Standing Committee on Environment and Sustainable Development

Transcription

1 Standing Committee on Environment and Sustainable Development November Dixon Road, Toronto, ON M9W 1H8 Tel: Follow us on and on the internet at Our File: CTA-Submission- Standing Committee on Environment and Sustainable Development

2 Introduction The is a federation of the provincial trucking associations representing over 4,500 trucking companies. The trucking industry s economic goals are aligned with Canada s commitment to reducing greenhouse gases. The Canadian trucking industry is recognized as a world leader in fuel efficiency and conservation. The current Canadian heavy truck fleet is, when payload is considered, 22 per cent more fuel efficient and emits 22 per cent less GHG than the US fleet. The industry wants to transition to lower carbon heavy trucks, trailers and fuel. There is a payback to becoming more fuel-efficient fuel is the second largest component of operating costs. Vitals Trucking is the dominant mode of freight transportation in Canada, moving approximately 90 per cent of all consumer products and foodstuffs and almost twothirds (by value) of Canada s trade with the United States. The industry generates over $65 billion in revenues per year. In terms of GDP, the transportation services sector represents 4.2% of total economic output, or $53 billion. The for-hire trucking sector accounts for 31 per cent of the total share more than air (12%), rail (11%) and marine (2%), combined. As such, trucking is a good leading indicator of economic activity. The trucking industry is responsible for creating over 400,000 direct jobs in Canada approximately 300,000 of which are truck drivers. Nearly 1 per cent of the Canadian population and over 1.5 per cent of the labour force are truck drivers by profession. The for-hire segment of the industry produces roughly $24 billion in personal income on an annual basis, which in turn generates $4.2 billion in personal income taxes and $4.1 billion in indirect taxes for government. Service Trucking is the dominant mode of freight transportation mainly because of the flexible, timely, door-to-door service that only trucks can provide. Trucking works with all the other modes, but its major market is the time-sensitive delivery of small shipments of lighter-weight, high value-added products over relatively short distances. The just-in-time inventory system, which remains a key to Canada s international competitiveness, is built around the truck. Other modes like rail and marine dominate in the movement of heavier, bulkier commodities that are generally less time-sensitive over longer distances. Overall, the three modes could overlap or compete on a very small proportion of the freight market certainly less than 5 per cent. Trucks and the Environment The trucking industry is only freight transportation mode in Canada that uses engines that are regulated to eliminate and reduce both air quality and greenhouse gas emissions. The air quality regulations were tightened in the 2000s, leading to the CTA 1

3 production of what the US Environmental Protection Agency describes as the nearzero-emission engine. Every truck built since 2010 is equipped with these clean, modernized engines. EPA and Environment Canada began regulating heavy truck engines in 2014 to reduce GHGs, specifically. A second phase of the rule comes into force in 2018, when heavy truck engine, tractors and trailers will all fall under the GHG-reduction mandate. The trucking industry is doing its part to improve both urban air quality and fight climate change. Impact of Environmental Regulations on the Trucking Industry There is a financial impact to environmental compliance. Phase 2 of the EPA rule is expected to cost the industry up to $15,000 more per unit, similarly to the premium paid for new equipment to comply with the previous air quality regulations between An ancillary challenge for carriers and their main concern in 2016 is the enduring costs to maintain the equipment due to poorer reliability of these greener vehicles. The volatile reliability was the result of regulators setting emission targets based on technologies still in the developmental stages, forcing acceleration of research and development to where engineering couldn t keep pace. Forcing the introduction of unproven technologies into the market put significant cost burdens on carriers who had to grapple with reoccurring reliability and maintenance issues. In fact, many fleets were forced to add 20-per cent more vehicles to their fleet to cover for the additional vehicle downtime. This is unacceptable and must not continue to worsen under the Phase II rule. Limp Mode & Driver Safety Relatedly, there are several wiring issues associated with the newest environmental equipment. with perhaps the new engine sensors (designed to identify an emissions control component malfunction) drawing arguably the most consternation from carriers. If an engine sensor (or a computer glitch) determines an emissions component malfunction it engages the engine into limp mode. If the sensor warning is not addressed by a qualified technician within a certain window, engine shut-down or depowering is initiated. While limp mode is mandatory under the air quality regulations introduced by Environment Canada and the EPA, it also ends up stranding drivers and vehicles across Canada. This is putting drivers at risk and causing significant disruptions in the supply chain. CTA supports a modified form of limp mode technology. CTA urges the time/range of the limp mode function be extended to allow drivers to reach a safe, cost effective location to have the component repaired if required or sensor reset. This option would also sustain necessary in-cab heating and cooling in the truck cab, rather than shut CTA 2

