NRC Advocacy submission and consultation summary

The second quarter of 2024 has seen many submissions and consultations for the NRC team to work through. Local, District and Regional councils consulted on their Long-Term Transport Plans, and we submitted on many appearing before council committees throughout the country either in person or via video link.

Turning now to central government and agencies, it is fair to say this Government is moving at pace and is focused on lifting productivity and the economic performance of New Zealand.

This pace will continue and the period for consultations will remain tight, so if you see a request for feedback on an issue you have an opinion on, please get in touch. We have seen several examples already where points raised in our submissions have changed policy.

Coming up we will be finalising our feedback on Health and Safety Act reform with MBIE, Long Term Insights Briefing for MOT, Road Funding reform for MOT and Regulatory Rules review with NZTA.

Links to Key Sections in this article:

  • Infrastructure
  • Labour and skills
  • Just transition

Infrastructure  

Level crossing closures for Auckland City Rail Link (CRL) 

Here is another example of how a lack of connected long-term planning leads to serious issues for our sector.

For those unfamiliar with Auckland, in particular the Takanini industrial area, here is some context. Auckland public transport has been undergoing significant investment so passenger trains can operate more frequently reducing the reliance on cars. The City Rail Link project has been one of the largest infrastructure projects seen in New Zealand. It provides twin 3.45 km tunnels under the Auckland CBD so trains can run in a circuit instead of the existing dead end stop at the Auckland CBD.

Once complete (November 2025) trains will increase in frequency, which will create a challenge where level crossings will be closed needing to be replaced by grade separation.

This is where Takanini enters the frame. Located in south Auckland adjacent to both the Southern Motorway and the North Island main trunk railway access to industry is via three level crossings that will have barriers down for 78% of the time from November 2025.

Given the project’s length of time in both planning and construction, it is reasonable to expect the grade separation would be completed BEFORE the increased rail traffic closes the crossings. Sadly, this is not the case. Auckland Transport does not have the project starting until 2025 with construction 2028-2029 – a staggering lack of foresight.

For transport operators who service this industrial area there will be years of disruption that could have been mitigated if the projects were aligned.

NRC is calling for greater connectivity between agencies and we will be looking to ensure the new Infrastructure Agency being established by Minister Chris Bishop provides a framework to co-ordinate projects to minimise disruption.

RONS (Roads of National Significance), RORS (Roads of Regional Significance), Potholes and Refurbs 

There is no question this Government understands the importance of having a fit-for-purpose transport network. It has wasted no time in restarting the Roads of National Significance and has added a new Roads of Regional Significance list.

In addition, there is clear direction on the expectation potholes are to be repaired quickly and refurbishment of the network needs to get a lot closer to the level needed to avoid the degree of degradation we have seen over the last decade.

What we will be looking for is locked-in dates where shovels hit the ground and that the projects are kept on track to be delivered.

Labour and Skills 

Industry training reform 

NRC attended briefings on the reform of the tertiary education sector being led by Minister Penny Simmonds and it is fair to say the review and consequential restructuring of the sector is going to take some time.

NRC is pushing for industry training to be controlled by the industry and we have attended several workshops with other associations in our sector and MITO, which provides on-the-job learning for people working in the automotive and commercial road transport, on what the various options are.

NRC members are encouraged to take advantage of the scholarship opportunities MITO has available to upskill themselves and their teams. There are a number of micro-credentials available that will formally recognise the skills attained.

Employment New Zealand 

The transport sector is generating too many calls to the Employment NZ complaints line.

Frustratingly, most of the complaints are caused by employers not complying with the basics of New Zealand employment law.

If your company uses subcontractors, it would be wise to run a compliance check that they understand their obligations. There are multiple language versions available here:

Minimum rights of employees – language translations | Employment New Zealand

Immigration New Zealand 

Work is about to get underway to update the Green List that has pathways to residency.

NRC will be working to get our sector included as attracting the right people.

Unfortunately, there were far too many examples of bad practice under the Accredited Employer Work Visa scheme. Immigration New Zealand is still processing complaints so if you have examples, contact the Immigration New Zealand exploitation team 0800 200 088.

