Last month the Government proposed a series of initiatives to help reduce transport emissions by improving the quality of our vehicle fleet. A lot of focus went on what’s called the “Clean Car Discount” where purchasing new dirtier vehicles will become more expensive and new cleaner vehicles cheaper. While there was a bit of political noise initially, polling had indicated the public support the policy:

Fifty-one per cent of New Zealanders support the Government’s proposed electric vehicle scheme that would see low-emission cars subsidised and a fee added to some high emitters.

The latest 1 NEWS Colmar Brunton Poll found 51 per cent were in support, 39 per cent opposed it and 10 per cent did not know.

The groups of people who were more likely than average to support the scheme were Green Party supporters, Wellingtonians, Labour supporters, Asian New Zealanders and people aged 18-34.

Those who were more than likely against were National supporters, people living in Waikato, men aged 35 and over and New Zealand Europeans.

More recent indications suggest about 80% of online submissions so far also support it.

Associate Transport Minister Julie Anne Genter said about 80 per cent of the online responses the Transport Ministry had so far received in response to a discussion paper on the feebate scheme and an associated “clean car standard” had supported the policies.

There is a clear and urgent need to reduce New Zealand’s transport emissions. Since 1990 emissions from transport – especially road transport – have grown faster than any other sector.

Furthermore, in recent years transport emissions have grown scarily quickly, possibly reflecting the previous government’s focus of transport investment into a few large and very expensive roads – as well as rapid population growth:

Much of our raison d’etre at Greater Auckland is about encouraging transport agencies and politicians to improve public transport, walking and cycling facilities, as well as to reshape our cities so people don’t have to be so car dependent, which is one of the best ways to help reverse this trend. But the scale of our emissions challenge is so great that we also need to dramatically change the vehicle fleet away from burning fossil fuels – so it’s great to see initiatives like this from the government.

Alongside the “Clean Car Discount” that most of the media discussion has focused on, the Government’s proposal also covers what’s called a “Clean Car Standard” – which seeks to improve the fuel efficiency of vehicles being imported into New Zealand. It’s described in a bit more detail below:

I was pretty shocked to find that New Zealand is one of only three OECD countries (along with Australia and Russia) to not have a vehicle fuel efficiency standard. This means that we often get much less fuel efficient versions of major models than other countries – meaning that we end up needing to burn more petrol, creating more emissions and also costing New Zealanders a lot in extra petrol costs. The table below shows how much less fuel efficient most vehicle models sold in New Zealand are compared to their UK equivalents:

While the standard (and indeed the Clean Car Discount) aren’t a complete solution to the transport emissions problem New Zealand faces, the graph below indicates that the standard will make an important contribution to reducing our emissions – especially if the standard continues to be tightened over time.

Overall, introducing the standard has significant benefits and really appears to be a ‘no-brainer’. In fact it’s pretty surprising that this wasn’t done a long time ago.

If implemented in 2021, a vehicle fuel efficiency standard with an emissions target of 105 grams CO2/km in 2025 is estimated to have lifetime emissions reductions of between 3.9 million and 6.7 million (mid-range 5 million) tonnes of CO2.

This level of emissions reduction is the equivalent to preventing the emissions from 359,000 to 616,000 (mid-range 476,000) vehicles. Alternatively, it is the equivalent to preventing nearly all the emissions that occur from electricity generation in a single year.

A vehicle fuel efficiency standard would have associated fuel savings estimated at $2.2 million to $5.6 billion (mid-range $3.4 billion) over the period 2020–2041. It would also contribute to a reduction in air pollutant emissions through facilitating an increase in the uptake of EVs.

You can make a submission on the proposal (as well as the Clean Car Discount) until 5pm today here.

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82 comments

  1. Please submit that e-bikes should have a rebate as well. The reason being is that people often find they use the e-bike instead of their fossil car – they can waft you up hills and bring home a load of groceries no sweat. However cost is a barrier for many people. The cost of recognising e-bikes as electric vehicles and bringing them into the scheme can be met by extending the pathetic $3k cap on highly polluting vehicles to a percentage of their total cost.

    1. Peter, I agree. But it does raise some other questions. We don’t manufacture cars here, and probably never will again. But we could easily have a big ebike manufacturing industry, and probably should. Do we need careful wording to ensure the incentive is targeted to manufacture as much as (or even more than) importing of ebikes?

      If the MoT truly recognised cycling as a valid transport mode, the scheme would include bicycles as well as ebikes. Then it would really contribute to a healthy transformation of the transport system, and allow slightly more of the externalities imposed by driving to be captured and applied to reduce the cost of the healthy modes.

    1. It doesn’t matter which because both numbers are carefully made up in laboratory conditions, under the direction of the manufacturers.

    2. The discussion document says, “The preferred measure for vehicle fuel efficiency is grams of CO2 per kilometre (gCO2/km). This measure ensures all fuel types, for example petrol, diesel, biofuels, electricity, and hydrogen are treated in an equitable manner. It also focuses directly on the overarching goal of the vehicle fuel efficiency standard, which is to reduce CO2 emissions”

      1. You are wrong. Fuel efficiency is measured after the car is manufactured and that shows BEV’s having a high energy efficiency. If you take an honest approach and count energy efficiency from well to wheel, BEV’s are poor compared to HFC and liquid renewable fuels

        1. Hydrogen Fuel Cells have been almost ready for 20+ years. My pick is it’s not going to happen. Battery tech has overtaken hydrogen already and, based on reports, solid state batteries will be in production cars in a couple of years. This will end the game. VHS vs Betamax

        2. Daniel, right or wrong, it is irrelevant. As Bryce mentions, VHS vs Betamax.
          BEV’s have already won. All the infrastructure is there already. It is non-existent for HFC. I’m not even going to talk about how you get the hydrogen in the first place.

          The longer you use a BEV car the better the efficiency because the manufacturing costs are spread out further. Distributed solar continually gets cheaper and is another nail in the coffin. Heck, if you are talking about NZ and you charge your car over night using cheap hydro, the energy efficiency improves again because that power was going to just go to waste anyway because the river needs to keep flowing. Battery tech continues to improve and drop in price and that’s not even taking into account radical alternative batteries that could arise.

          Betting on HFC tech for cars is a very poor investment. May as well just go to Vegas.

  2. It’s inevitable that the most opposition to such policies will be from people who currently have high emissions profiles. Particularly farmers and those in other primary production sectors who live in rural areas, actually need utes and regularly drive long distances. Those people have no real alternatives at the moment (at least until electric utes arrive in a couple of years).

