There are some very big… | Environmental Registry of Ontario

Comment on

Modernizing Ontario’s Vehicle Inspection Program & integrating safety and emissions inspections for commercial vehicles

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019-4277

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58598

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There are some very big oversights that are obviously being overlooked and not addressed with this New Ontario Integrated Safety and Emissions Program to ensure it is successful.

If these oversights are not addressed immediately this new program will actually burden the owners of heavy duty vehicles in Ontario and actually increase inspection times and costs over the current legacy program drastically.

• Require all inspections to be completed by qualified Ontario College of Trades technicians (310T heavy truck and coach mechanic) and permit the refusal/revocation of technicians.

This proposal of only allowing a 310T mechanic to simply perform an emissions inspection is complete overkill for the investment in skill these mechanics have earned, no current employer could pay the going rate that a 310T mechanic earns to simply perform an emissions test.

For an individual to become a 310t mechanic they must;

The Truck and Coach Technician (310T) apprenticeship program consists of on-the-job and in-school training. The program typically takes three and a half years to complete and consists of:

6,000 hours of on-the-job training/work experience
720 hours of in-school training
A minimum of Grade 12 high school education or its equivalent is required to qualify for the Truck and Coach Technician apprenticeship program. 

Truck and Coach Technicians make around $68,000 per year, two years after being certified.

https://www.ontario.ca/page/truck-and-coach-technician

There are currently some emissions stations in Ontario that don’t even make $68,000 a year in sales!!!

This pay scale is not inline with what a current heavy duty diesel emissions inspector would earn. It is much higher, therefore if Ontario goes ahead with this absurd proposal the cost of a simple emissions inspection will have to increase dramatically.

Currently the average rate for an emissions inspection is approximately $120.00. This rate will have to increase to roughly $185.00 to $210.00 per emissions inspection to compensate for the much higher pay required to employ a 310T.

This all goes without mentioning the well known massive shortage of these highly skilled 310T mechanics in Ontario.

The common knowledge that there is a serious shortage of these mechanics should be a huge red flag to the ministry and should be reassessed.

The fact that that certification is total overkill for a simple emissions test goes without saying. 310T mechanics on average own over $50,000 dollars worth of tools. All this is wasted when not even a simple screwdriver is required to perform an emissions test.

Included are links with regards to this drastic Ontario 310t shortage.

https://www.autoserviceworld.com/tech-shortage-continues-to-worsen-new-…

https://globalnews.ca/news/4161338/canada-labour-shortage-job-vacancies/

The other thing the province needs to realize is that this shortage is going to become much worse. In order to become a 310T mechanic the student is required to complete 720 hours of in class learning. Due to the Covid-19 Pandemic all in class learning was canceled for over 1 year at a minimum. This shortage is going to become even more serious.

The canceled in class learning has created a domino effect of 310T mechanics that is only starting to show now and will only get worse! Way worse than any pre-pandemic projected studies.

Currently certified emission technicians may continue to perform emission tests

I am happy to see this proposal that current certified emissions inspectors may continue in the new program.

However the fact that the province will allow current emissions inspectors to continue and new program requirements are that of a 310T will most certainly create an un levelled playing field within the emissions testing industry.

Emissions stations that are able to continue without a 310t endorsement will have an extreme monetary advantage over those stations that are forced to employ 310T mechanics.

The requirement of a 310T mechanic to perform and emissions inspection needs to be withdrawn.

Requiring assembled vehicles to have the required emission systems/devices to prevent/lessen discharge or emission of pollutants.

This proposal for assembled vehicles to be equipped with the emissions controls that the year of the chassis will most certainly burden the owners of these vehicles.

In many cases these vehicles were built using older pre-2007 engines that have superior, highly reliable and more fuel efficient engines.

It is not possible for owners of these all ready built assembled vehicles to comply with this requirement. The vehicle would have to be re-powered with an engine that was built to have emissions controls after treatment systems. This would not be cost effective at easily $100.000 per vehicle to comply.

Also how would the province enforce this regulation in Ontario with vehicles passing through Ontario that are registered out of province?

The province also needs to realize that relaying on OBD testing is not nearly as accurate as tailpipe opacity testing. Currently many heavy diesel vehicles fail the current emissions inspection for opacity readings over the current limits. Most of these vehicles DO NOT have the Engine Light Turned On. OBD testing will NOT identify these polluting vehicles.

The other more major problem with OBD testing in heavy duty diesel vehicles regardless of GVWR is the required distance needed to “Set the Readiness Monitors”. It has been reported that heavy diesel vehicles have had to be driven over 5000 Kilometres in order to set the readiness monitors. In some cases the vehicle still fails the OBD test as more than 3 monitors are not set to ready.

