SIVANZ Submission to the Climate Change Commission

Special Interest Vehicle Association of New Zealand

Submission on the Climate Change Commission 2021 Draft Advice Report for Consultation.

Andrew Ferrier- Kerr. 28 March, 2021

SIVANZ Submission Contents.

Executive Summary                                                                                                   P 2

Chapter 2. Our proposed emissions budget advice

2.2. Accelerating actions to reduce emissions                                                                      P 4

SIVANZ Recommendations List #1                                                                   P 5

Consultation Question #1                                                                                   P 5

2.3. Emissions budgets-stepping down emissions in Aotearoa                                                 P 5

           Consultation Question #2                                                                              P 5

2.6. Enabling an Enduring Climate Transition                                                                        P 5

           Consultation Question #5                                                                              P 6

2.6.2. Coordinate effort to address climate change across Government                                        P 6

           SIVANZ Recommendation List #2                                                                          P 7

           Consultation Question #6.                                                                            P 7

2.6.4. Central and local government working in partnership                                                     P 7

           SIVANZ Recommendation List #3                                                                          P 8

           Consultation Question #6                                                                             P 8

2.6.5. Ensuring inclusive and effective consultation, engagement and public participation                P 8

           SIVANZ Recommendation List #4.                                                                        P 9

           Consulting Question #9                                                                                            P10

Chapter 3: The path to 2035                                                                                             

3.3. We need to avoid pushing the burden to future generations                                           P10

           SIVANZ Recommendation List #5                                                                          P10

           Consultation question #10                                                                            P10

3.8.1. Transport                                                                                                           P11

           SIVANZ Recommendation List #6.                                                                         P12

           Consulting Question #12                                                                                P12

Chapter 5: The impacts of emissions budgets on New Zealanders

5.1. Looking at the opportunities – and the challenges                                                                P12

5.2. How Aotearoa creates a fair, equitable transition for people                                           P12

5.5.3. Small Business                                                                                                 P13

           SIVANZ Recommendation List #7                                                                          P14

           Consultation Question 13                                                                              P14

Chapter 6: Direction of Policy the Governments emissions reduction plan.

6.1.1. Transport                                                                                                           P14

           SIVANZ Recommendation List #8                                                                          P15

           Consultation Question 14. Transport                                                                  P15

6.2.2. Support behaviour change                                                                                    P15

           SIVANZ Recommendation List #9                                                                          P16

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 Executive Summary.

The SIVANZ submission is in response to Transport related proposals but makes comment on other parts of the report as it encompasses a holistic view, which includes potential impacts on the special interest vehicle (SIV) fraternity. SIV owners expect fair and equitable considerations and treatment throughout the emissions reductions transition journey.

SIVANZ acknowledges that the Climate Change Commission (CCC) Draft Report (the report) provides a future high level strategic path to transition to a low emissions economy. The report is prescriptive and holds central government to account for implementing those strategies via a range of actions; EG; Adopting a non-partisan approach, Vote Climate Change, put emission reduction debates on parliamentary record, reporting and action due dates etc.

These actions provide the right intent to ensure we can deliver an emissions strategy over the long period without major shifts in policy or implementation at every general election.

The report recognises that as the transition occurs not all targets may be met by the due date and other mitigation actions may be required. The CCC Key Principles (P29) discusses the need to be able to adjust plans if the planned strategy can’t or won’t deliver the expected outcomes.

We are not confident that the proposals for Transport emissions targets can be met as planned through the Clean Car Import Standard, Feebate initiative or some of the proposals in the report.

The proposed initiatives to reduce emissions and CO2 gm/Km by 40% in 5 years is one of the most aggressive in the world. SIVANZ is concerned that this target will become a galvanising number for the CCC and government that must be achieved at all and any cost.

Supporting government supplied reports from the initial Clean Car Standard proposal acknowledged that the reduction targets were dependant on overseas manufacturers and suppliers producing enough right-hand drive cars to meet the NZ market in time. No information is obvious that this situation has improved.

