INEQUITY
In Ontario's Drive Clean Program

INTRODUCTION

Synopsis: This site is to address inequity and other problems involving the Ontario Government's Drive Clean program.

[driveclean logo] The Ministry of the Environment decided to expand its Drive Clean program to increase the focus on vehicles more than 5 years old. Initial changes started on January 1st, 2006, only 6 weeks since a November 18th, 2005 public announcement. The implementation of the proposed changes came soon after a major prior expansion, which included doubling the RCL (repair cost limit) from $200 to $450 in 2003.

Can such increases be justified? While we all agree that the premise of emissions control is good, air pollution is bad, and internal combustion engine exhaust is a factor contributing to global warming and urban smog, it is important to view the pollution issue in a social context as well as a purely environmental context. To view all the positives of a program without assessing the negatives is to only see one half of the picture. One major negative impact of the Drive Clean program today and tomorrow is its measurable contribution to increasing poverty and consumer debt levels. This concerns thousands of unlucky car owners who own older vehicles that do not easily pass. Particularly affected by the overall ballooning costs of motor vehicle operation are younger families, who in many cases are forced by unavoidable financial circumstances to operate these older vehicles. Considering the significant cost to vulnerable groups in society, it is not acceptable that a program with such potential benefits to other parts of society has been very suddenly expanded without sufficient public consultation.

The evaluation of the Ontario Drive Clean program by "independent" consultant firm the Eastern Research Group (ERG) is currently posted on the Drive Clean home page. The report was made available one month prior to the 6-week public participation, released over the busy Christmas holiday period. To formulate any remotely meaningful public discussion of the ERG report, a longer time period than six weeks was most certainly merited. The consultants themselves appear to have had at least 8 months to assemble this study, and furthermore the Ontario government is not implementing recommendations of the report as recommended by ERG.

The true independence of ERG is questionable. ERG is an American-based middle-sized consulting firm with about 350 employees and 11 offices across the United States, including one in California. They have worked on vehicle emissions inspection and maintenance programs in U.S. jurisdictions and for the U.S. Environmental Protection Agency and Environment Canada. According to their website, ERG seeks out "prime contracts" with federal, state, and municipal governments. ERG was chosen, hired, paid and directed by the same provincial politicians who came into office with a policy of maintaining the Drive Clean program, not to mention bureaucrats and industry insiders who have a vested interest in seeing the Drive Clean program continue. Government accounting standards for evaluations like this generally do not recognize such a relationship as independent because the consultant firm could feel pressure to report favourably if it wanted to continue to do business with the province.

The ERG report focused mainly on evaluating: age and type of vehicles tested; vehicle testing technology and methodology; compliance and fraud prevention; and, repair effectiveness. ERG's final report included an examination of the "best" practices in U.S. jurisdictions with vehicle inspection and maintenance programs, and provided an assessment of improvement options for the program. Equity appears to be a concern of the Eastern Research Group, certainly considerably moreso than the Ontario Government itself. There is inadequate study in the ERG report of the possible downside of the Ontario government continuing a course (against recommendations) of ignoring equity issues in car and truck emissions control, while escalating the impact of the Drive Clean Program. Perhaps this is because no provisions for equity existed as part of the original Ontario Drive Clean program. The Ontario Program is the sole subject of the evaluation, however, most equity issues were referred to in the context of studies of U.S. jurisdictions.

The Ministry in its internal review (not posted at Drive Clean's website, and apparently not available to the public) appears to have found that equity concerns are not feasible due to "cost and implementation issues related to the consultants' recommended improvement options", (whatever that means). Where is the justification to describe why Ontario is rejecting the consultants' recommendations on equity? Is this not meant to be a "science-based" consultation process? The "internal review" should also have been made public. A new public participation period of say, 3 months should be initiated at that time.

Imagine if someone earns $24,000 per year and has just put $2000+ in regular repairs down on their older vehicle. Upon renewing the plate sticker, they may have spent their year's transportation budget on a vehicle that now suddenly fails Drive Clean. They also find to their horror about the new $600 RCL at their local garage, not before. These drivers deserved to be warned in advance, because only then can they have the option to put that $2000 towards the purchase of a newer vehicle with better emissions equipment instead of needlessly suffering through what may be a pointless wallet-emptying Drive Clean experience.

