The clean air we breathe in…

The clean air we breathe in Ontario is taken for granted every day. The Ontario Drive Clean Emission testing program ensures all heavy duty diesel vehicles pass below set limits and protect our climate and our health.

The Ontario Drive Clean Program sets the bar high as a benchmark for how a properly well organized emissions testing program should operate. The de-centralized drive clean program ensures vehicle owners with have their emissions inspection performed at a low cost and in a timely manor. Time is money for both the vehicle owner and the Drive Clean facility. Most heavy duty diesel emissions tests only take less than 20 minutes to complete from start to finish. The quick turn around time benefits both the vehicle owner and the Drive Clean Facility.

The Ontario government realizes that any new proposed emissions testing program needs to be just as good as the program it is replacing or better. The current Drive Clean Program delivers the best possible service to vehicle owners and facilities. Vehicle owners can choose from having their emissions inspections performed mobile on-site or they can visit a stationery Drive Clean facility. Most fleets of more than a few vehicle opt for mobile service as it could be much more cost effective than a stationary facility. The government must realize that If multiple vehicles are being inspected at the same time an On-site mobile emissions testing facility's would actually have less CO2 emissions associated with the testing, as the vehicles are not driven any distance to have the testing performed thus protecting our heath and climate even more.

I will answer to proposed changes to Drive clean one at a time.
1) (Proposed Integrated Vehicle Safety and Emissions Inspection Program
In addition, the government is aiming to propose regulatory amendments to integrate the new enhanced emissions testing program with the Ministry of Transportation’s (MTO) existing motor vehicle safety inspection program in 2021. Under the integrated program, which will be administered by MTO, owners of heavy diesel commercial motor vehicles would be able to get an emissions and safety inspection at the same time and location — one test, with one digital result.)

Answer; The MOE should be the only government agency to administer an emissions testing program in Ontario as they deal with environmental issue exclusively. The Ontario MOE has the people and the resources required to ensure our health and climate is protected day after day. By taking Drive Clean away from the MOE and having it administered by MTO this will put our health and climate at risk. The province of Ontario will loose all the knowledge and resources that the MOE has to offer. Emissions testing in Ontario should absolutely only be administered by the MOE ministry of environment, climate change and parks. Vehicle safety inspections should absolutely only be administered by MTO.

Answer; This new proposed "Integrated Vehicle Safety and Emissions Inspection Program" may sound good on paper but it will not be viable as a replacement for our current Drive Clean program. The government fails to see that the safety inspection "yellow sticker" and the Drive Clean emissions test have nothing to do with each other. The frequency of the annual safety inspection and the Drive Clean test that do not coincide with each other. The annual safety inspection is performed once a year at the vehicle owners discretion, usually when it suits them best. The Emissions test is done at time of plate renewal. Trucks may require a safety inspection in the winter but only renew their plates in the summer when their Drive clean test would be due. It will be absolutely impossible for the government to implement an integrated safety and emissions test program that will be as successful as our current program. Our current two different programs are cost effective and work just fine as they are. There will be absolutely no benefit in an integrated program. The government has promised to keep more money in the pockets of taxpayers and needs to make the right decision to not integrate the two programs.

I understand the the MTO would like to modernized the safety inspection program and move to a digital safety inspection. This would ensure an extra layer of compliance with current shops/garages that perform this work. The MTO can accomplish this without integrating the two programs. There are about 20,000 shops/garages in Ontario that are certified to preform 310T safety inspections “yellow sticker” I do not think it is fair for the government of Ontario to sneak in these proposed changes without consulting with safety inspection providers and other stakeholders to see whist they think about the changes. Forcing all shops/garages to purchase expensive equipment should not be done in secret. The taxpayers of Ontario deserve safety and emissions programs that are well respected and are held in high regard from both stakeholders and the general public. I have spoke with over 50 shops/garages/truck dealers/large private companies and not one is in favor of these proposed changes to the integrated safety inspection/ emissions testing program. There will be a huge backlash from affect stakeholders if these un-welcomed proposed changes come to light.

Here are some of the many examples of how the proposed changes will not work for Ontario taxpayers and stakeholders;

Example#1 a landscape seasonal company will have their safety inspection performed in the winter time as the vehicle is not in use and there is no downtime associated with the safety inspection. That same company would not renew their license plate sticker for a year at a time, they would only renew it quarterly and let it laps in the winter. There would never be a time when they would need both a safety inspection and an emissions test at the same time.

