Zero Emissions Vehicle (ZEV) 2023 Consultation
303 actions
goal: 500
There are three ways to submit a comment to the public consultation on Zero Emission Vehicles (ZEV) regulations:
Just
click "send"
on the pre-written comment to the right (quickest, but lowest impact).
Re-write the emailed comment with your own words
for added impact. You can use the
C
limate Messengers one-page guide linked here for talking points
, or you can use this
more detailed guide
if you've got a bit more time and want to go deeper.
Submit direct to the consultation comment forms. This is a more involved process, but our understanding is that it gives your comment the most weight. Climate Messengers has put together a step-by-step toolkit for doing this,
which can be found here: https://climatemessengers.ca/2023-draft-zev-regulations/
Whichever method you choose, you're helping to ensure that climate justice is considered in this consultation - thank you!
Send an email comment
Subject
Hello, I am writing today to submit a comment on the Zero Emission Vehicle (ZEV) draft regulations as identified in the Canada Gazette, Part 1, Volume 156, number 53, as per the notice posted on December 31st, 2022. The proposed regulations are a great start, and would be a substantial step forward towards achieving Canada's climate action obligations. The evidence is clear that manufacturer mandates drive much stronger action than consumer incentives (though both are worthwhile). In Canada, most ZEVs are sold in Quebec and BC - the provinces that already have mandates. And half of Canadians have already said they want their next vehicle to be a ZEV, but manufacturers are dragging their heels at delivering the supply to meet that demand. Mandates on sales would address this issue, and I am grateful the government is proposing these. It's also vital that the mandates come with teeth, and I am pleased to see that these regulations include real fines for manufacturers who fail to meet the quotas. $20,000 per missed sale, indexed to inflation, is an excellent way to ensure that automakers are properly focused on delivering on their share of the responsibility for transitioning away from carbon. That said, the regulations could still be improved by picking up the pace on the quota increases. BC and Quebec both have faster increases in quota requirements than these federal regulations, and cars and trucks stay on the road for an average of fifteen years - meaning new combustion cars sold in 2035 will still be in service in 2050. We must move faster, and I would like to see the quotas increase at a faster rate, to match the BC and Quebec levels at least. In addition, the compliance flexibility mechanism allows automakers to miss their quotas for three years and then apply credits from later years retroactively. This incentivizes automakers to push for extra combustion sales now, to maximize their profits, and then make up the difference later, when profit margins between ZEV and combustion vehicles have narrowed. This is a loophole that does not exist in the Quebec regulations, for example, for this very reason, and it should be eliminated. The bottom line is that these draft regulations are an essential step forward for climate action, and it is imperative that the final regulations remain at least as strong, if not stronger, in delivering on that promise. Thank you for consulting with the public and considering my submission, and thank you for your work to advance climate action through this regulation.
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