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The Imported Motor Vehicle Industry Association (VIA) commends the Ministry of Transport for its proposed amendments to the Land Transport Rule: Vehicle Exhaust Emissions 2007. VIA acknowledges the importance of reducing noxious emissions and shares the goal of minimising harm caused by vehicles.
In this document, we present comprehensive feedback that focuses on light vehicles while advocating for a methodology that should be applied across all vehicle types. This submission will outline VIA’s position, emphasising the need to prioritise harm reduction, maintain a fair market, and address the needs of New Zealanders.
VIA fully supports the objective of reducing noxious emissions and acknowledges the industry’s duty to supply vehicles that minimise harm. The detrimental effects of noxious emissions on public health are undeniable, and it is our responsibility to contribute to their mitigation.
Unfortunately, while VIA supports most of the policy as proposed, there are several factual errors that we must address. We have offered corrections, specifically around the equivalency between Euro and Japanese standards. We have provided a quantified model that compares the equivalency of standards, and we argue that policies should be adjusted accordingly. Otherwise, we support the proposed timeline and are open to discussing further strategies to reduce harm from emissions.
Should the government proceed with currently assigned standard equivalencies, which seem arbitrary and biased towards EU standards, we must object to the current policy on grounds of market fairness and equity.
VIA supports the proposed timeline for transitioning to Euro 5 and Euro 6 standards, providing the government corrects their stated equivalencies between European and Japanese standards before proceeding with the policy.
Finally, in addition to offering a methodology for comparing standards, we offer a more radical suggestion. VIA proposes a redesign of the proposed standard that would lead to even more harm reduction in both the short and long term while maximising options for the public to transition to less harmful options.
The modified standard we propose would proportionally restrict vehicles based on the amount of harm they cause. Diesel vehicle emissions, known to cause more harm than petrol emissions, should be subject to stricter restrictions. By prioritising harm reduction, we can remove a higher percentage of more harmful vehicles, allowing consumers to opt for less harmful alternatives, for which there should remain a wider range of options. This approach ensures a greater reduction in overall harm and a smooth transition to the strategies used in Euro 7.
While our response primarily focuses on light vehicles, we firmly believe that the proposed methodology and arguments should be applied across all vehicle types. The goal of harm reduction should guide our decisions, ensuring that changes implemented yield the greatest benefit for the general public.