The IPCC’s 1.5°C-aligned guidance on road transport recognizes different pathways for light-duty and heavy-duty transport. For heavy-duty transport, the IPCC identifies a need to phase out internal combustion engine (ICE) vehicles and transition towards electrification. However, the report also recognizes that heavy-duty vehicles face challenges (IPCC AR6 WGIII, April 2022, Chapter 4, Section 4.2.5.8) with electrification, such as driving range (IPCC AR6 WGIII, April 2022, Chapter 10, Executive Summary), cost, and infrastructure availability (IPCC AR6 WGIII, April 2022, Chapter 10, Section 10.3.4). The IPCC therefore acknowledges that alternative technologies, including biofuels and hydrogen produced using renewable energy or from fossil fuel generated energy with clear conditions around the use of carbon capture and storage (CCS), can be used as legitimate decarbonization pathways to complement electrification for heavy-duty transport (IPCC AR6 WGIII, April 2022, Chapter 10, Executive Summary).
A +2 score, indicating strong alignment with the IPCC’s science-based guidance for heavy-duty vehicles in 1.5°C pathways, is achieved by supporting the need for an ambitious phase-out of ICE vehicles and advocating for regulations promoting the electrification of heavy-duty vehicles. Support for policy, infrastructure, and investments to develop hydrogen produced using renewable energy or using fossil fuel generated energy with clear conditions around the use of CCS for use in heavy-duty vehicles is also scored as +2.
A +1 score, indicating broad alignment with the IPCC’s science-based guidance for heavy-duty vehicles in 1.5°C pathways, is achieved by generally supporting the electrification of heavy-duty vehicles and the phase-out of ICE vehicles. Statements that generally support the development of hydrogen produced using renewable energy or using fossil fuel generated energy with clear conditions around the use of CCS for use in heavy-duty vehicles are also scored a +1.
A 0 score, indicating unclear or mixed alignment with the IPCC’s science-based guidance for heavy-duty vehicles in 1.5°C pathways, is achieved by supporting the decarbonization of heavy-duty transport but placing qualifying factors on the pace and scale of a transition towards zero emissions vehicles, such as emphasizing concerns around available infrastructure. Statements advocating for the use of alternative fuels such as biofuels or low-carbon fuels or hydrogen without clarifying its production method are also scored as 0.
A -1 score, indicating broad misalignment with the IPCC’s science-based guidance for heavy-duty vehicles in 1.5°C pathways, is achieved by not supporting the decarbonization of heavy-duty vehicles or by advocating for the use of alternative fuels or ICE vehicles as preferable long-term solutions over electrification or hydrogen. Advocating for a technology neutral approach to the decarbonization of heavy-duty vehicles over a complete transition to zero emissions vehicles is also scored a -1.
A -2 score, indicating strong misalignment with the IPCC’s science-based guidance for heavy-duty vehicles in 1.5°C pathways, is achieved by opposing the phase-out of ICE vehicles and the electrification of heavy-duty vehicles.
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To enable growth of electric vehicles in the heavy vehicle transport sector, the Heavy Vehicle National Law Review should consider the implications of Australian Design Rules, while recognising the need for harmonisation across states and territories. [...] Australia lags the world in electric vehicle uptake. A lack of policy support limits uptake, model availability, investment, and transition. This is despite that the decarbonisation of the transport sector – and the road freight sector inside of that – has the potential to dramatically reduce our emissions and set us on the right path. The Heavy Vehicle National Law Review has a once in a decade opportunity to accelerate the adoption of electric vehicles in the heavy vehicle sector. Exemptions from ADRS and subsequent reform of them with the EV industry will enable manufacturers to supply our market with the vehicles that the freight and logistics sectors are asking for.
Created - 03/11/2022
Last Edited - 20/02/2023
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Supporting the decarbonization of the transport sector, specifically using zero-emission vehicles for heavy-duty transport (UltraTech Cement, Managing Director, Kailash Jhanwar, Press Releases, July 2023)
As the largest cement manufacturing company and as an industry leader, UltraTech is one of the partners of Moving India. Affirming UltraTech’s commitment to this crucial cause, UltraTech MD, Mr. K.C. Jhanwar, said, “India is the second largest cement producing country in the world, with cement plants spread across the country. The cement sector can provide an ideal use case for the early adoption of zero emission trucks.