The NZ market is tied to the Australian market and in the absence of any such agreement (currently) linked to Australia and overseas vehicle manufacturers, why would the CCC and government expect new compliant ICE and Electric vehicles to be manufactured in the required numbers to meet aggressive NZ CO2 gm/ Km targets over the next 5-7 years?

The size of the NZ market is less than .0.5% of new vehicle production. SIVANZ does not believe vehicle manufacturers will change models and set up sourcing agreements especially for NZ and the CCC schedule.

It is the probability of not enough compliant (by the CCC criteria) vehicles entering the NZ market by the proposed timeline that concerns SIVANZ.

The inability to obtain sufficient emissions compliant vehicles in the proposed timeline means emissions reductions targets would be compromised.

It is possible that the CCC and government may elect to divert focus from the tabled strategy and search for easier areas of the transport sector for emissions reductions. By doing so enables the CCC and government to demonstrate that NZ is staying on track to meet strategic horizons and the plan is working. Whereas the plan actually failed because of poor supply of low emissions vehicles and absent sourcing agreements.

The aged fleet is not a specific topic in the report and we acknowledge that the CCC is setting a high level framework for the emissions future of the country through to 2050.

That said, the silence on the current aged fleet contrasts with other sector commentary. The SIV business sector contributes $5.5Bn to the NZ economy and employs approx. 35,000 people. Individual SIV owners have in excess of $3.5Bn of vehicle assets and are generally in the higher income brackets.

The aged fleet is an opportunity to reduce the number of high emitters from our roads but is largely unexplored in the report. Those that monitor or have an interest in the Transport sector are aware that most of the poor performing cars on our roads are owned by lower socioeconomic groups.

To punish these groups by targeting their inefficient cars would be politically distasteful, yet, could deliver meaningful emissions reductions. The Feebate discussion to assist lower socioeconomic groups into EV’s fails to address the real winners and losers in the equation; it punishes the poorer groups of our society further because they are unlikely to be able to afford an EV even with a Feebate subsidy.

Special Interest Vehicles (SIV’s), however, are a specific subset of the aged fleet and deserve acknowledgment and separation from the general aged fleet category.

The report uses the term, or similar variants. “transition in an equitable and inclusive way”. The Climate Change Response Act requires the CCC to consider the potential impacts of meeting emissions budgets on the economy, society, culture, regions, communities and generations. SIV owners and SIV businesses operate across all of those areas and aspects and make significant contributions other than financial to other NZ’ers.

The CCC and government cannot stay silent on the unique status of SIV’s and collective contributions to the NZ economy and culturally.

Transition statements around Inclusiveness, Fair, Equitable, Wellbeing and Culture apply to every business and socioeconomics group. It is about how the transition will impact all groups; not just low- socioeconomic groups.

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Chapter 2. Our proposed emissions budget advice.

2.2. Accelerating actions to reduce emissions.

We believe that throughout the emissions discussions the CCC and government need to present all information in an open and transparent way. Both the domestic plan and how international effort impacts the NZ progress. If there is no meaningful change up from the large global emitters any effort NZ makes could be at significant cost to our economy for no real global return.

NZ’s contribution to global emissions is <0.2% yet domestic reporting would have the general public believe that NZ’s total and increasing (transport) emissions are the single cause of the worlds emissions problem. Statistics without proper context or meaning are inflammatory.

The CCC proposals are far reaching and to get it wrong early has the potential to create wastelands of broken regions, communities and individuals across the country that will not be able to be reconstructed.

 NZ emissions reduction targets and actions should be presented with actual costs of implementation and demonstrate how those actions and investments relate to NZ’ers year on year; what the country, region, community, business or individual gain, or, loss, really is.

The report talks about the transition needing to be managed in an equitable and inclusive way, to collaborate with communities and regions and to create genuine partnerships and to consider the wellbeing of all parties and to be fair with the transition.

The SIV community has a $9Bn + investment that is currently being ignored. We appreciate this report is setting the high-level framework for emissions reduction strategies but our concern is that most other areas of the economy get a mention and therefore tagged for a future conversation. 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 SDIV events.

