Mr. James Nix:

I will give a little bit of background about my organisation. Our Irish members are the Irish Environmental Network and An Taisce. We have about 60 members all across Europe, and we are working for cleaner and safer trends. This presentation is complementing what the other speakers have said. I will give some key statistics, then a word safety, a little bit more detail on France's weight tax and then some suggestions for Ireland.

From 2017-18 onwards, average weight rises quite sharply right across Europe, and Ireland is no different. It had been reasonably stable between 2010 and 2017. We have touched on why and how this happens before. The yellow dots represent SUV sales and essentially, they come to dominate and that trend is continued across the early 2020s These are data from France, taking all different vehicle types and showing their penetration and sales, but the trend is similar across Europe.

We have talked a little bit already about how over the past seven years SUVs, have gone from just over 20% to now just over 50% but 70% in the case of hybrids. The slide on display shows the data over the same time period for Ireland, looking at a time horizon from 2017 to 2022 where about 18 kg every year is being added to the weight of a new passenger car. It is more for electric cars as they are SUV-ised and given greater range.

The issue with safety is twofold. One is lower vision. As can be seen with the black car on the current slide, in the case of the taller vehicles, up to 12 or 13 children can be seated in front without the driver seeing them and as a result, there are more fatal collisions, particularly involving children. The other issue is that when a high-fronted vehicle strikes a cyclist or pedestrian, the severity of injury is much worse and rates of deaths and serious injury are much worse. As can be seen in the image on display, generally, the torso is impacted, which affects the vital organs in the centre of the body. It is very difficult to recover from those kinds of impacts.

The current slide shows a headline from the Insurance Institute for Highway Safety in the US on the impact on pedestrians and cyclists, stating that today's SUVs are more lethal than other cars. We have talked about the impact of vehicle height and the likelihood of the vehicle running over the injured party rather than deflecting, which is what lower fronted vehicles are more likely to do. Head injuries are particularly acute in the vast majority of case where an SUV is involved.

I will speak now about what is happening with tax. Dr. Mock referred to the situation in France. As the slide shows, since January 2022, when France introduced a weight tax, there is €10 payable for every kilogram above the threshold of 800 kg. Taking an example of a vehicle weighing 1,850 kg, an additional €500 is payable upon registration. Since 2022, France has exempted hybrid and fully electric vehicles, EVs, but they are very much in the crosshairs. There is a realisation that as their sales increase, they will need to be brought within the tax net. There are exemptions, such as that relating to wheelchair-accessible vehicles, as I have flagged. As Dr. Mock mentioned, France plans to lower the weight threshold from 1,800 kg to 1,600 kg from 1 January 2024. Consideration was given to including hybrid and electric vehicles in the tax but, from what we hear, they will remain excluded, with the possibility of their inclusion in budget 2025.

As to what we could do here in Ireland, I suggest that we apply the threshold level for a weight tax at the 2022 French level but include hybrid vehicles. Dr. Mock's evidence on those vehicles is particularly noteworthy in that their emissions are nowhere near what is claimed. Battery electric vehicles, BEVs, could stay out for the initial year at least. What would this mean? Having looked at the 2021 registration data, my proposal would capture the heaviest 10% of new internal combustion engine, ICE, and hybrid sales. Departmental officials often note that there is a short time window to get a new tax measure ready for 1 January. My suggestion is to use the upcoming budget to flag that a tax will apply from mid-year, for the second vehicle registration period starting on 1 July. Subsequent phases could follow that. There is already discussion in France and other countries on what higher threshold could and should be applied to EVs. A like-for-like comparison would suggest it should be set at approximately 300 kg more than the limit for other vehicles. A signal really needs to be sent in this regard and there is a good opportunity to do so on 10 October. That is my key suggestion.

I thank the committee for the kind invitation to attend this meeting. I am happy to take members' questions.