The Federal Chamber of Automotive Industries (FCAI) welcomes the opportunity to provide our views on the NSW Governments Statutory review of the Gas and Electricity (Consumer Safety) Act 2017 Discussion Paper.
The FCAI is the peak Australian industry organisation representing the importers and distributors of over 99% of new passenger vehicles and light commercial vehicles up to 3.5t Gross Vehicle Mass (GVM) and motorcycles sold into the Australia market. Our members through their authorised repairer networks indirectly employ thousands of automotive vehicle repair technicians and some associated trades with a large proportion of these being registered in NSW.
Australia is a small market comprising approximately 1 million new passenger cars and light commercial vehicles sales each year. This amounts to around only 1.2% of annual, global new vehicle sales. Following the withdrawal of all domestic manufacturing in 2017, Australia is a technology taker of increasingly complex automotive products particularly as we consider the technological changes that are occurring within the industry of which some of these may have implications for the proposed legislative changes.
In the first instance, FCAI points out that motor vehicles imported into Australia are designed and built to comply with Federal legislation being the Road Vehicle Standards Act (RVSA), it is this Act which describes several pathways through which a road vehicle can demonstrate compliance with the Australian Design Rules (ADRs) and be approved for sale across Australia. It is designed to set nationally consistent and uniform standards, with which road vehicles must comply with and are permitted to be registered by States and Territories across Australia.
The RVSA includes the Register of Approved Vehicles (RAV) being a publicly searchable database of approved vehicles that are available for supply in Australia.
In line with environmental considerations, we do expect that the light vehicle fleet will increasingly move away from Internal Combustion Engines (ICE), introducing a range of electrified powertrains in various manners. These electrified powertrains can include:
- Hybrid Vehicles (HV)
- Plug In Hybrid Electric Vehicles PHEV)
- Battery Electric Vehicles (BEV)
- Hydrogen Fuel Cell Electric Vehicles (FCEV)
It is under this environment that we need to ensure that there remains the ability for automotive manufacturers to bring these newer technology vehicles to market including maintaining the capability for these vehicles to be serviced and maintained by suitably qualified automotive professionals – we note that there is a separate discussion paper issued by NSW dealing with Electric Vehicle (EV) mechanic repair classes which we will respond to separately.
The FCAI in our response to this paper wishes to ensure that none of the changes proposed in this discussion paper would have the unintended consequences of restricting the ability for the automotive industry to import, comply, register for use on public roads in NSW or service and repair these newer powertrain equipped light vehicles using suitably qualified automotive technicians.
We would also like to acknowledge the separate NSW discussion paper released recently “Proposed introduction of Light Electric Vehicle mechanic and Heavy Electric Vehicle mechanic repair classes in NSW” and there is no doubt several interrelated issues between these two discussion papers depending on the scope contemplated or considered.
Below is the discussion response paper and we should point out that FCAI will only respond to the questions that we believe are relevant to the light vehicle automotive sector.
Read the full submission at the link below.