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Resilient Low Carbon Transport


Summary Report on Submissions on the Draft New Zealand Energy Strategy to 2050

[ Last Updated 30 October 2007 ]


Objectives/Direction

Submitters in general were critical of the limited focus of the NZES objectives for transport. While recognising that in the short term using alternative fuels and increasing the fuel efficiency of vehicles (the main focus of the NZES proposed actions) would help reduce greenhouse gas emissions from the sector many submitters considered that this would be insufficient to achieve significant reductions.

Consequently submitters suggested redrafted objectives including recognition of demand side measures and clear, measurable and more ambitious targets. They also proposed a range of other measures be considered either as part of the NZES or in detailed action plans.

There was strong opposition from some sectors, including local government, environment NGO's, sustainable transport advocates, some transport organisations and individuals to the objective "continue to meet the demand for transport services". This objective some considered was not feasible. It would do little to alleviate congestion, environmental issues or fuel consumption and it was unclear how it related to other objectives in the NZES and NZEECS which promote reductions in GHG emissions from transport, reductions in kilometres travelled and mode shift, for example.

Many suggested the objective be amended to give more recognition to initiatives to manage transport demand by encouraging a shift to lower impact modes.

Local Government wants to see the focus of the NZES on behaviour change and travel choices first and foremost. They suggest a hierarchy of actions based on the 1998 Transport and Environment Select Committee Inquiry into the environmental effects of transport. The hierarchy is:

  • reduce the need to travel
  • choose a low impact means of travel
  • choose a low impact propulsion system
  • improve the efficiency of propulsion.

They note that the draft NZES focuses primarily on the third and fourth tier and suggest a focused programme based on the first two steps in addition to actions to improve vehicle and fuel efficiency. Environmental organisations, sustainable transport advocates and many individuals supported this or a similar, more holistic focus.

Several submitters noted that maximum emissions reductions are achieved by working through the hierarchy in a systematic way and ensuring actions at different levels are mutually reinforcing.

Whilst the weight of opinion indicated that broader objectives were desirable, other submitters expressed support for the objectives as they stood, recognising that improvements in vehicle and fuel efficiency would provide the quickest short term gains. Several suggested more emphasis on efficient technologies and practices rather than focusing on suppressing transport demand. Technological advances for the heavy truck fleet in particular hold the most promise for emissions improvements, according to submitters with interests and dependencies in that area.

Land use and transport planning

Another criticism, which reflects the view that the objectives of the NZES for transport are too limited, is the under emphasis of the role urban land management and structural changes can have in improving the energy efficiency of transport. Government was urged to take a stronger role in the development of more sustainable urban form and transport infrastructure changes. These, some submitters noted, are the key drivers of consumer energy demand.

A section in the NZES, or sub strategy, devoted to urban design, urban form and travel demand management was suggested. Local government, one of whose primary roles is investment in transport and shaping built environments, seeks a partnership and further dialogue with government on this issue, perhaps leading to a section in the NZES on urban form and the built environment.

Targets

In line with the call for national targets for GHG reductions, ambitious targets are sought by many submitters, for transport. Several environmental organisations who were specific about targets proposed the following:

  • 15% reduction in net transport carbon emissions on 1990 levels by 2025
  • 50% reduction in net transport carbon emissions on 1990 levels by 2040
  • 90% reduction in net transport carbon emissions on 1990 levels by 2050

Urban/rural needs

Lack of recognition of the different transport needs of rural and urban dwellers was noted.

Comments, issues, actions

Developing and adopting future fuels

Biofuels

Views on biofuels ranged from high degree of support for development to those expressing extreme caution or rejecting development and uptake outright. Some submitters want the Government to accelerate the programme for development of biofuels recognising they had a role in security of supply and fuel self reliance as well as environmental benefits, others are skeptical that biofuels will solve fuel problems. Many recognised the limitations of obtaining biofuels from sustainable sources and the possibility that biofuels may have unintended adverse implications which exacerbate climate change.