    It’s also inevitable that the most support from such policies be from people who won’t be impacted by them: Those living in urban areas who already heavily use public transport and/or active modes. Those who don’t need to own a car etc.

    The key to political consensus on transport emissions reduction lies in acknowledging that, with current technology, change is very difficult for the former category but easy for the latter category. The low-hanging fruit is to invest heavily in PT and active mode infrastructure in cities where it’ll encourage the most mode-shift. Get more urban dwellers abandoning their cars so rural dwellers don’t need to.

    1. I’d argue that 99% of people that can afford to own a ute/SUV/large vehicle have no real reason to complain at all.

      I own one, drive long distances in it and am about to submit that the rego for them (or RUC for diesel vehicles), should be much higher.

      Currently it’s way too cheap to own one which is exactly why there are so many driving around town.

      1. As Matt points out we have no emission standards, and I’d put forward this is lack of constraint it is actually making total emissions worse in the Ute segement. At the moment it’s all whos got the biggest….towing capacity, torque, Beast, and it is a marketers dream. Its also cheap and easy to market – More power, more power.

        Your not going to get the manufacturers and local marketing to change their messaging unless they all have to. The best selling utes at the moment are the ones sold as the biggest beast, and that image appeals to the target market. And as the rules stand today they can keep on one upping each other over torque and towing capacity.

        Bringing in emission and efficiency standards won’t stop the sale of these vehicles, but it will force marketing will reshape the messaging, borrowing out of Europe etc. The power trains will change, but the market segment doesn’t disappear it will reshape. And maybe for the rest of us a little bit more marketing around responsibility

    2. Considering we are one of the most urbanised countries in the world I really doubt this will be much of an issue. Most farmers and rural business will buy these vehicles through the business and will be able to absorb the cost.

      Most people living in “rural” areas (like people living on lifestyle (or as Matt Heath calls them “deathstyle”) blocks) use their vehicles in much the same way as city people but maybe slightly more kms.

  3. Time to hit diesel cars with a heavy tax. With enough cheating by the manufacturer they can met standards when the are sold new, but within two years they are belching particulates and causing more deaths than CO2 does. Europe was conned by the diesel lobby, we should do better.

    1. And news out today is that a German court has determined that VW’s supposed “Dieselgate” software fix, which they put in place by agreement – after the first round of being caught red-handed. Actually has another software override in it that turns it off outside of certain temperature ranges. Making it ineffective.

      Oh Dear.

      So the grand plan of European car makers to relaunch their new, improved [now even more] Clean Diesels has stalled – before it even left the starting grid.

    2. Diesel cars are already slugged with a Tax, its achieved by levying them the same RUC rate as a 3.4 Tonne truck,

      This has helped keep a lid on the growth of (particularly small) diesel cars in NZ

      Diesel vehicles make up around 9% of the NZ light passenger fleet, In the UK ( and other European places) it is around 40%

      1. Lucky for us. Otherwise we could have an old vehicle fleet with worn out diesel engines. It is already bad enough that so many wankers by a small truck and use it as a car. Imagine if we had as many oil burners on our roads as they do in Europe or the UK.
        My point is there are already too many here so time to increase the tax on them.

    3. And yet here’s a “clean car” standard which ignores all pollutants except CO2, won’t cut in for years and has special allowances for heavier vehicles. If this turns out to be the diesel subsidy it looks like, it may actually make air pollution worse than we’d otherwise have had.

  4. One of the ironies is that we will have fossil fuelled evs as long as Genesis continues to run the Huntly Coal Power Station.
    We need to decarbonise the grid.

    1. EVs in highly fossil fuel intensive grids are still better for overall emission than diesel cars. This has been debunked so many times: https://electrek.co/2017/11/01/electric-cars-dirty-electricicty-coal-emission-cleaner-study/
      Huntly has quite a specific role in enabling the level of renewables in the grid at present. Without it security of supply would be much harder. How we transition to providing that security without coal is the challenge, and it being looked at.

      1. I know why Huntly exists, but that doesn’t make it right. The answer is to build more renewable energy plants as simple as that; no one needs to look for a solution.

        Have a look at the recent history of this. Memory says that the coal plant was due to close in 2020.

        1. We also must not let perfect be the enemy of better.

          A perfectly decarbonised grid is achievable – at a high real and opportunity cost.

          We can probably achieve a 96% decarbonised grid far more easily and at a lower cost, then use carbon offsetting of permanent native forests to cover the 4% of the grid that is not.

          Then spend the money saved by that apporach on decarbonising the many parts of the NZ economy that can’t [yet] run on electricity from that [decarbonised] grid.

          That overall will achieve more sustainable and better results than some textbook approach to 100% clean electricity can or will.

    2. I think they only run two of the original 4 coal/gas duel fuel boilers. The other two newer units are a big gas powered generator and a small gas/diesel unit used for the peaks.
      I don’t know a lot about it but it would seem a simple job to stop using coal in the first two units altogether. Gas creates CO2 but it isn’t in the same league as coal and unlike the coal it comes from New Zealand.

      1. Plus it is much faster to power up a gas powered turbine so it means it is much more efficient. Coal powered turbines have to be kept at a low level until they are needed or take ages to come on line.

        Gas can be up and running in minutes from cold.

      2. Most of the issue is around fuel flexibility and storage, so that the complimentary generation can flex up when the hydro inflows are low. We’re talking about thousands of GWh of seasonal storage. Gas doesn’t have that flex. The fields run almost at max 24/7, and outside of Ahuroa, it isn’t storable.

        1. And there is another major issue in that we only have current gas supplies that will last to 2029.
          We have to consider whether it is more equitable to run power plants and exhaust it quickly; or to allow hudreds of thousands of households and restaurants to continue to use gas for cooking and heating.

        2. I don’t think the renewable solutions for peak generation are too far off. There’s a couple of trial hydrogen generation plants that are on the drawing board in NZ that will be used to store excess renewable energy. This can then be either used in the vehicle fleet, industrial heating processes or converted back to energy on-grid.
          The whole process is only about 50% efficient at the moment but I’d expect that could become better over time and be used as a viable alternative for peak generation, possibly in conjunction with battery storage.

        3. “The whole process is only about 50% efficient at the moment”

          Rectification efficiency x hydrolysis efficiency x storage efficiency x fuel cell efficiency x inverter efficiency is around 50%?

          Sounds wildly optimistic. Do you have a link?

        4. JohnWood I would worry about the gas running out in 2029. I remember when it was going to run out in 2001.

    3. Partially fossil fuelled EVs, the majority of the electricity will come from renewable sources. Also coal fired power is still a lot more efficient than individual combustion engines in cars.

