Amanda Stoker (Queensland, Liberal Party, Assistant Minister to the Attorney-General) Share this | Link to this | Hansard source

I present the government's response to the report of the Joint Select Committee on Road Safety and seek leave to have the document incorporated in Hansard.

Leave granted.

The document read as follows—

Australian Government response to the Joint Select Committee on Road Safety report: Improving Road Safety in Australia

AUGUST 2021

Introduction

This is the Australian Government (the Government) Response to the Joint Select Committee's (the Committee) report on Road Safety — Improving Road Safety in Australia.

On 31 July 2020 the Committee released its interim report, noting that due to the COVID-19 pandemic, further time was required to consider evidence gathered during hearings and from submissions. The Final Report was published on 30 October 2020 and contains 22 recommendations to improve road safety.

The Government has a responsibility, collectively with state and territory governments, for the strategic direction and implementation of national road safety policy and actions. The Government has a guiding and influencing role in road safety and established the Office of Road Safety (ORS) in July 2019, with the aim of improving coordination and leadership across all levels of government. While many of the levers for road safety are controlled by the states and territories, the Government is responsible for developing the National Road Safety Strategy with all states and territories and supporting its implementation; funding infrastructure investment aimed at delivering road safety outcomes; and regulating first imports of vehicles into the country. The National Road Safety Strategy 2021-30 (Strategy) and its Action Plan for 2021-2025 are expected to be released in the coming months, subject to jurisdictional approval processes.

State and territory Ministers agreed in August 2019, through the former Transport and Infrastructure Council (Council), that the new Strategy would position Australia towards a 'Vision Zero' Target, with no person being killed or seriously injured from a road crash, by 2050.

Council also agreed in order to be successful in reducing road trauma over the decade, the Strategy must reach beyond traditional transport solutions and that road safety can no longer be viewed solely as a transport issue. To achieve this, Council agreed to adopt a social model approach to extend road safety opportunities into other sectors such as health and social services, law enforcement, education, justice, planning and industry, all of which will underpin the Action Plans supporting the new Strategy. A social model approach will allow the Strategy to reach beyond the areas that have traditionally coordinated road safety outcomes and foster a shift in road safety culture across Australian society to promote road safety as everyone's responsibility.

Many of the Committee's recommendations relate to areas where implementation and delivery is primarily the responsibility of state and territory governments. Where the Government has a national coordination role in delivering road safety outcomes, these are outlined in this response.

This Government response addresses the Committee's 22 recommendations in the Final Report.

List of Recommendations

Recommendation 1

The committee supports the findings of the NRSS Inquiry Report which recommended that the Australian government commit more funding to road safety.

The Australian Government supports an increase of funding by all governments towards improving road safety, as recommended by the Inquiry into the National Road Safety Strategy 2011-20

(NRSS Inquiry). This was agreed in principle by Council in November 2019. In response the Government has since made significant funding commitments that will deliver road safety outcomes in major cities and regional and remote areas.

Improving road safety to help Australia move towards zero fatalities and serious injuries on our roads by 2050 is a top priority of the Government and a key objective of the 10-year $110 billion land transport infrastructure program. The program is providing life-saving upgrades to roads and highways, including key freight routes, and safer and more efficient heavy vehicle operations. Investment in land transport infrastructure as well as targeted road safety packages are supporting the delivery of the Government's commitment to road safety.

As part of the 2020-21 Budget the Government committed significant additional funding to improve road safety, including:

An additional $1 billion to continue road safety upgrades through the Road Safety Program in 2022­2023 was announced in the 2021-22 Budget. In addition to the Road Safety Program and Data Hub initiative, the Government funds a total of $77.7 million over four years of non-infrastructure road safety projects/programs. In June 2020, announced the $500 million Targeted Road Safety Works Program to deliver smaller but critical projects to improve road safety and bolster the resilience of local road networks in every state and territory.

Recommendation 2

The committee recommends the Australian Government work with the states and territories to develop a plan and timeline for the harmonisation of data, including definitions, relating to casualty crashes, road safety ratings, and speeding across the ne twork. Such data should be published regularly.

The Australian Government supports the harmonisation of road safety data, including developing consistent definitions and the regular publishing of data.