Those offering qualified support for biofuels had concerns about engine technology incompatibility, particularly for heavy duty truck engines, compatibility of biofuels with the imported vehicles, warranty implications, increased costs (and the impact on business competitiveness), delivery infrastructure concerns and the implications for small petrol distributors. There was also risk of stranded investment if biofuels were overtaken by rapid development of other technologies.

Submitters in the oil sector, commented specifically on the minimum biofuels sales obligation. Their comments and suggestions were:

  • The proposed rate and pace of introduction fails to take account of the lack of biofuels infrastructure plant or supply in New Zealand and the age of the vehicle fleet. Hurried introduction could result in serious vehicle reliability issues thereby undermining consumer confidence. The Government should work with industry to ensure the availability of quality biofuels and develop appropriate infrastructure and consumer guarantees prior to introduction of the sales target.
  • Another company considered the current proposal is too flexible in the way companies can meet their biofuels targets, allowing, for example, the offering of both standard and biofuel blends concurrently. As biofuel blends will be more expensive then standard fuels the proposal as it stands could delay penetration. They suggested that Government should mandate a minimum bioethanol blend and a minimum biodiesel blend into existing fuel grades.
  • Another suggested maintaining current mandate levels and reviewing them every 5 years depending on the availability of locally produced biofuel feedstocks, available biofuel technologies, prevailing engine technology in the NZ fleet and outcomes of cost benefit analysis and consumer uptake.

Several submitters said incentives would be necessary to stimulate biofuel development. One suggested a portion of road user charges equivalent to the level of the sales obligation and any penalties be collected in a fund that would be distributed for investment in domestic biofuel production to help overcome cost barriers to development of the biofuels industry.

Other submitters rejected biofuels as an option. Submitters had concerns about the negative net energy equation if biofuels are generated from non-sustainable sources and noted that often significant fossil fuel input was required. The high environmental costs associated with their production particularly where there is a reduction in food crops or deforestation as a result was another concern.

Advanced diesel technology was considered more promising by some submitters and should be promoted for the heavy and light vehicle fleet including cars and family vehicles.

Electric Powered Vehicles

There was a high degree of support from most sectors and individuals for initiatives that would stimulate the uptake of hybrid and electric vehicles in the New Zealand fleet, especially if increased demand for energy to power hybrids was from renewable sources.

Some submitters noted that penetration of hybrids and electric vehicles into the fleet would be slow and that the electric vehicles were not a good option for rural areas.

There was qualified support from energy companies though measures, possibly mandatory, would need to be introduced to ensure electric vehicles are only charged off-peak and by means of a special plug.

One company saw spin off benefits in terms of the introduction of widespread electrical storage media into the network. If appropriate charging regimes are introduced than this provides an opportunity to load-smooth and gain greater utilisation of distribution and transmission systems. However, incremental system costs would more than triple if charging occurred at peak times.

Another suggestion was that research was required into the relative merits of electric versus hybrid vehicles to see which were the most efficient and effective for New Zealand conditions.

For the heavy truck fleet, hybrid trucks hold good promise for reduced emissions. As it is a dominant mode of land freight internationally and given world commitment to GHG reduction there will be a high degree of focus on technological improvement. To facilitate uptake NZ should make sure our regulations are consistent with those of potential technology suppliers and the NZES should focus on policies which will encourage uptake of superior technologies.

Hybrid/fuel cell vehicles were not seen as a viable option for the long distance bus/coach fleet at this time.

Improving fuel efficiency of vehicles

The proposed actions in this section of the NZES (mandatory labelling, import restrictions, variable costs, sales weighted fuel standard, improving driver behaviour and commitment to fuel economy) were supported by the majority of organisations and individuals commenting on this section as worth further consideration.

Some submitters, especially with interests in promoting sustainable transport systems, considered the NZES did not cover pricing mechanisms that can influence travel behaviour, reduce car journeys and increase use of active modes sufficiently.

Other submitters stressed that the single most effective measure would remain price. Introducing a price for emitting carbon would be the most efficient way of changing user's behaviour and also encourage investment in low emissions technology – such as electric and hybrid vehicles.

A submitter mentioned not enough use is being made of existing legislation regarding vehicle emissions and standards of imported vehicles, these minimum standards should be enforced.

