RE: Environmental Registry…

RE: Environmental Registry of Ontario (ERO) Posting No. 013-3867 Redesigning Ontario’s Drive Clean Motor Vehicle Emission Testing Program

Thank you for the opportunity to comment on the proposed redesign of Ontario’s Drive Clean Program.

The Region of Peel – Public Health supports the Drive Clean program as an important part of addressing the negative health effects of transportation-related emissions on health, particularly for sensitive populations and those living in close proximity to major transportation corridors. Data from the 2014 report “Improving Health by Design in the Greater Toronto-Hamilton Area” estimates the health impact of traffic-related emissions in the Greater Toronto-Hamilton Area (GTHA) at 700 premature deaths each year, with a related economic impact of over $4.6 billion. High-emitting vehicles are also a disproportionate contributor to greenhouse gas emissions, which also have a significant impact on health.

It is within this context that we offer the following comments on the proposed changes to Ontario’s Drive Clean Program.

1. Winding down the light duty vehicle emissions testing requirements

Recommendation: Continue mandatory emission testing on light-duty diesel vehicles.
- Every two years for registration renewal purposes for light-duty diesel vehicles older than 7 years;
- At any time if ownership is transferred for light-duty diesel vehicles older than 1 year.

While we support the idea that fuel-efficient light-duty non-diesel vehicles no longer need to be part of the Drive Clean program, we strongly advise that light-duty diesel vehicles older than 7 years continue to require mandatory emission testing every two years for registration renewal purposes, or at any time if ownership is transferred for light-duty diesel vehicles older than one year. Diesel exhaust is classified by the International Agency for Research on Cancer as Group 1, carcinogenic to humans. There is sufficient evidence that diesel exhaust is a cause of lung cancer, and preliminary evidence of a positive association with bladder cancer in humans. Reducing emissions from light-duty diesel vehicles is critical to protecting the health of the public.

Recommendation: Explore emerging on-road testing technologies (e.g. mobile or stationary emissions measurement systems) to ensure that motorists are appropriately maintaining vehicle emission control systems.

There are several emerging on-road testing technologies (e.g. mobile or stationary emissions measurement systems) that are worth exploring and we urge the MECP to evaluate these technologies for possible piloting and deployment in monitoring vehicular emissions control systems.

2. Redesigning the heavy-duty vehicle emissions testing program

Recommendation: Ensure annual mandatory testing of heavy-duty vehicles includes testing a smoke meter opacity test in addition to testing on-board diagnostic (OBD) computer-based emissions controls.

While we support annual mandatory testing of heavy-duty vehicle OBD computer-based emissions controls, we also recommend that standard testing also include a smoke meter opacity test. A study recently published by Wang et. al. (2018) at the University of Toronto has shown large trucks to be the greatest contributors to black carbon emissions close to major roadways. Black carbon is a marker for exposure to diesel exhaust which is a known carcinogen.

Recommendation: Clarify whether fleet owners with a Motor Vehicle Inspection Station license will be permitted to conduct and record the heavy-duty OBD test for their own fleet.

The proposal does not identify whether fleet owners that are operating a Motor Vehicle Inspection Station would be permitted to conduct and record the heavy-duty OBD test for their own fleet, or if they will be required to send vehicles to be tested by a third party. The policy must be made absolutely clear and we would appreciate a response clarifying this scenario.

Recommendation: Ensure the test standard for visible emissions opacity complies with the most stringent air quality standards.

We support the review of the appropriate vehicle test age and test frequency, as well as the review of the test standard for visible emissions opacity, ensuring that both comply with the most stringent standards to ensure public health protection.

Recommendation: Describe how the MECP will use incentives to industries that consistently demonstrate cleaner fleets as well as reducing costs to taxpayers.

We also recognize the importance of and fully support incentives to industries that consistently demonstrate cleaner fleets as well as reducing costs to taxpayers. However, again we request additional details on how this will be operationalized in order to provide further comment, specifically around the amount of the incentive, how incentives will be awarded and how taxpayer costs might be reduced, among other considerations.

The report “Climate Action in Ontario: What’s Next” written by the Environmental Commissioner of Ontario addresses the issue of incentives as well as other related issues (e.g. fees on high emission trucks) that are worth considering, such as:
• Offering a social responsibility designation to motivate large trucking companies to reduce emissions, retire old trucks and purchase/develop low-emission fleets
• Rewarding dealerships and manufacturers that sell or manufacture low/zero emission vehicles
• Providing incentives to retire old heavy-duty vehicles (e.g. “cash for clunkers”)
• Implementing road pricing (e.g. diesel fuel tax, road toll for certain routes/times of day)

Recommendation: Ensure that all recommendations related to heavy-duty vehicles from the 2012 Annual Report of the Office of the Auditor General of Ontario on the Drive Clean Program be fully implemented and publicly reported.

We recommend that all recommendations related to heavy-duty vehicles from the 2012 Annual Report of the Office of the Auditor General of Ontario on the Drive Clean Program be fully implemented and a full current Drive Clean Emission Report be produced and made publicly available prior to the April 1, 2019 effective date.

3. Strengthening the on-road enforcement of emissions standards for both light and heavy-duty vehicles and strengthen anti-tampering restrictions

Recommendation: Publish additional detail on the program’s revised approach to strengthening on-road enforcement and anti-tampering restrictions, and commit to providing driver and industry education.

We support the proposed program changes to strengthen on-road enforcement of both light- and heavy-duty vehicles, however, it is unclear at this time how the MECP will operationalize this component. As such, we are requesting additional details before we can fully comment, specifically around how enforcement will be conducted, by whom, how often, and what are the associated penalties, among other considerations.

Emission control system tampering is a serious concern and we support the proposal for increased enforcement of existing anti-tampering restrictions. However, it is also unclear how the MECP will operationalize this component. We respectfully request additional details on how these restrictions will be enforced (e.g. frequency of inspections) and recommend, at minimum, that your Ministry increase covert auditing of testing facilities to ensure compliance with legislation.

The Drive Clean program has served as an effective tool to reduce greenhouse gas emissions and has spurred positive responses and change from drivers and industry. In the absence of the Drive Clean Program, the MECP should also provide education to ensure drivers and industry maintain their vehicles to reduce air pollution and greenhouse gas emissions.

Recommendation: Increase efforts to raise awareness of the on-line reporting system for smoking vehicles to the public.

We recommend that the MECP increase efforts to increase awareness of the on-line reporting system for smoking vehicles to the public and promote this option as an additional strategy in mitigating the impacts of vehicle emissions through the Drive Clean Program.

Recommendation: Engage in a comprehensive consultation with other ministries, municipal partners, public health units and non-governmental associations on how to reduce vehicle emissions.

Finally, we recommend that the MECP engage in a comprehensive consultation with other ministries, municipal partners, public health units and non-governmental associations to develop broader provincial policy that will serve to reduce local traffic-related emissions.

I hope that these comments will be helpful as the MECP moves forward with redesigning Ontario’s Drive Clean Motor Vehicle Emission Testing Program.