Thank you for this…

Thank you for this opportunity to provide input. We support redirecting Drive Clean towards increased focus on monitoring truck emissions, so long as an effective policy with properly funded supporting programing is designed and implemented. This process can’t be rushed. It will take time and broad consultation to design a truly leading-edge policy that will position Ontario at the forefront of environmental protection and serve its citizens well for the next decades.

We have six recommendations

1. Shape program around finding outlier high emitters
Programs to improve air quality were traditionally based on reducing emissions that contribute to poor regional air quality so as to prevent smog covering a city on a bad air quality day. Thanks to all the improvements over the last decades, this paradigm has shifted from regional to localised impacts at the neighbourhood level. This is certainly the case for emissions from diesel vehicles, where the health impacts are believed to be greatest near the roads and within the communities with higher truck traffic.

This shift means that the focus needs to be on targeting the highest emitting vehicles, and restricting where they travel, rather only reducing the provincial average emissions. Certainly, properly maintained new trucks do emit a lot less than the old ones. The problem is that there are still a lot of these old trucks on the road. Further there may be newer trucks with tampered emission treatment systems. The program needs to target these high emitters and recognise and reward the low emitters.

2. Shape goals around Four Rs: Repair, Retrofit, Retire and Relocate
The success of the program will be determined by the elimination of the high emitting trucks and thus it needs to be shaped around promoting the desired mitigation mechanisms and goals. Once a high emitting truck has been identified, we see four options (the four Rs): repair, retrofit, retire or relocate.

Repairing tampered vehicles may be effective albeit expensive. However, repairing older trucks may only provide a temporary fix. Retrofitting trucks with diesel particulate filters can reduce the particle emissions but it will not necessarily reduce the emissions of gases. It is critical to remember that diesel exhaust is a complex chemical mixture that is a recognised human carcinogen. Diesel particulate matter, and its constituents such as black or elemental carbon, are markers used to assess exposure. Eliminating the markers with a particulate filter does not necessarily eliminate the toxicity.
Financial incentives should be provided to retire and replace high emitting vehicles. These might be supported by general revenue from fines, and/or offer individual truck operators the option to redirect first-time fines towards the purchase of a new vehicle.

Relocation of higher emitting trucks away from population centres is a final option. Communities may enact bylaws to completely prohibit trucks with conditional passes and/or only permit low emitting trucks to travel on certain streets or within certain neighbourhoods.

3. Impacts of diesel emissions are local, the locations of higher truck traffic matters
Traffic emissions can impact air quality at homes and facilities near major roads. This has major implications as a third of Canadians live with 250m of a major road. In Ontario this is almost 45% and in Toronto its over 50%. The impact of trucks is more localised, disproportionately impacting a portion of these residents. We know that there are neighbourhoods and street that are disproportionately impacted by truck traffic. Of key concern are facilities such as schools and daycares located near higher truck traffic. Municipalities need to have the capacity to regulate so as to reduce this exposure. Real world monitoring can help to identify and assess the hazard near these facilities or within these neighbourhoods. Creating a “low emitter” standard will give municipalities a lever they can use when needed to reduce exposure.

Canada is also introducing a new Canadian Ambient Air Quality Standards (CAAQS) for nitrogen dioxide (NO2) of 17ppb in 2020. This will likely be exceeded on roads with a higher percentage of trucks. A second pollutant of concern is black carbon (soot) which is used as a measure for occupational exposure to diesel exhaust. The Netherlands has proposed an ambitious new standard of 1 µg/m3 for occupational exposure that is actually lower than the level measured beside major truck routes.

4. Real world monitoring needs to be part of any program
Real world on-road and near road monitoring is really important as actual vehicle emissions can be quite different than the estimates measured in labs or by manufacturers. We have seasons in Canada that don’t get accounted for in a lot of manufacturer testing. These influence emissions, fuel composition and how emission treatment technologies perform. We have observed substantially higher emissions of nitrogen oxides beside highway 401 in Winter for example.

Near road monitoring can provide compelling information on the fleet average emission factors. For example, we have two years of baseline data from the Highway 401 site that can be used to track overall reductions in emissions, due to fleet turn-over. Portable near road monitoring systems can be used to assess emissions in hot spot communities, along with the effectiveness of mitigation through relocation. Smaller air quality monitoring devices installed as part of smart city initiatives can also provide information near key facilities such as schools and daycares. These data should be publicly available to encourage community awareness and engagement. For example, traffic pollution information might become posted on the highway Compass signs.

On-road monitoring needs to be strengthened as this is likely the most effective way to identify high emitters. The Ministry of the Environment, Conservation and Parks (MECP) enforcement vehicles should be equipped with monitoring instruments to be used in chase measurements. These instruments should be configured through appropriate software interface to measure the emission factors for a selected vehicle, compare it with historic data, so as to decide whether to send an alert or warning to the company, or pull the vehicle over. Pilot studies are needed to develop this technology and demonstrate the efficacy of these capabilities.

Monitoring of truck traffic data is also needed as far too few data are available on the distribution of trucks across our cities. For example, the Wavetronix traffic sensors operated by Ministry of Transportation (MTO) on the highways can provide truck traffic data and these could be deployed more widely.

5. Use a tiered-ranking:
The emissions monitoring program should be based on a four-tiered system of low emitter, average, conditional pass and fail. Creation of the “low emitter” category is essential to recognising and rewarding role model firms. Companies values their cooperate reputations as it is essential to their social license to operate. Thus, they should be recognised for having and maintaining a low emitting fleet, and perhaps given the option of including this designation on their trucks. Further municipalities may choose to grant priority access to low emitting trucks such as priority trucking routes or right to do deliveries during the day downtown. Conversely, conditional pass vehicles may have access to some areas prohibited or only be able to operate during off hours.

6. Broad consultation is recommended to leverage policy benefits
Broad consultation is recommended to recognise and leverage ways that the MECP’s policy and supporting programs can provide additional benefits, or benefit from related activity.

Federal partners at Environment and Climate Change Canada (ECCC) should be consulted on the measurement of emissions and how the proposed monitoring program might fit within existing or planned federal and national activities.
Fuel composition can have an important influence on emissions. For example, the level of aromatic compounds can influence emissions of black carbon. Thus, federal and provincial partners should be consulted to see if improved regulation of fuel composition can be used to reduce diesel emissions.

Consultation with Health Canada, Public Health Ontario, OCRC, Toronto Public Health and regional health units is needed so as to identify synergies with their traffic related programming.

NGO’s should be consulted on how best to engage the public through the related program so as to generate ongoing public support that is created from the outset.

Finally, we encourage consultation with trucking associations and related industry to find out what sorts of incentives and penalties will best encourage change. We want the policy to enable and support programs that recognise and reword the proactive companies and identify and penalise the smaller number of offending vehicles, in a way that really encourages positive change.