There is a strong favouritism with the EV solution from the CCC with support from the Clean Car Import Standard. EV’s will produce a quick and measurable reduction to emissions if sufficient numbers can be put onto NZ roads fast enough. The silver bullet approach and repeated messaging has the effect of conditioning government officials and the general public into believing there is only one real solution for emissions reduction; it may produce a subconscious bias against other solutions.

The subconscious bias could prevent other viable solutions being explored in depth, with an open mind and appropriate budget allocation. EG. There does not appear to be a strong desire to get started on exploring the biofuels or other liquid fuels as parallel solutions to an EV roll out. Liquid fuels have the potential to positively affect emissions reductions from the aged fleet. This is a missed opportunity in the early phase of setting the emissions reduction strategy.

SIVANZ Recommendation List #1.

• Be honest with NZ’ers and tell them what the cost to them will be to achieve emission reductions and their communities.
• Provide detail about industry impacts, job losses (or gains) and the impacts geographically.
• Explore and support a wider range of solution options and broadcast proposals with equal fervour and budget allocation as the EV solution promotions.
• Provide real Cost/ Benefit calculations of proposals.

Consultation Question #1.

• Noting our recommendations, we support the principles to guide the CCC analysis.

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 2.3. Emissions budgets-stepping down emissions in Aotearoa

Having a target budget is a sound policy. We are not sure that all economic sectors are being asked to contribute fairly and equitably to the total reduction numbers in the short term.

For example, the Clean Car Import Standard has set an aggressive 40% reduction target of CO2 gm/ Km over the next 5 years. This is aggressive and will be incredibly disruptive to the motoring industry and public. On another hand the agriculture sector appears to be given a free pass for the next 5 years and there is also a weakness in the report around “avoiding unnecessary cost……….. by avoiding the need to scrap assets before the end of their useful lives”. This is a good business asset management statement, but, it also opens the door for excuses or time extensions when or if the larger businesses discover the cost of transition is higher than expected.

The transition must be fair for all participants. The person who pays more for a higher emitting vehicle 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 transition.

It is not clear to us that strategies are clear and deliverable across all sectors to say with confidence that the targets are achievable.

Consultation Question #2.

• SIVANZ cannot determine that the budget recommendations are appropriate or realistic.

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2.6. Enabling an Enduring Climate Transition.

SIVANZ supports the need to maintain a long-term strategy for emissions reductions. Having non-partisan agreements, Vote Climate Change funding mechanisms, central/ local government cooperation etc removes the potential for continual Ad Hoc changes to the strategy dependant on each general election outcome.

We support open, honest and transparent debate and those discussions should be a matter for public record. It gives the public an opportunity to support and vote for the party most aligned with their own emissions reduction positions.

However, while the report doesn’t set the emissions reductions strategies in stone a non-partisan agreement and other cross -group(s) operational alignment, organisations need to have confidence that they can offer alternative views to the strategy when required.

We submit that the large sums of funding allocations that will be on offer may create an environment where political (funding) leverage could be applied to some groups who may be perceived as “out of step” to encourage a preferred direction or outcome.

Every political party and organisation involved with emissions reduction needs to be able to offer alternative views without fear of political interference or consequence from other self-serving groups. This includes withholding funding.

All organisations have a responsibility to call out excessive societal disruption, excessive costs, a poor strategy or poor implementation of strategy without fear of sanction.

Consultation Question #5.

• SIVANZ supports the need for cross party support on emissions budgets.
• SIVANZ supports political party debates on emissions budgets a matter for public record.

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2.6.2. Coordinate effort to address climate change across Government.

The setting of budgets accompanied by policies and operational strategies is a fundamental business task and is expected from government.

Nominating business owners is also a fundamental step in accountability for delivery of a project as is allocating appropriate funding.

The emissions reduction transition will require large sums of funding allocation. There is risk of manipulation and (funding) leverage to achieve political (government) or self-serving interests. EG EV’s promoted and heralded publicly as the silver bullet solution ahead of every other possible emissions reduction options.

Establishing a multi-agency appropriation mechanism to focus government spend is appropriate. Vote Climate Change is not an appropriate title label for this process.

Vote Climate Change has the potential to be abused by politicians around the time of general elections. It has the potential to confuse and mislead voters.