While consistent national data is available for road crash deaths, there is currently no national data source to report on the agreed national measure of serious injury. The Government and jurisdictions are pursuing a national project linking hospital and crash data to develop a consistent national source of serious injury data to allow measurement of progress against agreed serious injury targets in the new Strategy. To further support consistent data, the Government is investing $5.5 million over four years to establish a National Road Safety Data Hub, providing transparent monitoring and evaluation of road safety policies and investments.

Further, state and territory governments have also agreed, as part of the new National Partnership Agreement on Land Transport Infrastructure Projects (NPA), on a greater focus on data sharing between jurisdictions for project data including on-road safety. State and territory governments when seeking Commonwealth funding are expected to outline safety benefits in their project proposal reporting templates, including the average annual number of avoided crashes, number of avoided serious injuries, and number of avoided fatalities.

State and territory governments are also required to report key data to the Government as a condition of receiving funding through the $3 billion Road Safety Program.

Recommendation 3

The committee recommends that the Australian Government review its Black Spot Program funding conditions and site eligibility, with a view to making it more effective in proactively detecting and treating deficiencies i n road infrastructure.

The Australian Government notes this recommendation.

The Black Spot Program is already able to fund projects that treat road lengths in addition to 'spot' locations, and up to 30 per cent of program funds are available for investment in proactive projects where there is an assessed risk that fatal and serious crashes are likely to occur. Additionally, the Black Spot Program allows the Minister to consider proactive/Road Safety Audit proposals above the 30 per cent threshold if recommended by the Black Spot Consultative Panel in the relevant state or territory. These panels are established in each jurisdiction to review project proposals.

The Notes on Administration for Land Transport Infrastructure Projects — which guide the administration of the Infrastructure Investment Program — were amended in August 2019 to expand the types of risk assessments accepted for proactive nominations, including the Australian Road Assessment Program (AusRAP) and the Australian National Risk Assessment Model (ANRAM).

ORS will work with all governments to better communicate the proactive aspect built into the Black Spot Program to ensure a better understanding of the opportunities provided for within the Program.

In addition, the $3 billion Road Safety Program will make a significant contribution to proactively detecting and treating deficiencies in road infrastructure. State and territory governments are required to report key data to the Government as a condition of funding through the Program, which will assist in assessing road safety outcomes of the investment and identifying further areas for improvement.

Recommendation 4

The committee recommends that the Australian Government increase funding to the Black Spot Program and increase the percentage allocated to regional and remote areas.

The Australian Government supports this recommendation, and highlights the additional funding recently announced with provisions in place to increase the percentage allocated to regional and remote areas where necessary.

The Government has committed $110 billion for land transport infrastructure investment over the next ten years. In the 2019-20 Budget the Government committed $2.2 billion for the Local and State Government Road Safety Package, which provided additional funding for roads programs. This funding included an additional $50 million per year for the Black Spot Program, bringing the funding for the Program to $110 million per year. The Government's total commitment for the Black Spot Program from 2013-14 to 2024-25 is $1.2 billion.

A greater proportion of funding for regional and remote areas may be approved should such funding levels be recommended by the Black Spot Consultative Panels.

Recommendation 5

The committee recommends that the Australian Government works with states and territories and local government to ensure that all existing road safety programs are designed to implement Safe System principles across al l government policy areas, including health and education.

The Australian Government supports implementing Safe System principles through existing road safety programs in coordination with state and territory governments. This was agreed upon by Council in November 2019 in response to the NRSS Inquiry (2018) recommendations.

Council agreed to adopt a social model approach underpinning the Action Plans that will support the Strategy.

The NPA supports delivery of infrastructure projects and sets out how the different levels of government will work together to deliver infrastructure projects for the benefit and wellbeing of Australians. Well-designed land transport infrastructure, including improved transport safety, is essential for Australia's productivity and economic development to support prosperous and liveable communities. The NPA enshrines road safety as a key, shared objective of the Government and state governments. The NPA ensures new road infrastructure projects give regard to the Safe System principles, which also underpin the Strategy.

ORS was established to improve leadership and coordination across all levels of government to reduce deaths and serious injuries on the roads. Using a social model approach, ORS is engaging Australian Government portfolios beyond the areas that have traditionally coordinated road safety outcomes to become key enablers of change and advocates for road safety, facilitated through the Commonwealth Inter-Departmental Committee on Road Safety. The Committee includes representatives from the Department of the Prime Minister and Cabinet, Treasury, Department of Finance, National Indigenous Australians Agency, Department of Social Services, Australian Federal Police, Attorney General's Department, Department of Health, and the Department of Education, Skills and Employment.