  5. Thanks, Matt. Can someone explain to me why manufacturers are making different versions of the major models, with more and less fuel efficiency? It seems designed to confuse consumers and also to take advantage of countries like New Zealand who have neglected their emissions responsibilities.

  6. Thanks Matt, just made my submission. Is anyone aware of the RUC scheme being looked at? I support EVs paying their way (as an EV owner), but under the current scheme they will pay more than a small car or hybrid because fuel excise on petrol cars is effectively pegged to both distance and fuel efficiency. The other problem with the current scheme is that a PHEV will either pay twice or not at all, depending on how it is characterised. This scheme needs to be redesigned to come in at the same time and the clean car standard and feebate.

    1. You should submit on the RUCs issue (I did).

      I agree its ridiculous that a zero emission EV pays more in road taxes than a polluting Petrol car per-km travelled even if they are similar/the same weight.

      I think there needs to be a RUC rate for EVs which is at least half the current $72 per 1000 km (inc GST) – i.e. which is about 3 cents a km + GST.

      But PHEVs [and dual fuel vehicles like LPG/Petrol conversions] raise a good point – if they are run solely on petrol but are also required to pay RUCs then they could pay twice the tax.

      But that would occur for a PHEV only if the owner owns a PHEV and then drives it on petrol only.

      To be honest, that double taxing that occurs there is a reasonable penalty to discourage this behaviour, which in effect lets PHEV owners “greenwash” their driving, so they look like their reducing emissions when they are not.

      So I’d suggest we leave that “penalty” in place for PHEVs.

      If the PHEV owner only uses electricity and never puts petrol in it they would pay once – for the RUCs and not for the petrol excise tax as they don’t consume petrol. So again thats ok. They do pay something towards the roads.

      However exempting the PHEVs from RUCs would leave a large loophole that PHEV owners could run them [mostly] on electricity, which is good. but not pay any [or pay minimal] road taxes, which is bad.

      If this occurred for a small portion of the fleet it’s probably ok.

      But commercial operators will get wind of that loophole and we will end up with masses of PHEVs running around mostly not paying their way road tax wise.

      So in general PHEVs need to be in the RUC scheme. As should any “alternative” fuel vehicle, even if its a multi-fuel vehicle (as a PHEV is).

      I seem to recall duel fuelled Petrol/LPG powered vehicles (of which their are not too many these days), but many taxis were not that long ago now before Prius Taxis became the norm, are not exempted from RUCs. As it left a loophole there as well. Which I think was closed some time ago.

      And is why we have RUCs on “light” alternative fuelled vehicles in the first place.

      1. Thanks Greg. I have included it, inluding my suggestion below. I agree that we want to incentivise the PHEVs running on electricity, but making it more expensive than the full petrol version would be bad overall for our emission profile. E.g. a PHEV outlander can do ~30km on electricity so is good for people that can’t get past the “how do i get to Taupo” issue, but want an EV for short trips (ignoring that PT or a smaller car might be better). To make it cheaper for them to buy the fully petrol outlander is an undesirable outcome. Given that PHEVs will be a bigger portion of our fleet than LPG cars ever were I’ve only seen one work around that makes sense – remove the fuel excise from petrol and bring in a RUC scheme for all cars based on distance and/or emissions depending on policy/ equity goals. It needs to be frictionless like paying fuel excise is in petrol though, otherwise people will moan.

        1. I don’t agree a Outlander PHEV should be exempt RUCs just because it has crap mileage on batteries and someone wants to drive it to Taupo sometimes.

          In fact in Europe [and the US], PHEVs like the Outlander [and Volt/Ampera] are on the out and out sales wise, as the market switches to either fully BEV or goes non-Plug in “Hybrid EV”]. For which there is no dual taxing going on.

          If you drive a dual fuel vehicle you may have to accept you will sometimes pay twice the road taxes as a result. I can’t see any easy way to avoid this situation practically that doesn’t leave the barn door open for cheating.

          I think taxes on fuel at the source will remain for Petrol and Diesel for now. As any scheme that moves away from fuel excise at the pump needs ensure its designed to be as unavoidable as well.
          And we don’t have them in place at the moment.

          You can’t avoid paying fuel excise on petrol or diesel very easily at all and its painless – its baked in the price.

          But you can avoid RUCs easily enough if you want to do so.

          And once the concept of paying for upkeep for the roads is one you can opt out of – especially for private motorists rather than commercial operators, it becomes a potential enforcement nightmare.

          Think of the scale of issues we have now with unwarranted and unregistered cars and multiply that by the value of fuel excise you could avoid and you’ll see it will soon become everyones favourite past time – avoiding paying road taxes.

          And of course RUCs only work if you have a working odometer on the vehicle(s). For heavy vehicles thats managed now with Hub odometers on the trucks and trailers and they pay their RUCs separately on the truck and trailer as they don’t alway travel together.

          For private vehicles hub odometers won’t be practical/work and encouraging people to to disable their speedos to save fuel taxes is not a recommended practise for safety or road tax collection reasons.

          And putting an excise tax on electricity “at the wall” is not the solution either. What happens if I have solar panels do I pay tax on the portion I decide [or some boffin at MBIE deems] is used to fill up my EV?

          Too many fishhooks. Don’t go there.

  7. Should the government have combined work on clean car standards with more focus on safe car standards?

    The Advancing Sustainable Safety report from The Netherlands shows that they consider they’ve failed on one key strand of system safety – compatibility of vehicles in the fleet. New Zealand could heed their reflection, and take action now. Simply put, if our car fleet was more homogeneous in height, shape and mass, there would be reduced DSI. A homogenous car fleet also makes it easier to design trucks with front underrun protection. The Advancing Sustainable Safety report also mentions work done on improving outcomes specifically for the situation of two vehicles with differing characteristics crashing. As part of the Road to Zero strategy, New Zealand could seek those findings and form healthy policy around such developments, if any.

    The vehicles that cause much higher pedestrian and fatality rates should also be excluded from urban areas.

    I’m sure vehicle safety regulations can improve as the Government works on the Road to Zero programme, but is this something that would have been more efficiently managed in tandem with the clean car work?

    1. Clean Car Discounts should only apply to models that are both demonstrably safer and lower polluting.

      Its not one or the other, its both that we need.

      We could improve the existing fleets profile, for both emissions and safety by introducing [annual] emissions tests for the already here/existing fleet.

