Dear New Zealand Transport Agency,
I wish to know
(1)what is the enabling legislation which permits the issuance of pseudo driver licence?
(2) If there is no enabling legislation what is the legal basis for the issuance of pseudo driver licences?
(3) Can a pseudo driver licence be issued to a limited company?
(4)When did pseudo driver licences first come into existence?
(5)How many speed camera Infringement Notices have been issued since the inception of pseudo driver licences?
(6)How many speed camera Infringement Notices have been issued to limited companies by way of pseudo driver licences?
(7) How many speed camera Infringement Notices have been issued to individuals by way of pseudo driver licences?
(8)How many Infringement Notices, other than for speed camera offences. been issued both for limited companies and individuals, by way of pseudo driver licences?
(9) What is the total value of all Infringement Notices issued by way of pseudo driver licences?
(10)Going back quickly to (1) and (2) If there is no enabling legislation, are pseudo driver licences legal and if so, how are they legal?
(11) Why is there, apparently, no reference to pseudo driver licences either on your website or in the Land Transport Act 1998?

Yours faithfully,

Geoff. Waterhouse

Dear Chris Rodley
National Manager Regulatory System Design ,
I am writing with reference to your reply of 27 January 2025 concerning OIA request 17175 and wish to raise a number of points
1) I asked
(1) What is the enabling legislation which permits the issuance of pseudo driver licence?
2)You replied
There is no legislation which permits the issuing of a pseudo driver licence as the term ‘pseudo licence record’ is a term for a unique identifier created in the driver licensing register system that hold information against it. It is not a licence that is issued to a person or company, it does not grant any rights to a person or company to drive. It is like a reference number. It is an administrative process that is used when an offence is committed, and a unique identifier does not already exits or cannot be clearly identified." Looking back through records, I found Infringement Notices issued in the name of PAHIA TAXIS & TOURS LIMITED in 2019 and 2020 with the same pseudo driver licence number. How, if these were issued back in 2019 and 2020 how can a unique identifier not already exist?(I assume that "EXITS" is a typo which should be "EXIST," maybe you should get a proof reader, unless you do mean "EXITS" which doesn't make sense. Anyway, moving right along. I have a copy of a recorded telephone conversation of about 22 minutes with a so called "team leader," by the name of Catherine, the reference number is 38629790. I cannot add it here so I will just quote some of the bits. I have a whole load of other recordings with other inept members of your call centre which I need to listen to again and make notes. In the meantime, here are the relevant parts with the time in the call. (1)02:57 mark The Tanya that I spoke to first is a CSR and she, Catherine, is a team Leader (2)07:23 She agrees that it (the pseudo licence) is a FAKE record! She confirms that it is a FAKE! (How does THAT work?) (3)07.58 She talks about "creating a fake." (4)16.48 She says that the Police are legally allowed to make assumptions through legislation!! (I wonder where THAT legislation is? (5)17.18 She admits she has no idea what either "Mens Rea" or "Actus Reus" is and these people are answering questions from "WE THE PEOPLE!" i wish I could attach the recording but I don't think I can e mail it if anyone wants a copy. I have, since starting this, done some more research and I believe that you are playing with words. Soooooo Another question Are "pseudo" driver licences (1)issued (2)created or (3)generated? I did some research which produced the following "Specific Cases Where These Terms Have Been Legally Interpreted by NZTA
There are no specific cases mentioned in the search results where the terms "issue," "create," or "generate" have been legally interpreted by NZTA. However, their use appears consistent with standard administrative practices:
Issue: Granting legal authorization (e.g., issuing licences post-suspension)9.
Create: Producing physical or digital licence documents.
Generate: Systematically compiling data for records or reports. From the definitions above, it would appear that "pseudo" licences cannot be "issued." You say "There is no legislation which PERMITS the ISSUANCE etc." Is there legislation that PERMITS the CREATION of pseudo driver licences? Is there legislation that PERMITS the GENERATION of pseudo driver licences?
I asked (3) Can a pseudo driver licence be issued to a limited company?
You say
Yes. If a traffic offence is identified as having been committed by a vehicle registered to a limited
company, and the individual operating the vehicle cannot be identified, then a pseudo licence record is generated in the limited company’s name. An example of this occurring would be when a vehicle registered to a limited company commits an offense that is recorded by a speed or safety camera.
Moving right along How can " a vehicle commit an offence?" It's like "GUNS don't kill people, PEOPLE kill people," using that same reasoning, "VEHICLES don't commit offences, PEOPLE commit offences."
The Infringement Notice, Reminder Notice and Notice of Hearing ALL clearly state that "PAIHIA TAXIS & TOURS LIMITED" was driving the vehicle so how does that work? There is a lot more to this but I think that this is enough for you to chew on for the moment especially the bit about "Catherine, is a team Leader (2)07:23 She agrees that it (the pseudo licence) is a FAKE record! She confirms that it is a FAKE! (How does THAT work?) (3)07.58 She talks about "creating a fake." (4)16.48 She says that the Police are legally allowed to make assumptions through legislation!! (I wonder where THAT legislation is? (5)17.18 She admits she has no idea what either "Mens Rea" or "Actus Reus" is and these people are answering questions from "WE THE PEOPLE!"
I wish it was possible to highlight stuff here for emphasis purposes

Yours sincerely,

Geoff. Waterhouse

Dear Official Correspondence,
Dear Chris Rodley,
One thing I forgot to ask, in (10) I asked if pseudo licences are LEGAL, you did not answer the question sooooooooo, again, "Are pseudo licences legal, if they are legal what makes them legal?

Yours sincerely,

Geoff. Waterhouse

Dear Official Correspondence,
You have not answered the question "Are pseudo driver licences legal?" If they ARE legal, what makes them legal?
Are pseudo driver licences "FAKE" as stated by your team leader Catherine in recorded phone call reference number 38659790?
HOW and by WHOM are pseudo driver licences created?

Yours sincerely,

Geoff. Waterhouse