As a licensed 310T truck and…

As a licensed 310T truck and coach technician that has been licensed since 2007 I have seen first hand the challenge these emission systems have brought to the trucking industry. Implementing and enforcing these types of limits on the very first tiers of emission systems that were introduced will cause a significant challenges for the industry. The first tier systems and to be honest the systems that are offered to date are extremely unreliable and cause significant cost in repairs to the operator

To implement stricter standards and enforce what’s in place from 2008 and on would add a very heavy straw to camels back in an industry that has very limited service options as far as being able to fix and reliably maintain theses problematic systems

The transportation industry is already facing a shortage of skilled trades there are less and less people signing up to become mechanics in this province when I was in trade school there was a waiting list to get into schooling 20-30 per class, now I can say with certainty 4-5 people in a class at most!!

The technology is not reliable, the cost of operations in a strained industry that already has trouble attracting properly trained drivers let alone Mechanic’s is a challenge

There’s no doubt the clean air is important but for you to enforce and start cracking down on these engine without looking at the industry problems as a whole would be a mistake I can say with certainty the compliance levels that you are looking to achieve with the unreliable technology that’s in place you will see some serious challenges with enforcement, most brand new trucks off the lot today come back for emission related problems or warranty repair up 4-5 times in first year of operation after that first year of operation that figure doubles, almost every single truck that comes into the dealership anymore is emission related!

Please wait until this technology becomes more reliable put the burden on the corporations that build these engines protect the consumers better by implementing a system that holds the manufacturer responsible for the reliability of the system!

If you took every commercial vehicle on the road tommorrow and held it to your proposed standards you would see an industry that’s just not ready to meet the challenge

Fix skilled trades issues
Hold manufacturers to a reliability standard!
Subsidize the cost of repairs with a tax deduction for repairs required on emissions systems

These above stated items are key to enforcing what your proposed changes will bring to the industry and would allow the Industry to overcome the short falls of current technology!