      Studies show that a large part of the pollution comes from the worst 15% of the cars.

      Because those that are heavily polluting in the current fleet are also the least safe as well.

    2. Safer for whom? As a pedestrian I’d much rather be hit by a small, low, light vehicle than a large, heavy, tall one. Guess which gets higher safety ratings?

      Reinforced vehicle bodies for crash protection and other safety equipment all adds weight. This added weight increases the emissions of ICE vehicles and reduces the range of electric vehicles.

      Codifying strict safety standards will prevent adoption of future innovations in electric cars. It’s not hard to imagine a small, lightweight, cheap city runabout type car, similar to the Japanese Kei class. Such a vehicle might not be able to go over 50km/h or have more than a 100km range. It’d save weight by only being designed to handle crashes up to 50km/h. It’d be way better for the environment than the current fleet average but it’d be illegal to import if we had strict safety standards.

      1. The problem there occurs when you get hit by a heavier vehicle exceeding 50kmh, for example a speeding driver. Safety rules need to take this into account. I know I would want to be in a vehicle designed for impact protection at higher speeds in this situation.

        1. Yes but the point is, each iteration of safety improvements for car occupants has come at the price of vulnerable road users, a factor in the lower and lower physical activity levels. If we can have safety for both, great. But we don’t currently have that choice. For that, we need to peel back a whole lot of ‘improvements’ and get back to some pretty small, low height vehicles that can’t go very fast. In urban areas, at least. So small, perhaps, as to be unattractive to some people.

  8. The figure is a revelation.
    Last month I drove a car in UK and was surprised to see how economical the car was. I drove VW Golf and was doing 70mph or 110km/hr along the motorway plus some around town driving for a couple of day. I got the fuel consumption figure of 5.5L/100km which is amazing.
    The problem with our government is that they like collect some money from fuel tax so they will not care about the emission standard in NZ.

    1. There are plenty of other things to criticise central and local government and the various agencies for. 🙂 But not caring about emissions standards when they’re consulting on emissions standards seems an unreasonable topic, to me.

  9. New Zealand has one of the widest range of possible car models anywhere in the world – we have the best (and worst) of the range of available cars from Europe, from the UK, from Japan, from USA, etc etc – a far wider range than is really affordable. Unfettered choice. Massive cost.

    I like the Egyptian model, when i was last there. Each town has one car dealer – one is Citroen, one is Peugot, another is Renault. Each dealer just has one model of car, painted just one colour. So, Edfu has only red Renaults, Aswan has only beige Peugeot 504s, and it is only Cairo where there is a full mix. Tourists only drive white cars, so they are easy to spot. You can have a white Fiat Panda if you’re cheap, or a white Toyota Landcruiser if you’re more wealthy. But it is a remarkably efficient system. If you have a crash, and your door panel needs replacement, then it is easily replaced, as everyone in your town has the same car, in the same colour. Brilliant. If you see a yellow Citroen coming towards you, you know what town it is from, and know that it will go back there in the end of the day. If you see a white Fiat Panda coming towards you on the other side of the road, it is because they are tourists, and do not know that either side of the road is available, dependent on pot-hole location.

    NZ is hamstrung by its unfettered, market-driven solution, where we have so much choice and so little sensibility. Ford Ranger, Isuzu Trooper etc – its all bullshit. They’re all made in Thailand, and all are much the same. Realistically, if we had just one 4wd, in beige (to disguise the mud), available in one engine type, one fuel source, one spec level, we could also target one system for better fuel consumption. One saloon – Toyota Corolla – one colour: blue. One sports car – Mazda MX5 – red.

    Makes life simpler for all. Keeps costs down.

    One parallel from the building industry: in NZ there are over 20 standard colours for colour steel roofing. In Australia, there is only 5. Their roofing is considerably cheaper than ours, as well as range of choice being substantially less – despite population being more. These things are linked….

  10. Aiming for net zero emissions by 2050 seems challenging but in fact we need to get our emissions way down by 2030 if we’re going to provide any sort of decent future for our children. The discussion document says:

    “There is considerable uncertainty about the possible pace of EV uptake. Even if there is a favourable uptake of EVs under business as usual, emissions will still be 12 percent above 2005 levels in 2030 and it would take until 2040 to reach 33 percent below 2005 levels. This pace of decline would not be consistent with a target of net zero emissions by 2050.”

    You’d have to seriously wonder how the National Party MP’s of the last government could sleep at night, since their were increasing vehicle travel with their road-building programmes and taking no action on improving the fleet. To me it seems there are three no-brainers here:

    – encouraging uptake of vehicles with better emissions standards, and preferably electrific
    – encouraging uptake of active modes. Perhaps not just e-bikes, but bikes, and actually cutting through the crap to allow safe infrastructure to be built
    – reducing vehicle travel radically, through proven techniques of low traffic neighbourhoods and road reallocation.

  11. Wow, reading the document is enlightening… even the target they’ve set is not ambitious by world standards.

    “This 105 gram target… would not be as stringent as standards in Canada and the European Union. It would also not be as strong as the average emission profile of vehicles already entering the Japanese fleet. As the graph shows below, New Zealand is currently near the back of the pack when it comes to the fuel efficiency of vehicles entering the market. That means that we have more ground to cover in a short space of time to improve the emissions profile of these vehicles. A target of 105 grams of CO2 per kilometre balances the need to make significant improvements while ensuring New Zealanders continue to be supplied with a wide variety of affordable new and used vehicles.”

    Sorry, but that’s crap. As with all the things we’ve neglected to do well, catching up means working twice as hard, not continuing to drag our feet in the name of choice.

    1. Completely agree Heidi. I told them to pull finger and set a target at least at the level of the Japanese fleet (80g/km), and to bring it in quicker. 105g/km by 2025 is just a weak target, that means we’ll miss our Paris goals by even further. We need to bend the emissions trajectory harder, not just accept that we wasted the last decade so lets waste another.

    2. The 105 gram target is complete bollox because it was supposed to be based on some watered down Aussie Federal standard proposal from years ago which we tagged onto, back in the days when the Aussies had a car assembly business and the officials here were told or assumed we would need to be the same standard as the Aussies to ensure their cars could be sold here. [As if that benefited anyone but the Aussie tank makers].

      Well the Aussies have no car assembly plants still operating. Ford and Holden plants are gone burgers. So any models sold in Aus now come fully assembled from off shore just as they do here.

      So we should look to Europe and Japan in terms of what they are achieving now and will achieve in the near future when this scheme comes in and them harmonise with these standards.