The report proposes that the Government develop its first emissions reduction plan by December 31 2021. The plan is for the period 2022 – 2025; the first emissions budget. This is ambitious for government to consider feedback and formulate a good plan based on the final report expected in May 2021.

For example, the Clean Car Import Standard will not have delivered any result with respect to lowered emissions vehicles and their impacts. The CCC and government are assuming real and meaningful emission reductions occur from January 2022 – 2025 during the first emissions budget period from low emission vehicle imports.

They will likely base the December 2021 emissions reduction plan, in part, on the back of expected emissions reductions from the Clean Car Import Standard. If those emissions reductions are not realised, we run the risk of the emissions budget plan being out of alignment with reductions reality within the first year of our transition.

This may affect the CCC and government credibility to deliver on climate change initiatives.

Such an aggressive timeline does not give all parties time to consider deeply the proposals, alternative proposals, Clean Car Import Standard results, further clarification or development of ideas consultation, the cost of implementation and the detailed and real (open, honest and transparent) impacts on regions, communities, business sectors and individuals.

In the absence of quality time, it is likely the path of least resistance be adopted for convenience. Once a decision is made using this criterion it may be difficult to “undo”; Politicians are not known to reverse decisions easily, even if they are ill conceived and poorly implemented.

SIVANZ Recommendation List #2.

• Move the first emissions reduction plan delivery date to 30 June 2022 from 31 December 2021.
• Put funding decisions on public/ parliamentary record demonstrating robustness and quality of decision-making criteria.
• Instigate external audits of funding allocations and decision making against the emissions reductions strategy.
• Publicise audit reports bi-annually.
• Do not adopt the Vote Climate Change slogan.
  •  Identify a more suitable alternative that cannot be abused or used mischievously by politicians.

Consultation Question #6.

Noting the SIVANZ recommendations above, we support points a,b, c of Enabling Question 2

• SIVANZ does not support Enabling question 2, point d.

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2.6.4. Central and local government working in partnership.

As we have stated in the section above, the emissions reduction transition will require large sums of funding allocation. There is risk of manipulation and (funding) leverage to achieve political (Central and Local government) or self-serving interests. EG EV’s promoted and heralded as the silver bullet solution. A skew of this type may enable a funding manipulation of (new) rules so that developers receive cash or kind to incorporate EV related infrastructure into developments when normally those value-add items are self-funded; taxpayers should not be funding value add items for private developers businesses.

There is potential for Local Government to introduce emissions reductions solution bias into their rules and approved developments. The EV silver bullet approach is an easy solution to fixate on and develop new rules that deliberately affirm EV’s as the preferred solution. For example, new housing developments require a certain number of car park spaces. It could transpire the new housing estates only provides parking for EV vehicles.

That approach may introduce a discriminatory mechanism against the owners of fossil fuelled vehicles. The owners of a fossil fuelled vehicle are not permitted to park their cars so are effectively excluded (discriminated against) from purchasing in the estate.

SIVANZ Recommendation List #3.

• Put funding criteria and decisions on public record demonstrating robustness and quality of decision making.
• Ensure that no rules or mechanisms exist that could exclude or discriminate against any vehicle owner or vehicle type.
• Instigate appropriate external auditing of funding allocations and decisions made against the emissions reductions strategy.
• Publicise the audit reports bi-annually.

Consultation Question #8.

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2.6.5. Ensuring inclusive and effective consultation, engagement and public participation.

Most NZer’s don’t know the impact that the report proposals are going to have on them personally, on their region, on their communities or the country as a whole.

As the report acknowledges, there are many representative groups who have the knowledge and capacity to prepare submissions or manage conversations that influence government. The issue is most people don’t have that collective ability to respond; to have a voice.

The significance of the proposals and the probable impacts is significant and not well understood by the general public.

Very public government sponsored and funded promotional campaigns focus on the extremes of the conversation; EV’s are good and clean. Fossil fuelled vehicles are dirty and bad. There is no balanced public conversation or explanation of options or long-term direction. In our opinion these types of campaigns are designed to condition the general public into;

• believing EV’s are the only emissions reduction solution.
• attributing blame for negative emissions impacts onto fossil fuelled vehicles and industries.
• divert attention from impending unpopular changes and foreseeable impacts.