Just Transition 

Driving towards a decarbonised future for New Zealand’s transport sector

Our sector plays a critical role in shaping New Zealand’s environmental future. With transport accounting for 17.5% of the nation’s total emissions, we are acutely aware of our responsibility in the collective effort to reduce carbon output. As the economy begins to rebound, however, our sector’s emissions are likely to increase unless we take proactive steps to change the profile of our heavy diesel fleet.

Looking ahead, the future of New Zealand’s heavy fleet is likely to involve green hydrogen trucks for long-haul transport and battery electric commercial vehicles (BECVs) for last-mile deliveries. Green hydrogen trucks, with their extended range and quick refuelling capabilities, are ideal for transporting goods over long distances, such as appliances and store goods. On the other hand, BECVs are well-suited for urban environments where they efficiently handle shorter trips, including the delivery of fresh groceries and other perishable items. Both technologies will play crucial roles in achieving a more sustainable transport sector, addressing diverse needs within our supply chain while reducing overall emissions.

To effectively decarbonise transport, we must expand our focus beyond merely transitioning to cleaner vehicles. NRC believes increasing productivity should be added to the Government’s list of solutions. By moving more goods with fewer resources, we lower emissions and drive economic growth. This dual benefit is essential in an era where cost pressures and environmental concerns are equally urgent.

Enhancing productivity is also key to overcoming the financial barriers associated with adopting heavy electric and hydrogen trucks. The initial capital costs of these vehicles, combined with other disincentives, can be daunting. However, by improving the efficiency of our fleet, we can offset these costs and make the transition more viable for fleet owners.

A critical area where productivity gains can be made is in the review of the Vehicle Dimension and Mass Rule. As we consider the changes necessary to accommodate battery electric vehicles (BEVs) and hydrogen trucks, it’s crucial we also look at how we can lift the overall productivity of the fleet. Adjusting axle mass limits for these innovative technologies will allow more efficient transport operations, reducing the number of trips required and, consequently, the overall emissions.

However, technology alone won’t solve the problem. Currently, there is a significant gap in the charging infrastructure for heavy trucks, particularly those towing trailers. Without a robust network of rapid charging stations, the adoption of electric heavy vehicles will be severely limited. Many of our members are already struggling to secure enough electricity to charge even a single truck, making the expectation that heavy freight vehicles will charge solely at their depots unrealistic. A stronger commitment from the Government to support the rollout of heavy vehicle charging infrastructure is essential.

We also believe strengthening the Emissions Trading Scheme (ETS) is crucial to creating a credible market for carbon which, in turn, will provide the certainty needed to incentivise the transition to lower-emission vehicles. However, NRC cautions against raising the price of carbon before lower-emitting technologies are widely available. Any increase in costs for our sector will ultimately be passed on to consumers, potentially stalling the transition rather than accelerating it.

The Government’s provision of a $30 million grant scheme for hybrid or zero-emissions heavy vehicles is a positive step that will help early adopters overcome upfront cost barriers. This will accelerate the uptake of these vehicles, allowing fleet owners to see low and zero-emission trucks operating in real-world conditions. By identifying and resolving the barriers to adoption, we can pave the way for a smoother transition for the entire sector.

Energy sector 

As 2030 approaches at 140,000km/hr there is an increased awareness that reducing our reliance on fossil fuel as an energy source is reliant on having realistic and commercially viable alternatives.

Simply turning off fossil fuels is not going to help New Zealand as even if we ceased all emissions our sacrifice would barely register globally. We are simply too small to make a difference to global emissions.

What we can do is lead the way in sustainable transition.

New Zealand has some unique advantages that place us in an advantageous position if we learn to capitalise on our strengths:

We already have a high percentage of our electricity needs produced by renewable sources.

From a transport perspective our distances between origin and destination are small with most truck trips falling within the range of emerging battery and hydrogen technology.

We are highly adaptive and innovative.

We have a single government and regulatory system.

We do face some challenges, however:

  • We are already running out of generation capacity at peak load times.
  • We are reliant on overseas supplied vehicles competing for supply.
  • New Zealand energy customers are highly price sensitive.
  • Existing electricity network does not deliver sufficient power to support transport electrification.

Balancing the discouragement to use fossil fuels with the availability of alternatives will be essential if New Zealand wants to avoid loading cost into the economy.

NRC will be advocating for long term solutions to increasing the supply of alternative energy sources at a pace that ensures supply is there as vehicle suppliers transition to alternatives to traditional diesel.

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