      Not bake our own version which is not fit for purpose, even when proposed years ago, let alone from 2021 onwards.

      1. Greg, just looking at the weight-adjusted emissions targets… They look like crap too. This regulation should be encouraging not just more efficient vehicles within their weight range, but also the replacement of heavier vehicles with lighter vehicles. Most people have cars far heavier than they require. Any thoughts to moderate that opinion of mine?

        1. Nope, you’re right on.

          They’ve been nobbled by the SUV makers to adjust the weight bands so that the “Aussie Tanks/UTEs” and Yank SUVs/F150 trucks fitted into the lowest band possible.

          And also to lobby for wide enough bands so that the gas guzzlers can basically benefit from, ride on the back of, the relatively “greener” vehicles in the lower part of the same band.

          While not needing to do anything better or different for what they have now.

          We see the same in the Clean Car Discount scheme going on. And it was a problem that France had with their Bonus/Malus scheme that the CCD was based on. Basically the manufacturers lobby long and hard for wide, discrete bands, so that they can maybe squeeze into the top end of the next lower band. Then they stay there.

          Content to them sit there.

          Clearly the industry has demanded what is best for them.
          And the officials have complied.

          What is best for NZ Inc?

          Plainly, never considered in the decision making.

  12. From the discussion document: “ensuring New Zealanders continue to be supplied with a wide variety of affordable new and used vehicles.”

    I’ve realised that part of the problem we have in Auckland with cars parked all over people’s front yards, driveways, vehicle crossings, footpaths, kerbside spaces, etc… is that cars are so cheap that people have several.

    I think people sometimes see a car they like, at a surprisingly low price, and buy it. They intend to sell their current one, but can’t get anything like what they thought it was worth, so after a few weeks of trying, that gets put on the back burner, and the car ends up just sitting there… available, of course, for friends, so no-one need take the bus when their own car’s out of action or when they’re visiting the city. Serious modeshift preventer.

    And then there’s the company vehicle thing. People have their own car, and of course, a bigger family car, so there end up being three or four or five cars per 2 adults… This wouldn’t happen if cars were so cheap.

    The low price of the cars is preventing modeshift. Higher car ownership is a known causal factor in higher vkt. And these excess cars are creating safety and equity issues where their storage is dominating the private and public realm.

    Why, when the policy is to encourage sustainable modes, is ensuring that we keep cars at this unsustainably low price range, a consideration?

    1. Heidi
      Yes when you look closely at the document you realise that the solution that is proposed is anything but a ” no brainer.”

      One of the things that is not mentioned in the document is, what would be the effect of inducing someone to travel on an electric train or light rail, rather than the proposed new average lower emission standard vehicle. The savings are 4.2 times more!

      As LB says earlier on the answer lies in public transport; C40 cities say that it lies primarily in PT.

      As you correctly say, even with the most optimistic uptake of evs NZ won’t make the required emission reductions needed.

      I have just skimmed your posts and maybe I have missed something about vkt. Recently NZ has imported on average much less polluting vehicles than 5 years ago, but despite that emissions have soared because particularly in Auckland there are more cars and they are being driven further as spread occurs to Milwater, Orewa etc

      This is an unambitious scheme that is likely to produce modest results just as the Bonus Malus did.

      On the other hand the Swedish model would shake things up.

      1. The existing fleet has aged and emissions have risen because while newer moire efficient vehicles have been imported, almost all the older vehicles have remained in the fleet instead of the new vehicles washing the older ones out.

        This has caused the average vehicle age to rise, and the pollution/emissions profile to also rise on a overall/fleet basis as older cars pollute more, due to their initial poor emissions standards and the fact they have got older, are less maintained so pollute far more than they ever did new.

        That is why emissions are so high and keep rising.

        We have to get the old dungers out of the fleet and quickly or we will never make progress. No matter what overseas emissions models we adopt.

        You keep saying the French clean car scheme was flawed, but you also know that lessons have been learned there and here and the proposed scheme has few of the drawbacks the initial French scheme did.

        In any case, doing something half decent now – even if its less than perfect is far, far better than spending decades deciding on the perfect system then having no time to implement it… Which is the alternative the industry and officials will plump for.

  13. Greg N
    “You keep saying the French clean car scheme was flawed, but you also know that lessons have been learned there ”

    But have we learnt the lessons? The current French scheme has a much more generous rebate for evs than does our scheme and yet the French scheme has led to only a very small uptake of evs. That’s hardly surprising because comparatively evs cost so much more cf a Kona here at about $74k for an ev and $32k for fossil fuelled. It’s a difficult economic decision to buy the former.

    We are paying a feebate for a Corolla with 139g/km emission. This car is a dinosaur in terms of emissions in Japan. This car will be a carbon dinosaur in our fleet in as little time as maybe 7 years. As you say this is likely to remain in our fleet for 19 years. It is a liability on the governments balance sheet from day one. I estimate that by 2040 the govt may need to spend $1-2 billion to buy these out of the fleet. Yes, repeating the gun buy-back debacle – no learnings there.

    I am concerned about your comments that “the industry will plump for.” Are you talking about the car industry? Are they running our emissions policy?

    A more sensible approach may have been to place a fee on the purchase of every fossil fuelled car and use the revenue to drive down PT prices. European cities that have taken an aggressive approach to PT pricing have achieved phenomenal results in terms of boosting ridership. The magnitude of emissions reduction is significantly more than putting people in slightly more efficient fossil fuelled cars – the annual change in France was only 3% emission reduction for new cars per year.

    I can accept your comment that this scheme is half decent i.e. it may achieve about half the vehicle emission reduction required

    1. I agree the CO2 emission targets for Feebates are woefully low.

      I submitted on that aspect. I suggest you do too.

      As clearly the car industry doesn’t really want change over their most currently profitable vehicles. Yes they are ruining our emission policies for a short term profit. Have done for years. Will keep doing it until made to do otherwise.

      As a country we decide what vehicles we want in our fleet, not the importers.

      Remember these Jap imports are not the “barely 5 year old” near brand new immaculate cars it would be a shame to waste that we used to get from Japan, they are more like 8+ year old, never maintained, usually badly out of tune, basically cast offs, and we gladly take them off their hands when the alternative is they would scrap them and turn them into new cars.

      We also need to start emission testing out of the fleet the dungers. No matter their age. So that the Corolla Jap import doesn’t stick around past its 15th birthday, even better if its less. And there are far worse poilluters than the Corolla already here that are emitting CO2 and other crap like crazy and will do so until forced off the road if we don’t do something sooner than later to make its owner clean its act up.

