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Considering climate change, simplifying compliance and making better use of technology as our transport system changes January 2022 Consultation Document
He maramatanga tō tēnei
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tērā whetū Every individual has
their own luminescence
Find out more at hei-arataki.nz
UARA
OUR VALUES
WHAKAPAKARI AKO MAHI TAHI
IMPROVING OUTCOMES CAPABILITY DEVELOPMENT WORKING TOGETHER
RANGATIRATANGA KAITIAKITANGA WHANAUNGATANGA MANAAKITANGA
EMPOWERING GUARDIANSHIP AND COLLABORATION CARING FOR AND
AND LEADING PROTECTION AND UNITY VALUING OTHERS
Te Manatū Waka | Driving Change: Reviewing the Road User Charges System 1
CONTENTS
Ngā ihirangi | Contents
Preface by the Minister of Transport 9 03
01 Improving the RUC system for end users
Introduction 3.1 Reviewing the requirements for 29
electronic RUC and mandating
1.1 Background to Road User Charges 11 eRUC for all heavy vehicles
(RUC)
3.2 Using eRUC devices to improve 30
1.2 What changes are needed to make 13 road safety
RUC work more effectively?
3.3 Enabling partial RUC rates for 32
1.3 We’d like your feedback on how to 14 vehicles that also use a fuel subject
make the RUC system better to fuel excise duty
Should there also be changes to 14 3.4 Enabling partial RUC rates for 34
Fuel Excise Duties (FED) settings? vehicles after RUC exemption ends
1.4 Additional sources of information 15 3.5 Exempting certain types of vehicles 35
1.5 Making and sending a submission 16 and vehicle combinations from RUC
1.6 The structure of this discussion 17 Extending the heavy EV RUC 36
document exemption to 31 March 2030 to
support their uptake
02 Exemptions for vehicle 36
combinations where the motive
Using the RUC Act to do more than
recover road costs power is from a vehicle exempted
from paying RUC
2.1 Including externalities in the costs 21
3.6 RUC for electric and diesel vehicles 37
considered in setting RUC rates
with a Gross Vehicle Mass of less
2.2 Including impacts on greenhouse 23 than one tonne
gas emissions when setting
3.7 Exempting low emission vehicles 39
RUC rates
from RUC based on distance
There are risks with changing the 24 travelled
purpose of RUC
3.8 Adjusting the overweight 41
2.3 Including fuel type, origin, and 27 permit regime
blend in RUC rates
3.9 Removing the requirement for 42
2.4 Any other feedback on this chapter? 28 light vehicle owners to display
a RUC licence
3.10 Allowing for the purchase of 43
RUC licences in amounts less
than 1,000 km
2 Te Manatū Waka | Driving Change: Reviewing the Road User Charges System
CONTENTS
Ngā ihirangi | Contents (continued)
3.11 Removing the requirement to 46 4.5 Clarifying the requirements that 65
display other transport paper labels certain persons must make and
retain certain records
3.12 Allowing the use of historic RUC 48
rates when carrying out 4.6 Clarifying the provisions relating 66
an assessment to access to records held by
third parties
3.13 Transitioning CNG- and LPG- 49
powered vehicles into the RUC 4.7 Creating a requirement for RUC 67
system Electronic System Providers (ESPs)
to notify Waka Kotahi of the status
3.14 Assisting new RUC payers to 50
of RUC payments
commence paying RUC
4.8 Clarifying the requirements 68
3.15 RUC offences and penalties 51
around the display of heavy
Increasing maximum infringements 51 vehicle eRUC licences
and infringement/fine ratios
4.9 Exempting vehicles that are only 69
Amending the non-payment 54 travelling on a road for Certificate of
penalty regime Fitness purposes from paying RUC
3.16 Any other feedback on possible 55 4.10 Extending an operator’s time to 70
changes to the RUC system? request an independent review of
a RUC assessment
04 4.11 Changes to how mobile cranes are 71
Technical amendments to the RUC Act defined for RUC
4.1 Clarifying what ‘partly’ means in 57 4.12 Any other feedback on this chapter? 72
the definition of an electrically
powered vehicle 05
4.2 Redefining RUC vehicles types for 58 Annex 1
eight axle combinations
Explanation for how road user 74
Approach to clarifying vehicle types 59 charges rates are determined through
Te Manatū Waka Ministry of Transport
Changes to RUC rates for H types 59
Cost Allocation Model
for eight axle combinations
4.3 Changing the Warrant and 62
Certificate of Fitness requirements
so the assessor must report
evidence of odometer tampering
4.4 Clarifying the definition of 64
accurate for a distance recorder
in a light vehicle
Te Manatū Waka | Driving Change: Reviewing the Road User Charges System 3
CONTENTS
Table of questions
What are the advantages 20 What are the advantages and 26
Q1 and disadvantages of using Q8 disadvantages involved in changing
RUC to recover more than the purpose of the RUC Act so
the direct costs of building, that climate policy generally,
operating, and maintaining or greenhouse gas emissions
the land transport system? specifically, can be considered
when setting RUC rates?
If RUC should not be used for 20
Q2 recovering more than road costs, What advantages and 26
what alternative approach might Q9 disadvantages would there be if
be appropriate for recovering there was an explicit requirement
those other costs? to consider RUC exemptions as
part of the development of the
What advantages and 22 Government Policy Statement on
Q3 disadvantages are there to land transport?
considering externalities when
setting RUC rates? What are the advantages and 26
Q 10 disadvantages of enabling
If externalities were to be 22 consideration of greenhouse gas
Q4 considered, what criteria could emissions when setting RUC rates?
be used to determine what
externalities should be taken into How should the RUC rates be set 26
account in setting RUC rates? Q 11 for vehicles that could use more
than one fuel and these fuels
If externalities were to be 22 had different greenhouse gas
Q5 considered, how should these emissions?
costs be set?
What advantages and 26
Would charges for externalities 22 Q 12 disadvantages are involved in
Q6 be in addition to the current form using NLTF revenue to reduce
of RUC, and potentially used to carbon emissions rather than
address the externalities directly, foregoing RUC revenue?
or be a core part of total land
transport revenue? What are the advantages and 27
Q 13 disadvantages with the source of
How would vehicles not paying 22 different fuel types being included
Q7 RUC be affected? in RUC calculations (separately
from the direct climate impacts of
the fuel used)?
