Land Transport Rule: Vehicle Exhaust Emissions Amendment (No.2) 2024

Submission from Spokes Canterbury

Reference: https://www.nzta.govt.nz/about-us/public-consultation-hub/current-consultations/amending-the-vehicle-exhaust-emissions-rule/

Tēnā koutou katoa

Thank you for the opportunity to comment on the proposed Land Transport Rule: Vehicle Exhaust Emissions Amendment (No.2) 2024.

Introduction

Spokes Canterbury (http://www.spokes.org.nz/) is a local cycling advocacy group with approximately 1,200 followers. Spokes is affiliated with the national Cycling Action Network (CAN – https://can.org.nz/). Spokes is dedicated to including cycling as an everyday form of transport in the greater Christchurch and Canterbury areas. Spokes has a long history of advocacy in this space including writing submissions, presenting to councils, and working collaboratively with others in the active transport space. We focus on the need for safe cycling for those aged 8 to 80. Spokes also supports all forms of active transport, public transport, and has an interest in environmental matters.

Proposal Overview

Overall Spokes supports the proposed changes but would like them to go further.

The aim of this Land Transport Rule on vehicle emissions is to reduce harmful pollution from vehicles. Reducing harmful pollutants protects people’s health including cyclists and pedestrians.

• Spokes supports recognising the new Australian Design Rules as an acceptable alternative to Euro 6d on the understanding that there is no compromise to the level of reduction of emissions from the original standard.
• If Australia subsequently loosens their rules, then New Zealand should revert back to the Euro standard.
• Spokes would prefer that New Zealand implement Euro 7 by 1 July 2028 for all new diesel and petrol vehicles.
• Spokes agrees with the alignment in implementation dates with Australia as it brings the implementation date forward.
• Spokes agrees with the minor amendments.
• Spokes would like to see additional constraints for the import of light diesel vehicles, both commercial and private, that takes into account the significant additional harm caused by these vehicles, particularly in urban areas. We recommend all newly registered light diesel vehicles, new and used, private and commercial, should meet Euro 6d by 1 December 2025.

According to the NZTA Transport is responsible for two thirds of the harm estimated to be caused by human-made air pollution. Each year in New Zealand noxious emissions result in:

• the premature deaths of more than 2,200 adult New Zealanders,
• more than 9,200 hospital admissions for respiratory and cardiac illnesses,
• over 13,200 cases of childhood asthma, and
• social costs of $10.5 billion.

Both petrol and diesel vehicles release pollution harmful to our health. However, while diesel vehicles make up a small part (23 percent) of our vehicle fleet, they produce most (82 percent) of the harm, because their engines produce higher levels of nitrogen oxides and particulate pollution. Exposure to nitrogen oxides causes respiratory and cardiovascular damage and can contribute to smog. Particulates can cause lung cancer, and both forms of pollution contribute to asthma.

In 2024 17% of the newly registered light vehicle market share in New Zealand was diesel. Diesel vehicles also tend to be driven more than petrol equivalents. They are also larger vehicles that are more likely to harm cyclists and pedestrians in an accident.

In 2014 testers discovered that car manufacturers were using software to manipulate diesel emissions tests. The EPA found that Volkswagen, Audi, and Porsche sold certain diesel cars and SUVs from 2014–2016 that emitted up to nine times more pollution than allowed. Toyota has also been involved in multiple diesel emissions scandals, including defective diesel particulate filters and irregularities in certification tests. In 2022, the Federal Court of Australia ruled that Toyota engaged in “misleading or deceptive conduct” in marketing and selling the affected vehicles.

I would like the opportunity to present at any hearing on this submission and I am happy to discuss or clarify any issues that arise.

Submissions Coordinator

Spokes Canterbury

submissions@spokes.org.nz