4 down the engine and pose health risks to the driver. CTA believes that under the Canada Labour Code, Section 124 & 128 (1), the Government of Canada has the responsibility to work with the trucking industry to create a limp mode policy that balances both labour and policy issues. How Has the Industry Responded to Reliability Issues? As mentioned, many fleets were forced to add truck redundancy to their fleet to cope with some of these reliability issues. Others in the larger industry have become so frustrated they have adopted emission control defeat devices into their power units. This tactic typically involves bypassing or deleting the exhaust gas recirculation (EGR) device or the diesel particulate filter (DPF). CTA does not support such devices and has lobbied Ottawa to introduce US-style engine tampering legislation under CEPA, which should be adopted by the provinces as well. The US-Canadian Enforcement Experience Fines for emission control tampering can reach up to six figures in the U.S. under the Clean Air Act. Enforcement of these rules is focused on original equipment manufacturers or OEMs, parts suppliers, and repair shops. Canada has no such legislative approach; enforcement on these issues can be characterized as weak and disjointed. Once the vehicle is sold to the consumer in Canada, CEPA has no authority over that vehicle. Not all provinces have legislation on engine tampering and CTA questions the vigilance of enforcement in jurisdictions that have some sort of rule on the books. This black hole of enforcement in Canada has spawned a rapidly growing underground market (and in some cases, not so underground) for tampering, at the expense of the environment and fair competition. CTA Recommendations (1) That CEPA be amended to allow the Canadian federal government to enforce the same or similar penalties administered under the Clean Air Act for engine tampering. (2) Although it s not ultimately the decision of the Government of Canada, that Transport Canada and Environment Canada assist CTA in championing that a tampering inspection that specifically looks for evidence of EGR/DPF delete be added to the Periodic Motor Vehicle Inspection (PMVI) program and performed annually or semi-annually at private inspection facilities licensed and monitored by Canadian provincial and territorial governments, under the Section 11B of the National Safety Code (Canadian Council of Motor Transport Administrators). (3) Environment Canada must begin working with Transport Canada to establish testing protocols for GHG reduction qualifying technology and supporting wiring systems. There is no doubt Transport Canada is the lead federal department responsible for the motor vehicle safety mandate. This is evidenced by its CTA 3

5 statutory authority under the Motor Vehicle Safety Act. Furthermore, Transport Canada is presently engaged in testing the safety and environmental performance of passenger vehicles and heavy duty trucks through its ecotechnology for Vehicles Program. All qualifying GHG reduction technology and associated wiring must be tested by Transport Canada to ensure all technology imported into Canada meets our safety and climate conditions. (4) In June 2015, the Government of Canada introduced the Safer Vehicles for Canadians Act. The bill proposes new powers which would allow the Minister of Transport to order a company to issue a recall and require manufacturers to fix defective or non-compliant vehicles. The minister could also order manufacturers or importers to pay for repairs and ensure new vehicles perform reliably before they are sold to the public. In addition, manufacturers and importers can face fines of up to $200,000 per violation, per day, with no maximum cap through new administrative monetary penalties. These fines are an alternative to prosecution in order to help address safety issues more quickly. The Canadian government should re-examine the introduction and expansion of the Safer Vehicles for Canadians Act to better protect purchasers of commercial equipment. (5) CTA supports a modified form of limp mode technology. CTA urges the time/range of the limp mode function be extended to allow drivers to reach a safe, cost effective location to have the component repaired if required or sensor reset. For More Information Contact: 555 Dixon Road, Toronto, ON M9W 1H8 Tel: govtaffairs@cantruck.ca Follow us on and on the internet at CTA 4