4 Te Manatū Waka | Driving Change: Reviewing the Road User Charges System
CONTENTS
What are the advantages and 27 What are the advantages and 33
Q 14 disadvantages with the Q 24 disadvantages of mandating
environmental effects of different integrated telematics solutions
fuel types being considered in that could support improved
calculating RUC rates for productivity and safety
vehicle types? compliance, either as part of eRUC
systems or as standalone devices?
How would fuel supply chains 27
Q 15 be verified? How can privacy concerns be 33
Q 25 managed if we are going to make
greater use of eRUC data?
How could we ensure that, if 27
Q 16 different fuels are available (for What, if any, changes in costs 33
example mineral and biodiesel, or Q 26 would additional requirements to
hydrogen from different sources), allow eRUC devices to be used to
only approved fuel types were support improved productivity and
used by the RUC vehicle? safety compliance place on users,
eRUC devices and eRUC providers?
How else would you change the 28
Q 17 setting of RUC to ensure it is What are the advantages and 33
adaptable to future challenges? Q 27 disadvantages of enforcement
authorities having greater access
What are the advantages and 31 to eRUC data for enforcement of
Q 18 disadvantages of mandating logbook requirements or other
eRUC for heavy vehicles? on-road enforcement tasks?
What vehicle types should 31 What are the advantages and 34
Q 19 or should not be required to Q 28 disadvantages of allowing the
use eRUC? RUC Act to set partial RUC
rates to recognise FED paid
How would phasing-in of eRUC 31 by dual-fuel vehicles?
Q 20 for the heavy vehicle fleet be best
accomplished? According to what criteria should 34
Q 29 partial RUC rates be determined?
Are the existing requirements 31
Q 21 for eRUC devices reasonable if
the technology was to be made Should operators of dual-fuel 34
compulsory? Q 30 vehicles with a reduced RUC rate
still be able to claim a full FED
What alternative technological 31 refund if they used more fuel than
Q 22 models should we be exploring the average?
for eRUC?
What are the advantages and 35
Q 31 disadvantages of enabling partial
How would making eRUC 31
Q 23 mandatory affect your business? RUC rates to help transition
exempted vehicles to full RUC rates?
What are the advantages and 37
Q 32 disadvantages of the heavy EV
exemption being extended for
more than five years?
Te Manatū Waka | Driving Change: Reviewing the Road User Charges System 5
CONTENTS
How would extending the end date 37 What changes should be made 42
Q 33 be effective in encouraging the Q 42 to section 12 of the RUC Act
uptake of heavy EVs? to improve the overweight
permit regime?
Should the current exemption 37
Q 34 be extended to 31 March 2030 How would other potential 42
to encourage the uptake of Q 43 changes in this discussion
heavy electric vehicles? Would an document, such as greater use
alternative date be better and why? of eRUC, assist in the overweight
permitting process?
How would exempting vehicle 38
Q 35 combinations where the motive What are the advantages and 44
power is from a vehicle exempted Q 44 disadvantages of removing the
from paying RUC encourage the requirement to display a physical
uptake of heavy electric vehicles? RUC label?
What safeguards would we need 38 What problems for non- 44
Q 36 to ensure that only trailers towed Q 45 compliance and enforcement
by exempted vehicles were able might this cause?
to be exempted?
How can Waka Kotahi assist drivers 44
What are the advantages and 40 Q 46 in ensuring they remain compliant
Q 37 disadvantages of subjecting road- with RUC if the label-display
registered very light vehicles that requirement is removed?
are not powered by petrol to RUC,
or a higher annual licence fee, for What are the advantages 44
travel on public roads? Q 47 and disadvantages of retaining the
option to request a physical licence?
Under what circumstances should 40
Q 38 ATVs and motorcycles primarily What advantages and 45
designed for use off road be Q 48 disadvantages are there in allowing
required to pay RUC, or a higher RUC licences to be purchased in
licence fee? units of less than 1,000 km?
What principles should we use to 40 What are the advantages and 47
Q 39 determine a RUC rate, or higher Q 49 disadvantages of removing the
annual licence fee, for motorcycles requirement to display physical
and mopeds? vehicle licence (‘rego’) labels?
Is having a GVM of less than one 40 How can Waka Kotahi assist drivers 47
Q 40 tonne an appropriate cut-off point Q 50 in ensuring they remain compliant
for treating ATVs separately? If with their vehicle licensing
not, what is an appropriate cut- obligations if the label-display
off point or other way of defining requirement is removed?
these vehicles for RUC, and why?
What are the advantages and 47
What are the advantages and 41 Q 51 disadvantages of retaining the
Q 41 disadvantages of a distance-based option to request a physical vehicle
rather than time-based exemption licence label?
to RUC for EVs?
6 Te Manatū Waka | Driving Change: Reviewing the Road User Charges System
CONTENTS
What are the advantages and 48 On what basis should the penalty 54
Q 52 disadvantages of letting Waka Q 62 for non-payment of RUC be
Kotahi use historical RUC rates calculated?
when carrying out an assessment?
What should be the maximum 54
What are the advantages and 49 Q 63 penalty for non-payment of RUC?
Q 53 disadvantages of removing FED
from sales of LPG and CNG and
having all road vehicles using these Should the non-payment penalty 54
fuels move to paying RUC? Q 64 regime recognise the time the RUC
payment has been outstanding?
If LPG and CNG powered vehicles 49 If so, how?
Q 54 are included in the RUC system
what reasons would justify their What other improvements do 55
operators paying a different rate Q 65 you think are needed in the
than other light vehicles? RUC system?
If a partial rate is possible for dual- 49 What criteria should be used to 57
Q 55 fuel LPG or CNG vehicles, what Q 66 define, or replace, the word ‘partly’
principles should be considered in in the definition of electric vehicles
setting the rate? and why?
Are there any new issues that might 50 What are the advantages and 60
Q 56 need to be considered, including Q 67 disadvantages of our proposed
those that might justify changes to approach to classifying vehicles
RUC legislation, to address an influx with eight axle combinations?
of new RUC system users when the
light EV exemption ends? What are the advantages and 63
Q 68 disadvantages of requiring
How should the RUC system help 50 inspection of the odometer on RUC
Q 57 new users purchase RUC from the vehicles at the time of Warrant or
exemption end date and from the Certificate of Fitness inspection?
correct initial odometer reading,
after the exemption ends? What form would this inspection 63
Q 69 take and what would the costs of
Should the maximum 52 the inspection be?