The Department of Health and ORS are also working closely together in the preparation of the National Road Safety Strategy, the National Injury Prevention Strategy and other initiatives to further align targets and cross-Government work on road safety issues.

Recommendation 6

The committee recommends that the commonwealth works with states and territories to ensure that funding avenues are identified that specifically support local councils to attract and reta in the relevant skills and expertise required for development of all aspects of road safety policy, infrastructure and maintenance.

The Australian Government supports in-principle this recommendation noting there are constitutional limitations for direct funding by the Commonwealth.

As owners of an extensive road network, local governments are responsible for the road safety performance of roads under their control and authority.

The responsibility for development of all aspects of road safety policy, infrastructure and maintenance is shared by state, territory and Federal governments. State and territory governments are responsible for implementation of the Local Government Acts as well as supporting - through Austroads and other mechanisms - the delivery of training to assist in the development of road safety risk assessments and local government road safety network plans. As local governments have no status within the Australian Constitution, funding from the Government is often provided through grants such as the Local Roads and Community Infrastructure Program (LRCI) or directed through state and territory governments who often provide assistance through their road safety manager responsibilities.

Currently over 600 major Government funded road infrastructure projects are in planning, underway, or under construction, many of which will deliver road safety benefits. Work is being undertaken by all levels of government to deliver these projects.

The $500 million Targeted Road Safety Works package, announced in June 2020, is delivering smaller but critical projects to improve road safety and is bolstering the resilience of local road networks in every state and territory.

In addition, in May 2020 the Government announced the LRCI Program providing $500 million to support local councils to deliver priority local road and community infrastructure projects in the 2020-21 financial year. Through the 2020-21 Budget, the Government committed an additional $1 billion to this program for works to continue in 2021-22, and a further $1 billion to continue road safety upgrades through the Road Safety Program in 2022-2023 was announced in the 2021-22 Budget.

In 2018, the Government committed $2.55 million to the Australian Road Research Board (ARRB) to assist local governments to better understand, and deliver on, their road asset and maintenance requirements. Completed in June 2020, the funding delivered updates to three operational manuals for sealed and unsealed roads and bridge structures and a new manual focused on road base materials. The program also delivered specialised optics devices which is enabling local road managers to assess the condition of road infrastructure to enable better performance assessment and optimise maintenance activities.

In the 2019-20 budget, the Australian Government allocated $8 million over two years to the Strategic Local Government Asset Assessment Project (SLGAAP), which is administered by the National Heavy Vehicle Regulator (NVHR) on behalf of the Australian Government.

The SLGAAP assists local government road managers across Australia to undertake capacity assessments of bridges and culverts on key heavy vehicle routes to help them better understand the safe operating limits of road infrastructure.

The NHVR has so far delivered more than 230 asset assessments across twelve local governments.

Due to the successes of the pilot program, the Australian Government announced in the 2021-22 budget an additional $12.1 million over three years for SLGAAP. Strong participant interest has seen more than 90 local governments register approximately 900 assets across the nation to be assessed over the next three years.

Recommendation 7

The committee recommends the establishment of a Parliamentary Standing Committee on Road Safety.

The Australian Government supports the recommendation for the establishment of a Standing Committee by the Federal Parliament.

Recommendation 8

The committee recommends the Australian Government ensure all Commonwealth

funded road projects incorporate Network Design for Road Safety principles.

The Australian Government supports in-principle this recommendation in coordination with state and territory governments.

The NPA supports delivery of infrastructure projects and sets out how governments will work together to deliver infrastructure projects for the benefit and wellbeing of Australians. Well-designed land transport infrastructure, including improved safety across the network, is essential for Australia's productivity and economic development to support prosperous and liveable communities.

The NPA promotes road safety as a key, shared objective of the Commonwealth and state governments. The Government is committed to reducing the number of deaths and serious injuries on our roads and has put forward strengthened safety arrangements for all road funding projects in the NPA. This ensures new road infrastructure projects give regard to the Safe System principles, which also underpin the new Strategy.

