Request for evidential basis, speed enforcement, safety cameras, roadside drug testing, medical-event causation, and public financial harm

Dear Sir/Madam,

Formal request for evidential basis, proof of claim, and accountability pathway — speed enforcement, safety cameras, roadside drug testing, medical-event causation, and public financial harm

Date: 9 June 2026

I write on behalf of InLandsAirWater Counsel.

This letter is a formal request for NZTA’s evidential basis, proof of claim, and accountability pathway in relation to current and proposed road-safety enforcement measures, including speed-limit settings, safety cameras, increased speed enforcement, roadside drug testing, infringement consequences, and related transport-safety initiatives.

This is not a refusal to obey road rules. It is a formal accountability request concerning the legal, scientific, financial, and evidential basis for enforcement measures being applied to the public.

1. Science Council review

InLandsAirWater Counsel has referred these issues to its Science Council for independent consideration.

The concern is that current road-safety policy and enforcement appear to focus heavily on speed, driver behaviour, alcohol, and drugs, while other plausible contributors to driver performance and crash risk may not have been adequately investigated.

Those possible contributors include sudden medical events, cardiovascular events, neurological events, fatigue, cognitive impairment, prescription-medication effects, illness-related impairment, reaction-time changes, sensory changes, and other health-related factors affecting driver competence, confidence, attention, and situational awareness.

Please confirm whether NZTA has investigated, commissioned, received, or relied on any records since 2020 addressing whether broader population-health changes, medical events while driving, neurological events, cardiovascular events, blackouts, fainting, fatigue, medication effects, cognitive impairment, or other non-drug/non-alcohol health factors have contributed to road crashes, injuries, or fatalities.

1. Safety claim and proof of causation

NZTA and related agencies appear to rely heavily on “safety” as the justification for speed enforcement, speed-limit reductions, safety-camera deployment, and roadside drug testing.

Please provide the records showing how NZTA distinguishes between crashes caused or materially contributed to by:

1. excessive speed;
2. ordinary speed-limit breaches;
3. alcohol impairment;
4. illicit drug impairment;
5. prescription-medicine effects;
6. fatigue;
7. distraction;
8. sudden medical events;
9. cardiovascular events;
10. neurological events;
11. cognitive impairment;
12. road design;
13. poor signage or confusing variable-speed environments;
14. road maintenance issues;
15. weather or visibility;
16. vehicle condition;
17. enforcement design or delayed camera-based enforcement.

Please provide the evidence showing that recent enforcement measures are directed at proven causes of harm, rather than assumed causes of harm.

1. Medical events while driving

Please provide all final, formal, relied-upon, or decision-maker records from 1 January 2020 to the present showing:

1. the number of crashes attributed to medical events while driving;
2. whether medical-event crashes have increased or decreased since 2020;
3. whether cardiac, stroke, neurological, blackout, seizure, fainting, fatigue, or sudden-collapse events are separately coded;
4. whether medical events are excluded from, included in, or separately reported in road-death and road-injury statistics;
5. whether any analysis has been undertaken comparing pre-2020 and post-2020 crash causation;
6. whether NZTA has considered whether road-safety outcomes may be affected by broader changes in population health.

If NZTA does not hold this information, please transfer this part of the request to the Ministry of Transport, Ministry of Health, Health New Zealand, Police, Ministry of Justice, Statistics New Zealand, or any other agency that holds it or whose functions are more closely connected with it.

1. Roadside drug testing and scientific validation

Please provide all final, formal, relied-upon, or decision-maker records concerning roadside oral-fluid drug testing, including:

1. the scientific validation of the testing devices;
2. false-positive and false-negative rates;
3. the effect of prescription medicines;
4. the effect of legally prescribed or medically necessary substances;
5. the relationship between a positive oral-fluid result and actual impairment at the time of driving;
6. laboratory confirmation procedures;
7. chain-of-custody procedures;
8. officer training;
9. calibration and maintenance records;
10. complaint, review, cancellation, and error-correction data;
11. the process for a driver to challenge a result;
12. the consequences for a driver before final proof is established.

Please also confirm whether NZTA accepts that a positive test result does not automatically prove that a driver was unsafe, impaired, or causally responsible for any road-safety risk.

1. Compulsion, proportionality, and procedural fairness

Roadside drug testing is presented as compulsory, with serious consequences for refusal or non-compliance, including fines, demerit points, and driving prohibition.

Please provide the legal and policy records showing how NZTA, Police, and the Ministry of Transport satisfied themselves that compulsory roadside drug testing is:

1. lawful;
2. reasonable;
3. proportionate;
4. scientifically reliable;
5. procedurally fair;
6. not arbitrary;
7. not punitive before proof;
8. not financially incentivised;
9. compatible with rights protections;
10. subject to proper correction, appeal, and compensation mechanisms where error occurs.

Please identify the accountability pathway for a person who suffers financial loss, loss of licence, vehicle seizure, employment harm, reputational harm, insurance harm, court consequences, or other loss because of an incorrect or unsupported roadside drug-testing or safety-camera enforcement action.