Q 58 infringements set out in section
89(q) of the RUC Act be amended? What should happen if a Warrant 63
If so, how? Q 70 or Certificate of Fitness inspector
thought an odometer had been
Are the existing infringements 53 tampered with?
Q 59 set at appropriate levels for
the offence? Is it necessary to define ‘accurate’ in 64
Q 71 the RUC legislation, or can we rely
Should the offender type ratios 53 on existing case law and practices?
Q 60 differ between individuals and
body corporates? If so, how? How could ‘accurate’ be defined 64
Q 72 in RUC legislation for the distance
Would you also change the fee/fine 53 recorder fitted to a light RUC
Q 61 ratio? If so, how? vehicle?
Te Manatū Waka | Driving Change: Reviewing the Road User Charges System 7
CONTENTS
What should happen if a vehicle 64 What are the advantages and 68
Q 73 owner finds that their distance Q 82 disadvantages of completely
recorder is not accurate and does removing the requirement for
not correct it? carrying or displaying a RUC
licence for heavy vehicles?
What are the advantages and 65
Q 74 disadvantages of requiring What are the advantages and 69
vehicle operators to retain Q 83 disadvantages of exempting off
weight-based records? road vehicles from paying RUC
if they are only travelling on a
How long should any weight-based 65 public road for the purposes of
Q 75 records be retained for? undertaking a safety inspection or
maintenance?
What could Waka Kotahi do to 65 What are the advantages and 70
Q 76 make this requirement more Q 84 disadvantages of giving Waka Kotahi
feasible for companies that create discretionary power to extend the
weight-based records? time for independent reviews?
What are the advantages and 66 In what instances should an 70
Q 77 disadvantages of allowing Waka Q 85 extension be granted, and in what
Kotahi to access third party instances shouldn’t an extension
records to ensure operator be granted?
compliance with the RUC Act?
What are the advantages and 71
What evidence threshold 66 Q 86 disadvantages of removing mobile
Q 78 or circumstances would be cranes from the list of vehicle
appropriate for Waka Kotahi types that are exempted from RUC
to trigger the power to access on the basis that all vehicles can
third-party records now fit eRUC devices?
What are the advantages and 67 What are the advantages and 71
Q 79 disadvantages with RUC legislation Q 87 disadvantages of amending the
requiring ESPs to notify Waka definition of ‘All Terrain Crane’
Kotahi of changes to the status of used in the RUC regulations to
RUC payments? allow for the use of single large
or single mega tyred axles rather
What are the advantages and 68 than tyre contact area?
Q 80 disadvantages of removing the
requirement for an electronic What other issues might there 71
distance recorder (ehubo) to also Q 88 be with the way RUC rates are
display the RUC licence? calculated for mobile cranes?
What requirements should the 68 What other technical amendments 73
Q 81 RUC legislation have around the Q 89 should be made to the RUC
display of distance on an electronic Act, its regulations, or the rules
distance recorder (ehubo)? and manuals that make up the
RUC system?
8 Te Manatū Waka | Driving Change: Reviewing the Road User Charges System
CONTENTS
Further information
Table of figures List of abbreviations
Figure 1: Main sources of revenue for the 11 ACC Accident Compensation Corporation
National Land Transport Fund ATV All Terrain Vehicles
(NLTF) in 2020/2021
CAM Cost Allocation Model
Figure 2: Diesel vehicles within the light 12
fleet and percentage of revenue CNG Compressed Natural Gas
from light RUC DME Dimethyl ether
Figure 3: Indicative timing of proposed 15 eRUC Electronic Road User Charge
RUC legislation reforms ESA Equivalent Standard Axle
Figure 4: Te Manatū Waka’s five 19 ESPs Electronic System Providers
aspirational outcomes for the
ETS Emissions Trading Scheme
transport system
EV Electric Vehicle
Figure 5: Example of combinations of 38
trucks towing heavy trailers FED Fuel Excise Duty
Figure 6: Example of motor vehicle licence 46 GVM Gross Vehicle Mass
indicating the information fields GVW Gross Vehicle Weight
Figure 7: H Type Vehicle Configurations 60 HFCEV Hydrogen fuel-cell electric vehicle
Figure 8: 2019/20 NLTP expenditure by 76 HV Heavy Vehicle
cost category as percentage of LPG Liquefied Petroleum Gas
total RUC revenue
NLTF National Land Transport Fund
Figure 9: Allocation of costs making up 77
RUC rates for six common NLTP National Land Transport Programme
vehicle types PCE Passenger Car Equivalents
PHEV Plug-In Hybrid Electric Vehicles
PV Powered Vehicle
List of tables RUC Road User Charge
Table 1: Costs per tonne of CO2 25 VKT Vehicle Kilometres Travelled
emissions avoided through
a RUC exemption
Table 2: Potential amount of revenue 36
foregone from different options
for RUC exemptions
Table 3: Motorcycles, mopeds and light 39
four-wheeled vehicles (ATVs) in
the New Zealand fleet (July 2021)
Table 4: The maximum fees set out 52
in the infringement offences
regulationsTe Manatū Waka | Driving Change: Reviewing the Road User Charges System 9
Preface by the Minister of Transport
New Zealand has a road user I am committed to improving our road user
charges system. This document outlines a range
charge (RUC) system that is truly of options on how we can make our system of
one of a kind – it remains world- road user charges more effective to overcome the
challenges and changes we will face in the future.
leading as a distance and weight-
based charge for both diesel and Many of the changes discussed here could
be significant for the RUC system if they were
heavy vehicles. implemented. This is why we are using this
discussion document to get your views before we
It is a well-established system having been propose any legislative changes. The matters put
designed in the 1970s and undergoing a forward in this document are for discussion only
substantial reform in 2012 to modernise and and are intended to seek feedback. All of the ideas
simplify it. The 2012 changes also enabled the would need refinement before they could proceed
voluntary use of electronic devices (eRUC) to pay and some may not proceed at all, depending on
road user charges for heavy vehicles. However, your feedback.
since 2012 the transport industry has changed We want to hear from vehicle owners, drivers,
significantly with a substantial increase in the and industry experts to help us make well-
number of light diesel vehicles and as a result, considered decisions and help shape the future
an increase in those paying road user charges. of our transport sector. The consultation will be
The New Zealand transport industry is also facing open until Friday 22 April 2022. I encourage you
the confronting challenge of climate change and to share your views through the online survey,
a pressing need to reduce our transport sector’s written submission or by getting in touch with
climate change emissions. Climate change is an Te Manatū Waka Ministry of transport if you
area this Government is very passionate about and want to discuss any of the proposals.
we are working hard to find solutions that can work
across the transport sector. Our uptake of electric
vehicles has increased and continues to do so with
the help of initiatives such as the current RUC
exemption and the Clean Car Discount announced
earlier this year. I am interested to see whether Hon Michael Wood
we can make better use of the RUC system to help Minister of Transport
promote the uptake and use of vehicles with low-
carbon emissions to help us meet our climate goals.
