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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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B. Ceasing to Burn Fossil Fuels for Transport is Absolutely Necessary

The world’s climate change problem is caused overwhelmingly by humanity’s burning of fossil fuels.

An enormous quantity of carbon had been stored in the Earth’s crust. Coal was formed during the Carboniferous Era, from about 359 to 299 million years ago.1 The majority of oil and gas was formed during the Mesozoic Era, between 252 and 66 million years ago. After organisms such as algae, plankton, bacteria and plants died, they either sank to the lake and ocean floors or ended up there after being carried to the lake or ocean by a river. Eventually, they were buried by layers of sediment. Over time, they were compacted and became rocks.2

The massive amount of carbon that was buried in the Earth’s crust created an atmosphere on the Earth with a balance of oxygen, nitrogen, and carbon dioxide that was conducive to human life, both in terms of breathing and in terms of temperature.

According to Mark Jaccard, Professor of Sustainable Energy at Simon Fraser University, “Except for the last 250 years, the human energy system has relied almost entirely on wood, brush, crop waste, and animal dung, and these have been essentially carbon neutral. As they grow via photosynthesis, trees, bushes, grasses and crops extract CO2 from the air to produce carbohydrates. When plants are burned or decay, this carbon is returned to the atmosphere, with no net increase in atmospheric GHG concentrations.”3

However, by drawing the coal, oil, and gas out of the Earth’s crust and burning it over the past 250 years, humans have significantly increased the quantity of CO2 and other greenhouse gases (“GHGs”) in the atmosphere. They are called “greenhouse gases” because they trap heat within the atmosphere, similar to the way a greenhouse traps heat, rather than permitting the heat to dissipate into space. The effect is to warm the planet and cause climate change.

The vast majority of climate change is caused by burning fossil fuels. We simply must stop burning fossil fuels.

Unfortunately, many Canadians have not been taking the climate emergency seriously, despite the increase in deadly forest fires and the other adverse effects of climate change. As a September 2025 study by the Canadian Climate Institute indicates, “Canada’s emissions flatlined in 2024 at 694 million tonnes (Mt CO2e), with emissions essentially unchanged from the previous year…Canada’s emissions reduction progress to date is fragile.”4

Transportation is the second-largest source of greenhouse gas (GHG) emissions in Canada after the oil and gas industry.5 It is not possible to make the necessary reductions in Canada’s GHG emissions without significantly reducing emissions from transportation.

In the case of fossil fuels burned for transportation, there is no feasible means of “carbon capture, utilization, and storage” (“CCUS”) on transportation vehicles.

In the case of light-duty vehicles, meaning cars and pickup trucks, the solution is both obvious and readily available. Instead of powering these vehicles with internal combustion engines (“ICE vehicles”) that burn fossil fuels, we can readily power them with electric motors, with the electricity coming from renewable generation.

This is about as close to a “no-brainer” as we could possibly get. A growing number of people agree, which is why the International Energy Agency (IEA) forecasted that in 2025, more than one in four cars sold worldwide would be electric vehicles, as EVs become more popular and affordable.6 In Canada, sales of ICE vehicles reportedly peaked as early as 2017.7 It is becoming more obvious to consumers that ICE vehicles are highly inefficient and expensive to operate and maintain relative to EVs. In fact, “Today’s gasoline-fueled cars and trucks waste around 80% of the energy that gets pumped into their gas tanks,” whereas EVs “operate with only around 11% energy loss.”8

✉️ Make Your Submission!

1 University of California at Berkeley, “The Carboniferous Period”. Retrieved on 15 September 2025 from https://ucmp.berkeley.edu/carboniferous/carboniferous.php

2 Chevron, “Explainer: where do oil and gas come from?”, 30 December 2024. Retrieved on 15 September 2025 from https://www.chevron.com/newsroom/2024/q4/explainer-where-do-oil-and-gas-come-from

3 Mark Jaccard, The Citizen’s Guide to Climate Success (Cambridge: Cambridge University Press, 2020), p. 168.

4 Dave Sawyer and Seton Steibert, “Canada’s emissions flatlined in 2024, early estimate shows,” 440 Megatonnes Project, 18 September 2025. Retrieved on 18 September 2025 from https://440megatonnes.ca/insight/canada-emissions-flatlined-in-2024-early-estimate-shows/

5 Government of Canada, “Greenhouse gas emissions: drivers and impacts”. Retrieved on 20 September 2025 from:

6 “More than 1 in 4 cars sold worldwide this year is set to be electric as EV sales continue to grow,” IEA News, 14 May 2025.

7 Arthur Zhang, “Gas-powered vehicle sales have peaked in Canada,” 440 Megatonnes Project, 15 February 2024. Retrieved on 18 September 2025 from https://440megatonnes.ca/insight/peak-gas-powered-vehicles-canada/

8 Karin Kirk, “Electric vehicles use half the energy of gas-powered vehicles,” Yale Climate Connections, 29 January 2024. Retrieved on 19 September 2025 from https://yaleclimateconnections.org/2024/01/electric-vehicles-use-half-the-energy-of-gas-powered-vehicles/

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