Austroads guidelines provide practical advice and tools for road authorities, with the Network Design for Road Safety User Guide outlining a simple process for assessing the level of risk and forecasting the number of casualty crashes. The guidance assists road managers, planners and designers to achieve improved safety outcomes by applying consistent standards along a road corridor. This simple approach is based on the most advanced knowledge of safety metrics using the ANRAM and iRAP in the Australian context.

Recommendation 9

The committee recommends that the Australian Govern ment work with state, territory and local governments to collect accurate data on the current condition and rate of change of Australian roads.

The Australian Government supports this recommendation.

Typically, state and territory road managers collect data to track the condition of Australian roads over time as part of their asset management systems. However due to inconsistencies in data collection requirements and interpretations across the states and territories, data is far from complete or fully accurate.

The Road Safety Program announced in the 2020-21 Federal Budget requires states and territories to provide their current analysis of road safety risk and the expected change in risk rating with the application of their proposed road safety treatments.

The National Road Safety Data Hub, along with the National Freight Data Hub, will work with state and territory governments to improve the quality of data and develop a national status report of the Australian road network.

Recommendation 10

The committee recommends that the Australian Government identify priority roads for dedicated and targeted road funding partnerships with the relevant jurisdictions to improve the star rating performance of road infrastructure for all road users. The Australian Government supports this recommendation.

In response to the NRSS Inquiry, in November 2019 Council agreed to invest in road safety infrastructure, safe system and mobility partnerships across all governments that accelerate the elimination of high risk roads. The Government has commenced the $3 billion Road Safety Program as part of its ongoing commitment to improving road safety for all Australians and reducing the number of deaths and serious injuries our on roads. The Road Safety Program will see safety improvements on state highways, arterial roads and urban and pen-urban roads, through the application of various safety treatments to raise the standard of the road.

States and territories are required to submit their proposals under the program in priority order, demonstrating the safety benefits of each proposal in order to lift road safety performance.

In addition, the $500 million Targeted Road Safety Works Program is providing upgrades across states and territories to improve road safety for all road users. Projects include the rollout of rumble strips, shoulder widening and installation of safety barriers on high speed undivided roads.

Recommendation 11

The committee recommends that the Australian Government support and fund research into the effectiveness of varying road treatments in a wide range of circumstances, with a view to improving the road safety outcomes of infrastructure investment.

The Australian Government supports this recommendation, noting other levels of government also play a key role in establishing an evidence-base for road investments.

ORS will continue to collaborate with state and territory governments to prioritise research on a range of road safety topics, particularly through implementation of the new Strategy and Action Plan. Further, state and territory governments are required to report key data to the Government as a condition of funding through the $3 billion Road Safety Program, which will assist in assessing road safety outcomes of the investment.

It is also anticipated over time as the Road Safety Data Hub matures it will become a widely used resource of data sets and series for the purposes of furthering research into the effectiveness of various road safety treatments.

The Government also funds a number of road safety programs as part of its commitment to reducing the number of deaths and serious injuries on our roads. Programs such as the $12 million Road Safety Innovation Fund are designed to contribute to the reduction of road trauma in Australia by funding research into road safety issues and emerging trends.

The Government also currently supports road safety research through our participation in Austroads' taskforces, including on-road safety, road design, registration and licensing, bridges, assets, tunnels, pavements, project delivery and design and barrier safety assessment.

Recommendation 12

The committee recommends that the Australian Government establish a national consultative committee on motorcycle safety.

The Australian Government does not support this recommendation.

Robust stakeholder consultation mechanisms are in place allowing direct liaison with key stakeholders (such as the Australian Motorcycle Council) or collectively with associations representing vulnerable road users. As part of its role in improving coordination and leadership, ORS adopts a flexible and efficient approach to stakeholder engagement, allowing the Government and the transport portfolio to engage with road user groups including motorcycling groups. Avenues such as the Ministerial Roundtable for vulnerable road users held in October 2020, and attended by the Australian Motorcycle Council, allow for efficient engagement and opportunity to raise issues directly with Government.

ORS will work with key motorcycle stakeholders to establish a regular consultation process to ensure the concerns of the motorcycling community are factored into the Strategy and its accompanying Action Plans. The consultation process will cover trends in fatal and serious injuries related to motorcycle use, evidence based treatments and the countermeasures needed.

Recommendation 13

The committee recommends that the Australian Government, state and territory, and local governments review their procurement practices to ensure that the safety of vehicles is a key criterion in purchasing decisions.

