Thank you for this…

Thank you for this opportunity to provide input on the proposed new Regulation for Vehicle Emissions under the Environmental Protection Act. R.S.O 1990. c. E. 19

We appreciate and support any regulation that brings increased attention to emissions from highly polluting heavy-duty diesel vehicles. The key goals of this regulation should be the elimination of tampering and the removal of older highly polluting trucks from Ontario’s roads, particularly roads that pass beside facilities such as schools, daycares and retirement homes. If effective, this regulation will reduce the exposure of Ontario residents to diesel exhaust, providing substantial associated health benefits and costs savings. By aggressively addressing the issue of diesel exhaust exposure, Ontario has an opportunity to lead both nationally and internationally.

We agree that on-road enforcement will be key to achieving these goals; tampering will not be eliminated through annual safety and emissions testing alone. The frequency of on-road enforcement needs to increase if this proposed regulation is to be effective. The emission enforcement branch’s web site reports that they did 3000 on-road vehicle inspections last year. There are 260,000 trucks in Ontario alone hence the current level of on-road enforcement only inspects 1% of trucks per year; much more on-road enforcement is needed for this regulation to be effective. Highly polluting trucks may represent 10 to 20% of this fleet, so we recommend inspecting at least 5% of the trucks on-road per year. Clearly, this increased enforcement will require a significant increase in staffing and other resources.

The Province must also invest in developing and deploying new on-road technologies to identify highly polluting vehicles. Ministry cars can be equipped with these technologies in order to directly measure emissions of nearby vehicles while driving in order to identify potential offenders. Opacity testing can be used once a vehicle has been pulled over, to assess compliance and potentially to identify faulty diesel particulate filters. A similar road-side technology needs to be developed to easily identify excess nitrogen oxide emissions due to faulty or failing emission treatment systems.

We encourage the Province to develop a low emitter or clean diesel vehicle standard as part of implementing this regulation. This standard should be aligned with or surpass the stringent EPA standards phased in a decade ago (PM (0.01 g/bhp·hr) and NOx (0.20 g/bhp·hr)). Only diesel vehicles meeting this standard should be allowed to operate in densely populated areas. Municipalities may choose to grant priority access to low emitting trucks, such as priority trucking routes or the right to do deliveries in more sensitive locations (e.g. near schools and daycares). Government tenders for large infrastructure projects within populated areas should require the use of clean construction vehicles.
Given that the older highly polluting trucks will have increasingly limited utility, financial incentives should be provided to accelerate their retirement and replacement.

Near road monitoring needs to be continued and expanded in order to monitor the long-term success of implementing this regulation. Fleet average emission factors should be measured for key pollutants that are indicators of diesel vehicle emissions, such as black carbon, nitrogen oxides and ultrafine particles, in order to monitor the benefits achieved. These types of measurements should be made in a variety of locations across our Province. Gains in terms of lower fleet emission factors and improved air quality should be compared against milestones to verify that the expected progress is being achieved.

The regulation should be extended to address the increased emission of brake dust from all vehicles. In this regard the quantity and quality of brake pads being sold in Ontario should be monitored along with the chemical composition of the road dust that they produce.

Traffic related air pollution contributes to impaired health and mortality in Ontario. The associated costs can be estimated to be in the billions of dollars annually. Thus, allocating tens of millions annually to effectively enforce this regulation and monitor its success, will provide substantial financial returns

Additional recommendations and more context can be found in the attached report along with the full report on the near road air pollution study available on our website