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Executive Summary & Introduction

  • Executive Summary
  • Introduction

I. REASONS TO KEEP THE ZEV REGS

  • A. Canada, and the World, Must Cut GHG Emissions
  • B. Ceasing to Burn Fossil Fuels for Transport is Absolutely Necessary
  • C. Burning Fossil Fuels, Including to Power Light Duty Vehicles, Is a Health Hazard
  • D. The Automakers Will Not Transition to ZEVs Unless They Are Forced to Do So
  • E. The Automakers Have Met 2024 and Earlier Sales Quotas in Canada and Other Jurisdictions
  • F. The Automakers Will Still Make Profits With a 100% ZEV Sales Quota
  • G. Canada’s 20% Sales Quota for 2026 Could Be Achieved If Not Hindered by Changes in Government Policy
  • H. Canada’s 20% Sales Quota for 2026 Could Be Achieved But for the Automakers’ Intransigence
  • I. Canadian ZEV Sales Are Depressed By Limited Selection
  • J. The ZEV Regs Already Have “Compliance Flexibility” to Help Automakers
  • K. ZEV sales mandates work, and they work in Canada

II. SUGGESTIONS FOR IMPROVING OR "FIXING" THE ZEV REGS

  • A. The 2035 sales quota requiring that 100% of light duty vehicles be ZEVs must be maintained
  • B. Maintain the 2027 and future sales quotas as they are currently set, but let the automakers earn credits for the ZEVs they sell in 2026
  • C. Provide extra credit for selling ZEVs at a price below $40,000 CDN

III. SUGGESTIONS FOR COMPLEMENTARY POLICIES TO ASSIST THE ZEV REGS

  • A. SUGGESTIONS FOR COMPLEMENTARY POLICIES TO ASSIST THE ZEV REGS
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A. The 2035 sales quota requiring that 100% of light duty vehicles be ZEVs must be maintained

It is vital that the government maintain the final sales quota in the ZEV Regs that requires 100% of new light duty vehicle sales be ZEVs in 2035 and each year thereafter. In the RIAS for the ZEV Regs, Environment and Climate Change Canada states light duty vehicles have an estimated life expectancy of 15 years.1 At the Paris Agreement in 2015, Canada, along with most of the rest of the countries of the world, committed to achieving net-zero emissions by 2050. Canada subsequently enacted this as domestic law in the Canadian Net-Zero Emissions Accountability Act.2 If Canada permits the sale of any light duty ICE vehicles in 2035 or thereafter, those ICE vehicles will still be emitting GHGs in 2050. There is no viable Carbon Capture Utilization and Storage (CCUS) system for light duty vehicles.

✉️ Make Your Submission!

1 RIAS, pp. 4043-4044. Canada Gazette Part II, Vol.157, No. 26. 20 December 2024. Retrieved on 14 September 2025 from https://gazette.gc.ca/rp-pr/publications-eng.html#a2

2 Canadian Net-Zero Emissions Accountability Act, (S.C. 2021, c. 22), s. 6. Retrieved on 28 September 2025 from https://laws-lois.justice.gc.ca/eng/acts/c-19.3/fulltext.html

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