To quote the Climate Council on transport emissions: “Australia lags well behind the pack. We have the ninth highest transport emissions per capita in the world”. Reasons include the lack of greenhouse gas emissions standards, our high emitting cars, the relatively long distances travelled per person, and our relatively low use of public transport. Mandatory greenhouse gas emissions standards for cars now cover 80% of the global car market. After a long delay, the Federal Government is now consulting on the introduction of mandatory vehicle emissions. It called for submissions on a Draft Regulation Impact Statement on Improving the Efficiency of New Light Vehicles.
Submissions closed on 10 March 2017. 350 Australia made a submission.
Access the full text of our submission here:
We support the core aim of the Ministerial Forum – to achieve a reduction in greenhouse emissions from Australia’s road transport sector. Our comments are driven by the urgency of this imperative in the light of the worsening climate crisis. It is our view that, as Australia’s electricity sector is progressively transformed, the decarbonisation of the transport sector will, during the next decade, emerge as a major priority for meeting our commitments under the Paris Agreement and for taking the further actions required if Australia is to contribute its fair share to limit global warming to 2°C and preferably less.
We recognise that some of the issues canvassed in these comments could have been made last year in a response to the Ministerial Forum’s discussion paper. Nevertheless, during the past 12 months there have been significant advances in vehicle technologies which we urge the Ministerial Forum to consider.
We note COAG’s target of a 40% improvement in energy productivity between 2015 and 2030, and its strategy of “reducing barriers to entry in the market for new technologies and service options” as one means of achieving this target. Our comments will refer specifically to some of these “new technologies and service options”.
The Draft RIS identifies three options for fuel efficiency standards, and claims that the most ambitious of these options (105 grams of carbon dioxide emitted per km travelled) would align Australia with EU and US targets. However, we draw attention to the fact that the EU has a target of 95g/km by the year 2021, and is already assessing a target in the range 68-78g/km for the year 2025. We also note that the US has a target of 89g/km for the year 2025, and South Korea has a target of 97g/km for 2020. Given this background, in our view even the strongest target option in the Draft RIS looks quite weak.
We appreciate that Australia is starting from a higher-emissions baseline than these other jurisdictions, but we think it reasonable for Australia to lag their targets by no more than 5 years. On this basis we recommend a timeframe of no later than 2022 target of 105g/km, and we recommend that the Ministerial Forum undertake a review in 2020 with a view to aligning with the new EU standard (95g/km) by 2026.
In our view, the benefit-cost analysis for each of the three options in the Draft RIS was based on an inadequate estimate of the Social Cost of Carbon (SCC). We cite research supporting the use of a higher SCC which, had it been used, would estimate significantly higher benefits of CO2 abatement and would support our arguments for earlier and more stringent fuel efficiency standards.
We urge the Ministerial Forum to look beyond traditional vehicles and transport models, and to take account of two significant developments which will transform the light vehicle transport sector in the next two decades: the uptake of plug-in electric vehicles (EVs) and the trend towards new models of vehicle sharing. We will cite studies that underscore these developments and their implications for carbon emissions, and we will make some recommendations for action by the Ministerial Forum in this space.
Supplementary information may be found in this presentation.