Street Person Costs Dialogue Doc 2022

Street Person Costs Dialogue Doc 2022


Drive Electrical utilises the experience of our board, member base and researchers to make well-informed submissions on coverage that pertains to the decarbonisation of the transport sector. Under is our submission on the dialogue doc Te Huringa Taraiwa: Te arotake I te pūnaha utu kaiwhakamahi rori | Driving Change: Reviewing the Street Person Costs System. The doc covers potential modifications supposed to enhance the Street Person Costs (RUC) system and help the uptake of low carbon autos.


12 April 2022 

Govt Abstract

Drive Electrical is a not-for-profit advocacy organisation supporting the uptake and mainstreaming of e-mobility in New Zealand, a key a part of decarbonising transport.

Drive Electrical represents a member base comprising new automobile OEMs, used automobile importers and distributors, infrastructure organisations (electrical energy turbines, distributors and retailers, electrical car service gear suppliers), e-bike/scooters, heavy car importers, finance, fleet leasing and insurance coverage corporations, together with electrical car customers.

We have now framed this response round our mission, which is to speed up the uptake of e-mobility in New Zealand. We acknowledge that an RUC exemption is at the moment in place for mild autos and heavy electrical autos (however not hydrogen gasoline cell autos).

We additionally would welcome the chance to react to extra particular proposals sooner or later. It’s, partly, troublesome to completely assess the long run position of RUCs in decarbonising transport with out the context of the broader Emissions Discount Plans in transport.



The long run function of RUC and externalities

We help Te Manatū Waka’s 5 aspirational outcomes for the transport system, particularly {that a} transport system should decarbonise.

A future RUC system needs to be designed so it allows or helps New Zealand to attain its local weather change targets, in addition to generate funds for transport infrastructure.

Nonetheless, the exact position of RUCs on this transition wants cautious consideration together with:

  • Accelerating e-mobility is a vital part of lowering transport emissions. A future highway pricing system must be rigorously designed in order that it doesn’t curtail the uptake of e-mobility or different new low emissions transport applied sciences or fuels.
  • There are already insurance policies and taxes in place which can be designed to speed up e-mobility, such because the ETS, the Clear Automotive Low cost/Penalty and different proposed coverage measures. If highway consumer costs are additional used to disincentivise ICEs/stimulate EVs, how would that work alongside these current measures? Coverage effectiveness, value per tonne of emissions lowered, fairness and public help all should be thought of collectively.
  • To keep away from perverse outcomes, any modifications to RUCs that had been designed to help local weather aims would want to see equal measures positioned on petrol autos by different mechanisms, in order to not disincentivise EV uptake. In different phrases, any incentives (or disincentives) ought to all the time help EV uptake, over petrol/diesel autos.

We additionally help the exploration of how highway consumer costs sooner or later may very well be used to get better different prices relating to move, past direct roading prices, together with air pollution and congestion. Concepts round highway pricing and congestion charging needs to be thought of as a part of a bundle of mechanisms to make sure there may be an funding in infrastructure, but additionally that local weather and different aims will be effectively met.

The uptake of public and lively transport and fairness should be thought of as properly, and shouldn’t be undermined by modifications to RUC.


EV Mild autos and RUC

New Zealand has a proposed goal to achieve 30% of the sunshine car fleet as electrical by 2035 within the Authorities’s Emissions Discount Plan Dialogue Doc. This can require round 1 million new and used EVs to be introduced into New Zealand over the following 13 years.

Measures can be required to stimulate electrical car uptake to achieve this goal.

By March 2024, the Clear Automotive Programme can have solely been in existence for 2 years. By then, we would anticipate round 150,000 electrical autos on the highway (estimated).

Any modifications to the RUC exemption should not undermine momentum in direction of assembly New Zealand’s emissions budgets and transport targets. Whereas it isn’t understood the extent to which the RUC exemption helps the uptake of e-mobility in New Zealand, abroad proof has proven that eradicating EV incentives too quickly, slows down their uptake.

