* "It can affect handling, braking and safety features such as electronic stability control."
A correct statement, but the assumption that the effect is automatically negative is remarkably naiive, as is the assumption that vehicles where these are negatively affected will be legal.
Many older vehicles that are lowered are done so as part of modernising the suspension and improving the vehicle dynamics including handling and braking. Such vehicles usually have their other safety features improved at the same time, such as by fitting seatbelts, a collapsible steering column, windscreen washers and demister and improved windscreen wipers. Encouraging such vehicles to continue to be driven without these modifications would be to discourage safety improvements.
Modern safety features already limit the extent of modifications that can be carried out on vehicles. For example, because the dynamics of how the front of a vehicle collapses in a crash are critical to the operation of SRS airbags, 4WD vehicles that are equipped with SRS airbags cannot be fitted with a body lift, (spacing the body up on the chassis) unless it is possible to prove that the SRS system will not be adversely affected by the body lift. To date, I have never seen such proof for any vehicle model, and body lifts are not legally fitted to any SRS airbag equipped vehicle that I know of.
For vehicles where Electronic Stability Control is fitted, a similar situation applies, with alterations in suspension height and tyre diameter being restricted. As I understand it, aftermarket companies in the USA now offer "piggyback" computers to re-tune the ESC system to compensate for suspension height and tyre diameter changes. Aftermarket companies in Australia already offer re-tuning kits for ESC on several models of car. This needs to be addressed specifically for ESC equipped vehicles rather than trying to apply a rule relating to ESC to vehicles that are not fitted with it. When there is an Australian Design Rule that mandates the performance of ESC, such recalibration will be mandatory for continued ADR compliance.
* "Raising a vehicle's suspension can also reduce the driver's ability to see pedestrians and cyclists, and higher headlights can startle other road users,"
Is the minister allowing Harold Scruby to write his speeches for him?
Raising a vehicle within the limits of safe and predictable handling and within the ADR prescribed limits for light heights, including the ADR prescribed legal maximum height for headlights effectively limits any adverse reduction in vision of pedestrians and cyclists close to the vehicle while improving vision of people and objects further away.
For vehicles 1994 and newer, ADR 8/01 also prescribes a Primary Vision Area, and legal raising of such vehicles is limited by the ability to maintain compliance with that requirement.
An ADR compliant headlight installed at a height within the prescribed limits of the ADRs and adjusted in accordance with those rules is legal in NSW according to the Road Transport (Vehicle Registration) Regulation 2007.
Again, the minister appears to be confusing illegally modified vehicles with legally modified vehicles.
If the minister is genuinely concerned about vehicle lights startling other drivers, it would be far more productive for him to act upon the continued widespread illegal use of front and rear fog lights and the failure of the checking of headlight aim during registration inspections. It is over a decade since an RTA IVR told my then employer to "at least wipe the dust off the top" of his headlight aim testing machine "so that it looks like it has been used". Judging by the number of vehicles driving around with obviously misaimed headlights today, this problem appears to remain widespread.
* "Mr Daley said any vehicle being raised or lowered would require certification stating the modifications conform to safety standard requirements."
This proposal means that many vehicles that presently wouldn't require certification will require certification in the future. Leaving aside the issue of how it is determined whether a vehicle was raised before or after the implementation of these new rules, there are the connected issues of the fact that many new vehicles are raised within this range by rural new vehicle dealers before delivery, and the availability and distribution of engineering signatories across the state. Quite simply, the economic implications of requiring certification of these vehicles are staggering and the limited availability of signatory engineers makes it virtually impossible to implement.
* "The changes also mean any modifications must meet specific requirements such as the vehicle having at least 10 centimetres ground clearance."
This is a misrepresentation of the current situation. Regardless of whether a vehicle is certified or not, the 10cm minimum ground clearance requirement is already an enforceable requirement within Schedule 2 of the Road Transport (Vehicle Registration) Regulation 2007. It is not a new requirement. I also understand that regulations governing licensed vehicle repairers makes it an offence for them to modify a registrable vehicle such that it does not comply with the ADRs or state regulations. Again, the minister appears unfamiliar with the existing legislation and appears to be confusing illegally modified vehicles with legally modified vehicles.
* "Vehicles raised above the 5 centimetre limit will only be granted conditional registration for use under specified conditions like competing in an off road competition."
This assumes that vehicles raised by more than 5cm are not "daily use" vehicles. That is an assumption that many people in rural NSW would dispute. During the debate about banning bullbars in urban areas a few years ago, one farmer who had to travel to Sydney on a regular basis to take his then pregnant wife to see a specialist asked whether this would mean that he would have to unbolt the bullbar from his vehicle and chain it to a post on the side of the Great Western Highway on every trip. Conditional registration that limits the use of raised vehicles in the city, as Mr Daley's policy advisor has apparently stated as being part of the intent, would seem to imply that rural people would have to change their suspension during each trip. An obviously absurd and impossible proposition.
This also assumes that the vehicle owner is rich enough to pay to buy an additional vehicle and pay for registration and insurance on an additional vehicle. So much for the Aussie Battler.
I note that the method of implementation of this announcement is by way of a policy document issued by the RTA, and not by legislation. It is extremely worrying that the rule has not been the subject of parliamentary scrutiny and has not apparently been the subject of any consultation with any affected groups outside the RTA.
I call upon the minister to immediately order that Vehicle Inspectors Bulletin 50 be rescinded, and given that the minister appears to have displayed gross incompetence and appears to have lost the confidence of a significant portion of the voting population of NSW, I call upon the minister to resign.
Posted by Athol Mullen at 3:43 PM