Example#2 A MTO/MOE officer sees a smoking vehicle and issues an order to have and emissions test performed, that vehicles safety inspection is still valid and would cost hundred of dollars to have performed again out of frequency.

Example#3 During the year a vehicle owner may decide to change the vehicles registered weight on the ownership for any reason, the vehicle would need an emissions test in order to do so, however the safety inspection is still valid and would cost hundred of dollars to have performed again out of frequency.

Example#4 in July of 2021 when proposed changes come into effect, all vehicle owners would be out of sink with the new changes and for more than 12 months vehicle owners would need to perform multiple safety inspections at a huge cost to both time and money.

Example#5 It is unlawful to perform vehicle safety inspection "yellow sticker" mobile. These vehicle safety inspection "yellow sticker" must only be performed at the location/address of witch the business is registered. This will eliminate the option of having emissions tests performed on-site. The government is fully aware that almost all of the emissions inspections are performed on-site by mobile Drive Clean facilities. These facilities also do not have a 310T mechanic on staff. So all of these facilities would have to shut down as they will not be able to perform safeties mobile or otherwise. The proposed changes will cost the vehicle owners more money and time to have the same inspections performed as it costs now. The new proposed program must be better, faster, cheaper and well respected than our current two different programs but it will not be. It will cost more to vehicle owners, it will take longer costing more valuable time, it will not be respected.

Example#6 Most Drive Clean facility have been in business for over 20 years and have extensive knowledge of emissions system and how to properly perform emissions inspections. The new proposed changes would hurt the trucking industry in a way it would never recover from. Ontario needs to keep its current emissions inspectors and the valuable knowledge that inspectors have gained with our current program.

Example#7 If the government allows for mobile on-site Integrated Vehicle Safety and Emissions Inspections it will put the public at risk, our roads will be less safe. A heavy duty diesel vehicle should never be taken apart for a safety inspection unless it is being done in a proper shop/garage.

Example#8 Current Drive clean facility do not employ 310T mechanics to perform emissions inspections. 310T certification is required to perform safety inspection. The government is proposing changes in july of 2021 but it would take current drive clean inspectors till the year of 2023/2024 to obtain the 310t certification. The 310T certification consists of 6,000 hours on-the-job and an additional 720 hours of in school training,total of 6720 hours The government is proposing changes that are unrealistic to the current Drive clean facilities and making participation in the new proposed program impossible.

Example#9 The proposed changes would require current Drive clean facility's to terminate current employees/inspectors who do not hold a 310T certification and hire 310T certified inspectors. The government is also well aware that there is a shortage of 310T mechanics and Drive Clean facility's will suffer as a result of the proposed changes to Drive clean integrated safety and emissions testing program.

Example#10 The OTA and other stakeholders have long said that they want emissions inspections performed quickly with as little vehicle downtime as possible. The proposed changes will add untold amounts valuable time and cost vehicle owners more money that if the program was to stay as it is. Time is money for both vehicle owners and Drive Clean facilities.

1)Clarify that on-road emission standards apply to all motor vehicles on Ontario's highways, including out-of-province vehicles.
Answer; Yes any vehicle in the province of Ontario must comply with our rules. Out-of-province Canadian vehicles are more at risk of polluting as they do not have to pass and annual emissions inspection

2) (.Ensure a vehicle’s originally installed emission control systems are present and operating as intended, by clarifying existing laws that prohibit emission system tampering.)
Answer; Yes all originally installed emission control systems must be are present and operating as intended., this will ensure our air, health and climate will be protected and it will also ensure a level playing field for all trucking companies .
However there are some major engine manufactures that have been sued and lost in Ontario court and other courts for providing emission control systems that do not function properly or operate as intended. In the year 2007 the government/EPA implemented much stricter emission compliance from engine manufactures. Most engine manufactures did not have the access to the required technology to build an emissions control system that would operate for extended periods of time as intended. The emissions control system is designed to last the life of the engine. In most cases the emissions control systems from a 2007-2011 year engine only last 8 months. These systems cost thousands of dollars to repair and add huge amounts of downtime to the vehicle. In most cases the vehicle has to be towed to the engine dealer to be repaired. This was well know by engine manufactures who continued to sell their products after knowing there were extensive problems thus committing fraud. The courts have deemed these engines/emissions systems “defective” as they do not function as indented and have rendered the vehicles “unmerchantable ” and “Not-fit-for commercial use”.Most of these defective emissions control vehicles are the ones that are tampered with using delete kits> It is estimated that there are some 10,000 heavy duty diesel vehicles that have tampered emissions controls. It is now the governments duty to protect taxpayers and force engine manufactures to recall these emissions control systems and redesign them to work as intended, so far nothing has been done. It is estimated that some 20,000 vehicles are affected by this fraud in Ontario alone. Most of the tampering/delete kits are performed on these “defective” engines. It is well known that a complete emissions control system on a 2007-2011 vehicle costs around $15,000 and 2012-present costs around $25,000 to repair. In Ontario alone it will cost over $160,000,000 to repair these vehicles and bring them back into compliance. The fraudulent engine manufactures stand to make a profit from these repairs while forcing the vehicle owner to pay for the repairs or go bankrupt trying to fix their trucks and subsequently keep them on the road. This is what happens when governments force unrealistic emissions compliance on engine manufactures. The Ontario government must address this issue by either forcing OEM manufactures to recall defective trucks or allow the implementation of aftermarket technology that reduces emissions and fuel consumption by way of Hydrogen enhanced combustion.It has been proven that older diesel engines from the early 2000's (equal to a tampered /deleted truck) when equipped with dynacert hydragen have lower emissions than those of a 2011 truck with functioning emissions controls.

