In our submission to the Ministry of Transport on transport emissions - pathways to net zero by 2050, we support the commitment to lower emissions and our national emissions targets.

MoT’s strategy to reduce transport emissions is incompatible with national targets. A target of zero gross emissions in a large, capital-intensive sector such as transport risks ruinous costs for no emissions benefit, threatening our emissions targets. MoT has not established how its strategy lower emissions under a binding ETS.

Diminishing returns mean MoT should be concerned about doing too much to reduce emissions in transport. MoT should aim to optimise rather than maximise transport’s contribution to national emissions targets. Rapid innovation in low-emissions transport technologies should lead MoT to consider the timing of transport’s efforts to lower emissions.

We urge MoT to:
• Reconsider its proposal to target zero gross emissions from transport.
• Form a view in principle about the relationship between transport emissions policies and offsets.
• Recognise how the ETS could neutralise MoT’s strategy, and
• Investigate the performance of the ETS, recognising this is critical for MoT’s strategy.

For further information, download the full submission.