Created - 24/07/2023
Last Edited - 25/07/2023
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Advocating for the use of biofuels in aviation, marine, heavy-duty transport (Corporate website, 'Advancing Climate Solutions,' January 2024)
These fuels generate less emissions over their life cycle than the traditional fuels they replace. They include biofuels made from renewable sources like plants and waste biomass and synthetics made from hydrogen and captured carbon dioxide. Lower-emission fuels have the high energy density required to move heavy trucks. Renewable diesel can reduce carbon emissions by up to 70% compared to conventional diesel.17 Demand for these fuels is expected to grow rapidly, driven by the aviation, marine, and heavy-duty trucking industries
Created - 23/07/2024
Last Edited - 23/07/2024
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Promoting a long-term role for ICE heavy-duty vehicles powered by CO2-neutral fuels, over rapid decarbonization of the sector (Repsol consultation response on the EU's review of emission standards for heavy-duty vehicles, May 2023)
We welcome the revision of the regulation on CO2 emissions for new heavy-duty vehicles as a fundamental tool for the decarbonization of the transport sector. However, in relation to the proposal launched by the Commission on February 14, 2023, we miss the recognition of the contribution of CO2-neutral fuels as a complementary way to electromobility, so that the decarbonization of road transport is carried out in an agile, resilient, safe and socially just way. To ensure a successful energy transition, it is essential to guarantee the competitiveness of industry as an essential pillar of the European economy. To this end, regulation must enable technology development and deployment of all carbon neutral technologies while ensuring that European industry can compete on a level playing field compared to other regions that do not have the same climate ambition. Therefore, we consider it is essential to recognize the contribution of CO2-neutral fuels (CNFs) for the decarbonization of road transport in this regulation […] The use of CO2-neutral fuels entails the following advantages: - Reducing the investment needed in distribution and supply infrastructure. - Reducing the necessary investment in the transformation of the automotive industry. Allowing the transformation of the current fuel production industrial sites, guaranteeing their continuity and development and, consequently, employment. […] THEY ARE A LEVER TO BOOST RENEWABLE HYDROGEN CONSUMPTION IN EUROPE, without having to wait for the development of hydrogen engines. […] If the EU only recognize electrification as the only tool to decarbonize heavy-duty transport, it will jeopardize these investments and the opportunity to rapidly develop the renewable hydrogen market. THEY ARE NECESARY TO PRESERVE THE COMPETITIVENESS OF EUROPEAN INDUSTRY: they are an optimal solution for carrying out the decarbonization of heavy transport in the most cost-efficient way possible. This is especially relevant in Spain as the share of road freight transport is significantly higher than in the rest of Member States. […] THEY MAXIMISE OPTIONS TO DECARBONIZE AVIATION AND MARITIME TRANSPORT: the exclusion of CO2-neutral fuels from heavy-duty vehicles regulation would threaten the viability of essential investments for the development of sustainable fuels for aviation and maritime transport. […] JUST TRANSITION: they guarantee industrial transformation plans, promoting employment and the development of depressed rural and industrial areas, ensuring investment and the capture of value for European and national GDP, in sum, avoiding the relocation of industry. […] THEY CONTRIBUTE TO STRENGTHEN ENERGY SECURITY OF SUPPLY IN EUROPE: the production of CO2-neutral fuels from non-reusable and nonrecyclable waste makes it possible to replace the import of crude oil from other regions.
Created - 04/07/2023
Last Edited - 04/07/2023
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Opposing ZEV sales mandates and emphasizing numerous challenges associated with a heavy-duty ZEV transition, such as inadequate charging infrastructure, insufficient regulatory support, and pressure on the grid (Daimler Truck North America comments on GHG Emissions Standards for Heavy Duty Vehicles – Phase 3, June 2023)
The proposed standards are based in significant part on EPA’s assumptions about HD ZEV market acceptance and adoption rates, thus successful implementation of the Phase 3 program will depend entirely on these assumptions proving accurate over the long term. Buildout of ZEV fueling infrastructure, in particular, is essential to widespread ZEV adoption. As EPA details in the Proposed Rule, payback periods and total cost of ownership (TCO) relative to comparable internal combustion engine (ICE) vehicles will also be crucial factors for HD ZEV market acceptance. ZEV suitability for commercial trucking applications is another key component of the uptake equation, which requires careful consideration of daily vehicle miles traveled (VMT), charging dwell times, weight penalties, and the viability of depot charging. […] The Company has studied this issue extensively and models its projections of HD ZEV market uptake based upon a “transformation equation” that is a function of three main factors: (1) vehicle technology development, (2) cost parity between ZEVs and conventional vehicles, and (3) infrastructure development. The Proposed Rule addresses only the transition in vehicle technology, and it does nothing to address the other two factors, as they are outside of EPA’s regulatory authority. It is important for EPA to recognize, however, that without these other two important factors, HD ZEV demand may never materialize—at least at the rates that EPA projects. Another important criteria for projecting future HD BEV adoptions rates is the readiness of electric power generation sources, utilities, and the electric grid to adapt to new demands from increased use of electric vehicles. Similarly, hydrogen infrastructure must be available for FCEV or H2-ICE uptake. This is yet another component of the market uptake equation over which EPA has no regulatory control and is thus difficult to predict or incorporate into the Agency’s future projections. […] Based upon these considerations of ZEV suitability, EPA should adopt more conservative maximum adoption rates. EPA states in the Proposed Rule that it limited the maximum penetration rate to 80% to account for the “actual needs” of purchasers related to two primary areas of its analysis, namely application suitability and infrastructure availability.37 DTNA submits, however, that an 80% maximum adoption rate over-represents the fraction of the market where BEVs or FCEVs are suitable in the near-term and that application suitability is inadequately addressed in the HD TRUCS methodology. […] In the Proposed Rule, EPA excludes a number of considerations that are integral to the fleet purchase decision, and which exist independent of calculated payback periods: Infrastructure Challenges […] Reluctance to Adopt New Technology […] Inflation and Other Economic Conditions […] Vehicle Suitability to Fleet Operations. […] EPA seeks comment on how incentives enacted with passing of the IRA and BIL should factor into its TCO and market uptake projections, and asserts that these recent congressional actions will reduce uncertainty related to infrastructure. While DTNA appreciates the positive effects that these ambitious pieces of legislation will likely have on the HD ZEV market and believes they are directionally correct, the Company is concerned they may not have the magnitude of impact EPA is projecting. […] State HD ZEV incentives are not uniform and have been adopted only by a minority of states. […] ZEV sales mandates alone will not drive transformation of the HD transportation sector. […] Simply stated, ZEV mandates placed on manufacturers will not by themselves influence demand, thus it would be inaccurate for EPA to assume that the imposition of its regulatory requirements based on projected sales will necessarily promote HD ZEV market uptake.
Created - 29/06/2023
Last Edited - 29/06/2023
InfluenceMap Comment
Strongly supporting specific regulatory measures towards the electrification of transportation; advocating for heavy vehicle road reform to accelerate the adoption of EVs in the heavy vehicle sector (Electric Vehicle Council, Submission to the National Transport Commission on the Heavy Vehicle National Law Review, December 2020)