Attached please find the Road Transport Forum’s (RTF) response to the Climate Change Commission’s (CCC) 2021 Draft Advice for Consultation, which RTF lodged last Friday on behalf of the road transport industry.

We are aware of the strong interest in the CCC’s report and the response to it from industries across the country.

In summary, RTF acknowledges the requirements of New Zealand to meet its obligations to the Paris Accord’s climate mitigation requirements. We are supportive of this principle and will work co-operatively with the CCC and the Government to this end, while recognising the broader importance of having a viable and productive road transport industry to support New Zealand’s economy. We also acknowledge the growing number of industry operators who are trailing trucks powered by alternatives to fossil fuel.

While RTF has summarised a response to the CCC from an industry perspective, we have also discussed the impacts as we see them on individual households and the wider community, particularly the disproportionate impact we believe the approach may have on those on lower incomes.

Overall, we believe the CCC has recognised that technology doesn’t currently exist to progress to decarbonising the heavy transport industry. We are concerned however, that the CCC appears to have taken a heavily slanted position that electric vehicles will be the solution for our industry. This may well be accurate, however, it is too soon to tell and we are concerned that the Government may lay all its eggs in one basket. Currently, the duty cycle of most heavy trucks renders existing electric technology useless for line haul.

The RTF is concerned about the economic costs of the industry having to deal with stranded vehicle assets at some point in the future. Our view is there must to be ongoing communication and clarity based on evidence, not sales pitches or ideology, around the future powering of heavy vehicles. There must also be incentives for industry to switch as new, tested technology becomes available.

You will note from our submission, that RTF has attempted to provide evidence through articles of what is occurring currently in relation to vehicle powering technology. It is difficult to judge quite where an eventual non emission solution will emerge, but our view is that the Government must continue to take a wide consideration for a significant period of time, otherwise it risks being captured in a solution that may not be a sustainable one.

The RTF recognises the need for the road transport industry to continue to develop its position on climate change and sustainability. We hope to provide members with more useable resources in this area that might be applicable in your business before the end of 2021.