If you want to buy an EV but need it to be more affordable, this is your chance!
The Clean Car Standard would set a limit on the carbon pollution of vehicles brought into the country – at the moment there are no standards and as a result NZ has the dirtiest fleet in the OECD. Because of their inefficiency, despite our fuel being cheaper than some other countries, our cars cost more to run on average.
Separately, the Clean Car Discount policy would levy a fee on the sale of the most polluting vehicles and provide a discount on the cleaner ones, making it revenue neutral. Ministry of Transport analysis shows these policies wold save the country billions overall and cut emissions.
Low Carbon Kāpiti’s view is the introduction of these policies is a good thing and should be supported, despite the fact some of the settings are too weak and slow. Once the policy structures are in, the settings can be adjusted. What we don’t want is the government dropping this altogether due to lack of public support and nothing being done for years. There is an anti-campaign being run by the Opposition for short term political gain, so it is vital support is shown. If you want to buy an EV but need it to be more affordable, this is your chance to make it happen!
There are 29 yes/no questions in the consultation, each with a ‘why?’. Is you only have time to do the yeses and the noes that is fine! If you want to go further into the ‘whys’ feel free. If you go to this link there is a very brief summary of LCK’s response that you can follow, and further reading if you want to get across all the issues.
LCK response to Clean Car policies
Further analysis on the EV Association of Aotearoa website (from whom we borrowed heavily!)
Government summary of ‘Clean Car’ proposals
Click here to go to the online submission portal/questionnaire
Summary of LCK’s recommended responses for the time poor!
No. | Question | Answer | Why? |
1 | Is the Clean Car Standard appropriate for New Zealand? If not, why? | Yes | |
2 | Is an average emissions target of 105 grams CO2 per kilometre by 2025 an appropriate target for NZ? If not, why? | Yes | Ideally the target date should be brought forward |
3 | Do you think the Clean Car Standard would have an effect on vehicle supply and prices? | No | |
4 | Do you consider the overall process outlined for the Clean Car Standard is workable? If not, why? | Yes | |
5 | The Clean Car Standard will cover new vehicles and used vehicles being brought into NZ. Should people who import 3 vehicles or less be exempted? | Yes | |
6 | Do you support phasing-in the 105g CO2/km emissions target by: adopting multiple targets that progressively lower to 105g? OR using the increasing percentage of fleet approach? Please explain why. | Adopting multiple targets that progressively lower to 105 grams. | |
7 | Do you support the time-frame for the phase-in period? | Yes | As a minimum, but it should be faster |
8 | Do you support adopting a weight adjusted Clean Car Standard? | Yes | |
9 | Do you support a penalty of $100 for each gram CO2/km that a supplier of new vehicles exceeds its fleet target? | Yes | |
10 | Do you support a penalty of $50 for each gram CO2/km that a supplier of used imported vehicles exceeds its fleet target? | Yes | |
11 | Do you support the “banking” mechanism to provide flexibility for vehicle suppliers? If not, why? | No | |
12 | Do you agree that the new vehicle sector should have the added flexibility of “borrowing”? If not, why? | No | |
13 | Do you support an arrangement for suppliers to “pool” their vehicles together to comply as a group? | No | |
14 | Do you agree that new and used vehicle suppliers should not be able to “pool” their vehicles and comply as a group? | Yes | |
15 | Do you support having a fine not exceeding $15,000 for an individual for misreporting data for the Clean Car Standard? | Yes | |
16 | Do you support having a fine not exceeding $75,000 for a person or organisation other than an individual (eg a company) for misreporting data for the Clean Car Standard? | Yes | |
17 | Do you support the sanction of disqualification from being a registered motor vehicle dealer if a supplier deliberately attempts to evade meeting annual targets? | Yes | |
18 | Do you support amending the Fuel Consumption Information Rule so that only vehicles tested to the WLTP, NEDC, the JC08, and the American Federal Test Procedure meet requirements for entry certification? | Yes | |
19 | Do you agree with the proposed process for setting future emission targets? If not, what would you change and why? (The proposal is that vehicle emissions targets will be set by the Ministry of Transport in response to the recommendations of the Climate Change Commission.) | Yes | |
20 | Do you think the Clean Car Discount is appropriate for New Zealand? | Yes | We recommend that the RUC exemption be ‘grandfathered’ i.e. stay in place for an extended period for those EVs that were purchased prior to the Clean Car Discount being available. Furthermore when RUC is introduced for EVs, it should be at a much lower level than for fossil fuelled vehicles. We recommend that for people that purchase EVs between now and the introduction of the Clean Car Discount at point of purchase be able to apply for their discount retrospectively. |
21 | Is the emissions benchmark of 105 gram of CO2/km by 2025 an appropriate one to have for the Clean Car Discount? | Yes | |
22 | Would an initial emissions benchmark of 150 grams CO2/km be suitable for the first year of the Clean Car Discount? If not, why? | Yes | As a minimum, but the government should aim for better. |
23 | Do you think the level of the fees and discounts in the example Clean Car Discount schedules would increase demand for low-emission vehicles? | Yes | The current level of fees and discounts as set out in the example schedule could be improved. The zero band should start lower and the maximum fee for high emissions should increase over time. |
24 | In the example schedules, the schedules change every year to lower the emissions benchmark and to keep the scheme self-financing. Do you think annual change is practical or should there be less change? | Less change | A two year schedule would be more appropriate. |
25 | Should new vehicles include near-new vehicles less than 3 years old? | Yes | |
26 | Do you think a zero band is appropriate? | Yes | |
27 | Do you think the size of the zero band in the example feebate schedules is appropriate? | Yes | |
28 | Do you support the proposal to apply the fees and discounts directly at the point of vehicle purchase? If not, why? | Yes | |
29 | Do you support the penalties outlined in this section to ensure that fees and discounts are displayed on each vehicle and are correctly applied by vehicle suppliers? If not, why? | Yes |