The Australian Government supports the recommendation.

It is already a requirement of the Whole of Australian Government Vehicle Leasing and Fleet Management arrangement Fleet Vehicle Selection Policy that entities must select vehicles with a five star Australasian New Car Assessment Program (ANCAP) safety rating.

Local, state and territory government procurements are governed by their own policy frameworks. In August 2019, Council agreed that road safety will become a genuine part of business-as-usual across all levels of government, outlining it will be a key feature of the next Strategy. ORS will work with all government jurisdictions to review their procurement practices for their vehicle fleet to ensure safety is in-built to their processes.

Promoting the market uptake and knowledge of vehicle technologies and other safety equipment with high safety benefits, and reducing workplace trauma, is currently being considered through the Strategy and Action Plan. The Government provides $1.4 million in funding to ANCAP Safety per annum to ensure updated research is undertaken and consumer safety ratings for new vehicles are publicly available.

Recommendation 14

The committee recommends the Australian Government review current t imeframes for the mandatory introduction of safety features likely to have the greatest impact on reducing road trauma in Australia.

The Australian Government supports the recommendation to review timeframes for the mandatory introduction of safety features in vehicles.

In November 2019, Council supported the NRSS Inquiry recommendation to implement rapid deployment and accelerated uptake of proven vehicle safety technologies and innovation. It was noted that work in this area is currently underway with the Government investigating options to streamline regulatory process and embed them into the next Strategy.

The Government is committed to harmonising road vehicle standards in Australia with regulations adopted by the United Nations World Forum for the Harmonization of Vehicle Regulations (WP29). As sales of new vehicles in Australia represents less than 1% of the global vehicle market, harmonising with UN regulations provides more Australians with access to the safest vehicles at the lowest prices.

The Government supports the introduction of new regulation where the potential benefits of the regulation exceeds the associated costs. Implementing standards in Australia in advance of international standards setting is less likely to be supported by a cost/benefit analysis, as the new technology will be expensive because of its innovative nature and smaller market share.

Implementing Australian standards in harmony with international standards is the best way to reduce the cost of these features. It will also ensure Australian standards are developed with regard to world leading design and testing.

The Government commits to ensuring the adoption of international standards at the earliest possible opportunity through:

Recommendation 15

The committee recommends that the Office of Road Safety assist in the facilitation of research to identify the incidence, frequency and type of driver distraction in crash data.

The Australian Government supports this recommendation, noting that the collection of crash data is inconsistent across jurisdictions and reporting on driver distraction is challenging in practice. Council has discussed the broader issues in relation to driver distraction, including improving data collection and developing nationally consistent messaging and guidelines.

Driver distraction is nationally recognised as a critical road safety risk that needs to be addressed effectively. Distractions maybe be internal or external to the vehicle and come from a variety of sources, including passengers. Road safety authorities and researchers face difficulties in data collection and reporting on driver distraction due to the challenges of accurately measuring the source of driver distractedness and applying consistent interpretations when reporting on driver distraction in crash data.

The Government's $12 million Road Safety Innovation Fund will support road safety research and the development of new, innovative road safety technologies and products to support the Safe System approach and make road safety 'business as usual' for all road users. The outcome areas for the fund include reducing driver distraction.

The Government supports further road safety research on driver distraction through our support of and participation in road safety enabling bodies. The Government has worked with the Queensland Government to undertake key research on driver distraction, producing a National Roadmap for Driver Distraction (the Roadmap). The Roadmap outlines a range of solutions to reduce road trauma resulting from mobile phone and other forms of distraction. Council has endorsed the Roadmap and agreed a working party structure would determine and manage the activities under the Roadmap.

Through the Roadmap the National Transport Commission (NTC) has developed a proposal to amend the road rules to regulate driver interactions with technology through a technology-neutral approach. Ministers have considered the NTC proposal and agreed to work towards amending the road rules.

VicRoads and the Australian Automobile Association are also leading work to develop an ongoing driver distraction rating system in new vehicles as they come into market with the goal of incorporating this system into the Australasian New Car Assessment Program. This would further support the adoption of safety systems that prevent crashes.

Enforcement of driver distraction is a responsibility of the states and territories with some states already utilising roadside camera technology able to detect mobile phone use by drivers. As data becomes available it is anticipated it will be shared for further research and to allow for the development of new policy responses to distraction.

