John Brett

John is a professional engineer with 50 years experience.

John has designed and built many cars, trucks, and vehicle assembly facilities.

John has worked on design of roads, bridges, cranes, transmission towers, and buildings, and operation, maintenance and upgrade of hydro and gas turbine power stations.

John was a LVV Certifier for 13 years. John has long been a whistle-blower, expressing the view that the LVV system is dangerously deficient. John's authority was revoked in December 2012.

John rides a 1992 Yamaha FJ1200ABS, and is also a keen road and off road cyclist.


“The LVVTA has brought it to my attention that statements I have made in relation to it and its employees may have been perceived as defamatory.

I sincerely regret that and apologise for any harm caused. I have taken down the statements identified by the LVVTA of concern to it.

I have strong views about the low volume vehicle certification process and intend in the future to direct my energies into the public inquiry now being held in relation to it.”

John Brett 7th October 2015


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Electronic Systems- LVV standard required?

It is no secret that a modern car is becoming a computer on wheels. Critical functions such as braking, steering, chassis dynamics are becoming- not just electronically enhanced, but electronically CONTROLLED by embedded software and electronics systems. Self-driving cars are not yet on New Zealand roads, but they do exist- and most of the enabling technology already exists to varying degrees in most modern vehicles.

Drive-by-Wire is not some futuristic concept. Drivers today are already “driving by wire” far more than they suspect.
Pressing the brake pedal simply starts a process controlled by electronics. The brakes can be applied even without the driver pressing the pedal. Steering on some new models is fly-by wire. Traction control, chassis control all have electronic systems that over-ride the driver.
Disability drive by wire control systems exist and are used in other countries. Using such systems, a driver can control steering, acceleration, braking all from a tiny joy-stick- just like the pilot of a modern jet fighter or airliner! At present there is no process to allow such systems in New Zealand, and they are ruled out by the Low Volume Vehicle Technical Association.
Driving with a joystick

Safety is also a key area that is electronically managed- a possible approaching collision can trigger self-actuating brakes, then arm airbags and seat-belt pretensioners according to tested protocols, activate safety systems in the event of an impact, and even send out an emergency message!

There are International Standards such as ISO 26262 is a Functional Safety standard, titled “Road vehicles – Functional safety”

Modifications impinge on these Electronic Systems in many ways. Examples include seat and seat-belt modifications, disability adaptions, power train, suspension or brake modifications or changes, and structural modifications.

At present, all of this passes below the Low Volume radar- the Low Volume Vehicle Certifier may or may not identify modifications affecting electronic systems, and may or may not make a sensible decisions about whether the modification can be allowed, if so what the affects might be, and what actions should be taken to achieve a reasonably safe vehicle.
The Low Volume Vehicle Certifier may or may not not adequately understand the implications of the modifications.
The Low Volume Vehicle Certifier may or may not not document all of this for his own records, or may not document anything.

There is no guidance available, and no formal processes for a Low Volume Vehicle Certifier to follow.
The contingent liability for injuries of death could be high- It might be argued that a modification affected an electronic system to the extent of causing or contributing to an accident, or that the modification resulted in greater exposure of the vehicle occupants to Injury or death.

A formal process needs to be written as a “Low Volume Vehicle Standard” to ensure optimized vehicle safety, provide guidance to LVV Certifiers, and to protect all parties from potential legal action.
Such a Standard should follow steps such as : 1 Identify, 2 Quantify, 3 Justify, 4 Certify.

Government probe into LVVTA and LVV system

1 Low volume vehicle review welcomed

Press release- NZ Police
Thursday, 9 July 2015, 11:53 am

Hon Craig Foss

Hon Craig Foss
Associate Minister of Transport
9 July 2015

Low volume vehicle review welcomed

Associate Transport Minister Craig Foss is welcoming a review of the certification process for vehicles built from scratch or modified for a specialised purpose.

The review of low volume vehicle (LVV) certification, initiated by the New Zealand Transport Agency, will be undertaken by Standards New Zealand.

“The LVV certification process is about ensuring vehicles built from scratch or modified for a specialised purpose are safe to be on the road,” Mr Foss says.

The review will begin this month with a scoping phase. This will involve working closely with the vehicle industry, certifiers and others to better understand the strengths of the current system and potential areas for improvement.

“Standards New Zealand brings an independent perspective to this review. I’m pleased it will be seeking feedback from a wide range of people, including those in the industry,” Mr Foss says.

“I’m keen to ensure our LVV certification system enables innovators to utilise new technologies and create opportunities.”

