(Government Bill 196–1, Chris Bishop)
From: Ukes Baha | 25 September 2025
Submitted in response to the call for submissions on the Land Transport (Clean Vehicle Standard) Amendment Bill (No 2)
I oppose the Land Transport (Clean Vehicle Standard) Amendment Bill (No 2) in its current form.
While the Clean Vehicle Standard was intended to reduce emissions from the light vehicle fleet, this Bill weakens its purpose. It delays action, creates loopholes, and distorts carbon accounting.
Core stance: The Bill extends credit lifespan (s 180), removes barriers between new and used import credits (ss 180, 184), extends borrowing beyond 2025, grants ministerial discretion without safeguards, and introduces manipulated credit exchange rules that destroy the integrity of carbon accounting.
Recommendation: Reject the Bill in its current form. If Parliament insists on proceeding, it must be amended to preserve genuine emissions reductions, restrict regulatory loopholes, and align with New Zealand’s Paris commitments and Te Tiriti obligations.
Bill reference: Extends lifespan from 3 to 4 years.
Problem: Allows importers to delay action by sitting on credits instead of improving fleets each year. Dirtier cars remain on roads longer while paperwork hides real emissions.
Position: Retain 3-year expiry.
Bill reference: Allows free transfer of credits between new and used accounts.
Problem: Creates loopholes where new importers buy their way out of responsibility while used importers profit without change. Compliance becomes financial trading, not emissions reduction.
Position: Maintain separation of new and used credits.
Bill reference: Permits ongoing borrowing of future credits.
Problem: Lets importers flood the market with high-emission cars now on the promise of future offsets that may not occur. Vehicles imported today will lock in pollution for decades.
Position: End borrowing after 2025.
Bill reference: Empowers Minister to alter standards by regulation.
Problem: Weakens parliamentary oversight and allows standards to be diluted without scrutiny[1].
Position: Require substantive changes to be approved by Parliament.
Bill reference: One new credit = two used credits; two used credits = one new credit.
Problem: Arbitrarily inflates or deflates credits. A credit no longer equals one unit of CO₂. This encourages system gaming and undermines integrity.
Position: Delete artificial exchange ratios; one credit must equal one unit.
Problem: Larger importers dominate by hoarding and trading credits while smaller PAYG importers are squeezed out[2].
Position: Level compliance to protect smaller operators.
Bill reference: Eliminates weight-adjusted CO₂ formula.
Problem: Favours heavier, dirtier vehicles (utes, SUVs) at the expense of lighter ones, fuelling “weight creep”[3].
Position: Reinstate weight adjustments.
Bill reference: Relies on RIS that only “partially met” quality standards[4].
Problem: Policy changes are built on flawed evidence.
Position: Commission a full independent RIS before legislating.
Bill reference: Original scheme required motorcycles and mopeds to hold CO₂ accounts[4].
Problem: Shows poor drafting and oversight, raising risks of future anomalies.
Position: Ensure robust consultation and technical review before amending.
Problem: Importers may pass penalties onto buyers, raising prices while still importing high-emission vehicles[1].
Position: Ensure industry, not the public, bears compliance costs.
This Bill weakens the Clean Vehicle Standard at the very moment when urgent emissions cuts are needed. It creates loopholes, delays action, shifts costs to the public, and undermines both Te Tiriti obligations and international credibility.
Recommendations:
Respectfully submitted,
Ukes Baha
Public Health Advocate | Counsellor | Policy Analyst
ukesbaha.com