My company has been involved…

ERO number

013-3867

Comment ID

10016

Commenting on behalf of

Buehler Automotive & Transmission Inc

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Comment

My company has been involved with Emission Testing since the fall of 1999 when we started with the Emissions Testing of Heavy Duty vehicles. At beginning of the program we witnessed a lot of heavy vehicles fail for various reasons ie: poor maintenance, emissions devices removed or modified, injection pumps modified to name a few. What the program led to was better maintenance, removed parts reinstalled and some of the modifications undone. Overall we saw a big improvement after the first 3-4 years.

Now we have mostly electronic controls on diesel engines and there are many vehicles that are chipped or reprogrammed to bypass or overide emissions components. These can be easily returned to stock by the vehicle owner for an emission test then switched back again after the test.
We have not seen a lot of modifications done on highway trucks in our immediate service area. What we do see is 3/4 ton & 1 ton pickups chipped & reprogrammed so that the ecm reports the monitors as being satisfied with what they see or in some cases the ecm has been reprogrammed that the monitors are no longer present. Catalytic convertors can be punched out so they no longer function yet they are physically present. EGR systems can be deleted or bypassed with aftermarket kits. The public is not aware of how much Nox emissions occur from a diesel engine that is belching out black smoke.
By eliminating the light duty emissions program this opens the door for more of this too occur.
What I am proposing would be to lower the GVW weight for diesel testing to 3,800kg upward instead of 4,500kg which would curb a lot of the tampering with this category of trucks.

With the suspension of the Light Duty vehicle testing program terminating this coming spring I guarantee we will see a return to vehicles being driven with their check engine lights on like they did back before emission testing was implemented.
If there were changes made to the MTO Mechanical Fitness Standards for all passenger vehicles in regards to check engine lights not being illuminated to be able to pass mechanical fitness that would address some of these issues.
Also a bi-annual mechanical fitness inspection program with regulations regarding check engine lights would provide incentives to better maintain vehicles and remove unsafe vehicles from our streets and highways. This would eliminate the need for a provincial testing program for light duty vehicles.

These are some of my thoughts. My company has been involved with Heavy Duty since 1999 and Light Duty since 2000.