Recommendation 16

The committee recommends that the Office of Road Safety work with states and territories to expand crash data collection and reporting on the incidence, frequency and type of driver distraction.

The Australian Government supports this recommendation.

The National Road Safety Data Hub will identify opportunities to improve the collection of data on crashes, as well as work towards an increased understanding of the presence of and type of driver distraction when a fatal or serious injury crash occurs. ORS will work with jurisdictions to establish consistent national definitions for crash data collection and ensure timely data collection. However as previously identified, currently the source or type of distraction is not always identifiable by crash investigators.

Recommendation 17

The committee recommends the Office of Road Safety works with states and territories to fund community awareness campaigns on the impact of driver distractions on road safety.

The Australian Government supports this recommendation.

As outlined in recommendations 15 and 16, in June 2020 Council endorsed the Driver Distraction Roadmap. The Government will continue to work closely with state and territory governments and road safety organisations to address the impact of driver distraction.

ORS administers the $4 million Road Safety Awareness and Enablers Fund that provides funding for 20 projects aiming to improve road user awareness of a range of road safety issues, including driver distraction.

Recommendation 18

The committee recommends that the Australian Government continue to work with state and territory governments and police agencies to increase the number of point-to-point speed cameras and mobile phone detection cameras.

The Australian Government notes this recommendation, noting state and territory governments have direct responsibility for traffic regulation and enforcement.

State and territory governments have direct responsibility for traffic regulation and the setting and enforcement of speed limits, including decisions about the use of speed cameras and mobile phone detection.

Recommendation 19

The committee recommends the Office of Road Safety liaise with the Transport and Infrastructure Council with a view to conducting further research into the potential benefits to be gained from various emerging driver assistance technologies.

The Australian Government supports further research into the potential benefits of various driver assistance technologies.

To overcome human fallibility, the Government is committed to supporting road safety research and the development of new road safety technologies and products.

The Road Safety Innovation Fund is a $12 million Government initiative to decrease harm and trauma related road crashes on Australian roads and create a safe and sustainable road transport system with zero deaths and serious injuries.

The fund supports road safety research and the development of new, innovative road safety technologies and products to support the Safe System approach and make road safety 'business as usual' for all road users. The outcome areas for the fund are:

In line with the general principles set out in the response to recommendation 14, the Government believes the quickest way to implement standards for emerging driver assistance technologies is by:

Recommendation 20

The committee recommends that the Australian Government support future driver education campaigns with an emphasis on the development and demonstration of safe driving attitudes that address the following topics:

road sharing and pedestrian, motorcycle, bicycle and heavy vehicle awareness;

safe driving in different environments, with an emphasis on regional and rural roads; and

the dangers of distracted driving and the need to remain alert to the driving task.

The Australian Government supports this recommendation on road safety education campaigns.

The $4 million Road Safety Awareness and Enablers Fund is designed to contribute to the reduction of road trauma in Australia by increasing awareness, education and collaboration in the Australian community. Projects include:

The Heavy Vehicle Safety Initiative program funds initiatives that will deliver tangible improvements in road user, road and heavy vehicle safety. It is administered by the NHVR on behalf of the Government and has provided $22.8 million for 89 grants over the past five years with a total of $33 million in grant funding to 2022-23.

Further emphasis on education campaigns will be considered through the new Strategy and Action Plan.

Recommendation 21

The Committee recommends that Australian Government review funding for programs that reduce barriers to disadvantaged groups obtaining and retaining driver licences.

The Australian Government supports in-principle this recommendation, noting that state and territory governments have direct responsibility for driver licensing arrangements.

Options for improving access and reducing barriers to driver licensing in remote communities is currently being considered through the Strategy and Action Plan.

Recommendation 22

The committee recommends that the Australian Government work with state and territory governments to introduce compulsory first aid training as a condition of receiving a learner's permit or renewing a driver's licence.

The Australian Government notes this recommendation.

The Government considers this to be a matter for state and territory governments, which have responsibility for driver licensing arrangements. Most have given consideration to the inclusion of a first aid training requirement at some stage but none have done so to date. The Government notes this recommendation may result in an additional requirement for learners and significantly increase the cost of licensing, becoming a further barrier to those already disadvantaged in obtaining a licence.