In the absence of a balanced conversation and full understanding of the emissions reduction proposals, the transition consequences will be overwhelming for communities and effectively render them powerless to influence better outcomes for themselves and communities.

The public forum/ public assembly concept has value if it is targeted, structured and relevant to a particular audience.

We would recommend that the proposals are taken to the people for face-to-face sessions. The applicable agenda to be well publicised and detailed with proposals and potential outcomes prior to the session. People will respond if they understand how proposals will affect them personally, their communities and if they think their voice can influence their futures.

It may be beneficial that face to face sessions also include post proposal implementation results; did the changes deliver the right outcomes at the right cost.

We acknowledge that there will be significant upfront organisation effort and cost to establish a detailed consultation approach. We submit that early and relevant engagement would encourage participation. As the public gained in knowledge and understanding of the discussion, the face-to-face sessions could reduce and potentially move to an online forum.

We note that the Progress Indicator for Enabling recommendation #5 is that the government publish a proposal on the mechanism it will use to incorporate the views of all NZ’ers. The delivery date is 31 December 2022.

This date is not synchronised with the first emission budget release date. The first emission budget release (December 31 2021) sets the transition in motion. It’s disrespectful to NZ’ers to ask for their inputs into significant change proposals some time in 2023 well after transition implementation has commenced.

SIVANZ has recommended the first emissions budget date be moved out to June 30 2022. We propose that the budget release date and a published detailed mechanism to consult with all NZ’ers appropriately be the same date.

The report acknowledges the risk of over consulting. It’s a valid point but if meaningful engagement and inclusiveness are genuine goals of the CCC and government then a mechanism needs to be identified. The report states that climate change action will involve making choices, judgements and trade-offs and that all NZ citizens should be involved in making such judgements.

For that to happen the CCC and government have an obligation and duty of care to do everything possible to reach all citizens of NZ so they are not blindsided, isolated or rendered powerless by the changes.

Without a national discussion, the groups that do have knowledge and capacity to engage with government will be permitted by default to be the only influencers in the climate change discussion. That has the potential to skew decisions in favour of a preferred/ manipulated government direction, decisions that benefit self-serving groups or both.

SIVANZ Recommendation List #4.

• Promote with an equal funding allocation all emissions reductions options; not just EV’s
• Align the timing of the first emissions budget with the detail engagement mechanisms government will adopt to consult and inform the general public.
• Appoint sector and sub-sector champions to set up and deliver engagement facilitation.
  • Review/ audit effectiveness of the champions at the end of the first emissions budget.
  • Monitor consultation fatigue.

Consulting Question #9.

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Chapter 3: The path to 2035.

3.3. We need to avoid pushing the burden to future generations.

“Locking in net zero” (to avoid burdening future generations) is another slogan statement that is well intentioned but has the potential to be abused.

Cynically, It could be a useful, emotive, tool in diverting attention away from the implementation of unpopular or expensive emissions reduction initiatives.

Locking NZ into the global goal of 1.5’C is appropriate, but, NZ should only be contributing to total emissions reductions on a scale that is equal to all other participants in the Paris Accord ( based on comparative eonomic and population size).

Developing strategy that can and would achieve NZ’s goals is appropriate. However, the economic and social costs of the transition must be measured in parallel with global achievements. This means that NZ is investing and delivering on emissions reductions at the same rate as other countries (using comparative population and economy size) and therefore not disadvantaging ourselves economically or socially.

 SIVANZ Recommendation List #5.

• Apply the “Locking in net zero” statement (to achieve 1.5’C global target reduction) only when comparisons with other countries is genuinely relative, measurable and deliverable.
• Measure and publicise openly and honestly international progress and impacts of emissions reduction initiatives. Both economic and social.
• Mirror international emissions timelines and progress. If they are below the Paris Accord agreement targets then pressure should be applied to the high emitters to achieve international targets.  
• Plan the NZ strategy but only Invest in solutions as or when other member countries of similar economic and population size can demonstrate emissions reductions at rates that match NZ targets.
  • We submit that global targets must be met in a fair, inclusive and equitable way by each member country.