Although we currently have an exemption from
RUC for electric vehicles, once that exemption
expires, their operators will be required to pay
road user charges like other road users. This will
mean that they will contribute to the functioning
of our transport network that they are already
using. RUC means that, unlike many countries, we
already have a mechanism to recover these costs.
This doesn’t mean, though, that we shouldn’t look
at ways to make paying RUC simpler and easier.CHAPTER CHAPTER CHAPTER CHAPTER 1 2 3 4 Introduction
Te Manatū Waka | Driving Change: Reviewing the Road User Charges System 11
INTRODUCTION
1.1
Background to Road User Charges (RUC)
New Zealand was a pioneer In the 2020/21 financial year RUC contributed
nearly $2 billion in revenue to the National Land
in implementing a national Transport Fund (NLTF) out of a total of $4.3
distance-based road user billion. Of this the operators of the 800,000 light
RUC vehicles purchased approximately $800
charge (RUC) system. million in RUC licences, while the operators of
the 190,000 heavy vehicles (including trailers
RUC imposes charges on RUC vehicles for towed by heavy vehicles) purchased $1.1 billion.
their use of the roads that are in proportion to The owners of roughly 3 million light petrol
the costs that the vehicles generate. Since its vehicles contributed around $2.1 billion in
introduction in 1978, RUC has been updated FED and another $230 million was collected in
and simplified a number of times to allow for registration and licence fees.
technological advancements and to modernise
the system. Today, our RUC system remains Figure 1: Main sources of revenue for the National
world-leading, but it needs to evolve. It needs Land Transport Fund (NLTF) in 2020/2021
to be able to adapt to changes in technology
and changes in the transport sector, such as the
increasing importance of light vehicles to RUC
revenue and the increasing use of fuels other
than petrol and diesel. We also want to consider
whether RUC should be able to address wider
Government priorities and not focus solely on
recovering direct costs.
Under the Road User Charges Act 2012 (RUC Act), 50% 45%
operators of all vehicles that do not use a fuel that
is charged fuel excise duty (FED) (primarily diesel
vehicles), or heavy vehicles with a gross vehicle
mass (GVM) greater than 3.5 tonnes (primarily
trucks, buses and some trailers), are subject to 5%
RUC. Currently, almost all RUC vehicles are diesel
powered vehicles, but vehicles using other fuels
such as electricity, hydrogen and biodiesel are also Road user charges 45%
subject to RUC. Light Electric Vehicles (EV) (mainly otor vehicle registration and annual
M
cars) are currently exempt from paying RUC licensing fees 5%
until 31 March 2024 and heavy EVs (trucks and Fuel excise duty 50%
buses) are exempt until the end of 2025 as part
of existing measures to encourage people to buy
and use them.12 Te Manatū Waka | Driving Change: Reviewing the Road User Charges System
INTRODUCTION
The last major suite of amendments to the RUC
Act were made in 2012. In the intervening years
the number of light diesel vehicles subject to
RUC has increased significantly and these are
often operated by private motorists, rather than
companies. Heavy diesel vehicles, which are
mainly operated by companies, remain the core
of the scheme, but are now only responsible for
around sixty percent of RUC revenue. Light diesel
vehicles, which now make up 20 percent of the
light vehicle fleet, contribute the other 40 percent
of RUC revenue. Once the EV RUC exemption
ends, owners of EVs will also pay RUC in ever
increasing numbers.
Figure 2: Diesel vehicles within the light fleet and percentage of revenue from light RUC
45%
40%
35%
30%
Percentage
25%
20%
15%
10%
5%
0%
2000
2002
2004
2006
2008
2010
2012
2014
2016
2018
2020
Year
Light diesel vehicles (percent of light fleet) Light RUC (percent of RUC revenue)Te Manatū Waka | Driving Change: Reviewing the Road User Charges System 13
INTRODUCTION
1.2
What changes are needed to make
RUC work more effectively?
The current RUC legislation is In addition to the potentially significant changes
to the purpose of RUC, we are taking this
focussed on recovering the opportunity to consult on a wide range of other
costs of damage to our road possible amendments to RUC legislation that
could improve its operation. Te Manatū Waka
network, especially that caused Ministry of Transport (Te Manatū Waka) and Waka
by heavy vehicles, and ensuring Kotahi NZ Transport Agency (Waka Kotahi) have
that operators of vehicles that identified a large number of potential operational
and legislative improvements to the RUC system
cause the damage pay the and RUC Act. Currently it costs Waka Kotahi
appropriate amount. approximately $20 million per year (around one
percent of RUC revenue) to administer the RUC
This approach remains key, but the current system system and it costs operators an additional amount
does not recognise other costs imposed by vehicle to manage their own compliance. Amending the
use, such as pollution or congestion. There is a RUC Act and its regulations is an opportunity to
growing interest in using the RUC system to also make changes that will reduce these costs and
capture some of those other costs, or to offset the improve the value for money the sector gets.
higher costs faced by some emerging technologies,
ahead of their widespread adoption.
We want to look at whether changes to the
legislation are needed to enable our RUC system
to adapt to these changes in the types of vehicles
and their operators, and whether we should
amend it to accommodate future changes in
how we seek to raise land transport revenue.14 Te Manatū Waka | Driving Change: Reviewing the Road User Charges System
INTRODUCTION
1.3
We’d like your feedback on how
to make the RUC system better
This paper is designed to get We recognise that some of the changes discussed
are potentially large and complicated. We are
your feedback on a wide range allowing a relatively long time for the consultation
of potential changes to the so that we can engage with stakeholders to
develop lasting solutions. This means that you
RUC system. will also have an opportunity to make further
submissions before any changes to the legislation
If the changes are progressed, most would require are made.
amendments to the RUC Act to enable them.
