Dear Mr. Gerald Gillespie, …

Dear Mr. Gerald Gillespie,
I would like to submit a suggestion in reference to ERO number 013-3867 pertaining to the emissions testing of diesel trucks for personal/non-commercial use. Under current legislation, all diesel truck (including pickup trucks for personal use) that are registered over 6000kg Gross wt, are required to have an annual emissions test and are classified as commercial. This includes the personal use of pickups towing their RV's, dumpers, flat beds, utility trailers and car haulers. The vast majority of these towing combinations are used only a few times per year as it is part of their summer hobbies. They are not used on a daily basis and many drive less than 1000 or 2000 km a year with said trailers. Also as current legislation states, vehicles regardless of year, when registered to tow a trailer over 4600 kg, are also classified as commercial and required to go for e-test annually, even a 1960s pickup.

I would like to submit a suggestion that light trucks being used for personal use, and not being used in a commercial environment, also be exempt from emissions testing even if the vehicle is registered at more than 6000kg. Towing a 5,000 kg car trailer to a classic car show, with a 4000kg pickup truck, requires the vehicle registration to be now viewed as commercial. When attending a classic car show twice per year, it shouldn't require a vehicle to be registered as commercial, and thus require it to be emissions tested annually. The same would be for say a farm tractor enthusiast who would restore a old 1950s farm tractor, and now his 4000kg truck, 4000 kg trailer, plus his 3000 kg tractor (totalling 11,000 kg required registration on his ownership) for the local fall fair display, would require him to be seen as commercial. Further, as the vehicle is now seen as commercial, the owner of the pickup is now required to pay for his own e-test as the "free e-test" program does not cover annual required e-tests. Unfortunately, due to the classification of "commercial" now requiring an e-test regardless of model year, you have a citizen that has to take a vehicle that doesn't even have an emissions system as it so old (1950s, 1960s, etc), going into a test facility to get an emissions test! Per Drive Clean rules, the individual towing his classic car with his classic restored pickup, now is in a situation where the test facility doesn't even know how to test the vehicle as there isn't even a protocol around the testing.

In closing, I would like to leave this thought; that trucks used for towing trailers for personal use do not emit the volume of emissions into our environment as daily used commercial trucks because of the limited amount of milage traveled per year.

Thank you for the opportunity to submit our thoughts.