Consultation question #10.

• In conjunction with the commentary above and SIVANZ recommendations, SIVANZ would support a focus on decarbonising sources of long-lived gases.

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The report sets target dates for when emissions reductions proposals need to be implemented without consideration of successful delivery, or not, of any preceding initiative.

For example, 2032 is proposed as the end date for all importation of light vehicles that have an internal combustion engine.

If the low emission vehicles strategies up to 2032 have not delivered the right number or type of low emissions vehicles then why would NZ ban all low emission vehicles as a matter of process?

The absence of a remedial option (to strategy failure) indicates a lack of depth to the report in places and therefore allows for manipulation of the strategy.

For every 5 paragraphs on EV’s in the report there is one on alternative options for emissions reductions. This continual EV silver bullet approach adds a negative weighting to a fair discussion on the options. The other options start from a deficit position before the discussion begins.

Box 3.1; (Page 70); Different ways to meet our emission budgets, offers the “alternative” discussion but fails to be meaningful because the adaptations only promote accelerating current proposals not challenging if those proposals are Fit For Future or if they are actually deliverable and or deliverable at a cost effective price. Other options are not mentioned.

Further, accelerating the ban on ICE vehicle imports to 2030 (from 2032) doesn’t address why emissions reduction hasn’t been achieved in the first place.

The report also talks about” further reducing travel” because of a slower uptake of EV’s into the fleet. There is no accompanying commentary on what “further reducing travel” may mean for NZ’ers. It infers a social engineering undercurrent through travel constraints.

EV’s have a significant role to play in reducing emissions. It appears that a “low hanging fruit” option has been initiated. The report fails to actively explore or promote any viable alternative option to EV’s.

Further, the EV discussion continues to only promote the positive, of which there are many, attributes of ownership and use. It doesn’t discuss the future emissions and environmental impacts on battery disposal and management nor does any group talk about the additional 7.5Mt CO2 (average) emissions into the atmosphere at the time of manufacture compared to an ICE vehicle.

In a global discussion, EV owners need to be aware that their purchase has already impacted the global emissions profile. The running costs may be cheaper over the vehicle lifetime but EV owners need to be accountable for the future cost of battery disposal and or management and vehicle disposal when it too becomes end of life. Those costs should be factored in the upfront purchase price of the vehicle. The taxpayer should not carry any cost provision burden.

The report cites similar timelines set by other countries. As we have stated in paragraph 3.3 above, if NZ achievement is in line with other similar countries (population and economic size) then following the strategy initiatives is appropriate. If other countries are not delivering on their goals then we need to check that the impacts on our country to date are sustainable and palatable and be prepared to put in place revised strategies that are sustainable and palatable. In a global sense, NZ should transition at the same pace as our international counterparts.

SIVANZ Recommendation List #6.

• Develop and consult on alternative strategies in detail to reflect  “what If” scenarios. What is Plan B?
• Explain what “further reducing travel” really means for the general public.
• Publicise the EV battery disposal and management strategy and how the costs of disposal or management of the EV and End Of Life items will be funded.
• Transition at the same pace and at the same rate of economic and social impacts as international counterparts of similar economic and population size.

Consulting Question #12.

• In conjunction with the commentary above and SIVANZ recommendations, SIVANZ would not support “our path to meeting budgets as proposed”.

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Chapter 5: The impacts of emissions budgets on New Zealanders.

5.1. Looking at the opportunities – and the challenges.

As the report states, there is the necessity to work alongside people to maximise the benefits and reduce negative impacts.  

SIVANZ has stated elsewhere that we acknowledge that the report sets out a future strategy and does not specifically discuss the current aged light vehicle fleet.

The aged fleet is referenced again because we predict challenges with budget #1 goal(s) delivery and therefore expect CCC and government discussion on the aged fleet opportunities for emissions reductions sometime during the first budget period.  

As SIV owners we are entitled to have a fair and equitable opportunity to have our voice heard even if the aged fleet isn’t on the current CCC or government agenda.

We reiterate the need to classify SIV’s as a separate and distinct vehicle type in the aged fleet category.