More information on the LVV certification process:

Craig Foss Letter and Standards Association review proposal

Statement from David Seymour, Epsom electorate MP, leader of the ACT party New Zealand, and qualified Engineer

“I have viewed the reports related to UDM’s vehicles, both those prepared by LVVTA and those by professional engineers. It is clear that the LVV process, while ideal for builders of hot rods, kit cars, and the like, does not have the technical expertise to service commercial operators working closer to the frontier of technology.

A review of this system is long overdue. If New Zealand is going to be have the knowledge economy that most of us want, it must have a regulatory environment that works.”

3 Government minister to probe NZTA ban on wheelchair-access vehicles
Automotive News

Government minister to probe NZTA ban on wheelchair-access vehicles

The Government is to look into why a minor transport body charged with approving ‘hobby’ projects like hot-rods has banned the use of NZ-built wheelchair-access vehicles that continue to be passed fit by independent authorities.



Associate Transport Minister Craig Foss has asked his officials to appoint an adjudicator to look into getting the self-drive cars back on the road. Transport Minister Simon Bridges and Disability Issues Minister Nicky Wagner are also in the loop.

The deadline brings executive attention to a two-year dispute between the company that built the vehicles and the Low Volume Vehicle Technical Association (LVVTA), a branch of the NZ Transport Agency that banned them. It comes soon after ACT leader David Seymour, a qualified engineer, checked out one of the vehicles himself.

The are 11 in all, converted Skoda Yetis (top) designed to be driven by the wheelchair-users themselves. They were built by U-Drive Mobility (UDM), a Waiuku-based operation owned and run by businessman Roger Phillips. The LVVTA at first approved them for use, but later banned them, claiming they didn’t meet LVVTA standards.



Wheelchair-users who had bought the vehicles were suddenly stranded. Three owners have died since the ban was imposed late in 2013. Since then, Phillips, the LVVTA and the NZTA have been butting heads while Phillips set up a plant in France to make identical vehicles for Europe. A French provincial government helped kick-start the operation with a 400,000 euro grant.

Phillips said Seymour rang him after being told of the stalemate with the NZTA. “He came out to the plant on a Sunday night, went over the Skoda, and left,” Phillips said. “That same night he sent me an email, saying he was particularly impressed with the vehicles, couldn’t understand why they had been banned, and that he would be asking government for an urgent inquiry.”

The inquiry is long overdue. There is anecdotal evidence of departmental duck-shoving, of ministerial staff being deliberately fed mis-information, of one transport department knowing very little of what the other one is doing. No one in the government’s transport sector will admit as much, but the LVVTA’s bungling of the UDM vehicles has annoyed its NZTA masters.

NZTA review aims to find out if a review is needed

The NZTA has confirmed it will review a branch of the LVVTA to see if a review of the branch of the LVVTA is needed. The branch is the Low Volume Vehicle (LVV), more a system than a branch.

The NZTA will also review the LVVTA, although it says it is doing no such thing. “We are not reviewing the LVVTA,” says NZTA executive Robin Elston. “As one of the participants in the system they (LVVTA) are naturally included in the wider review of the LVV systems and processes.”

Loosely, then, the NZTA review of the LVV includes a review of the LVVTA, because the NZTA is largely responsible for how the LVV works and what the LVVTA does.

So what is LVV? In a nutshell, it is a process put in place by the LVVTA and NZTA which vehicle certifiers follow. The LVVTA trains and monitors the certifiers; the NZTA appoints the certifiers. The LVVTA? It was set up by the NZTA in the late 1990s to approve for use on NZ roads ‘home-built’ vehicles like hot-rods.

Elston said the review of the LVV would be broken into three phases: scoping, analysis and implementation, that is if implementation was required. She said: “We are currently working with a potential provider to finalise the terms of reference for the scoping phase.

“It is intended that this phase will provide the opportunity for all system participants, including customers, to identify pain points and areas that are working well. This information would be then used to determine any specific areas for review.”

Roger-Phillips, UDM

Roger-Phillips, UDM

The LVVTA has been up to its ears in controversy of late, especially since being accused of overstepping its hobby vehicle brief with UDM and Phillips. Another case in point: one of its LVV certifiers approved as roadworthy for NZ converted wheelchair vehicles later found to be dangerously faulty.

There were 90 of them, modified in Italy by the KIVI company, and bought by the Accident Compensation Commission in 2008 for $8.34 million. Then ACC claims executive Gail Kettle signed off on them. Kettle is now the claims manager for the Earthquake Commission.