We will compile the responses we receive into We have allowed two months for written
advice for the Minister of Transport and his Cabinet submissions, with written submissions due
colleagues about which changes might, or might not, on Friday 22 April 2022. However, written
proceed. Cabinet will then consider proposals and submissions will not be the only opportunity
any potential legislative changes – weighing up the to have input. Stakeholder feedback is very
impact on the sector, the economy, and everyone important to us and we would like to engage
who uses or is affected by the RUC system. with groups on specific topics, either virtually
or in person (provided it is safe to do so under
Should Ministers decide to make changes the COVID-19 Protection Framework). If you are
following this consultation, we expect there will interested in participating in a discussion on any
be several packages of amendments to the RUC of the proposals, please let us know by emailing
system (see Figure 3). The first package would RUCConsultation22@transport.govt.nz
include changes that can be made by amending
regulations under our existing law. These
changes can proceed relatively quickly after the 1.3.1 Should there also be changes to
consultation concludes. Other changes would Fuel Excise Duties (FED) settings?
require amendments to the RUC Act. The exact
timing of when those changes could be made At present, motorists using petrol pay for their
will depend on the timing of the parliamentary use of the road network through the amount of
process. The timing of these processes will not FED that they pay as part of their petrol. If we
be known until the final package of possible are to consider wider changes to the purpose of
amendments is prepared. Once the amendments RUC, then we may also need to consider if these
are in place there would then be another package concepts or policies could also be applied to
of regulations to implement the remaining vehicles using petrol. For example, if the goal was
changes. These changes are likely to come into to reduce congestion it would not be sensible to
effect at the same time the new Amendment Act only charge operators of RUC vehicles. If you have
comes into force, or shortly after that. Finally, views on how the FED system could be modified
there could be some changes made to the RUC to achieve the outcomes discussed in this
Act that would create the legal ability to do document for RUC vehicles, then you are welcome
something, but which we won’t want to implement to respond on these matters as well, when
immediately. These provisions might not be used responding to the questions in this document.
until some years from now.Te Manatū Waka | Driving Change: Reviewing the Road User Charges System 15
INTRODUCTION
1.4
Additional Sources of information
Annex 1 discusses in detail Figure 3: Indicative timing of proposed RUC
legislation reforms
how RUC rates are calculated
at present.
January –
Public consultation
Further information about RUC is also available April 2022
on Te Manatū Waka’s website here:
https://www.transport.govt.nz/area-of-interest/
revenue/road-user-charges-system/ Written submissions
and Waka Kotahi’s website here: close
22 April 2022
https://www.nzta.govt.nz/vehicles/licensing-rego/
road-user-charges/about-ruc/ Package of measures
The RUC Handbook and Code of Practice for submitted to
Electronic Road User Charges Management August 2022 Government
Systems also contains good background on the
operation of the RUC system: First batch of
https://www.nzta.govt.nz/assets/resources/ regulations proposed
road-user-charges/docs/road-user-charges- Late 2022 for consultation
handbook.pdf
https://www.nzta.govt.nz/assets/resources/
road-user-charges/eruc-guidelines/docs/ERUC- First regulations
code-of-practice.pdf come into effect
Late 2022
RUC Act amendments
considered by
2023 Parliament
RUC Act amendments
anticipated to come
Late 2023 into effect
Implementation of
regulations enabled by
Late 2023,
RUC Act amendments
early 2024
Light EV RUC
exemption ends
31 March 202416 Te Manatū Waka | Driving Change: Reviewing the Road User Charges System
INTRODUCTION
1.5
Making and sending a submission
We welcome your submissions We are likely to publish a summary of
submissions. As part of consultation we collect
on changes that the Government your name and any other identifying information
is considering that relate to RUC you provide. If you do not want your name or
identifying information to be included as part of
set out in this document. the published public summary, please note this
at the end of your submission and we will ensure
Your feedback will help the Minister of Transport identifying information is not included. This will
and his Cabinet colleagues to decide on what, if also be taken into account when we respond to
any, amendments are made to the RUC system. any Official Information Act requests that cover
You can comment on as many or as few of the your submission.
items raised in the document as you prefer. You
do not need to respond to the questions directly You have the right to ask for a copy of any
if you do not want to. They are only intended as personal information we hold about you, and to
a guide. You can also suggest other matters that ask for it to be corrected if you think it is wrong.
should be considered as part of this package of If you’d like to ask for a copy of your personal
reforms to the RUC system. information, or to have it corrected, please contact
us at info@transport.govt.nz. If you are planning to
Please include the following information in make a submission via an online petition page or
your submission: other automated platform, please contact us first
• The subject of the proposed change to ensure your submission is accurately identified
• Your name and collected.
• Your organisation’s name if applicable
• Your email address (preferred) or Submissions can be made after the closing date,
postal address but we cannot guarantee that these will be able
to be included in the formal submissions analysis.
You can send your submission via the
online submission form or by email to
RUCConsultation22@transport.govt.nz.
The online submission form is available at
https://www.transport.govt.nz/RUCconsultation22.
If you prefer, you can also mail a copy of your
submission to:
RUC Consultation 2022
Te Manatū Waka Ministry of Transport
PO Box 3175
Wellington 6140Te Manatū Waka | Driving Change: Reviewing the Road User Charges System 17
INTRODUCTION
1.6
The structure of this discussion document
We have set out this discussion
document to guide you through
the different levels of potential
changes that could be made to
the RUC Act.
Chapter 2 discusses ideas relating to the purpose
of RUC and the powers that are used to set RUC
rates. We are thinking about the scope of costs
we should seek to recover as part of RUC, what
the future RUC system could look like and what
powers the RUC Act needs if RUC was to be used
support wider transport policies.
Chapter 3 presents a range of changes to
improve the general functioning of the RUC
system. The ideas and concepts proposed for
your feedback focus on improving the collection
and administration of RUC and the use of RUC to
influence the national vehicle fleet. These changes
could affect most RUC users.
Chapter 4 sets out a range of potential, mainly
technical, amendments that are intended to
address specific issues we have encountered
through administration of the RUC Act. These
are mostly minor amendments which only
affect a small number of people or companies
and focus on changes to specific parts of the
current legislation.CHAPTER CHAPTER CHAPTER CHAPTER 1 2 3 4 Using the RUC Act to do more than recover road costs
Te Manatū Waka | Driving Change: Reviewing the Road User Charges System 19
USING THE RUC ACT TO DO MORE THAN RECOVER ROAD COSTS
The transport system creates costs and impacts of road transport when we set
the costs of using the road network could help the
significant social and economic transport system become more effective; improving
benefits but also many costs. it as a system so that it enhances wellbeing and the
liveability of our cities and towns.
