Open letter to Minister of Transport re clean car discount
11 December 2023
Hon Simeon Brown
Minister of Transport
By email: Simeon.Brown@parliament.govt.nz
Dear Minister
Air pollution from transport in New Zealand does significant harm to people’s health.
We were lead authors on the Health and Air Pollution in New Zealand study.1 The study estimated that air pollution from motor vehicle emissions alone results in:
• premature deaths of 2,247 New Zealanders per year
• nearly 9,400 hospitalisations for respiratory and cardiac illnesses, including 845 asthma hospitalisations for children per year
• over 13,200 cases of childhood asthma each year in New Zealand
The social costs of the health impacts of motor vehicles were estimated at more than $10.5 billion per year. Prior to the HAPINZ 3.0 study, the burden of ill-health in New Zealand that is attributable to air pollution was greatly underestimated, particularly for motor vehicles.
The flipside of these sobering estimates is that emission reductions can deliver significant improvements in public health.
This means that there are many win-win opportunities for health, climate, and environment. One of the most effective ways to gradually improve air pollution is to ensure that vehicles being imported into New Zealand are clean.
The clean car discount has been extremely successful in encouraging the uptake of clean, low emission vehicles. We are concerned that removal of the discount in the absence of suitable alternatives will have serious long-term implications for the health of New Zealanders. We are also alarmed to read in the NZ Herald that decisions may be being made currently without adequate consideration of all benefits and costs via regulatory impact assessment.
We urge you to consider and assess alternatives to the clean car discount with urgency. In doing so, it is critical that the wider public health benefits and costs of policy changes are understood.
For example, we estimate that air pollution from a new (Euro 5) diesel ute costs society (in terms of harmful emissions) around 40 times more than a petrol hybrid car for every km driven.2 Vehicles being imported into the country now will remain on the road for many years, which means that today’s policy decisions could have significant implications for the health of New Zealanders for decades to come.
Air pollution benefits were not quantified in the development of the clean car discount. This is a major oversight that this new Government could rectify.
Any policy that increases the uptake of low emission vehicles, will have significant economic and public health benefits that will be at least as significant as the monetised benefits of CO2-e emission reductions.3
Treasury publishes official monetised benefits for both harmful air pollution and greenhouse gas emissions in their CBAx tool.4 CBAx is designed to support rigorous transparent evidence-based cost-benefit analysis of budget and policy initiatives. It is an important element to ensure that robust wellbeing and value for money assessment is applied to decisions.We urge you to explicitly consider the social costs of air pollution in the consideration of alternatives to the clean car discount and in the development of all transport policy.
We appreciate your consideration of this matter.
Your sincerely
Dr Gerda Kuschel, Director & Senior Air Quality Specialist, Emission Impossible Ltd
Jayne Metcalfe, Director & Senior Air Quality Specialist, Emission Impossible Ltd
Professor Alistair Woodward, Epidemiologist and public health medicine specialist, Faculty of Medical and Health Sciences, University of Auckland
[1] Kuschel G, Metcalfe J, Sridhar S, Davy P, Hastings K, Mason K, Denne T, Berentson-Shaw J, Bell S, Hales S, Atkinson J, and Woodward A (2022). Health and Air Pollution in New Zealand 2016 (HAPINZ 3.0). Report prepared for Ministry for the Environment, Ministry of Health, Te Manatū Waka Ministry of Transport and Waka Kotahi NZ Transport Agency, Auckland, New Zealand, March. [Online]
[2] Based on estimated emissions related health impacts developed for RightCar, which are $0.59 per km for a Euro 5 light commercial vehicle and $0.01 per km for a petrol hybrid car. Emission Impossible Ltd (2023). Rightcar air pollution rating system: updated methodology. Prepared for Waka Kotahi NZ Transport Agency. April. [Online]
[3] We recently modelled proposed reductions in motor vehicle emissions in New Zealand’s first emissions reduction plan and found that the net air quality benefits of vehicle emission reductions are likely to be at least as significant as the CO2-e benefits. ESR (2023). Public Health Risks associated with Transport Emissions in NZ: Part 2 Road Transport Emission Trends. March. [Online]
[4] Values for monetising air pollution costs and benefits are provided in the Waka Kotahi monetised benefits and costs manual and the Treasury’s CBAx tool.