SIVANZ made a submission in response to the Emissions Reduction Plan (ERP) discussion Paper: Transitioning To A Low-Emissions and Climate-Resilient Future. You can read our submission below.
The SIVANZ submission is in response to the Emissions Reduction Plan (ERP) discussion Paper: Transitioning To A Low-Emissions and Climate-Resilient Future.
SIVANZ represents a membership base of special interest vehicle (SIV) owners and SIV manufacturers and suppliers (the special interest vehicle industry sector).
A typical SIV profile;
*SIVANZ Industry Survey 2019
** SIVANZ calculation based on documented SIV owner membership to national organisations
Special Interest Vehicles (SIV’s) are a specific subset of the light vehicle fleet and deserve acknowledgment and separation from the general light vehicle fleet category.
We acknowledge that the ERP does not specifically discuss the current light vehicle fleet. That silence at the beginning of such an important journey to a low emission economy is of concern to us.
Most SIV’s are included in the light vehicle fleet category. Not all SIV’s are easily identifiable or differentiated within the fleet.
We propose that SIVANZ and other national SIV organisations work with officials and regulators to develop a framework to exempt SIVs’ from any legislative and regulatory changes which could restrict their restoration, construction and ongoing use on New Zealand roads.
SIVANZ would like to work with government and officials to develop a palatable mechanism for SIV’s to be easily identified in the fleet and exempt from any and all future Rule or Legislative changes proposed to limit their use or removal from the light vehicle fleet. SIV’s travel on average low Km’s so can be considered low emitters compared to vehicles in daily use.
SIVANZ also proposes that it be involved with officials to develop and implement initiatives that assist SIV industry to transition into lower emissions business opportunities and to help workers train, cross and up skill into low emissions employment and retain the economic values derived from both groups.
The SIV community creates more than $10Bn of economic and personal value to New Zealanders. We estimate that figure to be at least doubled when the wider contributions to the domestic tourism economy are factored in. EG the accommodation, restaurant and retail sectors are well served by travelling SIV owners and SIV events. Charities are huge beneficiaries of proceeds from SIV events.
We appreciate the ERP is setting the high-level framework for emissions reduction strategies but our concern is that most other areas of the economy and specific groups within society are mentioned on numerous occasions through the ERP. That indicates that they are already tagged for a future conversation and clearly significant financial support.
We are not aware of any other group within the emissions reduction (Transport) discussion to date that has the potential to suffer significant business and personal losses without transitional support already on the table along with financial incentives on offer to move to low emission transport modes or business shift support.
The transition must be fair for all participants. The person who pays more for a higher emitting vehicle, either by choice or necessity, must feel the additional costs are helping the whole country achieve the emissions goals. They cannot be looking at the agricultural sector, or any other sector who may not be paying their fair share, or are by all accounts reluctant participants and evaders in the emission reductions transition.
We are disappointed that submissions made to the Ministry of Transport Hikina te Kohupara Green Paper are so heavily referenced in the ERP and used as validation in support of proposals or initiatives in the ERP.
The ERP seeks to justify proposals using a bias that is clearly evident from the submitters who were permitted to participate. This immediately marginalises other stakeholders in the discussion who were denied the opportunity to participate in the discussion.
The offer made on the cover of the Green Paper for the public to participate later in the year (2021) is disrespectful when the public submission offer is to a different discussion paper; the ERP. And, to reiterate, the ERP discussion is not the same as Hikina te Kohupara. Related yes, but not the same. The manipulation of the public in this way does not encourage open, honest and transparent debate.
SIVANZ has to believe that it is possible to work with officials to develop a mechanism that identifies a bonafide SIV within the current light vehicle fleet and provide an exemption criterion to climate change proposals that may impact, negatively, SIV use.
SIV’s make up less than 3% of the light vehicle fleet and only travel on average between 5000 and 10000 Km’s per year. On this basis SIV’s can be considered low emitters.
SIV use as described further supports the generation of $5.5Bn of economic value to NZ through the SIV industry sector.
On the assumption that it is possible to achieve SIV identification in the light vehicle fleet and exemption criteria as described above, the SIVANZ responses to the ERP (Transport) are below.
Question Section; Taken From the ERP
We are proposing four new transport targets in the emissions reduction plan, and are seeking your feedback.
SIVANZ: There are two parts to the question.
Part 1. We support a reduction of VKT’s in the larger cities where vehicle congestion, poor throughput and poor flow are clearly evident. To financially penalise vehicles “out” of cites as a standalone initiative may not deliver meaningful emissions reductions. A scheme such as this would likely be perceived as revenue generation first; emissions reduction second.
Improved public transport systems that consider where people really work and implemented properly for the long term may deliver better results.
Part 2. The problem with a universal VKT reduction target is that it has potential for officials and politicians to become fixated on the target and its achievement at all cost. We contend that there is potential for consequential impacts from poor decision making in the pursuit of a VKT target.
Rural towns and communities have quite different transport needs as does industry. It is possible that a set VKT could also attract a penalty system to “tax” people into meeting the target VKT. Again, such an approach would likely be perceived as a revenue generator first and emission reduction mechanism second.