For example: road transport is the fastest growing Te Manatū Waka has identified five outcomes
source of greenhouse gas emissions; by some (Figure 4) that the transport system should be
estimates, congestion costs Auckland alone up to placing at its centre to create a system that
$1.3 billion a year; and on average, someone dies improves wellbeing and liveability.2 Each of these
on our roads every day. A 2012 report1 found that outcomes has a variety of indicators, many of
air pollution from motor vehicles has a social cost which focus on the measurement of externalities.
of nearly $1 billion. Being able to consider these
Figure 4: Te Manatū Waka’s five aspirational outcomes for the transport system
Inclusive access Healthy and safe people
Enabling all people to participate in Protecting people from
society through access to social and transport-related injuries and harmful
economic opportunities, such as work, pollution, and making active travel
education, and healthcare. an attractive option.
A transport
system that
Economic prosperity improves
wellbeing and
Supporting economic activity
liveability
via local, regional, and international
connections, with efficient Environmental sustainability
movements of people and products. Transitioning to net zero carbon
emissions, and maintaining or
improving biodiversity, water quality,
and air quality.
Resilience and security
Minimising and managing the risks from
natural and human-made hazards, anticipating
and adapting to emerging threats, and recovering
effectively from disruptive events.
1 https://environment.govt.nz/assets/Publications/Files/updated-health-and-air-pollution-new-zealand-study-summary-report.pdf
2 https://www.transport.govt.nz/area-of-interest/strategy-and-direction/transport-outcomes-framework/20 Te Manatū Waka | Driving Change: Reviewing the Road User Charges System
USING THE RUC ACT TO DO MORE THAN RECOVER ROAD COSTS
The Government is progressing policies to support
these outcomes by developing programmes
that focus on road safety, vehicle emissions,
regulatory development, and smart infrastructure
investments. The RUC system could also
potentially support these outcomes.
Currently the RUC legislation provides for the
setting of RUC rates to be in proportion to the
costs that the vehicles generate. These costs have
historically been limited only to the direct costs
of damage caused by the vehicles’ use of the
roads, along with the wider costs of building and
maintaining the transport system. In response to
the trends that we expect to impact the sector,
we are seeking your feedback on whether it is
appropriate to expand the costs that could be
taken into account when setting RUC under the
RUC Act.
The intent of broadening the purpose of RUC,
as set out in the Act, would be to ensure that
the Government can respond appropriately
and efficiently to the changing environment the
transport sector operates in.
What are the advantages and
Q1 disadvantages of using RUC to recover
more than the direct costs of building,
operating, and maintaining the land
transport system?
If RUC should not be used for
Q2 recovering more than road costs,
what alternative approach might be
appropriate for recovering those
other costs?Te Manatū Waka | Driving Change: Reviewing the Road User Charges System 21
USING THE RUC ACT TO DO MORE THAN RECOVER ROAD COSTS
2.1
Including externalities in the costs
considered in setting RUC rates
Road transport causes a The Government Policy Statement on land
transport 2021 made climate change a ‘strategic
range of positive and negative priority’. Decarbonising land transport is going
impacts and these are referred to be challenging and a comprehensive set
of measures will be needed to achieve the
to as externalities. reductions recommended by the Climate Change
Commission. We are going to need a wide range
These externalities can include environmental of incentives (and potentially disincentives) to
damage such as air or water pollution, noise move away from fossil fuels. The RUC system
pollution, road damage, accidents, or other harms could provide the Government with greater
such as congestion. Other than road damage, flexibility to manage the economic and equity
these externalities are not explicitly considered impacts of its greenhouse gas reduction
when setting RUC, or FED rates for petrol vehicles. commitments, while continuing to raise enough
We want to look at whether we should be able revenue to maintain the road transport network.
to consider some of these other costs when
setting RUC; especially those associated with Pricing externalities can recover these other costs –
greenhouse gas emissions. At the same time, fully or partially – by passing them on to those who
we need to ensure that we continue to raise created the costs. Managing externalities through
sufficient revenue for the transport system to pricing could be a fairer way to allocate costs
operate in a way that achieves our other and benefits of transport options and it could be
transport outcomes. used to influence travel or purchasing decisions.
An example of using road pricing to affect
The transport sector is responsible for over externalities can be drawn from some European
21 percent of New Zealand’s gross domestic countries where discounts are offered on toll
greenhouse gas emissions and road transport roads to users who purchase cleaner vehicles in
is the fastest-growing domestic source of advance of the legal requirement to do so.
greenhouse gas emissions. Around two-thirds
of our transport emissions come from cars, New Zealand’s main taxes are income tax and
SUVs, utes and vans. Heavy road vehicles are GST, both of which are designed for revenue
responsible for around a quarter of transport generation. They are intended to be as neutral as
greenhouse gas emissions, even though they are possible and not change behaviour. In accordance
only responsible for six percent of the total annual with good taxation principles New Zealand favours
vehicle kilometres travelled (VKT) on our roads. taxation that is broad based, as it provides a
sustainable revenue base and low administrative
costs. This means that compared to most other
countries, we make little use of taxes to deliver
non-revenue objectives. Other than the Emissions
Trading Scheme (ETS)3, only the problem gambling
levy4 and tobacco and alcohol excise taxes are
designed to influence behaviour.
3 https://environment.govt.nz/what-government-is-doing/key-initiatives/ets/
4 https://www.ird.govt.nz/duties/problem-gambling-levy22 Te Manatū Waka | Driving Change: Reviewing the Road User Charges System
USING THE RUC ACT TO DO MORE THAN RECOVER ROAD COSTS
Using RUC to charge motorists for externalities
other than road damage would be a significant What advantages and disadvantages
Q3 are there to considering externalities
shift in taxation policy generally and RUC policy
specifically. A wide range of matters would need when setting RUC rates?
to be considered to determine if this was the best
way to achieve policy goals. It would also raise If externalities were to be considered,
questions about how to address equity between Q4 what criteria could be used to
motorists paying RUC and those paying FED as determine what externalities should
it would not be as easy to apply similar distance- be taken into account in setting
based charges to petrol vehicles. We would need RUC rates?
to decide if any charges for externalities were in
addition to the current charges, or if they were If externalities were to be considered,
only used to create discounts (such as the current Q5 how should these costs be set?
