The Province of BC has set emission reduction targets for the transportation sector of 27-32% below 2007 levels by 2030. In October 2021, the CleanBC Roadmap to 2030 was released, which committed to several policies to help reach these targets. This included a commitment to establish regulated zero-emission vehicle (ZEV) requirements for medium- and heavy-duty (MHD) vehicles in line with California and other leading jurisdictions.  The Ministry of Energy, Mines and Low Carbon Innovation recently released proposed elements of the MHD ZEV regulated requirements that are under consideration and are seeking input on the proposals by June 27, 2023.

BCTA will be pushing back on the provincial government’s  BC Medium- and Heavy-Duty Zero-Emission Vehicles: 2023 Consultation Paper, on the basis that it is void of any facts or recognition of BC’s transportation sector realities.

BCTA’s Position

BCTA strongly supports a commercial transportation ZEV mandate for BC. In fact, BCTA has been calling on the Province to establish a zero- and low-emission vehicle mandate for MHD vehicles for over a year, along with other measures to help foster a cleaner, more sustainable transportation sector. The development of these measures must be prioritized to address the climate emergency.

The proposed ZEV mandate outlined in the Province’s consultation paper includes the following:

• Sales targets for vehicles classes 3-8 that mandates a percentage ZEV sales requirement by vehicle class, effective January 1, 2026, which become increasingly more stringent until 2036 in which all class 3-8 vehicles sales must be zero emission;
• ZEV requirements for transportation refrigeration units (TRU), which requires carriers to convert diesel TRU to electric starting January 1, 2026, with the requirement that all reefers are converted to electric by 2030; and
• A phase-out period of fossil fuel powered forklifts starting January 1, 2028, with the requirement that all fossil fuel powered forklifts be phased to zero emission forklifts by 2038.

While BCTA supports the provincial emission reduction targets for the transportation sector, we are very concerned that because the mandate outlined in this consultation paper is so unachievable, it will further harm our sector’s ability to meet its emission reduction targets and hinder our collective fight against climate change. Specifically:

1. Implementing a proposed ZEV sales mandate when 78.5% of our sector has no market ready ZEV option (due to duty cycle and/or at Canadian weights) will force carriers to operate their existing diesel vehicles for longer. This will increase pressure on the used diesel vehicle market, and/or force carriers to relocate their terminals to a neighbouring jurisdiction that does not have a restrictive, unrealistic ZEV mandate.
2. Implementing a TRU mandate will force those carriers that operate in BC to relocate to neighbouring jurisdictions as zero emission TRU’s do not exist for commercial trailers or straight trucks with a box greater than 28 feet. This will lead to increased kilometers driven and increased transportation costs which gets passed onto consumers.

Real-world Limitations

As previously communicated to the Province in our countless submissions and meetings with government officials, the only MHD zero-emission vehicles that are currently market-ready are battery electric vehicles with real-world, all-weather demonstrated range of approximately 300-400 km.  BCTA coordinated a tour at PACCAR Technical Centre as well as a Low- and Zero-Emission Commercial Vehicle Summit last November, where government officials got to see, touch, and experience market-ready zero-emission vehicles up close to get a comprehensive understanding. We remain hopeful that hydrogen fuel cell hybrid vehicles will enter the market with ranges of up to 700 - 800 km, but these units remain in their infant stage of development.

Further, all current ZEV heavy duty vehicles, regardless of fuel, are at present engineered to US weight standards which have a maximum gross vehicle weight rating (GVWR) of 36,500 kg. This is far less than the current provincial GVWR of 63,500 kg, which provides Canadian tractor-trailer configurations a 22% advantage over the average US tractor-trailer combination in both the amount of fuel consumed and greenhouse gases (GHG) emitted. Specifically, in the US, 6.2 kg of carbon dioxide (CO2) is created to move one tonne of payload 100 miles, whereas in Canada, only 5.1 kg of CO2 is created. If the Province brings the proposed ZEV mandate into force, vehicles will be limited at US weights and will require additional vehicles on the road to move the up-to 27,000 kg capacity that is lost from the Canadian advantage. This is a serious issue discussed further below, but in terms of freight capacity the difference is stark. GVWR less tractor weight yields s cargo capacity of approximately 27,000 kg. The effective difference in freight capacity means that ZEV vehicles in BC will be able to move effectively HALF the weight of conventional trucks (using US weights versus Canadian weights, including greater tare weights for ZEV vehicles which can be north of 5,000 kg in additional weight over its diesel equivalent, less maximum weight allowances).

