Submission to National EV Strategy

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INTRODUCTION
To reach net zero greenhouse gas emissions, Australians must embrace a wide range of
new, sustainable behaviours.
This is particularly the case in the area of private transport where the use of medium and
large vehicles is entrenched in our social fabric and reinforced by aggressive marketing,
advertising and sponsorship campaigns by industry.
Comms Declare is an organisation of more than 360 marketing, advertising and media
professionals and agencies that understand the profound impact these campaigns have on
increasing demand for high-emissions vehicles.
If we are to have any chance of reaching net zero, we must prevent these campaigns from
continuing and, better educate consumers about the climate impacts of their vehicle choice.


In addition to the measures in the proposed Framework for the National Electric Vehicle
Strategy, Comms Declare advocates for:
• Mandating standardised greenhouse gas emission labels on all vehicles
• Mandating greenhouse gas emission information on advertisements for ICE and
PHEV vehicles
• A ban on advertising new vehicles with emissions intensity of 210 g/km or higher
• Begin public education campaigns to promote low-carbon consumer choices.

These measures will reinforce the aims of the Climate Change Bill 2022 and our obligations
under the Paris Agreement.


DEMAND IS THE PROBLEM
The National Transport Commission has found Australia’s love for large SUVs and Utes,
means our transport emissions are not falling even as EVs become more popular.
The Commission’s 2022 yearly report found:

• Sale of 4×4 and 4×2 Utes increased by more than 43,000, and large SUV sales
increased by around 25,000. The emissions intensity for many of these popular
vehicles exceeds 210 g/km
• Half of all new car sales were SUVs, up from a quarter of all sales a decade ago.
• Small vehicle segment once accounted for a quarter of all sales but today is one
in 10.
Highly polluting larger cars are aggressively marketed, manipulating emotional triggers.
Large Utes are marketed using appeals to masculinity. SUVs are sold using the desire for
family safety and a love of nature. However, they never mention the dangers that air
pollution (including greenhouse gases) pose on our safety or the natural world. This is
despite growing SUV demand being “the second-largest contributor to the increase in
global CO2 emissions since 2010 after the power sector.”
SUVs are heavily marketed because they are more profitable. In 2018 Ford reportedly
shifted 85% of its marketing budget into SUVs and trucks.


PHEVS AND EV DEMAND
Toyota has been focussing on selling hybrids, entrenching fossil fuel use, delaying the
transition to EVs and slowing emissions reduction. In 2018, Go Auto News reported:
“It is virtually impossible to miss Toyota’s current media campaign highlighting its hybrid

technology, with the message spray-painted on AFL football fields and reinforced by non-
model-specific commercials shown on prime time television.

“These include a ‘Why plug in?’ TVC that suggests consumers look to Toyota’s full-hybrid
models rather than the newer wave of plug-in hybrid and electric vehicles.
“The TVC implies that plug-in vehicles aren’t worth the bother with the inconvenience of
cords and battery depletion.”
In 2021, Toyota hybrid sales passed 200,000 and there was reportedly a “lengthy wait
for the RAV4 Hybrid”. Part of the reason this demand is high is because people are
falsely told hybrids are a ‘green’ vehicle choice.
We believe that there should not be further inducements to sell PHEVS, as any
government incentives would be promoting the misconception that PHEVs are good for
the climate and environment.
EV demand also strong, with wait times up to nine months for new models. Therefore,
we believe marketing efforts should be focussed on behaviour change and reducing
demand for high emissions vehicles, not increasing demand for EVs.


BEHAVIOUR CHANGE
Reducing demand for SUVs and Utes can be done relatively quickly and can follow overseas
examples.

France is already acting. Its Climate Bill was far reaching, tackling consumption, production
and work, transport, housing, food, and law.
France’s actions to reduce high-emissions vehicle use include:
• Ban on advertising the most polluting large vehicles from 2028
• Mandate that green transport options and carbon-dioxide emissions appear on car
ads
• Mandate clear carbon labelling
• Mandate climate education in schools


The UK’s Environment & Climate Change Committee found that one third of greenhouse gas
emissions reductions up to 2035 require decisions by individuals and households to choose
low-carbon products and services, as well as reduce carbon-intensive consumption. But
that, like the tobacco industry, legacy companies were likely to strike back to protect their
profits:
“There is a risk that parts of the food and fossil fuel industries, as well as heavy users of fossil
fuels, similarly seek to undermine the policies needed to enable behaviour change to meet
net zero.”


It recommended:
• Product standards and labels to encourage low-carbon consumer choices
• Measures to regulate advertising of high GHG products
• Assess how online climate misinformation can be challenged
• Support climate-friendly life choices through education


It added: “..the Government should introduce a public engagement strategy to build support
for helping people adopt new technologies and reduce carbon-intensive consumption in key
areas where behaviour change is required. Net zero cannot be achieved without addressing
both.”

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