1. Winding down the light…

1. Winding down the light duty vehicle emissions testing requirements.
We agree that focus should be taken on heavy-duty diesel vehicles; 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. Will this be addressed in the new program?
2. Redesigning the heavy duty vehicle emissions testing requirements.
We agree that additional guidelines for heavy-duty vehicles are a necessary step toward improving air quality in Ontario. We support On Board Diagnostic testing, however, it is not defined who will be conducting this testing, and this will need to be clarified. 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. When and how is this to be determined and when is this expected to be defined?
A review of the appropriate vehicle test age and test frequency as well as opacity test standards will be significant for the new program. 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? How will anti-tampering be enforced and what will penalties be if regulations are broken? How will the Ministry ensure that basic maintenance such as 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?
Drive Clean focused on on-road vehicles, 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?
Providing incentives to industry who consistently demonstrate cleaner fleets will encourage industry to exceed standards. What will the guidelines be?
3. Strengthening the on-road enforcement of emissions standards for both light and heavy duty vehicles.
We agree that strengthening the on-road enforcement of emissions standards should be put into practice. Further clarification as to how road enforcement will be conducted for all vehicles, how will testing on the spot will be completed, and what the consequences will be for offenders is needed.
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 potentially be led and coordinated by the Ministry.