RE: Environmental Registry…

RE: Environmental Registry of Ontario (ERO) Posting No. 019-0416 New Regulation for Vehicle Emissions

Thank you for the opportunity to comment on the proposed New Regulations for Vehicle Emissions.

Region of Peel staff support the Ministry of Environment, Conservation and Park’s (MECP) proposed changes to strengthen on-road enforcement for all vehicles, including: clarifying who the standards will apply to, ensuring emission control systems are present and operating as intended, clarifying requirements related to emission control defeat devices, prohibiting the sale of defeat devices, and tightening the visible emission restrictions and the smoke opacity standard.

These improvements are an important part of addressing the negative health effects of transportation-related emissions on health, particularly for sensitive populations and those living near major transportation corridors who have the highest exposure to traffic emissions. It is estimated that 53% of Peel’s population lives within 300 m of a high-volume traffic road or highway and that 27% of Ontario’s population lives near major roads or highways . 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 at 700 premature deaths each year, with a related economic impact of over $4.6 billion.

Large trucks continue to be the greatest contributors to black carbon emissions close to major roadways . Black carbon is a marker for diesel exhaust exposure, which is classified by the International Agency for Research on Cancer as a Group 1 human carcinogen. Exposure to diesel exhaust can cause lung cancer, as well as bladder cancer based on preliminary evidence.

Vehicles are also a large contributor to greenhouse gas (GHG) emissions, which have a significant impact on health and the environment. Since 1990, transportation has accounted for the largest and fastest growing share of GHG emissions in the province. While large trucks continue to be the greatest source of near-road air pollution, passenger vehicles contribute more GHG emissions than heavy-duty vehicles.

Controlling traffic-related pollution and reducing GHG emissions is important to the Region of Peel as our area is a significant goods movement hub, and growth is expected to continue in this sector in the coming years. Initiatives to address emissions from commercial vehicles will be important for mitigation of transportation-related emissions and GHG. Currently, the Region of Peel has undertaken an Off-Peak Delivery pilot project to further reduce the impact of truck related emissions.

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

1. Recommendation: Increase on-road enforcement for vehicle emissions and anti-tampering for all motor vehicles with visible emissions in Ontario.

We are concerned that the limited enforcement capacity of the Ministry of Transportation Vehicle Emissions Enforcement Unit (VEEU) will allow for many vehicle operators to operate in non-compliance with the Environmental Protection Act and related regulations. According to the Drive Clean website , approximately 3,000 roadside inspections are done each year in Ontario. However, in 2018 there were approximately 262,000 vehicles registered in Ontario weighing over 4,500 kg , As such, fewer than 1% of heavy vehicles registered in Ontario, are undergoing roadside inspections in Ontario each year. When you consider the number of additional heavy trucks driving on Ontario roads each day from out-of-province, the reach of the emissions enforcement unit is even less.

Reducing emissions from diesel vehicles is critical to protecting the health of the public. We therefore strongly recommend that the VEEU receive increased resources to enable more roadside inspections and that a comprehensive communication plan be used to raise awareness about the rules and penalties for non-compliance. To effectively deter vehicle emissions tampering and poor vehicle maintenance, vehicle operators need to know there is a likelihood that no matter where they operate in the province, they could be subject to an inspection.

2. Recommendation: Conduct on-board diagnostic system testing on all vehicles with a registered gross weight of more than 4,500 kg.

While we support the recommendations for strengthening the Heavy Diesel Commercial Motor Vehicle Emission Testing Program (e.g. requirement for a smoke opacity test for vehicles over 4,500 kg), it is unclear why the on-board diagnostic (OBD) system test would not apply to trucks greater than 6,350 kg or with a model year before 2007.

According to the decision summary from ERO # 013-3867 (Redesigning Ontario’s Drive Clean Motor Vehicle Emission Testing Program) the use of a computer-based electronic emissions diagnostic test to ensure emission control systems are operating as intended would apply to all commercial vehicles with a registered gross weight of more than 4,500 kg. We recommend that OBD system testing should apply to all vehicles over 4,500 kg.

3. Recommendation: Ensure new emissions control standards are based on evidence and clarify which vehicles will be exempt from these standards.

The ERO does not provide the evidence source for the new emission control standards (i.e. tightening of the visible emissions prohibition from fifteen (15) seconds in five minutes to five (5) seconds in a one-minute period). We recommend that the MECP ensure that the new standards being proposed are based on the best available evidence to ensure they are sufficiently health protective and that the evidence source be provided in future communications on this ERO. Furthermore, we recommend that the Ministry clarify which specific vehicles will be included in the Heavy Diesel Commercial Motor Vehicle On-Board Diagnostic Exemption list.

4. Recommendation: Through stakeholder engagement, develop a comprehensive plan to reduce traffic-related air pollution and GHG emissions.

In Peel, transportation emissions from non-commercial vehicles account for the largest share of GHG emissions from on-road vehicles and vehicle travel is expected to increase with population growth. Furthermore, GHG emissions from light-duty commercial gasoline vehicles account for approximately a quarter of all commercial vehicle emissions in the community.

Broader policy options should address issues such as congestion reduction, anti-idling and using lower emitting modes of transportation such as public transit, low-carbon vehicles and active transportation.

According to the decision summary from ERO # 013-3867, the MECP committed to establishing a working group to provide advice on additional program implementation options (e.g. incentives, burden reduction measures for cleaner fleets), however no additional information has been provided on this action. The Ministry should engage in a comprehensive consultation with other ministries, municipal partners, public health units and non-governmental associations to develop broader policy to reduce traffic-related air pollution and GHG emissions.

5. Recommendation: Provide incentives to industries that consistently demonstrate cleaner fleets.

Consideration should be given to providing incentives to industries that consistently demonstrate cleaner fleets. Incentives may include:

• 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”)

6. 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 encourage members of the public to report smoking vehicles to the Emissions Test Contact Centre (through the phone line and the online reporting form). Public reports of smoking vehicles are an important strategy to help mitigate the impacts of vehicle emissions.

We hope that these comments will be helpful as the MECP moves forward with new regulations for vehicle emissions in Ontario.

A copy of these comments in letter format has also been submitted.