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The Pembina Institute welcomes the opportunity to share our views on the government’s recent proposal to redesign heavy duty vehicle (HDV) emissions testing program and strengthen on road enforcement of emissions standards. 

We are pleased to see the government move to address heavy duty vehicle emissions as a means to improve the health and safety of Ontario’s communities. The policy actions proposed by the province are, broadly speaking, positive steps toward combatting the ecological, health, and safety impacts of heavy duty vehicle emissions. We support the province in targeting the use of delete kits through on board diagnostic monitoring and on road spot checks, as these kits have become increasingly popular and sophisticated in recent years. We recommend these new measures be bundled into existing vehicle testing programs to mitigate the economic and operational costs to vehicle operators. Taken as a whole, these steps will ensure a level playing field for the province’s freight operators while laying the foundation for a cleaner freight industry as drivetrain technology and energy infrastructure evolves in the medium to long term.

We encourage the government to align these efforts with its commitment to develop a new, credible climate plan that addresses the biggest pollution sources in Ontario, and establish an Emissions Reduction Fund to support this effort. We recommend that the province consider building on the present policy proposal to integrate even stronger action to combat pollution from freight and support the sector in becoming more efficient. A fuel efficiency requirement for existing fleets is one such option.