, and the safe speed limits it has implemented since 2020.

Timing of Auckland Transport’s announcement of reversals

4. As an initial comment, we note that Auckland Transport published the list of reversals on 28 February 2025.  Consultation on the draft speed rule began on 11 June 2024 and the Rule itself was made on 28 September 2024.  Under the Rule, Auckland Transport is required to reverse speed limits by 1 May 2025.
5. The significant delay in making public Auckland Transport’s assessment of the reversals has regrettably left only a limited window for stakeholders to raise issues with the approach that Auckland Transport is proposing to take.

Errors in Auckland Transport’s assessments

6. We recognise that Auckland Transport is required to comply with the Rule (despite the obvious harm that will cause) while it remains in force, including:
   1. the requirement in rule 11.2 for amended speed limits for “specified roads” to be reversed before 1 May 2025 (unless the exception in clause 11.4(1) applies); and
   2. the requirement in rule 11.3 to set a variable speed limit of 30 km/h outside school gates during “school travel periods” (as defined).
7. “Specified roads” are defined in rule 11.1.  A local (residential or neighbourhood) street is a specified road if a permanent speed limit was set for it on or after 1 January 2020, and the reason or one of the reasons for setting that speed limit was because there is a school in the area.
8. We have reviewed Auckland Transport’s proposed reversals for local streets, and compared them to the reasons Auckland Transport gave for each local street at the time the permanent 30 km/h speed limits were proposed and set.  For at least three suburbs, Freemans Bay, Ponsonby and Manurewa, it is clear that Auckland Transport is proposing to reverse speed limits for roads that are not “specified roads” under the Rule.  We elaborate below.
9. Since 2020, Auckland Transport has delivered three phases of speed limit changes.  The issue we are raising concerns phases two and three.  Prior to and at the time of the phase two and three speed limit changes, Auckland Transport was clear, both in its internal documents and in its public-facing communications, about the reasons for speed limit changes on each road (or cluster of roads).
10. For phase two speed limit changes:
    1. Papers presented to the board identified that each proposed speed limit change fell into one (and only one) of the following categories: “high risk rural roads”, “town centres”, “residential areas”, “complementary and customer request roads”, “marae” and “schools”.
    2. Assessments of individual streets were included in the board packs, and identified the specific reason for individual speed limit changes.  Roads where speed limits were being changed because of the presence of schools in the area were assessed separately.
    3. Auckland Transport’s map for public consultation identified the specific (and only) reason for the proposed speed limit reduction on each street.
11. Again, for phase three speed limit changes:
    1. Papers presented to the board identified that each proposed speed limit change fell into one (and only one) of the following categories: “high risk rural roads and Waiheke Island”, “town centres”, “residential areas”, “complementary and customer request roads”, “marae” and “schools”.
    2. Assessments of individual streets were included in the board packs, and identified the specific reason for individual speed limit changes.
    3. Auckland Transport’s consultation page made clear that the “Manurewa Coxhead Quarter” was included in the “residential roads” category, not the “schools” category.
12. You will see from these documents that for many streets in Freemans Bay, Ponsonby and Manurewa, the fact that a school was in the area was not given as a reason (either internally or externally) for the speed limit reduction.  Rather, most or all reductions in those areas were because they were “residential areas” or “customer requests”.
13. We anticipate you may seek to suggest that (i) there are schools in those residential areas, and it was implicit that the presence of the schools was a reason for the reductions, and/or (ii) Auckland Transport published maps of the speed limit reductions that showed local schools.
14. Neither of those points justifies Auckland Transport reversing all speed limit changes in Freemans Bay, Ponsonby and Manurewa.  To repeat, Auckland Transport’s own internal and external documents were clear about the reasons for the changes in question, which in many cases did not include the presence of a school.  The Rule only requires reversals where a reason for the change was that there is a school in the area.
15. We note that Auckland Transport has taken the correct approach of not reversing speed limits for other local streets where there are schools in the area, but speed limits were changed for other reasons.  For instance, speed limits are not being reversed on Waiheke Island (despite Auckland Transport’s communications at the time noting that speeds would be dropped outside schools), or in Devonport and Takapuna town centres (where Auckland Transport published maps showing the speed limit changes as part of clusters that included schools).
16. There is no basis for Auckland Transport to take a different approach for residential streets in Freemans Bay, Ponsonby and Manurewa, where the speed limit changes were expressed to be for reasons other than schools being in the area.
17. It is important to be clear that taking an overly wide approach to the application of the Rule is not a one way bet for Auckland Transport:
    1. First, these are speed limits that Auckland Transport’s own subject matter experts have identified as the safe and appropriate ones.  We do not consider that Auckland Transport could responsibly and lawfully increase speed limits where that is not required by the Rule, and in circumstances where Auckland Transport knows that the outcome of the reversals will be an increased risk of deaths and injuries.
    2. Secondly, as Auckland Transport correctly identified in its consultation plan at the time the safe speeds were implemented, it has consultation obligations, including under the Local Government Act 2002 and the Land Transport Act 1988, that mean it cannot unilaterally impose new, unsafe speed limits on the public without proper consultation.  If Auckland Transport were to proceed with speed limit changes that are not mandated by the Rule without first conducting a proper consultation process, it would again be acting unlawfully.

Auckland Transport’s failure to defend safe speeds

18. More generally, we are concerned that Auckland Transport has failed to defend its safe speeds programme, and the safe speed limits it has implemented since 2020, in the face of the Government’s efforts to impose higher, unsafe speeds on Auckland.
19. Auckland Transport’s statutory purpose is to contribute to an effective, efficient and safe Auckland land transport system.  Auckland Transport:
    1. has collected data and evidence showing that speed limit changes 2020 have reduced deaths and serious injuries in the areas where they have been implemented;
    2. has knowledge and expertise regarding the social and economic harm that will result from the Rule; and
    3. is in a position to point out to the Government the perverse outcomes that will result from the Rule (which include, for example, the imposition of mandatory variable speed limits outside school, even where the surrounding streets will retain permanent speed limits of less than 50km/h).
20. Auckland Transport can and should be making the Government aware of these issues, and seeking for the Rule to be amended to allow lower permanent speed limits to be retained and/or to require consultation before any speed limits are increased.
21. We also ask that Auckland Transport considers participating in the application for judicial review that Movement has brought against the Minister for Transport in respect of the decision to make the Rule.  We understand that Movement intends to seek interim relief from the High Court so that speed limits are not required to be changed by 1 May 2025.  Auckland Transport could, and in our view should, support a delay to the implementation of the Rule so that the substantive issues in that case can be resolved by the Court before any changes are required to be made on the ground.
22. Delaying implementation of the Rule would also allow time for Auckland Transport and other road controlling authorities to engage with the Government about how the worst impacts of the Rule can be mitigated.

Next steps

23. We want to be clear about our intention is to ensure that the speed limit changes Auckland Transport makes in response to the Rule go no wider than the Rule requires.  
24. Given the relatively short time until the new speed limits must be notified to NZTA (which has resulted in large part from Auckland Transport’s delay in publishing its assessments), we ask for your response within five working days.
25. In the meantime, we will be providing this letter to relevant members of the governing body and local boards and Houkura, so they are aware of these issues.
26. We look forward to hearing from you.

Nicholas Lee, Chair, All Aboard 

Caroline Perry, NZ Director, Brake

Karen Hormann, Chair, Bike Auckland

Tim Jones, President, Living Streets Aotearoa