      “comparatively evs cost so much more cf a Kona here at about $74k for an ev and $32k for fossil fuelled. It’s a difficult economic decision to buy the former.”

      Yes EVs do cost more up front than a Fossil. The reason is that you are buying a big battery *and* a maintenance free future *and* reduced fuel costs. And paying it up front.

      Add it all up though and consider the 5 year Total Cost of Ownership. That Kona EV will be pretty close to the Fossil version after 5 years.
      Toss in that $8K “off the sticker” rebate from 2021 and you can tip the balance for the car they buy now to be an EV, not the one they buy in 15 years time.

      And all that’s now, in the lifetime of the Feebate (CCD) program you will see EVs massively close the gap – when the sticker price of an EV with CCD included is lower than the similar Fossil then the program will have achieved its goal.

      You will know the policy is working when you see all the Taxis/Ubers/Lyfts/Zoomys suddenly switch to EVs.

      As Taxis did to Prius’ a few years ago.

      I predict you will see EV taxis/Ubers et al en-masse from about mid-2021.

      You may say the scheme is half baked. But its better to have a half baked scheme now, then toughen it than navel gaze for 25 years before getting it right.

  14. More importantly we are the only OECD country that does not have proper emissions testing for WOF, i.e. NOx, CO, unburnt hydrocarbons and soot (PM10 & PM2.5). A 5 second visible smoke test is a joke.
    All of this stuff is bad for everyone (carcinogenic) so it seems a no brainer that the public would want cleaner air.

  15. The clean car discount is just a tax on lower income families. If you can afford a new BEV, you do not need a discount.
    Tradies and farmers who need to use diesel vehicles are now being forced to pay for people in Remuera Tesla’s.
    For as Long as a significant proportion of our power generation is from fossil fuels, then the energy efficiency gains of BEV’s do not warrant a discount. FYI, energy efficiency when counted as well to wheel comparison is as follows: HFC (from green hydrogen) 90%, liquid renewable fuel 80%, BEV (with typical fossil powergen) 30%.
    The government should put more money into ports of Auckland hydrogen plant and less in Elon Musks pocket.

    1. Which all a) completely ignores the used car market (which is where new EV’s eventually end up and b) Toyota aren’t alone in currently developing a hybrid (at least) pickup.

    2. “The clean car discount is just a tax on lower income families. If you can afford a new BEV, you do not need a discount.”

      No its not. Its a tax on all excessively polluting Imported and new to NZ Fleet vehicles.
      Existing vehicles are not touched by this scheme. and most lower income families are buying second hand cars already here in NZ.

      If they can afford to buy a Jap import car, then they need to be given a price signal that the cheap but polluting models come with a higher cost.
      Then they’ll find they can buy a similar model which pollutes a lot less, and in some cases, they’ll get a discount to buy it.

      Hardly a tax on poor people.

      Secondly even BMW buyers can get a Clean Car Discount – If it costs less than $80K and it pollutes less than most other cars coming into NZ at that time.

      “Tradies and farmers who need to use diesel vehicles are now being forced to pay for people in Remuera Tesla’s.”

      Tradies and Farmers are businessmen. They currently can and do write the cost off against their incomes. They will continue to be able to do so.
      That is if they buy the vehicle. Many actually LEASE their vehicles, which
      means the lease payments are 100% deductible. So they won’t see much if any increase in their lease payments.

      But NZ’s emissions sure will benefit as a result of the cleaner cars [yes., maybe even low end Teslas] that will be bought by others who don’t need a diesel ute. Hardly a Win/Lose, more like a Win/Win to me.

      “For as Long as a significant proportion of our power generation is from fossil fuels, then the energy efficiency gains of BEV’s do not warrant a discount”

      The majority of our electricity is from renewables. Currently it sits at about 80-85% annually is renewable (its not just Hydro, but includes Wind, Geothermal and Utility Scale Solar and domestic scale solar).

      So how big a portion of the grid does Fossil generation need to be before it completely wipes out any and all the BEV efficiencies, ya reckon?

      You say 30% Sounds BS. and it is.

      Well, the Union of Concerned Scientists in the US calculated that even in the US states with the most heavy fossil fuel generation [some approaching nearly 100% fossil generation – Hawaii was one such at one point].

      That a BEV is more efficient on a full life cycle basis when considering the Carbon emission caused in mining, making, *fuelling* and disposing off, a BEV compared to a Fossil Fuelled vehicle on a like for like basis.

      Which included the CO2 emissions in drilling transporting, refining and distributing the fossil fuels you put in your vehicle – which many so called “well to wheels comparisons” conveniently forget and assume the petrol or diesel they fuel the vehicle with just appears in the local petrol station by magic. Yet they then want to ping the electricity you put in the BEV with the full CO2 emissions cost of the power generation.

      So the portion of renewables you need in your grid for a BEV to be better than a fossil is pretty damn low. Well under the renewables percentage of the power grid we have here in NZ.

      So arguing that BEVs don’t help solve the problem here in NZ is rubbish.

      Its also rubbish in most other countries as well. Even coal loving and burning Australia!

      “FYI, energy efficiency when counted as well to wheel comparison is as follows: HFC (from green hydrogen) 90%, liquid renewable fuel 80%,”

      We already have renewable liquid fuels, they’re called Biofuels. We have Biodiesel for sale here in NZ. Made from byproducts like Tallow from the meat processing industry. As its made from a waste stream its less carbon intensive. But its not carbon-free. More like Carbon less.

      For Hydrogen Fuel Cells (HFCs), tell me, where is this “green” hydrogen with 90% efficiency actually coming from? Electrolysis of water you say rather than the usual suspect of natural gas?
      And we make it via some electricity from somewhere renewable right other than our power grid?

      And where is this “green” electricity for our green hydrogen coming from?
      Some solar cells in the desert somewhere, a tidal power plant in the sea, ala the pilot project in the Orkneys? Or some adjacent “spare” wind farm generators hooked up to it to minimize transmission losses?

      Hmm, so let me see, you will take 100% renewable energy, magically wave a stick at it and make hydrogen gas using it [efficiently, maybe], that needs to be compressed, stored, transported then put into HFC vehicles that run along the road?

      And what do you think the end to end efficiency of that will be in terms of efficiency from the moment the electron leaves the generator, until it turns the wheels on the HFC vehicle?

      How about a low number? A very low number, say one between 19 and 23 per cent?

      What if we simply put that green electricity into the grid, then used it to fuel up a BEV and how efficient would that be?