Choices round implementing highway consumer costs should be conscious of ranges of e-mobility uptake, accessible know-how, and the availability of that know-how. We should acknowledge that New Zealand is a taker of those new applied sciences and that we have to be open to newer/higher applied sciences.

That mentioned, we recognize that methods to fund transport infrastructure, together with roads, should be recognized as petrol taxes and highway consumer costs generate much less income over time. This funding shortfall will intensify over time, notably as ICEs are phased out globally by each states and by producers from 2030.

It’s cheap, in time, for EV drivers to contribute to a fit-for-purpose highway pricing system. Finally they need to pay no extra in equal RUCs than they might pay driving an analogous fossil gasoline car.

We additionally recommend that when EVs attain value parity with ICEs and adoption reaches a tipping level, authorities incentives and exemptions might want to play much less of a task in supporting uptake. RUCs needs to be launched progressively as this variation takes place.

We be aware the problem of implementing the RUC on EVs already on the highway in March 2024. Probably, this may very well be carried out step by step and needs to be signalled properly upfront. We help a distance-based exemption. As an illustration, to introduce RUCs for EVs from a specified odometer studying, eg first 30,000kms no RUC payable, to encourage the acquisition of recent EVs (that are then recycled again into the market as second-hand EV choices).



Shifting to distance-based charging needs to be the aim, utilizing digital means or in affiliation with the annual registration course of (with customers capable of top-up simply on-line). We’d welcome the chance to seek the advice of on a particular proposal choices. There are implementation complexities with this that should be explored. Specifically, the benefit-costs.

Different complexities embody:

  • Privately funded roading contains 12.1% of the New Zealand community utilized by mild autos for day-to-day journey, in keeping with NationalMap. If we use a distance-based methodology how is journey on these roads exempted from highway consumer costs?
  • How will RUCs on mild car EVs be levied, if they’re completely different weights on a distance calculation?


Heavy autos and RUC

For heavy electrical autos, we acknowledge that the uptake of electrical buses in New Zealand is beginning to speed up, nonetheless, the variety of electrical vans remains to be very low.

At COP-26 New Zealand signed the worldwide Memorandum of Understanding on Zero-Emission Medium and Heavy Obligation Zero-Emission Autos (ZE-MHDVs) which commits to having 30% of heavy car gross sales as zero-emission by 2030 and 100% by 2040.

The RUC exemption on heavy autos needs to be retained till there may be a minimum of an equal bundle of incentives for heavy electrical autos in place which is in line with attaining the World MOU on ZE-MHDVs.

For current electrical heavy autos, the RUC exemption shouldn’t be eliminated completely if up-front incentives are established for brand new heavy electrical autos to switch the RUC exemption, as this penalises early movers in heavy electrical autos which have made a major non-public funding for public profit. As an alternative, the RUC exemption may very well be retained or wound down over the lifetime of current electrical heavy autos which haven’t benefitted from buy incentives.

To make use of a particular instance Mahu Metropolis Specific took supply of two full-electric luxurious coaches in 2021. These autos run below a allow resulting from their weight, as battery autos are extra equal than diesel equivalents. If RUCs had been to be utilized this might value Mahu $837 per 1000km. Successfully, this could make it dearer to run zero emissions coaches, relative to their diesel counterparts.

In abstract, we see a necessity for the exemption to proceed by to a minimum of 2030 and this to be properly signalled to the market. As well as, we suggest some type of grandfathering scheme or related be used to recognise people who moved early to undertake electrical coaches and vans and never penalise them for this transfer.


RUCs on buses/coaches 

We additionally be aware that buses have excessive loadings in peak durations (mornings and late afternoons), however outdoors this era have comparatively low masses. Buses run routes as much as 20 hours per day, and just for 4 hours are loaded to Gross Automobile Mass (GVM). Operators are paying for that GVM fee on their RUCs when more often than not they function at 4 tonnes or so much less. Any consideration of RUCs ought to take this into consideration – given the general public curiosity in stimulating public transport (and electrical buses).

If a weight-based methodology is sustained, a possible resolution may very well be having buses pay for an RUC on tare weight, and add a passenger cost by the ticketing system.


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September 2022