Soon after their arrival in NZ a Tauranga engineer contracted to the ACC and NZTA found most of them were unsafe. What happened to them? They got shoved here and there for five years until the LVVTA was told to have them fixed.

It got Carterton company Braiden International to do the work. Braiden says it worked on 50 of the 90, to repair sloppy Italian workmanship, including structural problems the Tauranga engineer years earlier said would surface to bite the ACC, LVVTA and NZTA on the backside.

The ACC and NZTA should have hired a qualified structural engineer to inspect the vehicles in Italy before the ACC’s Kettle signed the $8.34m cheque. Instead, the ACC sent a LVV certifier, who was wined and dined by KIVI’s public relations people and never got to check out the NZ-bound shipment until it landed here.




The Low Volume Vehicle System has failed in the following:-

The LVVTA have failed to develop and maintain LVV Standards- SEE- ORS Submission2
The LVVTA are failing to maintain an acceptable standard of safety of vehicles modified. LVVTA DANGERS- THE FACTS
I understand that another Coroners report is pending, concerning a fatality resulting from the failure of an LVV Certified trike.

Illustration by Nick Reedy

Illustration of a “HOBBY CAR” by Nick Reedy of Greymouth


Here are two examples of the sort of questions that do need to be asked and answered before a way forward for the LVV System can be found:

QUESTION 1 How can the NZ Transport agency justify allowing the LVVTA to make Certification judgements?
The LVVTA have a contract for ‘Desktop Auditing’ to ensure LVV Certifiers are meeting the LVV Standards, however the LVVTA appear to be making Certification decisions under this guise.
We can see no provision in any legislation authorizing NZTA to allow this.

QUESTION 2 On what basis does the LVVTA assume that their knowledge is superior to that of the LVV Certifiers? None of the LVVTA Staff are LVV Certifiers, and do not even meet the requirements for many categories. Yet experienced LVV Certifiers have their judgement questioned, are required to accept the judgement of the LVVTA, and are reported to NZTA for ‘incorrect’ decisions. Several recent incidents have proven that the judgement of the LVVTA can be seriously wrong.

The LVV system is failing to retain the skilled Certifiers
on which integrity and safety of the system depends- such as-

( Names removed by request )

LVVTA are now slanderering these ex-Certifiers, calling them ‘Rogue Certifiers’ and ‘safety risks’ instead of recognizing them as outstanding, highly regarded Certifiers whose experience is a major loss to the system.



The LVV system is reverting to just a low-level ‘hobby car’ certification system.

Emergency appointments of Certifiers from a ‘Hot-Rod’ background lacks credibility, because:-
1…..’hot rod’ experience in no way qualifies a LVV Certifier to deal with the range and complexities of modern automotive engineering.
2…..a Certifier who is beholden to the LVVTA lacks the independence required by the deed of appointment.

The LVV system is failing to meet the needs of vehicle modifiers– the number of Certifications is falling whilst the number of vehicles and the number of mods needing LVV Certification are rising-

1…….Abandoned Certifications We receive continuous enquiries for LVV Certification, from all over New Zealand.
We give out the phone numbers of other Certifiers, we even contact them ourselves on behalf of customers.
In the end, we are left with sheaves of job-sheets, for vehicles which WILL NEVER BE LVV CERTIFIED

2……Modified cars exported- We are aware of many modified and scratch-built vehicles EXPORTED to avoid the LVV system in NZ

3……Modifiers leaving the business- We are aware of PROFESSIONAL MODIFIERS (many with export business) who have CLOSED THEIR BUSINESSES or moved out of NZ.

U Drive Mobility are one recent example of this- now building in France

4…..Avoidance of LVV System Motor-home builders IN NEW ZEALAND switching to Certification to ADR Second Stage system, to avoid the costs, delays, and irregularities of the New Zealand LVV system. Private modifiers are being forced to drive vehicles without LVV Certification

Uncertified vehicles

Police at the bottom of the cliff (Ambulances not visible in this shot)

5……Soaring costs-
The LVVTA levy, has increased, with more increases anticipated, as legal and insurance costs start to bite.
LVV Certifiers have increased their charges to cover time they now require to process Certifications.
In Auckland the total cost to the customer for LVV Certification has increased by an average of 25% in June 2014.

This means that to LVV Certify say, a set of wheel spacers, or adjustable platform suspension struts, will now cost the vehicle owner $550 to $650, which could exceed the cost of the modification.

If NZTA loses faith in the LVV System, (Quite likely)
it is possible that:

1 … Minor Modifications: TSD agents, or WOF agents be authorized to pass a range of minor modifications

2 … Self- Certification: Professional Modification businesses (seat installers, motor-home builders etc) be accredited to Self-Certify

3 ….Hobby cars and Hot-rods– (a very small part of the LVV picture) could be left out in the cold, are unable to be driven on the road.