      Well that number would be about 69% Even after a very leaky grid and all the loses that occur from generation to the battery of the BEV and from the BEV battery to the wheels.

      Basically, a BEV, is about 3 times more efficient than a HFC is – on a like for like basis.

      “The government should put more money into ports of Auckland hydrogen plant and less in Elon Musks pocket.”

      For specific uses, like running a fleet of container straddle carriers around a wharf (compared to diesel powered ones) that can’t currently use batteries to make them work?

      Yeah sure, that’s a specialized, even if terribly inefficient use for HFC vehicles. And of course POAL need to work out how they make this green hydrogen. And then safely compress it, store it, distribute it right in the middle of downtown Auckland in a way that meets all the safety requirements of a dozen agencies.

      For the rest of the general vehicle fleet? Its a dumbfuck idea squared.

      Its also why Elon Musk, who is a physicist. Rubbishes HFC vehicles so much.

      Because he has done the maths and he see what a crock of shit using Hydrogen to power Fuel Cell vehicles over BEVS. No matter how much renewables you throw at it. It still sucks.

      1. You seem to be an angry man Greg. Let’s poke some holes in your comments.
        Hydrogen production from Renewables is proven technology and has 90% energy efficiency. You use solar and wind to crack the hydrogen – just google it.
        NZ may be lucky to have plenty of Renewables to use as powergen, but it’s mostly in the South Island. Huntley power station is just down the road and it’s making a significant percentage of the electricity used in Auckland. That’s how the grid works – you take the powergen closest to the demand as it reduces the ‘leakage’.
        Bio diesel is not a great solution. Renewable diesel is. BD is an ester and has a blend wall of 10% before your engine warranty expires. RD is a hydrocarbon and has no blend wall. That’s why it has an energy efficiency of 80-90%. It also uses wastes and residues, not Cobalt and Rare Earth Metals that are finite resources, that create a huge carbon footprint in the mining process.
        BEV’s are fine for city cars, but they are totally useless for HGVs or range. Giving a subsidy on BEVs and not HFC or liquid renewables is crazy. As you pointed out – poor people buy second hand cars. They should be encouraged to buy used diesels and run them on renewable diesel. Cleaner than a BEV (in every aspect) and no capex required as you can just replace the fossil fuel with renewables.

        1. On the subject of poking holes in comments:

          Googling “hydrogen cracking” mostly returned references to natural gas. Which is a fossil fuel & thus not renewable …
          Googling also turned up recent peer reviewed papers casting doubt about your efficiency claims for FCV over BEV.

          “That’s how the grid works…”
          Indeed. The Auckland hydrogen production at Ports of Auckland will use grid electricity to produce what they claim is “green hydrogen”. So your comment applies to that too. (And they’ll be using Auckland’s drinking water, which I understand is increasingly scarce…)

          “BEV’s … totally useless for HGVs”
          Better get hold of Foodstuffs NZ who’ve got some on order & tell them to cancel…

        2. I may appear annoyed, but thats only because I’m frustrated, because of continual “Ok. Hydrogen is the answer. Whats the question?” types who clearly are failing to think through the logic and practicality of their magic wand solutions.

          It is clear to me that if anyone has outstanding homework still to do it is you.

          The reality is that if all these solutions you and others propose were actually cheaper, that easy, practical, simple and worked, or were “good enough” we’d be doing them right now.

          We’re not. That tells you a lot.

          Many have been talking about doing Hydrogen since the oil shocks in the 1970s. The same arguments and solutions, then as now are mindlessly proposed.

          The same road blocks exist now to achieving it as they did then. The only difference is that we seem to have given up trying to directly burn hydrogen in the engines and now aim to generate electricity in fuel cells to power the car via electricity.

          That In itself that is not bad. But the source of the hydrogen you use and the eneregy required to make it is the sticking point. Always has been, and barring discovering limitless cold fusion energy sources to make limitless hydrogen its not the solution, always will be.

          In essence with all your ideas. Clearly these solutions are not the solutions you and others like you insist they are. They are not ready for prime time or are impractical or impossible to scale in the timeframes needed or simply, they just, you know, suck.

          While you say “Hydrogen production from Renewables is proven technology and has 90% energy efficiency. You use solar and wind to crack the hydrogen – just google it.”

          Assuming it is all as simple as you say – which is a mighty big IF. And you can do so on an industrial scale that is needed, the resulting Hydrogen still needs to be compressed/liquefied, distributed in bulk, then stored, then transferred into HFC vehicles then finally generates some electrons to make the wheels of the HFC Vehicle turn.

          The proven efficiency of that process from the moment the electrons are renewably generated, to when it is used in the HFCV is at best 23%. That is 23% of the energy you stored in the Hydrogen you made is actually used. The rest (i.e. 77%!) of the energy from the renewable source is simply pissed down the drain. Hardly efficient on any scale.

          Maybe one day renewable hydrogen cars will be more efficient end to end. But we can’t wait 100 years for the perfect HFCV to come along with matching infrastructure. We need something now, something that will work and something that will solve the problem in 32 years or less.
          I don’t see anything you offer will get us there.

          The only attraction this renewable Hydrogen seems to have is that you can seemingly just hook it up to a huge solar or wind farm and let it make some hydrogen for you.

          Ok. Then what?

          Umm, let me see. We have to compress/liquefy it, then pipe it or truck it somewhere. With infra we simply don’t have, to storage tanks we don’t have, using safety systems and protocols we don’t have, directly in local neighbourhoods for use in HFCVs we don’t have.

          All in all, a magic solution looking for a problem.

          Far better and way more efficient to put that energy directly in the grid and run your BEVs on it.

          Encouraging the buying of cheap (polluting) diesels is simply bad policy no matter what fuel you stick in them. Whether Bio/Renewable diesel, cow burps or pixie dust.

          Diesels of all stripe pollute way more than just CO2. It was focusing on just reducing CO2 emissions that lead Europe down the Dieselgate hellhole they’re still semi-permanently stuck in and having trouble escaping.

          Particulates, NOx, soot and other pollutants you can and many you cannot, see all spew with gusto from any Diesel exhaust – no matter how much AddBlue or Urea/Water formulate you stick in the exhaust plume to deal with it. Doing all that with Diesel engines is still putting lipstick on a pig.

          Yes, right now, HGVs need to run Diesel, the best option for them is to switch to some form of diesel not based on fossil fuels. as an interim step.

          In the medium term (5 years) BEV HGVs will become commonplace. They will marginalise Diesel HGVs quickly as the cost of not switching to BEV HGVs will become so high that the supposed high sticker price of a BEV truck won’t be a barrier you perceive it to be.

