Submission on the COE Categorisation Public Consultation: Why Singapore Should Recalibrate COE Categories A and B Before Any Merger

This record contains the author's submission to the Land Transport Authority's 2026 public consultation on proposed changes to Singapore's Certificate of Entitlement (COE) categorisation for passenger cars. The submission was made in the author's personal capacity on 19 October 2026. The document comprises two parts: Part I sets out the author's formal response to the consultation questions and recommendations; Part II contains the supporting paper, "Move the Fence, Do Not Demolish It: Why Singapore Should Recalibrate COE Categories A and B Before Any Merger". The paper accepts that engine capacity and power output have become unreliable proxies for vehicle market position, but argues that this does not by itself establish the case for merging Categories A and B. It examines the historical progressivity rationale for separate COE categories, household car-availability data, auction design, price responsiveness, the proposed value-based feebate, and the distributional implications of a common quota pool. It recommends moving the classification methodology to a value basis while retaining two passenger-car quota pools until counterfactual modelling demonstrates that a merged design preserves or improves progressivity, measured against both vehicle value and household income. The submission also separately examines the proposed application of a value-based feebate to COE renewals and argues that any such renewal mechanism requires an independent policy justification and appropriately calibrated transitional treatment.