December 12th, 2018

Dear Minister McKenna,                                                                                                              

The undersigned organizations believe that the currently established and enacted GHG emissions standards for light duty vehicles[1] should not be weakened. Continuing to align Canadian standards with those of the U.S. would further erode Canada’s ability to meet its 2030 and 2050 GHG reduction targets. Faced with imminent changes to U.S. standards that will increase GHG emissions and air pollution, Canada should take swift action to break from the present adoption of U.S. standards by reference and uphold the more stringent GHG emissions standards out to 2025.

Should the United States weaken its existing approved emissions standards by flatlining them from 2020 onwards, Canada must not follow. Canada’s best path forward is to maintain more stringent, scientifically demanded standards by aligning with California and the 13 other states which opt to follow the California regulation. This would result in more than 40 per cent[2] of the combined Canada-U.S. market being subject to the same stronger emissions standards.

There are no technological or cost-prohibitive reasons why the emissions standards cannot be met with existing vehicle technology, particularly in light of the accelerated pace of fleet electrification in Canada (214% year-over-year growth)[3]. In the U.S., cost estimates for meeting the 2025 standards have dropped significantly due to recent efficiency developments[4], and many large manufacturers reported beating their compliance standard in the 2016 model year without having to use accumulated credits[5].

Stronger standards will mean consumer savings on gasoline costs. According to ECCC, a Canadian driving a model year 2025 vehicle will see fuel savings of around $900 per year compared to driving a 2013 vehicle.[6] In the US, studies have shown that under weaker standards Americans will spend $55 billion USD more on gasoline by 2040[7].

Stronger standards also create jobs. Stronger U.S. standards were expected to create 100,000 jobs by 2025 and 250,000 U.S. based jobs by 2035.[8] Economic factors including job growth led major automotive parts suppliers in the U.S. to break with large automakers[9], stating that it’s “in the nation’s best interest” to maintain the stronger standards, and that the U.S. should maintain its competitive edge in the automotive sector by building “the cleanest and most efficient vehicles in the world.[10]

Maintaining stronger emissions standards also aligns with important upcoming federal government policy planks such as a Zero-Emission Vehicle Strategy and a Clean Fuel Standard, and with Canada’s broader goal to protect the health of Canadians by reducing vehicle emissions[11]. Health Canada’s latest air quality report illustrates that 14,000 to 15,000 people in Canada die prematurely every year because of air pollution.[12]  Upholding Canada’s current standard will reduce the health impacts of poor air quality from traffic-related emissions.

We urge you to uphold the more stringent GHG emissions standards in Canada through 2025 for light duty vehicles. This will reduce household costs, increase jobs in the auto sector, improve air quality, and bring Canada closer to meeting its climate change goals.

The undersigned,


Advanced Biofuels Canada

ArcTern Ventures

The Atmospheric Fund

Association des véhicules électriques du Québec (AVÉQ)

Barry Cullen Chevrolet Cadillac Ltd

Burlington Green

Canadian Wind Energy Association (CanWEA)

Canadian Association of Physicians for the Environment (CAPE)

Cannon Auto Manufacturing Inc.

Cascadia Windows


Clean Air Partnership

Clean Air Alliance

Clean Energy Canada



The Climate Reality Project Canada



David Suzuki Foundation

Delta Management


Environmental Defence Canada

EV Society

Emerge Guelph

Faith and the Common Good

FTQ – Fédération des travailleurs et travailleuses du Québec

Greater Sudbury EV Society


Ontario Secondary School Teachers Federation (OSSTF)

Ontario Geothermal Association

OpenConcept Consulting

Pembina Institute

Plug’N Drive

Pollution Probe

Propulsion Québec

Registered Nurses Association of Ontario (RNAO)

Renewable Industries Canada

Signature Electric


Switch Alliance


TREC Renewable Energy Cooperative

Uber Canada


*For more information, contact:

Sarah Buchanan

(416) 323-9531 ext. 244


[1] Government of Canada. 2014. Regulations Amending the Passenger Automobile and Light Truck Greenhouse Gas Emission Regulations, at

[2] International Council on Clean Transportation. 2018. Assessing Canada’s 2025 passenger vehicle greenhouse gas standards: technology Deployment and

[3] Fleet Carma Electric Vehicle Sales Update, Q2 2018, at

[4] International Council on Clean Transportation. 2017. White Paper on EFFICIENCY TECHNOLOGY AND COST ASSESSMENT FOR U.S. 2025–2030 LIGHT-DUTY VEHICLES. At

[5] Environmental Protection Agency. GHG Emission Standards for Light-Duty Vehicles: Manufacturer Performance Report, at

[6] Environment and Climate Change Canada. 2013, at

[7] Union of Concerned Scientists, 2018. “Car Standard Rollbacks Would Be Awful”

[8] Union of Concerned Scientists, 2018, “Cleaner Cars are Good For Jobs” at:

[9] Automotive Technology Leadership Group. 2018. Statement of Principles, at

[10] New York Times, March 1, 2018, “Parts Suppliers Call For Cleaner Cars, Splitting With Their Main Automotive Customers: Automakers, at:

[11] Environment and Climate Change Canada. 2017. Sources of Air Pollution: Transportation, at

[12] Canadian Council of Ministers of the Environment. Effects on Human Health and the Environment (website), at