          Companies other than Tesla are pursuing many types of electric HGVs. They will succeed collectively even if one or more of them fails along the way.

          Not because of Government policy [at the moment anyway], but because the economics of running electric trucks and buses stacks up. Fleet operators follow the money. The smart money in those operators will be piling into BEVs not Diesels very shortly.

          We also should not as a country be encouraging uptake and ongoing use of a dead and dying technology as embodied in [supposedly clean or otherwise] Diesel engines whether they are cars, medium trucks, buses or HGVs. Other than as a strict interim transition mechanism with strict controls and phaseout rules.

          Coal, Oil, and Natural Gas and such also do not forget pollute extremely when mined, and again when burned as required to release the energy within. And are definitely finite resources too.

          Lithium, Cobalt and Rare Earths are not in short supply nor particularly Rare despite their name suggesting so. They are sometimes inefficiently mined in some parts of the world leading to excessive pollution and political issues.

          But not all those problems are ones that can or should be laid at door of a BEV – particularly just because they happen to have an electric motor and batteries in them. After all those same minerals are used in cellphones and no one is demanding the world cease using them.

          Regardless of the so-called BEV pollution that anti-BEV folks push. Numerous scientific studies show that the higher embodied energy and emissions that making a BEV requires over a similar Fossil vehicle is quickly overtaken within 18 months of that fossil fuel vehicle is operating. Not matter how dirty the grid that powers the BEV is with fossil generation. The Fossil car ends up being the dirtiest car on the road in 18 months! Given we keep our cars on the road for 19 or so years, thats a long tail pipe of emissions that your BEV is not making. Even if it needs a second battery during its life and the original battery is simply junked without recycling.

          This has been proven over and over again. Even our own EECA did such a study and came to the same conclusion. Their conclusion incidentally was that for NZ, focussing on BEVs over Solar Power was best for NZ. They also noted that in Australia and other countries, the reverse is true – and that Australia should focus on Solar power over BEVs.

          The main factor/reason for the difference in the renewables portion of the Australian Grid, which is low and is still low.

          Basically, their Grid is too Fossil for BEVs so they need to add more Green via Solar first. We are too Green on our grid and best to add more BEVs than solar or renewables to ours.

          In any case pinging BEVs as the poster bad boy is false equivalence. We didn’t get to this point with CO2 emissions because of our use of BEVs. We’re in this boat we find ourselves in, precisely because the world stopped researching and developing/using BEVs 100 years ago and used oil based engines to run our vehicles on instead.

          Had we not done that, the, vehicles we use would all be clean and no need for Clean Car Discounts to encourage people to trade up to more efficient ones.

          But we didn’t so we need real practical and implementable solutions. And ones we can do now.

    3. “For as Long as a significant proportion of our power generation”
      So until the 1970s?

      Also, cite your sources for the energy efficiency (and how it is relevant to carbon efficiency). Hydrogen creation is only about 10% energy efficient so I don’t see how it could achieve 90% well to wheel!

  16. I’ve just placed an order for a new RAV4 Hybrid so you could say I support the proposal even though I won’t benefit this time around.

  17. A subsidy for the middle class; of course people are going to support that! That’s the no-brainier.
    Someone has to pay for the government’s generosity. I doubt that that the tariff is going to make up for it so will come from general taxes. Also, think about who is going to pay for this tariff? I guess people have forgotten the abysmal state of cars before we got rid of tarrifs in the mid 1980s – our family has some shockers.
    Personally, I don’t want to spend my money that way. And if a person wants to then there is nothing stopping him or her giving a $1000 to the next Nissan Leaf driver he or she sees.
    I thought NZ was past this nonsense but I guess when free money is on offer the eyes light up.

    1. The most potent way of reducing transport emissions is by a reduction of vehicle kilometres travelled.
      Admittedly this is difficult in much of the NZ land area but not where the bulk of our population is resident. Most of our population lives in large urban centres currently very underserved by public transport provision. The same with intercity public transport provision. A 5% reduction in private vehicle kilometres travelled is surely easier to acheive then a 5% overall increase in vehicle fleet fuel efficiency?
      Likewise it is surely easier to acheive a reduction in fossil use by reducing truck transport in favour of more rail and sea transport then by making trucks more fuel efficient.
      Sure replacement vehicles should be required to be more fuel efficient but the big gains are still by reducing our vkt.
      More resources need to directed at this goal, which as an aside will reduce the resources required for roading upgrades.

      1. Yep, and we could also implement a slower parallel policy of stopping the import pf diesels and vehicles with large engines. Subsidising new vehicles. like imposing road and fuel taxes on areas with poor public transport, is absolutely a tax on the poor.

  18. Greg and Daniel, thanks for your insight into this renewable issue, you both have given me a lot of points to research and eventually include in my classroom teaching.

  19. In principle I don’t like the rebate idea, as that adds even more work for our bureaucracy, and I rather have less of it than more. But I’m absolutely for additional taxes for polluting vehicles.
    I would be much more keen on a Singapore style system, where EV’s say are the baseline, of 0% additional tax, and tax increases proportionally to engine size/power of the vehicle. We could link it to the emissions for the vehicle, the more it produces the more % you pay on a new vehicle registration. So EV’s can be cheaper. Having it % based would be more fair than an arbitrary number, which would disproportionately affect the lower cost vehicles.

    Adding an emission standard as proposed would be good, preferably we simply join one that already exists, for example the Euro or US one, as opposed to create one ourselves, as that would be much quicker and easier to implement for vehicle manufacturers.

    We could also progressively increase the vehicle registration cost of older vehicles, as they do in Japan and Singpaore, even without the other policies this would move people towards less or newer vehicles. The biggest questions is what to do with the generated revenue? Investing into more sustainable transport infrastructure would be good, but there is still a lot of roardwork that needs to be done such as safety improvements, bypasses of towns as they do around Europe – as hardly ever do you drive through a town centre, even on a small road.

  20. Another aspect is that the existing fuel efficiency tests, on which the Clean Car Standard & Discounts will be based, do not accurately reflect real-world fuel use. In fact the gap has widened from 9% to 42% in the past decade, partly due to manufacturers’ response to fuel efficiency standards in the UK. So 2/3 of the improvement in the past decade has been illusory. (Luckily, the remaining 1/3 is real – VKT in the UK has increased 27% since 1990 but emissions in this sector are flat).

    More about this issue and links in this post by Steve Trewick:
    https://blog.planetaryecology.org/2019/08/23/emission-impossible/

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