Dear Ms. Mineava,…

Dear Ms. Mineava,

    The Truck and Engine Manufacturers Association (“EMA”) hereby provides feedback on the Ontario Ministry of Transportation’s (MTO’s) proposed modernized of its Green Commercial Vehicle Program (“GCVP”). EMA member companies design and build Class 3-8 commercial vehicles with a Gross Vehicle Weight Rating greater than 4500 kg (9,921 pounds) that are the subject of the GCVP.

    We applaud the MTO for its efforts to modernize the GCVP to help reduce emissions from commercial vehicles. We share that goal. However, we believe that the proposal fails to capitalize on two significant opportunities to achieve additional emissions reductions. First, as proposed, the GCVP would only provide incentives for the aftermarket installation of emissions-reduction technologies. By ignoring aerodynamic devices and anti-idling devices that are installed at the factory by the truck manufacturer, the GCVP fails to promote the purchase of highly-efficient new commercial vehicles with those technologies installed by the original vehicle manufacturer. The original vehicle manufacturer generally has the sophistication and expertise to optimize parts for fuel efficiency in a manner that aftermarket part suppliers do not, such that the GCVP misses the most fuel saving technologies and credits the less fuel saving ones. Additionally, by focusing only on a very limited number of technologies, the GCVP misses many emission-reduction opportunities. Promoting the adoption of more technologies in Environment and Climate Change Canada’s Heavy-Duty Vehicle and Engine Greenhouse Gas Emission Reduction Regulations would significantly reduce emissions from commercial vehicles. Specifically, the GCVP should provide a financial incentive for fleets to purchases low rolling resistance tires – both as original equipment and replacement tires.

    If you have any questions, or if there is any additional information we could provide, please do not hesitate to contact me.

Respectfully submitted,

Timothy Blubaugh

[Original Comment ID: 211155]