3) (Clarify existing requirements related to emissions control defeat devices and introducing a new prohibition for the sale of such devices.)
Answer; Emissions control defeat devices are something that are installed from the vehicle manufactures factory. However there are shops, garages and even OEM engine dealers that will tamper with and or install emissions delete kits. These shops/garages should be fully investigated and charged to the fullest extent of the law. If found guilty they should be made to do a project to off-set the impact to the environment and our climate.

4) (Tighten the visible emissions prohibition from fifteen (15) seconds in five minutes to five (5) seconds in a one-minute period.)
Answer; This new rule will be impossible to distinguish the difference from a vehicle that is preforming a “re-gen” or a vehicle that is smoking to much and polluting.. 2007 newer trucks have a DPF diesel particulate filter that captures fine particulates and once full the truck doses the exhaust with fuel and the re-gen process turns harmful particulates in ash from the DPF filter. This process can be done while the vehicle is in motion without the drivers knowledge. During the re-gen the vehicle will be contrary to the new proposed changes as plums of smoke will exit the exhaust stacks. How will and MTO/MOE officer distinguish between a vehicle operating as intended or a gross polluting vehicle?

5) (Tighten the current opacity standard for 2008 and newer heavy diesel vehicles to 20% from 30%. The new threshold is more appropriate for newer vehicles which were manufactured with emission systems designed to minimize smoke and soot from the diesel engine.)
Answer; Yes the new changes from 30% to 20% will help ensure Ontario has clean air. However there should still be a new lower limit (5%-10%) in place to be uses as a incentive to encourage good vehicle maintenance and give owners of clean vehicles a skip a year option.

6) (.The requirement to pass a mandatory computer-based electronic emissions diagnostic test to ensure emission control systems are operating as intended for heavy diesel commercial motor vehicles that have a registered gross weight of between 4,500 kgs and 6,350 kgs.)
Answer; Yes This is very important for all vehicles to pass an opacity test and an OBD test as well . However the current Otu Ontario test unit is unable to determine if a vehicles emissions controls readiness monitors are operating as intended . This was aperient in the light duty program when a tampered vehicle’s readiness monitors were all set to “Not applicable” the Ontario test unit would issue a “pass”.

7) (Elimination of the exemption for diesel hybrid vehicles.)
Answer; Yes all heavy duty diesel vehicles must pass an emissions test regardless of status.

There are a vast amount of light duty diesel trucks in Ontario that have tampered emissions controls systems and are gross polluting vehicles. These vehicles are no mostly out the the mandatory emissions testing program as they has RGW under 4500kg. What is the government doing to address this huge problem other than hoping to catch a vehicle at a roadside stop. These gross polluting vehicles emit huge clouds of black smoke and cause more damage than to the environment than heavy duty diesel vehicles. It was estimates that Ontario alone had over 5000 of these tampered vehicles licensed in this province.

Based on the news and recent events in the media I believe the government is working closely with the OTA Ontario Truckers Association and favoring their input and not listing to other major stakeholders who actually have the Drive Clean programs best interests in mind. The OTA does not run the government. It is comprised of owners of large trucking companies and have profits in mind not the heath of our climate or our air. The OTA membership is dwindling as more and more trucking companies leave the OTA for good and search for new trucking associations that actually care about helping smaller trucking companies. I believe that all the proposed integrated safety and emissions testing program changes are tailored to the OTA’s exact specifications and this is unacceptable if found to be true. I could not find one trucking company in Ottawa Ontario that is still a member of the OTA. It is the belief of many that large trucking fleets that make up the OTA membership stand to make a fortune on the new proposed changes to Drive clean as smaller trucking companies will find it much harder to compete. Any new proposed changes should be well accepted by all taxpayers not just a select few.

