An Taisce has written to the Taoiseach and other Government Minsters to raise concerns that the Climate Action and Low Carbon Development (Amendment) Bill 2020 presented on 7th October 2020, fails to ensure that new cars and vans sold after 2030 emit no tailpipe emissions, contrary to the Programme for Government.

In September 2020 the interdepartmental Tax Strategy Group (TSG) report “Climate Action and Tax” set out recommendations to address both the greenhouse gas and air pollution impact of vehicle emissions.

The TSG report confirmed that transport emissions are “on an unsustainable trajectory” and “private cars are responsible for around twice as much annual CO2 emissions than Heavy Goods Vehicles and Light Commercial vehicles combined”. It presented the 2019 data showing “a massive increase in the market share of SUVs (from a market share of about 19% in 2013 to about 45% in 2019), as well as very high volumes of used imports with above average CO2 emission profile”.

The TSG set out three overarching objectives:

  • Deliver on the Government’s climate action goals to the greatest extent possible;
  • Maintain a level playing field between cars tested under the NEDC and WLTP testing regimes; and
  • Ensure that the environmental health rationale in the regime, in the form of the NOx surcharge, continues to act as a strong disincentive to the acquisition of highly polluting cars.

A range of Vehicle Registration (including NOx surcharge), Motor, and Company Vehicle tax options were set out to meet these objectives.

It is An Taisce's submission that the most progressive measures outlined by the TSG should be adopted in Budget 2021 and integrated with action on climate and air quality.

These recommendations are in the national interest in confronting the climate emergency. We would highlight that the July 2020 Supreme Court judgment struck down the current National Mitigation Plan for breaching the Climate Action and Low Carbon Development Act 2015, for failing to provide effective mitigation measures.

In addition to this is the overwhelming public health imperative of addressing air pollution. Last month, in their latest Air Quality in Ireland report, the EPA confirmed that a monitoring station at St. John’s Road, Inchicore, had established that the EU NOx emission ceiling level had been breached, and that other areas of the Dublin city centre were likely to be affected. This also raised the issue of inadequate monitoring in other Irish cities.

Furthermore, emerging international evidence suggests that crash impacts with SUVs more frequently result in death than standard passenger cars. Similarly, a growing body of research demonstrates that SUVs have significantly greater environmental impacts than standard passenger cars in relation to a number of indicators (see the attached annex on SUVs).

On 7th October 2020, a deputy Government press secretary suggested that Ireland needs to wait for EU approval before taking any measures affecting the sale of new fossil-powered vehicles after 2030 . This is not accurate: it is entirely open to Government to set an environmental performance standard applying to the sale of new vehicles from 1st January 2030. There is a long line of EU legal precedent which confirms Member States’ discretion to take proportionate measures to protect the environment and public health of their citizens, stretching back to the 1980s with the Danish Bottle judgement (Case 302/86).

It is of grave concern that the publication of The Climate Action and Low Carbon Development (Amendment) Bill 2020 and associated Government announcements did not commit to the implementation of the TSG vehicles emission recommendations, along with action to be taken in the forthcoming budget

From media coverage it is obvious that there has been major lobbying by the motor vehicle sales sector against any effective taxation measures to incentivise the purchase of less polluting vehicles as the TSG report advises.

An Taisce has advanced the following as action requests:

  1. That national climate action and public health interests prevail and the most progressive taxation recommendation of the TSG should be adopted in the forthcoming budget, as well as an equalisation of petrol and diesel taxation and the removal of the farm diesel subsidy.
  2. That the Climate Action and Low Carbon Development (Amendment) Bill 2020 be amended to contain an explicit provision that ensures that new cars and vans sold after 2030 emit no tailpipe emissions.


Contact: Ian Lumley, Head of Advocacy for An Taisce, 083 153 2384

ANNEX: The road safety and environmental burden of SUVisation


In the United States, SUVs (including pickup trucks) as a percentage of new sales now stand at 72%, and this is expected to rise to 78% by 2025. Noting that SUVs in North America are generally bigger and blunter, there is growing evidence that the SUV sales boom in the US is associated with higher pedestrian fatalities. A study by the Insurance Institute for Highway Safety in the US found that impacts with SUVs were up to twice as likely to result in death [1].


Carbon footprint: Recently published data from WWF France indicate that SUVs sold over the last decade emitted on average 20% more CO2 than their equivalent standard passenger car for each kilometre travelled. Similarly, over its entire lifecycle (manufacture, use and end of life), an SUV has a carbon footprint almost six times greater than that of an electric city car traveling the same number of kilometres, and five times that of an electric sedan. Across Europe as a whole, the SUV boom is the greatest contributor to rising car emissions in 2017, 2018 and 2019 [2].

Battery size and emissions: Even if electric drivetrains were adopted for SUVs, an eSUV would still result in higher emissions and resource use than ordinary electric cars. This is because an electric SUV needs a 15% bigger battery than a sedan car (based on a comparison of a Tesla Model X with a Model S) [3].

The greater battery size needed for an SUV adds about two tonnes of GHGs to production emissions per vehicle. And, over its life, an eSUV in the EU will account for around two tonnes more GHGs compared to a regular sedan car (again, the comparison is based on comparing Tesla SUV v. sedan models). That equates to approximately four tonnes extra GHGs overall per vehicle (not counting the weight/volume of the raw materials themselves).

At the level of one individual vehicle, four tonnes is perhaps less significant. However, if Ireland moves from SUVs comprising 45% of new sales towards US levels (now increasing from approximately 70% to 80%), then four tonnes per vehicle puts huge pressure on our climate targets, as well as adding other resource and pollution burdens as outlined below.

Resource use, e.g. microplastics: Tyre wear accounts for almost half of ocean micro-particles. The typical tyre consists of 24% plastic (synthetic rubber), 19% natural rubber and the rest is other materials (e.g. metal wire). Counting the wear of both rubber and plastic, "the erosion of tyres would contribute to almost half of the releases (46.2%)”, according to the leading study on ocean pollution by the IUCN [4]. SUVs are one of key ‘emerging threats’ to tackling microplastic pollution from tyres, according to the testing laboratory Emissions Analytics: “the increased weight is also a factor associated with SUVs, along with the typically larger wheel sizes adopted by such vehicles. The larger the tyres, the greater the problem” [5].

In the short term, the SUV boom is more problematic for climate emissions, as almost all SUVs have internal combustion engines. In the medium and longer term, in which it is assumed eSUVs and e-cars are the only new passenger vehicles, limiting resource use will be crucial. Conserving lithium and other raw materials will enable e-mobility for a far greater percentage of citizens, companies and society as a whole.




[3] at page 35.



Photo by Matt Boitor on Unsplash