1. Do you agree with the proposed guiding principles? 

We note the 5 guiding principles are: maximise emissions reduction; value for money; maximise economic opportunity; inclusive and equitable; and being evidence-based. While also noting the potential for trade-offs between certain principles, AUSMASA agrees they provide good guidance for the Roadmap.

2. Do you support the use of the avoid-shift-improve framework as a tool to identify opportunities for abatement? 

AUSMASA supports avoid-shift-improve as an overall framework. However, as outlined in our Overview, we largely focused on the transition for light and heavy vehicles aligned to our remit, as opposed to wider transport issues. Insofar as ‘shift’ captures vehicular freight and public transport, we note regulatory issues and overlapping policies may complicate the ‘shift’ for heavy vehicles.

3. Do you agree the development of a national policy framework for active and public transport will support emissions reduction? 

AUSMASA supports this with one key caveat – states and territories are largely responsible for active and public transport, and various wider transport issues. For example, e-bikes and e-scooters discussed in the Roadmap are subject to different requirements in states and territories, which the Australian Government will need to be cognisant of, and factor in, for any national policy framework. Nevertheless, we recognise that the Australian Government could play a useful leadership and coordinating role, provided it complements requirements and any related work at the state and territory level. For example, presumably any mode share or investment targets would account for electric buses, which are currently subject to a range of state and territory policies, targets and timeframes.

4. What should be included in a national policy framework for active and public transport and how should it be developed? 

Further to above, any national policy framework for active and public transport should clearly differentiate the role(s) of the Australian Government, states and territories, and, importantly, the private sector – which will not always be as simple as fulfilling a leader or an investor role. For example, the striking down of Victoria’s distance-based tax on EVs illustrated an issue with role clarity, which could have affected private-sector EV manufacturers, retailers, and wholesalers. Targets for mode share, investment, road user pricing, and improved transport integration and incentives are all good options for a national framework, but the views of, and increased demand on, the private sector also needs consideration.

5. What additional actions by governments, communities, industry and other stakeholders need to be taken now and in the future to ensure the movement of people contributes to transport emissions reduction? 

Building on our remit and the proposed national policy framework, the VET sector and industry will need skills and workforce solutions for electric buses. As a key mode of public transport now and in the future, electric buses have unique repair, maintenance, and safety requirements that need to be met. Otherwise we risk premature write-offs like those seen with EVs and other environmental issues (e.g. from battery disposal instead of recycling in the automotive sector).

6. Given the Australian Government has already engaged in consultation on the 2023 review of the National Freight and Supply Chain Strategy, and those consultations will also inform the final Roadmap and Action Plan:

a. What additional actions by governments, communities, industry and other stakeholders need to be taken now and in the future to ensure that the movement of goods contributes to transport emissions reduction?

b. How would these actions address the identified challenges and opportunities for emissions reduction in the movement of goods? 

As AUSMASA was still in its establishment phase in 2023, we did not submit on the review of the National Freight and Supply Chain Strategy. However, we note that decarbonisation was included as a goal for the Strategy post-consultation, which we support on the basis that it complements the Roadmap, with clearly defined and agreed roles for governments, communities, industry and others. For additional actions, a key role for governments will be clarifying regulatory inconsistencies, uncertainties, and policy overlaps we discussed. While the pathway for heavy vehicles is less clear, due in part to industry maturity and technical challenges, we believe regulatory issues and some policies may be adding to this complexity. Therefore, greater clarity and alignment is needed to increase certainty and avoid potential paralysis. However, it is also clear other parts of industry are and can innovate further (e.g. with mobile plant equipment).

7. Do you agree with the proposed net zero pathway for light road vehicles? 

AUSMASA agrees with the pathway for light vehicles, while noting that under the NVES projected EV uptake between 2024–2030 will create additional demands for the repair and maintenance sector (discussed further below).

8. Given the Australian Government is has developed an Australian New Vehicle Efficiency Standard and has begun to implement actions in the National Electric Vehicle Strategy:

a. What additional actions by governments, communities, industry and other stakeholders need to be taken now and in the future to reduce light vehicle emissions?

b. How would these actions address the identified challenges and opportunities to reduce light vehicle emissions? 

Given no-one should be left behind under the Roadmap’s inclusive and equitable guiding principle, we have concerns about the skills and workforce challenges servicing EVs and existing ICE vehicles pose for the sector. For EV technicians, uptake of the only accredited VET sector qualification and skillsets has been low, and it is difficult to quantify what proportion of the existing workforce is (re)training, or will do so, through other avenues (at least until better ABS data is available). Added to this are large existing shortages of ICE technicians that are almost certainly reducing the demand to also upskill in EVs. Therefore, the VET sector and industry clearly need to coordinate to increase the uptake and scalability of (re)training to meet demand from the NVES in the short term, and any additional demand from further actions in the medium to long term. Otherwise, we risk premature disposal of EVs – reducing fleet numbers and adding to emissions and environmental issues. Our work with the VET sector, EV manufacturers, and governments on the first TAFE EV Centre of Excellence is one example of an initiative that could be used to bolster training.

9. Do you agree with the proposed net zero pathway for heavy road vehicles? 

AUSMASA agrees with the heavy vehicle pathway, while noting the hydrogen and low-carbon liquid fuels industries are still developing (discussed below).

10. The proposed pathway for heavy road vehicles relies on a mix of battery electric, hydrogen fuel cell and low carbon liquid fuels. Rank from 1 to 3 the order in which these should be prioritised for emissions reduction.
a. Why did you rank them in that order? 