Not road legal

Going to the Beach Hop?

4 …. The LVVTA and LVV Certification plates become history.


How about some clear thinking about the LVV System of the future?

1 Trust the Certifiers to do the job they are appointed to do. Cut LVVTA out of the Certification process. Allow Certifiers to make their own plates, or use a Certifier appointed Plate printing contractor.

2 Introduce proper “Certifier Training”, conducted ‘on line’ and on the job, by Certifiers or Industry Professionals, (not by the LVVTA) and allow proper technical debate to occur.

3 Allow Certifiers to Certify to proven International Standards if they choose, instead of faulty LVVTA Standards.

4 Form a Certifier controlled “Standards Committee” to develop and change LVV Standards, instructing LVVTA to print and distribute.

5 Simplify Certifier Categories to say “Mechanic based Certifier” (able to do most certifications) and “Engineer Certifier” for situations where the skills of an Engineer are required. Allow “Engineer Certifiers” to consult to “Mechanic Certifiers” when required.


This vehicle was built to our specifications, provided when I was still a Certifier.

Note the folded box beams connecting the Wheel-arches to the B-pillar, to replace the structure of the C-pillar and rear cant rail. The B-Pillar has been buttressed to about 400 mm depth, to withstand the bending moment from the eccentric load from the box-beam, and transmit loads to the upper cant rail.

See our new resource page about Body Restructure

Nissan Skyline Utility

Nissan Skyline Utility

LVV Certification Satisfaction Survey

Survey now closed, results to be provided to NZTA


DISCLAIMER THIS ARTICLE CONTAINS FACTUAL STATEMENTS MADE WHICH ARE VERIFIABLE FROM OUR CERTIFICATION RECORDS, COURT RECORDS AND OTHER SOURCES We have been threatened with Libel action by Lawyers acting for Mr Johnson of the LVVTA, and accordingly have:-removed some clauses, and changed others that were mentioned. We have also made the offer to Mr Johnson’s […]

Low Volume Vehicle Certification- Your Queries

We have been answering queries about LVV Certification ever since this website was started. The queries and the replies are spread around a number of posts.

So just to make things easier to find- here are some of the pages which might already have the answer you are looking for, or where you can post […]

Gagging Order application dismissed by High Court Judge

John Brett

Today 26th August in the High Court of Auckland, the Duty Judge declined to issue a Interlocutory application by plaintiffs on notice for an interim injunction, applied for on behalf of Mr AP Johnson and the Low Volume Vehicle Technical Association, both signed by Mr A.P.Johnson. The order sought would have had the […]

John Brett- Position Statement on Independent Enquiry

Position Statement- John Brett

John Brett

I commenced Low Volume Vehicle Certification in April 1999 when the LVV System was overhauled, and was administered by Motorsafe.

I have been told that Mr Johnson (then a Technical Officer with the LVVTA) very angry that LVV Certifiers had been appointed who were NOT from his […]

Current UDM position relating to certification of modern special needs vehicles in New Zealand

Skoda Yeti at French Factory

The LVVTA regulatory regime appears to have worked well for recreational builders of hot rods, vintage cars, and other vehicles that usually make a virtue of old technology.

On the other hand the straightforward and predictable nature of this regulatory regime is a major disadvantage for professional companies that […]

“NZTA clearly does not have very high standards..”

LVVTA problem From UDM rebuttal:

“It is quite clear that the NZTA does not recognize that it has a problem that it needs to fix, and at the very least it warrants an independent inquiry”

“Until NZTA accept that the LVVTA and its 20th century methodology and poor assessment systems that rely on opinions rather […]

Engineer’s report on faulty wheelchair vehicles haunts NZTA (UN-SAFER JOURNEYS?)

KIVI Kea Carnival conversion

Automotive News

The NZ Transport Agency dismissed a written report from one of its senior engineers warning that millions of dollars worth of wheelchair-access vehicles imported from Italy for use by the Accident Compensation Commission were unsafe and should not be allowed on NZ roads until they were repaired.

Tauranga […]

NZ Designed Wheelchair vehicles – a needless mess-LVVTA and NZTA were warned in January 2011

In January 2011 the Auckland LVV Certifiers collaborated to write this report ORS Submission2

Page 8 points out the lack of any suitable standard for Body Reconstruction, and the likely consequences No action was taken- except to attack those Certifiers who contributed.