B.C. Zero-Emission Vehicles Act and Regulation: 2022 Formal Review Intentions Paper

September 27, 2022

Attn: ZEV Act Team
Mary Storzer
Clean Transportation Branch PO BOX 9314 Stn Prov Govt Victoria, B.C. V8W 9N1

Dear ZEV Act Team,

Thank you for the opportunity to comment on the B.C. Zero-Emission Vehicles Act and Regulation: 2022 Formal Review Intentions Paper, relating to the BC Zero Emissions Vehicle Act and Regulation as it pertains to Light Duty Vehicles.

While the sales and forecast of Light Duty ZEV vehicle adoption is exceeding expectations, we urge further consideration and consultations with stakeholders on any proposed legislation or regulations relating to heavy duty vehicles, especially class 7 and 8 vehicles as their characteristics are unique compared to other classes.

We recommend that in any future mandates for heavy duty vehicles, B.C. incorporate some flexibility for the inclusion of a new class of vehicles, “Low Emission Vehicles” (LEVs), where the choice of ZEV vehicles are not yet commercially available, or are limited for the duty cycles now serviced by diesel engines. For example, in California the introduction of the Optional Low NOx Standard allows natural gas vehicles to participate in low emission truck replacement funding programs along with battery electric and fuel cell electric trucks. We feel that hydrogen combustion technologies could play a similar role in ZEV programs in B.C.

A Made in BC Approach is Needed for Class 8 Heavy Duty Trucks

Section 2.1 references sales targets for LD vehicles and the desire to align with targets in California and Quebec, and while this may work well for LD duty vehicles, this may not be appropriate for Class 7 and 8 vehicles in B.C. The power and hauling requirements needed to move heavy loads (140,000 lbs, or 63,500 kg) over mountainous terrains may not be reflected in the models available by OEMs which typically make products for the lower weight requirements (80,000 lbs or ~36, 280 lbs) in the United States. For example, many of the ZEV models available in California are targeted towards drayage trucks which typically haul lighter loads short distances..

B.C. requires flexibility in the types of vehicles permitted under the mandate to ensure that there are options for fleets that haul the heaviest loads. We strongly recommend that in the development of any HD sales mandates, consideration is given to include flexibility for LEV technologies as an option to meet the needs of fleets, and that any timelines for 100% ZEV sales targets, especially for the heaviest class 8 HDVs, reflect the availability of models (LEVs or ZEVs) that meet Canadian specific duty requirements.

Credit Frameworks Should Include a Wider Range of Technologies for Class 8 Heavy Duty Trucks

In considering how the credit frameworks will be set up for HDVs, we recommend that there is accommodation for a wider range of technologies including hydrogen combustion technologies alongside BEVs and FCEVs to qualify.

Vehicle Range Requirements Should Reflect Duty Cycles of Fleets

We recommend that in setting ranges for HDVs, that consultations with fleets, OEMs, technology developers and smaller suppliers take place to ensure that the ranges for vehicles are validated with fleet duty cycles and operational requirements and the capabilities of available technologies.

Thank you for your consideration, Hydra world be pleased to engage in further consultations on the development of HDV ZEV mandates or regulations.

We welcome further questions or discussion on our submission.

Sincerely,

Laura Guzman
Director Government Relations