Submission to the Ministry of Transport ‘Green Paper’ on Transport Emissions

Climate Karanga Marlborough (CKM) is a climate action group of citizens of the Marlborough Region, with the purpose “to assist elected representatives and their officials to pursue policies designed to limit the extent of rapid climate change and help New Zealanders to adapt to its consequences”. We are concerned about the rapid advance of global warming and work to assist our community and government at all levels in mitigating greenhouse gas emissions and preparing the country for the challenges that global warming will bring.
On the whole, we support the great majority of the ideas presented in the MoT green paper and feel that the transition of our society to low emissions transport is an urgent necessity. CKM believes that, if we are to achieve our aim of reducing harmful emissions, then not only do we need to make our consumption of energy in NZ more efficient and effective, we all need to expect to consume, and demand, less energy, particularly energy derived from fossil fuels.
The changes needed to our cities, outlined in Theme 1, are important and necessary, particularly when considering the possibility of limited future transport options in the absence of fossil fuels. Transitioning the nation’s light vehicle fleet to battery electric, proposed in Theme 2, seems to be the most straightforward and low risk option for continued automobile travel. The transition of heavy freight, discussed in Theme 3, will be more challenging and will present more difficult choices.
There are four issues which we wish to submit on, however, where we disagree with or suggest greater emphasis on, strategy elements presented of the green paper. These are outlined below.

1. We urge the MoT to use caution in planning on the success of new, innovative technologies to solve our low emissions transportation needs. The country should not count on technologies that are not already mature and in production. These can be introduced into later plans and emissions budgets, should they eventuate. History has shown that most ‘new’ technologies in energy and transport take decades to mature and reach a scale of production that makes them economically viable relative to existing technologies.
   
   I bring to your attention examples of current technologies that are being implemented in transport and energy to address global warming. These include electric cars, lithium ion batteries, wind turbines and PV solar cells. These have all been around for a long time but are only recently becoming economic relative to fossil fuels. The youngest of these technologies is the Li-ion battery – researched in the 1970s & 1980s, prototype in 1985 and commercial production in 1991. After 30 years, production has ramped up to the point that the price of these batteries is still falling, indicating that the technology is not yet fully mature.
   
   How long will it take to research, proto-type and ramp up production of new technologies such as biofuels and hydrogen for aviation and heavy transport? Not all innovative technologies work out when applied to scale.
   
2. CKM strongly opposes the promotion of biofuels. We base this opposition on the following points:
   
   1. Biofuels, with the exclusion of those based upon farming and forestry residues, take up farm land that might otherwise be used to grow food. In the US, it is estimated that fully one-third of the corn crop is diverted to making ethanol for a petrol additive. This has risen the price of corn domestically and internationally, making it less available to feed people. As a consequence, biofuel projects come under considerable criticism because of the food production that they displace. For example, the activist group Biofuelwatch in the UK and US actively campaigns against biofuel farming.
      
   2. Biofuels made from woody material (i.e., cellulosic ethanol) have the potential to greatly reduce the amount of farmland dedicated to biofuel production, but require more chemical processing to produce and are, therefore, much more difficult and expensive. Despite more than 100 years of research and development in Europe and the US and significant government subsidies, there was only one commercial cellulosic biofuel plant still in operation in the US in 2018 (Robert Rapier, Forbes, 11 Feb 2018). The conclusion here is that cellulosic ethanol biofuels are difficult to make, even with generous government support. New Zealand should not count on this technology until it can be demonstrated at scale.
      
   3. The production of first generation biofuels (those made from plant sugars, starch and oils) will likely be at an industrial scale, implying large scale monoculture farms using fertiliser, pesticides, herbicides and heavy soil-compacting machinery. This is unlikely to be the type of landscape change that New Zealanders will be comfortable with and will likely result in the same kind of organised resistance that biomass energy development in the UK has faced.
      
   4. Biofuels based upon cellulosic feed stocks have been optimised to use fast growing perennial grasses, such as switch grass and Arundo Donax, which is a serious riparian weed pest in western North America. Hybrid miscanthus x giganteus, which is sterile, might avoid the problem of weed spreading but is more expensive to plant.
      
   5. Since biofuels are now blended with liquid petroleum fuels to reduce emissions and improve social acceptability, there is the risk that oil & gas producers will over-sell biofuel availability and work to delay the elimination of petroleum fuel use, in order to maintain fossil fuel sales.
      

The conclusion here is that New Zealand should not count on biofuels to transition away from petroleum fuels. In addition, importing these fuels from overseas, as suggested in the green paper, simply off-loads these problems to another country, along with the potential for continued native forest destruction to grow our biofuel, much like the present day situation with palm oil.
CKM submits that the MoT should look to the Climate Commission for its recommendation on biofuels. In recommending a moratorium on new fossil gas hook-ups to industry and residences, the Commission suggested that the fossil gas industry first demonstrate that blending of low-emissions gases, such as bio-methane or hydrogen, with fossil gas (the industry’s proposed method to reduce fossil gas emissions) is feasible and will not result in higher costs to consumers (Section 15.1.5 of the final advice). This would prevent the construction of expensive new fossil gas infrastructure, for which locked-in gas customers would be required to pay.
Similarly, the petrol industry is proposing blending of low-emissions biofuels with fossil petrol as a way of maintaining their market share in transport. This might cause consumers to purchase new internal combustion engine vehicles able to accept the blended fuel, or pay to modify their existing vehicles. If these promises of low-emissions fuels do not eventuate at reasonable cost, consumers would then be saddled with the stranded investment. The MoT should first require that the petrol and biofuel industries demonstrate the viability of blended or pure biofuels before committing the nation’s transportation strategy to them.