The current program allows for 3 monitors to be “not ready”. But in my opinion ALL “ readiness monitors” should be ready and none should be “not ready” to ensure emissions controls are functioning as intended and working properly and ensuring the vehicle is not tampered with.
Allowing 3 crucial readiness monitors to be not ready defeats the whole purpose of OBD testing and does not level the playing field in the trucking industry.

The pandemic has allowed for vehicle owners to drive on expired license plates. Starting in January there will be a huge spike of heavy vehicles up to 6350KG GVWR that will not be able to set readiness monitors, and unable to license their vehicles. Leading to truck shortages and increased burdens on vehicles owners.

To set readiness monitors the has to be driven until the monitors are set. There is no way around this and reducing the amount of monitors required to pass an emissions test is not the answer to emissions tampering.

What will the province do when all HD diesel vehicles in Ontario need to pass a REAL ODB test with all monitors set to “ready”?

Most would agree that this is not possible, especially for brand new vehicles that have not been driven before. Imagine buying a brand new vehicle and not being able to pass the yellow sticker safety and emissions inspection because all the monitors are set to “not ready” as this is how a brand new vehicle is manufactured.

Enhancing emission requirements by introducing a smoke opacity standard of 10% for all CMV’s 2011 and newer subject to inspection.

This proposal is extremely ambiguous and could have been achievable if the government protected consumers of heavy duty diesel vehicles in North America.

There are hundreds of class action lawsuits against heavy duty Diesel engines manufacturers in North America and these lawsuits effect owners here in Ontario too.

These emissions controls lawsuits have lead to widespread emissions tampering in heavy duty vehicles built between 2007 to 2016.

The lawsuits range in complaints. They include Fraud, Failure to meet emissions standards, reliability, fuel economy issues and major failure to fix said issues.

In some instances, it was found that these controls actually led to releasing more pollutants in to the air than lawfully allowable. How will these vehicles produce an opacity reading less than 10%?

It will be extremely burdensome for owners of these vehicles to comply with the proposed regulation as the vehicle are not even able to be permanently fixed by the engine manufacturers!!!

The Ontario government is already well aware of these problems and held a workshop about the widespread emissions tampering.

https://prod-environmental-registry.s3.amazonaws.com/2019-09/EBR%20Exte…

Referencing the workshop, the stakeholders clearly stated that not all were “back actors” when it came to deleting their emissions controls and tampering with vehicles. It was a question of survival and economic need. The government has failed to assist or help resolve any of these issues.

Certain rule changes contained in the new program will only penalize these “Non bad actors” even further.

The province will have to investigate retrofit technology such as Hydrogen Enhanced Combustion for Diesel engines as a form of emissions controls to create a level playing field within in the trucking industry for vehicles that are not able to comply. There have been major studies performed and certified results prove that heavy diesel trucks that have tampered emissions controls that are retrofitted with hydrogen on-demand systems are able to rival the tailpipe emissions of non tampered heavy diesel vehicles.

It is my opinion that this new emissions program will actually lead to heavy duty diesel vehicle owners to purchase and keep older non emissions vehicles for much longer than ever anticipated.
As it costs less to operate them and they are more fuel efficient and more reliable. Older vehicles make owners more money and have way less downtime. The new emissions program does not do anything to reduce emissions from older vehicles. It really should as these vehicles emit much more NOX and Particulate Matter than newer vehicles. These older vehicles could benefit from Hydrogen Enhanced Combustion in an effort to reduce harmful tailpipe emissions in Ontario.

Links to class action lawsuits for heavy duty vehicles built between 2007 to 2016 in North America. Obviously there is a problem with these systems and I would like to know what Ontario plans to do about it?

Navistar/ international engine emissions lawsuits

https://www.thetruckersreport.com/navistar-may-opened-2-billion-potenti…

https://landline.media/court-reverses-31m-verdict-in-navistar-maxxforce…

https://www.forconstructionpros.com/trucks/trucks-accessories/heavy-tru…

https://www.overdriveonline.com/business/article/14896418/maxxforce-eng…

https://www.google.ca/amp/s/chicago.cbslocal.com/2018/10/16/navistar-la…

https://landline.media/navistar-reaches-two-large-settlements-with-u-s-…

https://archive.nytimes.com/www.nytimes.com/gwire/2010/08/19/19greenwir…

https://www.ccjdigital.com/business/article/14929780/carriers-sue-navis…

https://www.google.ca/amp/s/www.chicagotribune.com/business/ct-biz-navi…

https://www.truckinginfo.com/141709/navistar-hit-with-30-8-million-judg…

https://www.clg.org/pdf/9/7/7/Motion-for-Authorization.pdf