Canada’s Approach to Compliance Verification for Vehicle and Engine Emission Regulations South American Summit on Vehicle Emissions Compliance Buenos Aires, Argentina September 26, 2018
Purpose To provide an overview of ECCC’s approach for enhancing its compliance verification program for the on- road and off-road vehicle and engine emission regulations under the Canadian Environmental Protection Act, 1999 (CEPA). -2-
Context: Why Regulate Emissions? • The operation of on-road and off-road vehicles and engines is a major source of air pollution in Canada. • Air pollution has a significant negative impact on the environment and the health of Canadians, as well as the Canadian economy. • Greenhouse gas emissions from vehicles and engines are primary contributors to climate change. • To mitigate the above adverse impacts, ECCC has adopted: – air pollutant emission regulations for a broad range of on-road and off-road vehicle and engines – GHG emission regulations for on-road light duty vehicles and heavy-duty vehicles and engines -3-
ECCC’s Responsibility to Promote Compliance with Regulations • Canadians expect the Government of Canada to make laws and regulations to protect society and that laws are effectively enforced. • Parliament stipulated the duty of enforcement directly in CEPA, effectively stating that the Government of Canada shall “apply and enforce this Act in a fair, predictable and consistent manner” . • ECCC is responsible for the administration and enforcement of the vehicle and engine emission regulations made under CEPA. • Compliance and enforcement are essential to: – deliver the anticipated benefits of regulations and to achieving the highest level of environmental quality for all Canadians; and – ensure that persons who circumvent regulatory requirements don’t gain an advantage over competitors making investments to comply. -4-
Historical Approach to Compliance Verification • Historically, ECCC’s compliance verification testing program has focused primarily on: – conducting laboratory tests on a dynamometer using standardized driving or test cycles to verify compliance with applicable emission standards; and – conducting first-order reviews of regulatory information submitted by companies. • The historical approach has: – been effective for identifying evident non-compliances and has influenced numerous notices of defect issued by companies; and – resulted in referrals of cases of suspected non-compliances to ECCC’s Enforcement Branch. -5-
Need for an Enhanced Approach to Compliance Verification? • It is recognized that: – the traditional approach to compliance verification testing may not be sufficient to identify the presence of a sophisticated defeat devices (e.g., cycle-recognition software). – first-order reviews of regulatory information submitted by companies may not uncover false or misleading information . • In light of the recent defeat device issue, ECCC has: – expanded its ongoing collaborative work with the U.S. EPA to assess vehicles/ engines for the potential presence of defeat devices; – increased the volume of test specimens and the specimens are being subjected to additional tests (e.g., PEMS, modified cycles). …. but there are additional opportunities to improve our compliance verification program. -6-
Key Elements of ECCC’s Approach to Enhance Compliance Verification • ECCC’s will continue striving to enhance its compliance verification program for the on-road and off-road vehicle and engine emission regulations under CEPA. • The enhanced approach establishes five broad objectives, whereby ECCC will explore opportunities to: (1) expand data sources and improving data management systems; (2) diversify the types of testing conducted to verify compliance; (3) increase the scrutiny of information submitted by companies (4) expand collaboration with strategic partners; and (5) strengthen the legislative and regulatory frameworks. • The approach may be updated from time to time to continue based on new information and/or priorities. -7-
Expanding Data Sources and Improving Data Management Systems • ECCC will explore opportunities to : – use remote-sensing emission measurement projects as a screening tool to complement its existing compliance verification program – obtain data from the provincially-administered emission testing programs to help identify high emitters or high failures rates . – develop an on-line application allowing consumers to report emission-related complaints relating to their vehicles or engines. – support innovative research by universities and non-government organizations to better understand the potential use of emerging technologies and innovative methodologies that can support compliance and verification strategies. – develop a system to make linkages between all available sources of information to help identify vehicles or engines with higher risk of for non-compliance -8-
Diversifying the Types of Emission Testing to Verify Compliance • ECCC will explore opportunities to diversify the types of tests used to verify compliance with emission regulations, including: – Portable Emissions Monitoring Systems (PEMS) – Non-Standard Test Cycles – Expanded Durability Testing – Emissions Testing Relating to Air Conditioning – Permeability Testing – Data Logging – Adjustable Parameters Testing – Power Take-Off Testing – Load Bank Testing – Not to Exceed (NTE) Testing -9-
Increasing the Scrutiny of Information Submitted by Companies • ECCC will explore opportunities to independently verify elements of information submitted by companies that can impact compliance, including: – sales numbers used in fleet average emission calculations – vehicle attributes used to classify vehicles (e.g., footprint, approach angle, break-over angle, departure angle, running clearance, or axle clearances – road load used to establish dynamometer settings (i.e., via coast- down testing) – tire rolling resistance coefficients – emission control system specifications (e.g., composition of precious metals or active materials in the catalytic converters) -10-
Expanding Collaboration with Strategic Partners • ECCC will explore opportunities to expand collaboration with strategic partners, including: – ECCC’s Enforcement Branch – Canadian Border Services Agency – Transport Canada – Canadian Provinces and Territories – U.S. EPA and the California Air Resources Board – Global Regulators – Non-Government Organizations (e.g., ENGOs, Academia) -11-
Strengthening the Legislative and Regulatory Frameworks • ECCC will explore opportunities to strengthen the legislative framework under CEPA: – A Parliamentary Committee review of CEPA was completed in 2017 and the Committee made recommendations to strengthen the legislation – The Government plans to proceed with reforms the Act and the Committee’s recommendations will inform its work in this regard. • ECCC will also consider potential regulatory amendments, if warranted: – review lessons learned in the course of enforcement-related activities – identify potential regulatory amendments or best practices that may address any gaps or challenges experienced -12-
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