While not every truck moves at maximum weights, this limitation ultimately means using current technology AND technology being developed (as not one manufacturer has a market ready ZEV at Canadian weights), our industry will need to double their fleet size to move the freight we currently do, AND require a commensurate number of drivers. This will result in increased congestion on our roadways and associated safety issues that comes with increased congestion, as well as a significant increase in transportation costs which gets passed onto consumers across the 92% of the consumer goods our sector transports.       

The bottom line is that only 20.5% of the commercial goods movement sector can transition to these vehicles, leaving the remaining 79.5% of the sector without a zero-emission option. These carriers will be forced to run older diesel trucks for longer, buy used diesel trucks, or move to neighboring jurisdictions that have an unworkable ZEV mandate.

Beyond the concerns raised above, the ZEV mandate will result in new trucks sales being restricted in the Province, as they will being driven by the numerator, not the denominator. For example, if an OEM can only sell 15 class 8 zero-emission trucks, it can therefore only sell 150 diesel trucks in 2026 (15 zero-emission class 8 trucks divided by 10% sales mandate, excluding the weight class modifier), 100 diesel trucks in 2027, 75 in 2028, 60 in 2029, and so on. Restricting sales when most of the industry has no ZEV alternatives, leaves carriers with very few options.

Recommendations

As previously stated, BCTA is very supportive of establishing a ZEV mandate for MHD commercial vehicles. However, the mandate needs to:

• Be established in collaboration with carriers, OEMs, and governments based on available, market ready technology (and adjusted over time as new technology becomes available),
• Take into consideration the operational realities of British Columbia’s MHD commercial transportation sector (e.g., range, topography, and weights), and
• Be implemented after a comprehensive infrastructure plan has been developed to expedite the construction of alternative refueling stations (e.g., hydrogen) and charging stations at appropriate locations. With 94% of our sector operating 10 or less trucks, having access to available charging and refueling stations is critical to the adoption of low and zero-emission vehicles. Simply put, until an extensive network of charging and alternative refueling stations is established, MHD ZEV deployment will lag, consistent with the adoption of light duty ZEV.

BCTA will also be calling on the Province to do more with the tools it already has to make a significant reduction in MHD transportation emissions. Our recommendations include:

• Charging & Refueling Stations: The Province works with BCTA to expedite the establishment of alternative refueling stations (e.g., hydrogen) and charging stations at appropriate locations. If the Province is serious about climate change and establishing a zero-emission vehicle mandate, this work must be prioritized.
• Accelerate Turnover: The Province works with BCTA to identify mechanisms to help accelerate the turnover over MHD commercial vehicles. Examples include providing PST credit/exemption, similar to the one provided for Production Machinery and Equipment for MY 2020 and newer heavy-duty trucks, or extending the SCRAP-IT Program to MHD commercial vehicles with increased rebates for the purchase of low- and zero emitting vehicles. 
• Idle Management Mandate: The Province acts on BCTA’s recommendation, in an expeditious manner, to mandate a province wide idle management mandate on HD commercial vehicles. On average, HD commercial vehicles idle for 1,800 hours per year, and as a result burn approximately 7,200 litres of diesel and emit roughly 18,720 kg of carbon dioxide emissions per year for each vehicle— equivalent to four passenger vehicles per truck each year. Proven, market available technology such as electric auxiliary power units, cab heaters and coolers, exist today that can reduce commercial idling emissions to nearly zero.
• LCV Road Network: The Province acts on BCTA’s recommendation to establish a British Columbia to Alberta long combination vehicle (LCV) road network and establish designated commercial rest areas for the coupling and de-coupling of LCVs. They are not only the safest commercial vehicles on the road, but they also have the potential to reduce commercial road transportation GHG emissions by up to 41% compared to two individual tractor-trailers moving the same amount of cargo.

While not all bad, BCTA believes the proposed forklift ZEV mandate proposed in the Consultation Paper is achievable and should be adopted. Unlike class 3-8 ZEVs, ZEV forklifts are market ready with significant adoption across the transportation and warehouse sector — so much so, that the Province stopped providing incentives on the purchase of zero emission/electric forklifts through its Specialty Use Vehicle Incentive Program in 2020 due to significant market utilization. 

For More Information

The consultation paper is available to technical stakeholders to review and provide input on by June 27, 2023.  Your input will be used to inform the development of the MHD ZEV legislation in BC. We encourage all members to provide your written input to the Ministry of Energy, Mines and Low Carbon Innovation at ZEVRegulation@gov.bc.ca.

If you have any questions about BCTA’s concerns or the proposed MHD ZEV mandate, please contact Cory Paterson, BCTA Vice President.

For the B.C. Medium- and Heavy-Duty Zero-Emission Vehicles: 2023 Consultation Paper, visit the Government of BC’s website.