EV RUC exemptions). Alternatively, we would
change the way we calculate RUC to include new
elements, such as contribution to air pollution, in Would charges for externalities be in
the calculations. This might shift costs between Q6 addition to the current form of RUC,
users but not change the total raised overall. and potentially used to address the
We would also need to consider if the revenue externalities directly, or be a core part
from a component of RUC associated with of total land transport revenue?
externalities would be ‘land transport revenue’.
Would it be part of the National Land Transport How would vehicles not paying
Fund (NLTF), spent on the transport system Q7 RUC be affected?
directly, or should it be allocated to a fund that
addressed the externality? For example, a charge
for noise pollution could be used to fund local
councils to install sound insulation in affected
houses near local roads.Te Manatū Waka | Driving Change: Reviewing the Road User Charges System 23
USING THE RUC ACT TO DO MORE THAN RECOVER ROAD COSTS
2.2
Including impacts on greenhouse gas
emissions when setting RUC rates
One of the key recommendations Providing an exemption or reduced rate of RUC
could help support and promote the uptake
from the Climate Change of new fuels. This assistance would be most
Commission was for Government relevant while the transition to low-carbon fuels,
and to lower cost technologies, is occurring.
to encourage the production This assistance would most likely be through
and use of low greenhouse exempting vehicles subject to RUC (as happens
gas-emissions fuels. with EVs), or through charging a lower RUC rate
than equivalent petrol or diesel vehicles, to
offset higher operating costs. RUC exemptions
In addition to the existing temporary exemptions
or reduced rates would most likely need to be
from RUC for EVs, the Government is already
temporary, as with the current EV RUC exemption,
using a number of levers to assist the transport
in order to minimise any long-term risk to the
sector to decarbonise. Its primary tool to reduce
funding of the land transport system at a time
greenhouse gas emissions is the ETS, which puts
when there are significant demands for investment.
a price on emissions by charging certain sectors
of the economy for the greenhouse gases they Because of their higher purchase and operating
emit. This applies to transport fuels.5 In addition, costs, there is increasing interest in broadening
it is investing in low emission vehicles through the use of RUC exemptions to other types of
government procurement of vehicles and the vehicles that use low-carbon fuels, such as
Low Emission Transport Fund6; and establishing hydrogen fuel-cell electric vehicles (HFCEVs).9
the Clean Car Discount scheme and the Clean Car This exemption is not possible without amending
Standard.7 The Government is also progressing the RUC Act, as only EVs charged from an
a Biofuels mandate.8 external source of electricity are covered by the
wording of the existing exemption. Extending
One of the main reasons to allow climate policy
the exemption would not be consistent with the
or greenhouse gas emissions to be considered
RUC Act’s purpose or current powers. It would be
when setting RUC rates is that vehicles powered
possible to amend the RUC Act to add HFCEVs
by low-carbon fuels are currently more expensive
to the definition of exempt vehicles. However, if
than their fossil fuel counterparts. They either
we were to exempt HFCEVs, it could be better to
require the use of fuels that are more expensive to
create a broader power to consider climate policy
purchase, such as biofuels, or require the purchase
or greenhouse gas emissions when setting RUC
of new and more expensive vehicles, as in the case
rates. This would avoid having to amend legislation
of EVs. In the case of hydrogen, both the vehicles
if other technologies or fuels became important.
and the fuel are significantly more expensive than
diesel or electric alternatives. These costs are If the intent is to support technologies or fuels
expected to reduce as global production increases that are currently more expensive than existing
and technology matures, but at this stage that fuels, but which assist with reducing greenhouse
timing is very uncertain. gas emissions, then we would need to consider
whether RUC could be used to support the use of
biofuels. Biofuels can be used in existing vehicles
5 https://www.epa.govt.nz/industry-areas/emissions-trading-scheme/industries-in-the-emissions-trading-scheme/liquid-fossil-fuels/
6 https://genless.govt.nz/running-a-business/co-funding-and-support/low-emission-vehicles-contestable-fund/about-the-fund/
7 https://www.transport.govt.nz/area-of-interest/environment-and-climate-change/clean-cars/
8 https://www.transport.govt.nz/area-of-interest/environment-and-climate-change/biofuels/
9 https://www.hiringa.co.nz/post/what-the-ruc24 Te Manatū Waka | Driving Change: Reviewing the Road User Charges System
USING THE RUC ACT TO DO MORE THAN RECOVER ROAD COSTS
and provide significant reductions in greenhouse 2.2.1 There are risks with changing
gas emissions over the use of conventional fuels. the purpose of RUC
While biodiesel and bioethanol (usually a petrol
substitute) can be used in pure (100 percent) Providing reduced costs for operators of vehicles
form they are more likely to be sold as a blend. using low-carbon fuels may be supported,
Biodiesel is often sold with a relatively low level especially by those receiving the benefit.
(five or seven percent) of biodiesel blended with However, we do not have good information on
mineral diesel. It is also likely that not all fuels how important the existing RUC exemptions
sold around New Zealand would include biofuels have been in promoting EV uptake, or what
or, if they did, that this would be at the same effect exemptions or discounts would have for
percentage in all retail outlets and all locations. supporting the uptake of other low-carbon fuels.
Given the likely usage patterns of biofuels, it is not This would need to be better understood before
clear if RUC could be used to support these fuels. further exemptions could be proposed and this is
You are welcome to provide feedback on whether why we are seeking feedback on this issue. There
RUC could support the uptake of biofuels. may also be other opportunities where it would be
Looking ahead, there are also currently rare more efficient or effective to spend NLTF revenue
fuels that may become important and could be (that is, revenue from RUC and FED) directly to
appropriate to consider providing reduced rates reduce carbon emissions rather than forego RUC
or exemptions under a new RUC policy. These revenue. Potentially a RUC exemption could also
include fuels such as dimethyl ether (DME)10, be treated as an expense under the NLTF and
a possible alternative to petrol that, under our subject to the same processes for approval as
current legislation, would require the vehicle other funding decisions, through the Government
owner to pay RUC (as the fuel is not currently Policy Statement on land transport.13 This would
subject to FED). In another case, bioethanol is ensure that the impacts of any exemptions on
the only fuel in New Zealand that does not include transport revenue were fully considered.
FED in its price11, and where the vehicle owner RUC exemptions and reduced RUC rates risk
does not have to pay RUC. Although ethanol is undermining the key principle of the RUC system;
normally used as a replacement for petrol, that vehicle owners should pay for the use of
ethanol has been used experimentally as a fuel roads including pavement damage. They would
in diesel engines.12 If the ethanol was used in a also reduce the incentive to choose vehicle
heavy vehicle, the operator would be required combinations that minimise damage to the
to pay RUC. road network.