We would rank battery electric (1) low-carbon liquid fuels (2) and hydrogen fuel cell (3). While electrification is not suitable for all heavy vehicles, this technology is more advanced and better aligned to that for light vehicles. Low-carbon liquid fuels will make sense as an interim solution where electrification is not possible, with some benefits for utilising existing technology and skills. In contrast, hydrogen requires a new industry and technology, leading to later adoption.

11. What role should low carbon liquid fuels play in heavy vehicle decarbonisation? 

Although low-carbon liquid fuels may have many uses, the potential need to retrofit existing diesel engines means their best use case may be heavy vehicles that travel long distances (e.g., heavy line haulage) prior to hydrogen’s adoption.

12. What additional actions by governments, communities, industry and other stakeholders need to be taken now and in the future to reduce heavy vehicle emissions?

a. How would these actions address the identified challenges and opportunities to reduce heavy vehicle emissions? 

As outlined previously, a key role for governments will be clarifying regulatory inconsistencies, uncertainties, and policy overlaps we have discussed. Additional actions could include incentives for industries, including mining and automotive, to retrofit or repower existing heavy vehicle engines, or rebates for purchases of new vehicles if they are preferable (e.g., in some mining applications). These actions could assist in spurring demand for low-carbon liquid fuels, and later hydrogen, while these industries are still developing alongside electrification. 

Questions 13–16. 

These questions on the proposed net zero pathway for rail are not in AUSMASA’s remit. The JSC responsible for rail is Industry Skills Australia. 

Questions 17–18. 

These questions on the proposed net zero pathway for the marine industry sit largely outside of AUSMASA’s remit. Industry Skills Australia is the JSC responsible for maritime transport. NA. 19–20. These questions on the proposed net zero pathway for aviation are not in AUSMASA’s remit. Industry Skills Australia is the responsible JSC. 

Questions 21–22. 

These questions on the proposed net zero pathway for transport infrastructure are not in AUSMASA’s remit. Build Skills Australia is the JSC responsible for this kind of civil infrastructure. 

23. Given the Australian Government previously consulted on opportunities for the electricity and energy sector transition in April 2024, what additional actions by governments, need to be taken now and in the future to ensure the energy mix is ready to support transport emissions reduction?

While AUSMASA did not submit on this work, we note mining was highlighted as a key user of hydrocarbon fuels that could be shifted to low-carbon alternatives. However, it is important to note that many mine sites use diesel or natural gas to generate power in their off-grid locations, which present distinct challenges and communities, industry and other stakeholders opportunities (e.g., synergies with vehicle electrification). If natural gas is used, it is also important to differentiate this from higher emissions fuels. Nevertheless, given this and other industry-specific factors like faster asset use, we believe the mining industry can innovate and undertake demonstration projects, especially with certain supports (e.g., incentives and rebates for mobile plant equipment).

24. How should the use of low carbon liquid fuels be prioritised across different transport modes over time to achieve maximum abatement? 

Although this question is partly outside of our remit, we suggest that heavy vehicles be prioritised for the use of low-carbon liquid fuels. This is because they are responsible for the second largest source of transport emissions (after light vehicles), and engine retrofits are likely easier than for other transport modes.

25. What are the best ways for the Australian Government to work collaboratively with industry, business, governments and communities to implement (all of) the proposed pathways?

a. What are good domestic or international examples of partnership and collaboration on transport and transport infrastructure emissions reduction that could inform the final Roadmap and Action Plan?

b. What opportunities can the government leverage to show leadership in Australia and internationally? 

The concept of a ‘just transition’ has been central to several such international partnerships. This concept recognises the impacts of climate change and climate adaptations, including their benefits and burdens, must be shared equitably. As an example, the Scottish Government is partnering across agencies, research institutions and the transport sector on a just transition. After identifying strengths in batteries, on-road heavy-duty vehicles, greener railways and hydrogen, they proceeded to consult on workforce attraction and upskilling issues. We consider this lens was missing from the Roadmap and is needed to inform further work. Given our mining industry’s importance to Australia and abroad, and critical minerals’ importance to net zero, we believe Australia could show leadership by partnering across businesses, governments, and communities on reducing the industry’s emissions. As outlined (above), we believe a range of factors could allow the industry to deploy solutions that will reduce its emissions at-scale.

26. What measures and metrics should be used to evaluate the final Transport and Infrastructure Net Zero Roadmap and Action Plan? 

a. What other data and evidence could governments use and how could this offer further insights on the pace, scale and location of transport emissions reduction pathways? 

We believe VET data (including from the National Centre for Vocational Education Research) is a missing data source for the success measures. VET student commencement, enrolment and completion data will be important for some roles (e.g., EV technicians) and as a comparator to employment data. For example, our basic analysis of the NVES and VET data illustrates that the uptake of consistent and accredited EV technician training needs to increase. Governments could also use linked education and employment data to better understand how education and employment are supporting the transition.

27. Do you have any feedback on the proposed review process? 

We do not have further feedback on the review process’ principles or success measures. However, we would like to reiterate our feedback (above) on data measures and options that would assist with evaluating the Roadmap’s success.

28. Do you have any further feedback on the Consultation Roadmap and proposed pathways?
a. Is there anything missing? Are the sections appropriately integrated? Is the Roadmap appropriately ambitious? 

Yes – a component is missing. While the Roadmap lists existing Australian Government policy and key state and territory actions, it does not discuss how they may (or may not) algin or the policy levers that may be available. This could be problematic where investments, targets and timeframes do not align. Further, until or unless this analysis is done, it will be hard to conclude whether and how the Roadmap builds on existing policies and actions.

29. Is there any further information or documentation that you wish to be considered with your submission? 

Not currently. We look forward to the next steps and further consultation (if any).