Some submitters expressed concern about price based measures as higher costs of transport will impact hardest on low income citizens.

Several suggested revenue raised from price based measures should be funnelled back into the transport sector to fund other initiatives such as increased investment in public transport.

Reasons given by submitters not supporting some of the fuel efficiency measures were:

  • do not support varying the costs of purchasing vehicles based on vehicle fuel efficiency as this sanction does not reflect kilometres travelled or actual fuel usage
  • support restriction based on vehicle age provided there are exemptions for classic cars.

Distance based charging for all vehicles

There was recognition that distance based charging could have a role in influencing consumer behaviour. It would need to be supported by affordable and accessible public transport. Some commented that it seemed complex – fuel taxes could achieve the same effect and more cheaply.

Several mentioned anomalies in the current road user charge system which act as a disincentive to the uptake of more efficient vehicles and suggested these be reviewed. E.g. Light weight diesel vehicles for example pay a disproportionate amount of RUC (compared with contribution to road wear and tear) under the current system.

More efficient means of transport

Public transport

There was a high degree of support from many organisation and individuals for ongoing investment in public transport. Many also sought more recognition and support for active transport modes such as walking and cycling, car pooling and other measures to reduce the number of vehicles on the roads. It was noted a switch to active transport modes has significant collateral health benefits.

Local government noted that funding support for these modes remains a small proportion of total land transport funding. The imbalance needed to be addressed and long term certainty of funding was sought. Others suggested changes to the activity class funding mechanisms so that sustainable transport modes received priority.

There was recognition that for public transport to succeed, and for behaviour change to occur, it needed to be cheap, efficient and, importantly, convenient.

New Zealand Shipping Strategy

In the transport sector, most submitters considered there would be more value in an integrated cross-modal freight strategy, rather than a shipping strategy. The strategy should consider the roles of all the potential freight modes. Rationales for this view included:

  • a focus on shipping was contrary to integrated planning and multi-modal transport objectives
  • a freight strategy could look at a wider range of issues including inter modal transfers and congestion at inter modal rail and port terminals
  • opposition to promoting a particular mode of transport, which tended to result in each strategy simply promoting that mode.

Some submitters representing road freight carriers considered the NZES had a clear bias against road freight and noted that there was no evidence that distorting the playing field in favour of rail or coastal shipping will result in an increase in energy efficiency or economic efficiency.

There was endorsement for a shipping strategy from some quarters, particularly shipping industry representatives, some environmental NGO's and individuals who noted more needed to be done to promote shipping (and rail) with investment directed towards the lowest net emissions methods of moving particular items. It was suggested the strategy should not be limited to a port-to-port approach but, door-to-door and that coastal shipping be included in future rounds of the Surface Costs and Charges Study

Another suggestion was for the scope of the strategy to include port policy issues such as the long term effects of climate change on ports and the impacts of this for long term infrastructure planning.

Industry submitters noted:

  • there is often limited ability to adopt alternatives to road freight especially for time and temperature dependent products
  • the focus should be on an integrated strategy and improving the interfaces between the modes.

Increasing limits for truck weights and dimensions

Several industry submitters noted that the most readily available fuel efficiency saving would come from an increase in heavy truck loading rates. Increasing loading would enable fleet reductions and significant emissions saving. Road transport industry representatives also held this view. They considered removing existing regulatory impediments to efficient road transport, including New Zealand's limits on truck weights and dimensions, would give significant energy (reduced fuel use) and economic efficiencies without having an adverse impact on rail or coastal shipping.

Security of Supply

The need for secure fuel supplies was recognised given New Zealand's high dependency on imported fuels and its importance to the economy. Realistically, the dominance of oil as a source of transport fuel will remain for a long time. It was suggested New Zealand expand initiatives to encourage and facilitate oil exploration to improve self sufficiency in oil.

Diversity of transport fuels

Submitters commenting on this section were aware of the possibilities for alternative fuels in providing energy security and emissions reduction in the transport sector. They discussed the potential of a range of technologies for biofuels and suggested a range of other potential biofuel sources:

  • methane capture from biological material for rural and remote areas
  • biodiesel from tallow can make a small contribution in the short term
  • growing conversion of and processing of cellulosic feedstocks (this is an areas New Zealand can use its strengths in agricultural science and wood processing technologies) to produce ethanol.

