AA motoring affairs general manager Mike Noon said the two-star roads are high speed roads and if a motorist makes a mistake the consequences are extremely severe.
He said people blamed drivers for crashes, which was right because the driver makes a mistake.
But Noon said it was the road that deals out the consequences of that mistake from having a ditch, poles, trees or a bad run-off area.
"Not all roads are the same as each other ... but motorists tend to drive every road as if it is the same," he said.
The AA is also concerned that the NZTA figures are purely based on state highways and does not take account of local roads, which have a no-star rating.
An NZTA spokesman said several roads on the list are undergoing or will be undergoing safety improvements as part of the Government's Safer Roads Programme.
"The programme averages around $100 million a year for a six-year period and will improve safety on about 100km of state highways per year," he said.
State Highway 22 from Drury to Pukekohe was on the programme, along with four other stretches of state highway - Ohaupo to Te Awamutu, Katikati to Tauranga, Featherston to Maoribank, and Kawakawa to Springs Flat.
Noon said the AA wanted 150km of roads upgraded each year, saying the Dutch Government had set a target to upgrade all highways to three stars by 2020.
The AA has released the NZTA list of New Zealand's most dangerous roads.
• State Highway 22 from Drury to Pukekohe: three deaths, 19 serious injuries, 44 minor injuries
• SH58 from Pauatahanui to Upper Hutt: 2 deaths, 13 serious, 47 minor
• SH2 from Paeroa to Waihi: 1 death, 16 serious, 49 minor injuries
• SH3 from Palmerston North to Ashurst: 2 deaths, 9 serious, 42 minor
• SH3 from Ohaupo to Te Awamutu: 2 deaths, 4 serious, 25 minor
• SH2 from Katikati to Tauranga: 18 deaths, 35 serious, 95 minor
• SH3 from New Plymouth to Inglewood: 1 death, 11 serious, 40 minor
• SH2 from Featherston to Maoribank: 3 deaths, 13 serious, 60 minor
• SH6 from Frankton to Arrow Junction: 1 death, 10 serious, 37 minor
• SH1N from Kawakawa to Springs Flat: 14 deaths, 41 serious, 133 minor
- Based on crash data from 2012-2016