SIV owners have a combined asset base of vehicles exceeding $3.5Bn and SIV businesses contribute an estimated $5.5Bn to the NZ economy and employ an estimated 35,000 people.

5.2. How Aotearoa creates a fair, equitable transition for people.

The report states that “it is important that certain individuals and sectors do not unfairly bear the cost-burden of the climate transition.”

The owners of SIV’s and SIV related businesses do not feature prominently in the emissions reduction discussion. Yet the impact on the SIV community from climate change initiatives is likely to be significant unless specific strategies and exemptions can be identified.

The report states that clear and stable policy signals need to be sent to provide predictability for communities and businesses, and allow time to respond. And, that no group(s) should be disproportionately affected by the transition.

A significant number of SIV owners have large sums of money invested in their SIV’s. For some, the SIV’s are a large part of their retirement portfolios. Any climate change initiative or policy that affects the value of this vehicle type has the downstream impact of eroding value off retirement investments.

Consideration needs to be given to SIV owners so that if their asset value erodes through climate change initiatives a compensation mechanism is established so that the SIV community does not  carry the cost of climate change actions and impacts disproportionately.

The report notes that government is expected to develop “targeted assistance” strategies to help groups and communities less able to respond to the effects of climate change initiatives. We submit that SIV owners will not be able to respond in time to eroded SIV values and therefore future retirement wellbeing.

 5.5.3. Small Business

The CCC through recent press releases acknowledges that most NZ’ers do not understand the significance of the changes required to transition NZ into a low emissions economy. Not all SIV related small business owners understand the significance either.

They employ 35,000 people and generate $5.5Bn into the NZ economy. The need to signal change policy early is laudable but more is required other than “adapt and innovate” sentiment.

The report acknowledges that regions and small communities will face challenges in how to maintain their viability because of climate change initiatives and that localised transition planning will be required. SIV businesses operate in those communities as well. For the most part It is mature technology and without targeted help we will lose businesses, communities and employment opportunities quicker than anticipated.

The report recommends that government identify in the first budget period (2022-2025) specific impacts on small business and develop a plan to support them. If we assume that the small business transition discussion has 3 steps, Identify the impacts, Develop Support Packages, Implement Support Packages, it is conceivable that any meaningful small business transition support may not be delivered until the 3^rd budget period; 2031-2035.

The timing of the discussion for SIV small business transition impacts is not synchronised with the promotion of EV’s and the ban on ICE vehicle importation in the first budget period. The SIV fraternity experiences negative weighting (on fossil fuel businesses) now with the multiple drive EV campaigns and positive press releases promoting EV solutions and the “say goodbye to oil” advertising.

All of these statements are designed to influence public opinion about the harm that fossil fuel has on society. They have a negative weighting effect on the current fossil fuelled fleet and the SIV businesses supporting the fleet.

SIV related business groups will feel the impacts from emissions reductions policy and initiatives sooner than most. We submit that a conservative $5.5Bn of economic value is at risk by not paying urgent attention to the SIV business groups and how they can be supported.

The discussion ignores climate change impacts occurring sooner for SIV related businesses compared to others; the proposal is not equitable and well planned. There is not enough impetus on government to act urgently for SIV small business in consideration of other planned emissions reductions initiative roll outs.

SIVANZ Recommendation List #7.

• Add the aged fleet as an agenda in the item before 31 December 2021.
  • Specifically, SIV’s to be separated from the aged fleet category and emissions reduction exemptions distinctly discussed.
• The CCC and government accept that SIV’s are a unique vehicle type within the aged fleet category and a compensatory mechanism be established to mitigate SIV value erosion due to climate change policies and initiatives.
• Investigate, identify and consult on the impacts from the climate change transition on SIV related businesses by June 2022.
• Develop with the SIV business community support packages by December 2022.
• Allocate funding and Implement SIV businesses support packages no later than January 2023.

Consultation Question 13. An equitable, inclusive and well-planned climate transition.

We agree with the high-level discussion, intent and direction of the small business support packages.

We disagree with the proposed timing of actions and lack of understanding that some small business groups will require urgent consideration.

SIVANZ does not support the package of recommendations and action as written.