Several submitters in the transport sector considered CNG should be included in the fuel mix. It is an indigenous fuel, is widely available and has an emissions profile equal to or better than petrol or diesel. Government was urged to take a serious look at modern CNG applications and delivery infrastructure. LPG for light and heavy vehicles was also supported as a "here/now" fuel that was technically reliable.

For buses and coaches liquid based fuels mainly as derivatives or a blend of diesel have the most promise. Technologies such as extenders in the form of alcohols or esters also offer good opportunities. CNG and LPG are not seen as an option for this fleet.

Several submitters noted that lignites should not be discounted as a potential source of liquid fuels in the long term. Other submitters considered there was too little focus on hydrogen technology (and too much on biofuels). This is the main future energy source for transport – 100% CO2 and particulate clean. A hydrogen pathway should be included in the strategy.

Other issues and policy proposals

Air Quality

Concern was expressed from several quarters about the NZES promoting a shift in the vehicle fleet from petrol to diesel vehicles to reduce CO2 emissions. These submissions noted it was essential any such a move should not result in an increase of particulate emissions. There should be no trade-off for any initiative for climate change if another aspect of the environment, for example air or water quality deteriorates.

Aviation

A number of submitters noted the omission of the aviation sector from the strategy. Some saw this as a considerable oversight given:

  • the attention this is receiving overseas
  • that emissions at altitude are estimated to have greater impact then those at ground level
  • industry growth is outpacing emission reductions through technological improvements.

Policy suggestions for aviation included:

  • better data collection and assessment of lifecycle emissions
  • air emissions are included in international agreements
  • excise tax on aviation fuel domestically and internationally (if consistent with overseas practice)
  • establish a GHG emissions cap for international travel to and from NZ
  • working with the tourism industry to prepare for the changing nature of tourist visits.

One submitter noted that there are no technological solutions to emissions from aviation. Growth in air travel is exceeding possible increases in aircraft efficiency and hydrogen and biofuels are not suitable alternatives. They expected once global limits on emissions start to have an effect international travel could be curtailed. New Zealand will be at a carbon-disadvantage compared to other destinations and this should be addressed, by for example, ensuring tourists have a low emissions profile within New Zealand.

The aviation sector noted the price of fuel was a strong incentive to maximise fuel efficiency for both aircraft and ground operations.

Other recommendations

Other recommendations for policy included:

  • Review the institutional and funding systems for land transport in light of climate change objectives. Present institutional and financial arrangements favour road building over other transport modes.
  • Consider tax incentives for the uptake of more efficient new technologies or those meeting higher standards then those in force in New Zealand. Submitters cited accelerated depreciation, differential fringe benefit tax rates or adjustments to GST levels as options.
  • On public transport, suggestions included giving priority to electrification of Auckland rail, promoting integrated ticketing and broadening the focus of rail from urban rail to consideration of commuter rail between urban areas, reflecting the fact that people are choosing to commute long distances to work.
  • Develop strategic interregional and urban freight routes.
  • Use technology developed overseas more that would help reduce energy consumption e.g. better highway management; electronic road user charges, travel information and vehicle navigation systems.
  • Implement a moratorium on highway construction and free up funds for alternative modes.
  • Investigate workplace alternatives such as condensed working weeks and access to services via the internet to reduce travel demand.
  • Investigate the infrastructure, institutional and business barriers hindering uptake of telework, and work with existing telework providers and promoters on measures to increase uptake.
  • Develop a deposit and rebate system to encourage removal of older vehicles from the road.
  • Introduce compulsory fuel use meters in clear view of the driver on all new cars and those less than 10 years old.
  • Introduce measures to promote car pooling.
  • Provide Government support for facilitating the uptake of energy efficient lighting (street and traffic) systems.
  • Develop greater capacity and expertise in the sustainable transport field.
  • Use social marketing techniques to encourage behavioural change in individuals personal decisions on transport mode use.
  • Investigate a domestic carbon quota scheme for individuals.

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