We propose that properly introduced public transport systems, access to and consistent delivery of low emission vehicles to NZ may negate the need for any VKT target.
SIVANZ: We cannot offer blanket support for the proposal because the “…and the associated actions…” are not fully described. To agree to the question is akin to signing a blank cheque and hoping the recipient, a stranger, only fills in the agreed amount.
Theoretically, a consistent delivery of low emitting vehicles into NZ would be beneficial to achieving emissions reduction targets. We suggest that the government should be lobbying the governments where low emission vehicles are manufactured. If those governments were committed as NZ is to global emissions reductions, then they must see the benefit in supplying us with vehicle stock.
There is the possibility that we cannot obtain low emission vehicles in sufficient numbers to meet emissions reduction targets. If the supply chain cannot provide NZ with low emission vehicles, it is the undescribed “….and associated actions….” that provides a blank cheque approval to introduce any measure as decreed by government without any further consultation.
SIVANZ: We are not in the freight sector. However, the second part of the question is not fully described so it is our view that it would not be prudent to pre-agree to an unknown set of actions.
SIVANZ: We support this question as it applies to the light vehicle fleet. We would add that government should be providing financial investment to the alternative (liquid) fuels sector for fuel and distribution network development to the same level as currently invested in the promotion of EV uptake, subsequent national EV charging network infrastructure and taxpayer funded Feebate payments.
Assuming future supply chain challenges, EV emissions reduction benefits may not be realised by due dates. This means that other sources of emissions reductions may need to be developed in parallel, and in expectation of, a future EV supply disruption.
Alternative fuels for the current vehicle fleet may be an excellent opportunity for emissions reductions continuity and target achievements.
SIVANZ: There are two parts to this question.
Part 1. We acknowledge and support emissions reductions initiatives to achieve meaningful climate change objectives.
We would support a time limit on ICE vehicles entering NZ. We would propose 2035. This date gives those businesses and individuals involved with private importation of ICE vehicles sufficient time to wind down ICE imports and identify alternative lower emissions business opportunities.
If emissions reduction targets were not being met as promoted through Emissions Budgets 1,2, or 3, as a stakeholder in the SIV discussion we would welcome to opportunity to discuss the challenges in achieving targets and remedial actions to get back on track. A review of ICE vehicles entering NZ may be a topic for discussion.
Part2. SIVANZ totally rejects a time limit on the manufacture or assembly of ICE vehicles by 2030.
The SIV community creates more than $10Bn of economic and personal value to New Zealanders. We estimate that figure to be at least doubled when the wider contributions to the domestic tourism economy are factored in. EG the accommodation, restaurant and retail sectors are well served by travelling SIV owners and SIV events. Charities are huge beneficiaries of SIV event proceeds.
There are world class SIV restorers and manufacturers in NZ. A time limit on the manufacture or assembly of ICE vehicles sends a death notice to those businesses on announcement of a time limit.
SIV related business groups will feel the impacts from emissions reductions policy and initiatives sooner than most. Urgent attention must be given to the SIV business groups and how they can be supported through the transition.
The ERP has no credible statement about the consequential impacts on SIV related businesses compared to other business sectors. The proposal is not equitable and lacks any support structure for SIV business owners. SIV businesses or groups should not be disproportionately affected by the transition.
There is not enough impetus from government to act urgently on behalf of SIV small businesses in consideration of planned emissions reductions initiatives. SIVANZ submitted in the climate Change Commission Draft Report that;
These points were made in expectation that SIV businesses will be affected very early in any emissions reduction plan implementation. An announcement of a time limit on the manufacture or assembly of ICE vehicles will immediately begin the decline of those businesses.
Government has identified almost every other group or community that may be negatively impacted by emission reductions initiatives and has indicated a raft of support packages and funding.
SIV owners and SIV businesses have been universally excluded in every discussion paper to date on climate change or emission reductions proposals. Yet, more than $10Bn of economic value is derived from SIV owners and businesses. We are not aware of any other sector or group as marginalised as the SIV fraternity in the emission reductions discussion.
Government continually reiterates that this climate change journey and transition will be fair, equitable and just.
SIVANZ would welcome the opportunity to be involved in discussions that support, develop and fund a fair and just transition package for SIV business.
SIVANZ: We have noted the silence to date on emissions reduction initiatives as they may affect the current light vehicle fleet; our position is specifically focussed on SIV’s. We are also mindful that emissions reductions discussion on the current light vehicle fleet is imminent.
What is not clear at this point in time is how government and officials plan to include ICE vehicles that may not be imported, manufactured or assembled for normal road use into the emissions reduction discussion.
If emissions reductions are the objective, then privately owned ICE vehicles involved with motorsport, marine or aviation use must be included in the discussion. ICE motorsport, water and aviation vehicles are as equally imported, assembled and manufactured in NZ as ICE vehicles destined for normal road use are.
Emissions are emissions and we propose that all vehicle types that are powered by ICE are subjected to the same (potential) emissions reduction discussion, at the same time.
An equitable, fair and just transition strategy cannot be selective in what ICE vehicles are included in any emission reduction discussions and what are not. A just transition cannot favour one group of New Zealanders over another group determined by what vehicle they own or how and where they use it.