Thank you for the…

Thank you for the opportunity to provide comments to your Green Commercial Vehicle Program – 2017-2018 Program Guide for Consultation draft. We applaud the provincial government for developing programs that promote the use of low carbon commercial motor vehicles and technologies to reduce emissions.

As you know, goods movement is a backbone of our local and regional economies (38% of Ontario’s economy comes from freight-intensive industries), but increased freight activity, particularly road freight, has environmental and community impacts. For example, heavy-duty trucks alone are now responsible for just under 10% of Ontario’s emissions. Canada-wide, overall freight emissions (which include trucks, rail, air and marine) are projected to eclipse passenger emissions by 2030. Moreover, growing road congestion — caused by both passenger and commercial vehicles — is a mounting economic concern, particularly for the goods movement sector.

Within the draft program guide provided, our key recommendation is to provide greater clarity and inclusion of all classifications of commercial vehicles as part of the program. More specifically:

•   In section 3 of the guide, the “Vehicle Categories” outlined in the table have limited fuel options within each category. We strongly recommend that the program be designed to support maximum opportunities to advance low carbon fuels among all clean fuel categories and within all vehicle categories. Hydrogen fuel should also be considered if it can be sourced with lower life-cycle emissions.

•   In section 4.1, the program design excludes Class 6, 7 and 8 electric trucks from the program all together, although the technology is becoming available. For example, Cummins Truck has introduced a Class 7 heavy-duty truck cab with a 140 kWh battery pack that has a 100-mile range which will be available to commercial truck fleets starting in 2019. Several other companies including Mack and Tesla are developing similar products. Establishing eligibility for electric Class 6, 7 and 8 electric trucks will not only ensure a level playing field among emerging technologies but send strong market signals to manufacturers.

[Original Comment ID: 211157]