Thank you for the…

Thank you for the opportunity to comment on these important proposed changes to Drive Clean.

Re: two of the core objectives of the proposed changes:
- protection of Ontario’s air quality
- reduced human exposure to dangerous diesel emissions, including particulate matter, nitrogen oxides (NOx), hydrocarbons and other pollutants; and reduce emissions of black carbon, a short lived climate change agent.

Past and proposed opacity testing only addressed visible particulate such as carbon black. What does the Ministry propose to do about emissions of the many other harmful and toxic substances in diesel emissions? PM 2.5 is not visible and is not caught in an opacity test. NOx and toxic hydrocarbon emissions from diesel combustion never were captured in Drive Clean. How will we know?

While light duty vehicle emissions performance has made great strides, thanks to regulation of light duty car makers and owners, diesel carmakers have found ways to Game the on-board diagnostics to give false passes for cars that actually fail. (Note: Volkswagen, Audi, Mercedes, etc).

How will the Ministry enforce maintenance and emissions performance from car makers who have such deliberate disregard for air quality and the health of Ontario citizens? The Ministry in fact relied on discovery of emission fraud by US EPA - Drive Clean was blind to such criminal action. How will we know?

It is well known that the oldest vehicles are responsible for most of the emissions. Will the Ministry consider implementing incentive-based voluntary accelerated retirement programs for older diesel vehicles of all sizes/duties? Such a focus could offer the best bang for the buck in air quality improvement.

The new focus on heavy-duty diesel vehicles is a good one as these vehicles fell between the cracks in Drive Clean. However, there doesn’t seem to be any focus on light-duty and medium-duty diesel vehicles. Diesel emissions are among the most toxic of fossil emissions, particularly exposure at street level from light- & medium-duty diesel vehicles. The oldest vehicles also tend to be the highest emitting, and engines can be easily rebuilt to old standards.

It can be easy to “forget” to top-up the SCR/SNCR fluid to reduce NOx emissions. Particulate filters clog up and cycles of “burning them clean” are built into their design. How will the Ministry ensure that vehicle makers who have already failed public trust, will not play games again with emission control design, on-board diagnostics and public health? For example, how will the Ministry ensure that basic maintenance like regularly filling NOx control reservoirs is carried out by ALL diesel vehicle owners?

A particularly sensitive population to toxic diesel emission exposure is young school children who ride diesel school buses. Will the Ministry give special and timely attention to monitoring and reducing diesel emissions from school buses? I note that funding was recently withdrawn for important electric school bus pilot projects.

Drive Clean focused on on-road vehicles, and it’s early successes were significant. However, non-road and off-road Diesel engines are also significant and growing emissions sources. In transportation, this includes rail and commercial and recreational marine, off-road vehicles, industrial vehicles. It also includes diesel construction equipment, generators, compressors, road maintenance etc. Proximity to these emissions is also a concern. How might a new diesel-focused program also address these other significant sources of emissions?

An opportunity for government to lead by doing is presented by publicly funded transit vehicles. Enhanced maintenance and testing of these vehicles across regions and municipalities offers an early model of how fleets might be addressed. This could be led and coordinated by the Ministry.

Thanks again for the opportunity to comment.