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 Chapter 6: Direction of Policy the Governments emissions reduction plan.

6.1.1. Transport.

Accelerate uptake of electric vehicles.

In the SIV context, the direction being outlined in this chapter encourages government to introduce punitive measures that clearly impact SIV owners. Proposals to “use emissions pricing and other market incentives to influence choice” and “….. restricting or banning the import and manufacture of internal combustion vehicles” are not being made in in the context of an equitable transition. SIV owners will be disproportionately affected by these types of measures.

SIV owners are generally in the higher income brackets. Their combined tax contributions, in the broad sense, will be used to fund many other low-income groups into an EV or other low emissions solutions. At the same time the report is encouraging disincentives for continued ICE vehicle purchase and operation.

The report suggests that government use the tax system to discourage the purchase and continued operation of ICE vehicles, evaluate the role of other pricing mechanisms, such as road pricing, can have in the transition to a low emissions and equitable transport system.  To be clear, these suggestions are cost heavy on SIV owners. This is not a fair and equitable discussion or position for the SIV community.

Further, SIV events around NZ support regional and community economic prosperity. A punitive approach to SIV use and owners will have the, planned, impact of restricting SIV use. SIV use constraints will also have a downstream impact on domestic tourism and communities who benefit significantly from SIV events.

 In the segment Time-critical necessary action 2; Accelerate light electric vehicle uptake. (P108), to promote an accelerated uptake of electric vehicles least 50% of imports need to be electric by 2027.

To encourage those targets being met, it is proposed that a time limit of 2035 be agreed to ban light ICE vehicles entering, being manufactured or assembled in NZ, other than in exceptional circumstances. The report supports an earlier date for an ICE ban of 2030 if possible.

Within the SIV business fraternity, there are a significant number of national and internationally renowned artisans who manufacture cars, repair and assemble cars and associated ICE components for local and international clients. The businesses involved add significant economic value to NZ.

The report proposals have a consequential impact of stopping these businesses from operating. There is no discussion or recognition of their significance to the SIV industry. As a consequence of this lack of understanding a significant part of the NZ SIV economy is probably permanently disrupted.

The fair and equitable transition to a low emissions economy mantra does not appear to be applied universally or uniformly across all of society.

Low-income and disadvantaged groups need a range and appropriate levels of support. It is also true that other groups that will be disproportionately affected by climate change initiatives also need to be identified and supported, irrespective of income levels.

SIVANZ Recommendation List #8.

• Categorise Special Interest Vehicles differentially and separately from the “aged fleet”. category
• Exempt SIV’s from any and all emissions reduction initiatives and proposals.
  • SIV’s travel low Km’s per year and are for the most part as fuel efficient as when they were manufactured.

Consultation Question 14. Transport.

We find this chapter disproportionately and unfairly affecting SIV owners and SIV related businesses.

SIVANZ does not support the package of recommendations and actions for the transport sector.

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6.2.2. Support behaviour change.

A specific focus on how behaviour change can support climate action and will become an important tool in helping NZ’ers come to grips with the required changes and how those changes will affect them and how they will adapt to them.

The danger is that government and CCC messaging can be skewed in favour of achieving a particular predetermined outcome. There is no limit to the funding allocations for government to achieve predetermined outcomes.

We already have a strong one-sided promotion for the uptake of EV’s on television with an accompanying campaign highlighting the need to stop using “dirty oil”. Both are funded by government and both are designed to influence behaviour or influence in favour of one solution at the expense of the other; a negative weighting against fossil fuelled vehicles and industry.

Government has an obligation and accountability to serve all NZ’ers equally and not discriminate against any group in the transition to a low emission s economy. Their capability to social engineer the country has no limits other than the voice of the people to hold them to account.

The transition to a low emissions economy will require significant change across the board if we are to achieve 2050 targets with our economy, regions, communities and groups intact.

A fair and equitable transition needs to deliver climate change actions in real terms equally.

A “fair and equitable transition to a low emissions economy” cannot become just another political slogan.

 SIVANZ Recommendation List #9.

• Respect New Zealanders enough to genuinely hear their voices.

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End SIVANZ Submission.