Following member input into our consultation response process, the REA has submitted a final response to a Government consultation considering the policy design of a zero-emission vehicle (ZEV) mandate.
- Predictability of supply of ZEVs, therefore demand for EV charging
- Ambitious targets, driving higher demand for EV charging over a manageable timeframe
A summary of our key positions taken in our consultation response can be read below.
ZEV Uptake Trajectories
- We are supportive of ZEVs accounting for 80% and 100% of all new vehicle sales by 2030 and 2035
- We call for Government to adopt a more ambitious short-term trajectory
- We believe that the trajectory should begin in 2024 at 30% – in line with CCC Balanced Net Zero Pathway – intersecting with the TDP/NZS at 2029. From there we believe the ZEV mandate should continue to follow the trajectory of the TDP/NZS scenario until 2031, before slowing significantly to accommodate “hard-to-reach” vehicle categories and use-cases. Illustrated by the red dotted line
- The REA agrees that the annual frequency for ZEV mandate sales targets is appropriate.
- These targets should be reviewed, but no more frequently than once every two years
- Under normal circumstances, reviews should be considered “upwards only”
- Whilst the REA is broadly supportive of ZEV mandate targets being set as a percentage of all new vehicles sales, we are concerned that this metric is vulnerable to fluctuations in the overall new vehicle market.
- We recommend that Government tracks total vehicles sales against an anticipated sales trajectory, and sets a lower threshold that, were total car sales to fall beneath, would trigger an exceptional review of the ZEV mandate targets. We would suggest that, where this threshold is exceeded, the ZEV mandate targets should be increased in the short-term to ensure that the number of newly registered ZEVs remains comparable
- The positions stated above are mirrored for vans.
- Either alongside or as part of the ZEV mandate sales targets for vans, Government should introduce separate sales estimates/targets for battery electric vans and those powered by other zero emission drivetrains (most notably hydrogen) – to provide some predictability of demand for EV charging from ZEV vans.
ZEV Certificate allocation
- The REA is supportive of the Governments proposals to: a) only award credits to vehicles meeting a minimum eligibility criteria; and b) award additional credits to vehicles meeting conditions deemed favourable to the wider decarbonisation of light road vehicles.
- The credit eligibility and incentivisation metrics should be kept as simple as possible
- Measures must be in place to ensure that the ZEV mandate delivers a predictable number of ZEVs – not just a predictable number of credits
- It is essential that the ZEV mandate certificate system is fully transparent
- We are broadly supportive of Governments proposed metrics for ZEV eligibility
- Once plug-and-charge has been standardised through ISO15118, this should become part of the eligibility criteria
- We have highlighted several concerns in the Government’s proposed metrics for awarding credit incentives
- We are in favour of vehicle efficiency being used as the basis for awarding incentive credits
Banking, borrowing and transfer of ZEV certificates
- The REA supports proposals to not allow banking, borrowing or pooling
- Credit trading should ideally take place in the same trading period or, at the very least, delayed no longer than one trading period
- We have no view on minimum price for certificates
- We do not support there being a cap on the number of certificates earned by a vehicle manufacturer
- There should be a cap on the maximum certificates that can be awarded for a single ZEV
Operation of the ZEV mandate
- We agree with the Government’s position to link the ZEV mandate responsibilities across both cars and vans for vehicle manufacturers that produce both.
- We have no view on whether there should be any specific exemptions or derogations
- Any exemptions or derogations that are made should be published, alongside evidence of why they are necessary
Regulating CO2 emissions in the new non-ZEV fleet
- The REA believes that CO2 emissions regulations should remain in place, but not be linked to requirements under the ZEV Mandate, nor be part of the ZEV Mandate certificate system
- We agree that the CO2 emission requirements for non-ZEV vehicles should only undergo nominal reductions over time