Katerina Minaeva…

Katerina Minaeva
Senior Policy Analyst
Environmental Policy Office (Toronto)
Suite 700 777 Bay Street
Toronto Ontario
M7A 2J8

EBR Registry Number: 013-1381

Dear Ms. Minaeva,

Thank you for the opportunity to provide comments on Ontario’s Green Commercial Vehicle Program (GCVP). We commend the province’s climate leadership in supporting and facilitating the deployment of alternative fuel vehicles and associated technologies to reduce the greenhouse gas impact of Ontario’s commercial freight sector. I am writing on behalf of Westport Fuel Systems to express our support for the GCVP.

Westport Fuel systems is a publicly-traded company listed on both the NASDAQ and TSX with corporate headquarters in Vancouver, British Columbia. We engineer, manufacture, and supply the world’s most advanced alternative fuel systems and components offered under 18 brands, delivering innovative products for transportation and industrial applications. We serve customers in more than 70 countries including many of the largest and fastest growing alternative fuel engine and vehicle markets.

Our Cummins Westport (CWI) joint venture with Cummins Inc. designs, engineers, and markets 6- to 12-litre natural gas engines for commercial transportation applications. Our dedicated 100% natural gas engines are manufactured by Cummins and available as a factory-direct option from leading truck and bus original equipment manufacturers (OEMs). The engines are backed by a full Cummins factory warranty and supported locally by Cummins Eastern Canada and the OEM dealer network. Every leading truck manufacturer including Freightliner, Volvo, Kenworth, Peterbilt, and Mack produce trucks with CWI natural gas engines. CWI has delivered heavy-duty natural gas engines to customers in the largest refuse, transit, and trucking fleets in Canada including Waste Management, BFI Canada, Smithrite Disposal, Coldstar Freight, the City of Vancouver, the City of Hamilton, Emterra, and others.

CWI has delivered more than 70,000 natural gas truck and bus engines since its inception in 2001. Our newest engines – the L9N and ISX12N – represent the cleanest internal combustion engine technology with a 90% reduction in oxides of nitrogen (NOx) and particulate matter (PM) over current EPA standards. CWI is proud to have partnered with South Coast Air Quality Management District (SCAQMD) and the California Energy Commission (CEC) to develop this technology and gratefully acknowledges the funding received from these agencies.

Cummins Westport engines can operate on up to 100% renewable natural gas (RNG) without modifications, resulting in significant greenhouse gas reductions of more than 80% depending on feedstock pathway. In fact, the CEC and AQMD have determined, and publicly stated, that these natural gas engines operating on RNG have equivalent emissions to an electric vehicle. Given that the GCVP incentives are based on GHG emission reduction potential, we would encourage the government to evaluate recent reports from both agencies quantifying the emissions reduction benefit of this engine when determining per vehicle percentages and incremental cost caps.

In addition to the North American engines offered by CWI, we are also launching our proprietary Westport High Pressure Direct Injection HPDI 2.0 (WestportTM HPDI 2.0) technology in a Euro 6-compliant heavy duty truck with a major European OEM in late 2017. Our fully integrated WestportTM HPDI 2.0 system matches the power, torque, and fuel economy of a true compression ignition engine powered by natural gas, with reduced GHG emissions and the capability to run entirely on renewable fuels. We would encourage the government of Ontario to explore opportunities to develop and launch a North American certified engine via the Transportation Innovation Pilot funding stream.

I would like to reiterate our support for the GCVP and encourage the expeditious delivery of program funds to fleets looking to purchase heavy-duty natural gas vehicles. While the GCVP is a rebate-based program for the commercial transportation sector, other municipal fleets such as transit or public works would also benefit from the program as would fueling station providers and operators through higher fuel use and increased utilization.

We look forward to working with Ontario and provincial stakeholders to launch this program which provides critical GHG emission reduction benefits to the commercial transportation sector. Sincerely,

Karen Hamberg
Vice-President, Industry and Government Relations
Westport Fuel Systems Inc.
(604) 718-6463

[Original Comment ID: 211124]