1. Speed enforcement and delayed camera enforcement

Please provide records showing whether NZTA has assessed the difference between:

1. live roadside intervention that stops immediate unsafe driving; and
2. delayed camera-based infringement issued after the event, where no immediate intervention occurs.

Please provide any records proving that delayed camera enforcement prevents harm, rather than primarily creating after-the-fact infringement liability, debt, demerit points, fear, and compliance pressure.

Please also provide records showing whether warning-first systems, education, better signage, road engineering, maintenance, hazard removal, intersection redesign, or live targeted enforcement were considered before increased camera-based enforcement.

1. Revenue, financial gain, and public financial harm

Please provide all records from 1 January 2020 to the present showing:

1. total safety-camera revenue by year;
2. total speeding-infringement revenue by year;
3. total drug-driving infringement revenue by year;
4. projected infringement revenue;
5. actual revenue before and after speed-limit changes;
6. whether lower speed limits are expected to increase technical breaches;
7. where the money is paid;
8. which agency accounts for it;
9. whether it enters the Crown consolidated fund;
10. who forecasts it;
11. who audits it;
12. who reports it;
13. who benefits directly or indirectly from it;
14. whether any contractor, vendor, consultant, or technology provider is paid by reference to camera hours, camera numbers, event volume, processed notices, infringement volume, collection outcomes, uptime, or enforcement outputs.

If NZTA’s position is that revenue generation is not a purpose or factor, please provide the documents showing that revenue generation was expressly considered and ruled out as a purpose, factor, incentive, expected benefit, or foreseeable consequence.

1. Financial harm to the public

Please provide the records showing whether NZTA has assessed public financial harm arising from speed enforcement, safety-camera enforcement, roadside drug testing, fines, demerit points, licence suspension, vehicle seizure, court enforcement, debt collection, insurance consequences, employment loss, and family hardship.

Please confirm whether “harm” in NZTA’s road-safety analysis includes only injury and death, or whether it also includes financial harm, enforcement harm, debt harm, licence-loss harm, small-business harm, rural-driver harm, tourism harm, freight harm, and loss of public confidence.

If financial harm is excluded, please provide the legal, policy, Cabinet, or economic basis for excluding it.

1. Variable-speed and fair-notice environments

Please provide all records concerning Queenstown, Queenstown Lakes District, and other variable-speed or high-tourism environments where speed limits may change repeatedly over short distances.

Please provide records showing:

1. whether signage is clear, fair, visible, and consistent;
2. whether road users are given reasonable notice of changes;
3. whether tourists, rural drivers, tradespeople, delivery drivers, and unfamiliar drivers have been considered;
4. whether confusing or repeated changes in speed limit contribute to technical breaches;
5. whether enforcement is placed in areas where confusion is foreseeable;
6. whether NZTA has assessed whether such enforcement is genuinely safety-based or primarily punitive.
7. Proof of claim

For clarity, this letter asks NZTA to provide the proof of claim for the enforcement framework being applied to the public.

The proof of claim includes:

1. the legal authority relied on;
2. the evidential basis for the safety claim;
3. the scientific basis for drug-testing reliability;
4. the causal analysis separating speed, drugs, medication, medical events, road design, signage, and other factors;
5. the financial analysis of public harm;
6. the revenue analysis and Crown financial benefit;
7. the contractor and vendor incentive analysis;
8. the post-implementation proof that the measures reduce actual harm;
9. the correction and compensation pathway where enforcement is wrong.
10. Accountability and reservation of rights

Public decision-makers are expected to act lawfully, reasonably, proportionately, and on a proper evidential basis. Where enforcement causes financial loss, licence loss, vehicle loss, employment harm, reputational harm, or court consequences without proper proof, affected individuals may have rights to challenge, seek review, seek correction, seek compensation, or pursue other lawful remedies.

This letter is not intended as a threat. It is a formal notice that InLandsAirWater Counsel considers these matters serious and unresolved.

If NZTA, Police, Ministers, contractors, or other public decision-makers continue to rely on “safety” while failing to disclose the evidential, scientific, financial, and accountability basis for the measures being imposed, this correspondence may be relied upon in later complaints, Ombudsman processes, court proceedings, infringement challenges, disclosure requests, public-accountability processes, or claims by affected persons.

1. Transfer and refusal

If NZTA does not hold any part of the requested information, please transfer that part to the agency that holds it or whose functions are more closely connected with it.

If any part is refused, please identify:

1. the specific statutory ground relied on;
2. the reasons supporting that ground;
3. whether transfer was considered;
4. why transfer was not made;
5. the public-interest factors considered.

Please do not respond only by stating that safety-camera revenue is not retained by NZTA. If the money goes to the Crown consolidated fund, the question remains: who forecasts it, accounts for it, audits it, benefits from it, and considered it when designing or implementing enforcement policy?

Yours faithfully,

Tracy Lynch
InLandsAirWater Counsel
PO Box 265
Queenstown

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