HEAVY DUTY EMISSIONS TESTING…

ERO number

013-3867

Comment ID

11088

Commenting on behalf of

Ontario Recreation Vehicle Dealers Association

Comment status

Comment approved More about comment statuses

Comment

HEAVY DUTY EMISSIONS TESTING PROGRAM
ONTARIO RECREATION VEHICLE DEALERS ASSOCIATION
SUBMISSION TO THE ENVIRONMENTAL BILL OF RIGHTS REGISTRY
OCTOBER 2018

About the Ontario Recreation Vehicle Dealers Association
The Ontario Recreation Vehicle Dealers Association (ORVDA) is a provincial, not for profit, professional trade association uniting over 170 RV dealer and associate members. The ORVDA works to protect the interests of its members involved in the recreation vehicle industry.

Our members are classical small business owner operators and are a vital part of RVing in Canada, which has a considerable impact on the Canadian Economy.

Current Situation

Approximately 5500 RV units have been sold across Canada in 2018, including all classes of Motorhomes A, B and C; this figure represents 1100 units sold in the province of Ontario. Motorhomes are a very small percentage of recreation vehicles on the road and commonly maintain very low mileage. A 2011 Class A with 33,600 km’s is a common trend with Motorhome owners.

Most recreation vehicles are owned by retirees on fixed incomes and are classified as personal, recreation vehicles, not for commercial use. Additionally, the majority of recreation vehicles registered in Ontario operate infrequently within the Province, with travel mostly throughout the United States.

Recommendation to the Ministry of the Environment – Drive Clean Program

With the proposed changes to emissions testing requirement in Ontario for light duty trucks and passenger cars, weight of vehicles should not be the only factor when determining heavy duty emissions testing; use and commercial registration should also be considered.

The position of the Ontario Recreation Vehicle Dealers Association is that recreation vehicles and pickup trucks less than one ton and/or not requiring a CVOR by the Ministry of Transportation, be exempt from heavy duty emissions testing.