Many if not all past and current Drive clean facility's feel that the Parsons supplied emissions testing equipment was poorly build using the cheapest of components. The equipment lacks the simplest of mandatory features like; OBD unable to connect to most vehicles with J1939 type2 (green connector). Some vehicles abort emissions test if obd is connected. Equipment was sold without the J1708 6-pin connector and took over 4 years to convince them to offer this simple device that was always in the governments best interest to have. Thousands of official Drive Clean tests were and still are performed without being connected to the vehicles OBD computer. Mountains of import data was not collected by the province. The optical rpm device is completely out dated was the lest effective rpm device to choose from. The vibration rpm device should have been offered instead as it works every time properly.

The Diesetune DX270/DX240 Smoke meter has an operating range of –15c to +30 or more. It is capable of being used in all weather including rain, fog, snow ect.... The Drive clean program must now take the heath of its Drive clean inspectors and bystanders more seriously and allow testing to be performed within the actual specs of the equipment. Dieseltune created its DX270/DX240 with outdoor emissions testing in mind. Constantly being exposed to indoor emissions testing is very unhealthy for all party's involved. Please review the actual Dieseltune DX270/DX240 specifications and implemented them as soon as possible.

The mandatory maintenance plan was and still is a complete rip-off to Drive Clean facility's, It offers no value at all to facility's and in most cases the facility them selves are the ones preforming to repair work not a on-site service technician, for the type of money it costs Drive clean facility's all service work should be done by an on-site parsons certified repair person. Mobile Drive clean facility's have no choice but to pay $350.50 a month plus tax every single month for the term of the contract. This has cost hard working facility's $37968.00 per facility. This amount of money to maintain a $15,000 machine is unacceptable and wrong for the government do nothing. There must be more oversight and must be more options for Drive clean facility's. The profit margin on the maintenance plan is still unknown but based on my three (3) Mobile Drive clean facility's we paid $100800.00 and have not received 1/4 of that amount in actual service/repair parts. Parsons time after time would supply facility's with defective replacement parts and suffering Drive clean facility's have absolutely no recourse. Parsons would often say parts had to much wear-and- tear and were no longer covered by the mandatory plan, Parsons would gladly sell facility's new parts at a huge markup as facility's had no choice but to buy off the shelf parts only from parsons. Never have I seen such a one sided, completely unjustifiable maintenance plan that probably had a 75% profit margin. If new equipment is to offered the maintenance plan if any should be on a per test basis. It should be carefully reviewed and brought before a fairness commissioner to ensue what has happened from 2013-present is never repeated.

Here is just a few of the hundreds of class action law suits against engine manufactures. This problem is real and if not corrected in a reasonable fashion it will bring Ontario's trucking industry to grinding halt along with our economy. The world runs on diesel powered vehicles Ontario is no different.
1) https://www.ccjdigital.com/caterpillar-settles-engine-lawsuit-for-60m-t…

2) https://www.classactionsreporter.com/consumer/paccar-kenworth-peterbilt…

3) 2 Billion dollar law suit
https://www.thetruckersreport.com/navistar-may-opened-2-billion-potenti…

4) https://www.classlawgroup.com/volvo-trucks-faulty-emission-control-laws…

5) https://www.todaystrucking.com/trucking-companies-file-class-action-sui…

6) https://www.capitalremanexchange.com/cummins-sued-over-faulty-emission-…

7) https://www.epa.gov/enforcement/detroit-diesel-corporation-diesel-engin…

8) https://www.google.ca/amp/s/www.theverge.com/platform/amp/2019/9/24/208…

9) https://www.caranddriver.com/news/a15064420/ford-faces-4-2-billion-laws…

10) https://www.google.ca/amp/s/www.nytimes.com/2017/05/25/business/energy-…

The Ontario government needs to realize that performing OBD only tests on vehicles with a GVWR more that 11000kg will not work like OBD tests on smaller trucks 4500-6500KG. Large vehicles are not equipped with "readiness monitors" and stored MIL can be merely cleared and only once the vehicle is driven will the CEL or MIL come back on. The only way to perform an OBD only emissions test on large trucks will have to be done remotely. Remote OBD testing will ensure there are no stored code and CEL or MIL is not activated while the vehicle is in motion.