1. Considering the ambitious transport electrification plans presented in the green paper, CKM submits that planning for heavy transport should focus on the least energy methods, such as electric rail and coastal shipping. There is the very real possibility that New Zealand will not be able to develop enough renewable energy to meet the demand generated by electrifying transport. New energy resources will be restricted to wind, solar, biomass burning and geothermal, all of which, perhaps excluding solar, will face challenges developing. Wind development is opposed by many communities. Biomass burning for power generation will face issues with landscape change, since biomass feedstock will require large areas of plantation. Geothermal development is risky and increasingly expensive. Numerous geothermal exploration projects and field assessments fail before ever reaching power production.
   
   If new electrical generation does become limited, it would be prudent to plan for methods of heavy transport which use the least amount of energy. Although the green paper points out the expense of electrifying the existing rail network, this, along with coastal shipping, is the lowest energy way to move goods, and the least risk option for New Zealand’s heavy transport. Electric rail and coastal shipping are tried and true technologies. In addition, the cost of electrifying rail might be somewhat offset by the reduced highway maintenance needed today to address heavy truck traffic, a cost savings not mentioned in the green paper.
   
   Electrification of New Zealand’s rain network also makes a good match with the excess power expected to come on to the electricity market when the Tiwai Point smelter closes, as proposed by Prof Susan Krumdieck at Canterbury University. The government announcement of such a project would certainly help to soothe the nerves of domestic electrical power generators, who are nervous about adding new power projects when cheap Manapouri power could flood the South Island electricity market in the next few years. Considering the ambitious transport electrification plans presented in the green paper, we need to be planning and building new electrical generation as soon as possible, and not wait for a decision on Tiwai Point.
   
2. We are in support of coastal shipping as a replacement for road transport for heavy freight. The national benefits of coastal shipping are well documented in recent report by Ernst & Young to the Ministry (The Externality Value of Coastal Shipping, June 2020). Besides being energy efficient, coastal shipping reaches communities that do not presently have rail access (e.g. Nelson Tasman, the East Cape and the Far North) and as such, complements rail as a mode for heavy transport. As pointed out in the Ernst & Young (2020) report, coastal shipping also is vital to the supply of coastal communities cut off by natural disasters, such as occurred after the Kaikoura earthquake.
   
   Although modern shipping relies almost entirely on fossil fuels, there is the potential shift to renewable fuels (such as wood or charcoal) and wind assisted transport, as have been used in the past. We support government sponsored efforts to help decarbonise the country’s coastal fleet and maintain efficient port facilities.
   
3. In one further point, we question the accuracy of a quote on the efficiency of hydrogen fuel cells, on page 91, second paragraph, “Yet in balancing this, converting electricity into hydrogen and back to electricity can involve energy loss in the order of 45 percent making it an inherently inefficient process.90.” In fact, the efficiency of this transformation is much worse. The reference to this efficiency value is a 2019 article in the periodical ‘youmatter’, which simply quotes another article at: https://www.deingenieur.nl/artikel/hydrogen-car-wins-over-electric-car. The title of this second article doesn’t sound like a reliable source of unbiased information.
   
   An article in the Journal of Energy Policy (2008) by Susanne Page and Susan Krumdieck at the University of Canterbury: “System-level energy efficiency is the greatest barrier to development of the hydrogen economy” states the loss as closer to 71%; for every 100 KWh of electrical energy used in the electrolysis of water to hydrogen, followed by compression to 700 bar for transport and then conversion back to electricity in an automobile fuel cell, only 29 KWh of electricity would be generated. This compares with 84 KWh electrical energy returned in a battery electric vehicle under similar circumstances.
   
   We suggest your team further investigate this efficiency value and revise subsequent reports with a more credible reference. Technical numbers, such as efficiency values, reported in non-technical popular periodicals should not make their way into government reports!
   

In conclusion, we urge the MoT to adopt the “precautionary principle” in planning for New Zealand’s future transport. That means sticking to the low emissions transport solutions that are tried and effective, and require the least amount of energy. That means battery electric vehicles, electrified trains and decarbonised coastal shipping.
The country should not be led down the road of biofuels and hydrogen only to find that these fuels don’t work as planned or create a new set of problems. Let others work the bugs out of these systems first. If they work out, they can be added to the transport energy mix at a later date.
Whatever strategy the MoT ultimately adopts for decarbonising New Zealand transport, it goes without saying that this strategy needs to be in alignment with the strategies of other government ministries and commissions. We appreciate that this will be a difficult and time consuming task. The MoT has its work cut out for it, and it has our support.



Respectfully submitted,
Thomas Powell, Co-chair, Climate Karanga Marlborough
[email protected]