As well as being used in fuel cells, hydrogen can Broadly, road users have accepted regular
also be used directly as a transport fuel as a gas in increases to RUC (and fuel taxes) as well as
specially modified engines. This use may still cause the idea that heavier vehicles should pay more
air pollution through the combustion process, but because they cause more damage to the roads.
can have very low carbon dioxide emissions. This consensus is in stark contrast to other
Because other fuels and technologies may jurisdictions where there can be significant
become important in the move to a low-carbon protests and unrest when fuel taxes are raised,
transport sector, a more general power to exempt, or where taxes have not been able to be raised,
or otherwise support, low-carbon fuels through often for decades.
the RUC system may be a better approach than
creating an additional exemption for HFCEVS, or
any other specific fuel.
10 https://innovationorigins.com/en/dimethyl-ether-instead-of-diesel-how-trucks-can-become-cleaner/
11 T
echnically, ethanol is subject to FED, when used as a transport fuel, however the rate is set at zero cents. By setting the rate at zero it
means that the fuel is not covered by the RUC Act. It was set at this level to promote its use as a biofuel.
12 https://www.scania.com/group/en/home/newsroom/news/2018/first-scania-bioethanol-truck-hits-the-road.html
13 https://www.transport.govt.nz/area-of-interest/strategy-and-direction/government-policy-statement-on-land-transport/Te Manatū Waka | Driving Change: Reviewing the Road User Charges System 25
USING THE RUC ACT TO DO MORE THAN RECOVER ROAD COSTS
Some in the transport sector may not support the price of all transport fuels so accounting for
using RUC to provide discounts or exemptions them in RUC rates would duplicate costs.
because it would undermine the principles of the
While the ETS plays an important role in meeting
RUC system, that vehicle owners should pay for
the Government’s climate objectives, it will not be
their use of the roads. Wider use of discounts or
enough to reach the net zero target. Meeting the
exemptions could also lead to a decline in funds
Government’s targets will require a wider range
available for building and maintaining transport
of responses because although the cost of the
infrastructure and the likelihood of additional
ETS on fossil fuel use for transport is ten times
increased costs for other road users to offset
what it was five years ago, the impact on travel
the expected revenue loss.
has been minimal.
As well as offering a tool to support new
The cost in foregone RUC revenue per tonne of
technologies through RUC exemptions or
carbon dioxide avoided varies by fuel type and
discounted rates, there is a strong correlation
vehicle weight. As shown In Table 1, the amount
between transport emissions and the distance or
of revenue foregone per tonne of carbon avoided
vehicle kilometres travelled (VKT), when vehicles
ranges from around $260 per tonne of carbon
are fuelled by fossil fuels. As a distance-based
for a small diesel vehicle to over $430 per tonne
charge, RUC is a direct way to influence distance
of carbon for a very heavy diesel truck.14 For
travelled and it would be possible to set RUC
comparison the price of carbon in the ETS is
rates to also reflect greenhouse gas emissions of
around $50 per tonne at present and is expected
the fuels being used. However, these are already
to rise to around $100 by 2030.
addressed through the ETS which is included in
Table 1: Indicative costs per tonne of CO2 emissions avoided through a RUC exemption
Two axle
Light petrol Small diesel diesel truck/ Very heavy
vehicle* two axle truck passenger bus diesel truck with
(equivalent to (GVM 9-12T, (GVM > 12T, two trailers
RUC Type 1) RUC Type 2) RUC Type 2) (GVM 55T)
Average travel (km per annum) 11,000 20,000 50,000 150,000
Fuel use (l/100 km) 9.5 25 40 55
Fuel used (L per annum) 1,045 5,000 20,000 82,500
CO2 emitted (T per annum) 2.6 13.4 53.5 220.7
Cost of RUC (per 1,000 km) $76.00 $172.00 $315.00 $630.00
Total RUC revenue foregone (per annum) $836.00 $3,440.00 $15,750.00 $94,500.00
Cost per tonne of CO2 avoided $326.53 $257.20 $294.39 $428.21
(in foregone RUC revenue)
*Light petrol vehicle is provided as a point of comparison, showing indicative costs if they paid RUC.
14 h
ttps://www.nzta.govt.nz/vehicles/licensing-rego/road-user-charges/ruc-rates-and-transaction-fees/26 Te Manatū Waka | Driving Change: Reviewing the Road User Charges System
USING THE RUC ACT TO DO MORE THAN RECOVER ROAD COSTS
These costs are, to some extent offset by wider
benefits to the New Zealand economy through What are the advantages and
Q8 disadvantages involved in changing
increased quantities of fuels being produced in
New Zealand, such as electricity, hydrogen and the purpose of the RUC Act so that
biofuels. The increased use of low-carbon fuels climate policy generally, or greenhouse
is also expected to contribute to other benefits gas emissions specifically, can be
such as reduced local air pollution and potentially considered when setting RUC rates?
reduced noise pollution with EVs and HFCEVs.
What advantages and disadvantages
Using RUC to provide support separately from Q9 would there be if there was an
the ETS may also cause issues where vehicles explicit requirement to consider
can use more than one fuel, and these fuels RUC exemptions as part of the
would have different greenhouse gas emissions development of the Government
which may be subject to different incentives. For Policy Statement on land transport?
example, some hydrogen fuel cell electric vehicles
can also recharge their batteries directly from an
electrical source, which makes them an electric What are the advantages and
Q 10 disadvantages of enabling
vehicle under our current law. Should these
types of vehicles be considered hydrogen or consideration of greenhouse gas
electric vehicles? emissions when setting RUC rates?
RUC exemptions come at a cost in terms of How should the RUC rates be set for
reduced revenue for the NLTF. Any revenue not Q 11 vehicles that could use more than
collected (foregone), that is not offset by increased one fuel and these fuels had different
costs imposed on other RUC vehicles, will increase greenhouse gas emissions?
the pressure on the NLTF. The foregone revenue
will need to be balanced against the Government’s
What advantages and disadvantages
existing GPS investment priorities that may Q 12 are involved in using NLTF revenue to
need to be deferred or delayed as a result of
reduce carbon emissions rather than
the reduced revenue. We are interested in your
foregoing RUC revenue?
views as to whether it would be more efficient or
effective to spend NLTF revenue directly to
reduce carbon emissions, rather than forego
RUC revenue.You can also read