To summarize, the unnecessarily short time period between the public announcement and actual implementation was insufficient and perhaps deliberate to catch opponents of Drive Clean off their guard, and leaving no buffer zone for Ontarians to adapt their repair regimens or run down their old car in preparation to update to a newer vehicle.

MISLEADING NOV. 18th PRESS RELEASE

[burning money image] On the front page of the Drive Clean website is the (false) claim that the "government is saving Ontarians time and money". Considering the proposed changes, this is like saying the chocolate ration has been increased from 100g to 50g! Time and money will be saved only by owners of vehicles 5 years or newer. For the rest, there will be more time and considerably more money involved in getting through the Drive Clean process. Exemptions are only for the newest vehicles. One wonders if the ample spin on the November 18th, 2005 press release is an attempt to hide the doubling of annual costs to pass 5-year and older vehicles through Drive Clean's increasingly strict parameters. (Passing the test in the first place has also become much more difficult due to stricter technical parameters in tandem with the repair cost limit increases). Such obvious spin certainly does not lend the Drive Clean program any credibility, a program which already has a well-earned negative reputation for fraud, etc. (see the links at the bottom of this page to read about literally thousands of documented cases of fraud involving the Drive Clean program. Who knows how many cases have not been documented?)

SOME OF THE CHANGES

Effective January 1, 2006, the Drive Clean program was revised to focus on vehicles most likely to pollute. Simply put, things are getting very expensive very fast for any operator of an older vehicle.

* Increase the repair cost limit (again) from $450 to $600 so that more vehicles can be more "fully repaired".

* Requiring annual testing for vehicles 12 years old and older.

* Using the vehicle's own onboard computers for testing 1998 and newer vehicles.

* Starting emissions tests to renew licence plates when vehicles are five years old, instead of three, because newer vehicles have much better emissions controls and three-year-old cars pass Drive Clean over 99 percent of the time.

* The 20-year-old rolling exemption of light-duty vehicles will be eliminated. Testing of model years 1988 and newer (effective January 1, 2006; will be implemented January 1, 2009).

SOME DRIVERS HAVE A CHOICE: OFF THE ROAD, OR BANKRUPT

Low-Income Repair Assistance Programs are in operation in California, in Texas, and elsewhere to provide subsidies to qualified low-income motorists for the cost of repairing their vehicles. However, Ontario has so far failed to include this aspect in its own program.

There will be an increasing number of "non-compliers". Those who can't afford the price of a new vehicle or to repair their old one, and keep driving past the date of plate sticker expiry. There are also drivers whose plates may have been stolen, damaged in an accident, lost entirely, or they may have simply forgotten to update their plates. Since compliance can require significant funds to pass Drive Clean tests, sometimes over $1000 total given preliminary costs, sticker renewal may be delayed due to financial reasons. If and when these drivers are caught up with and ticketed, a Drive Clean information loophole currently exists, casting into doubt the Repair Cost Limit when a vehicle owner does not update their license plate stickers. Presently the Province, Drive Clean, Police, MTO staff, and most mechanics falsely say that lost plates mean that a conditional pass, and the RCL is no longer an option. Dishonest (vs. honest) mechanics will plead ignorance if confronted, but this loophole is a major source of additional work.

Although obviously best avoided at all times, driving with expired plate stickers as a financial necessity will increase due to the increasingly daunting repair cost limit (RCL), which more than doubled in cost between 2002-2004, and is due to increase by another 33% to $600. This means it can cost as much as $670 to update Ontario license plates for just one year on a vehicle under a "conditional pass" in 2006. [rusty muffler image] This is assuming that the exhaust system is airtight for testing, of course. If there are any holes, then the vehicle will not even be accepted for testing. It is not just holes in the muffler, etc. however. Many other expensive preliminary repairs may have to be completed prior to the financial burden of the actual Drive Clean test. Adding in preliminary service costs, not to mention lost work time and the potential for costs related to the loss of the use of the vehicle for the testing/repair period, the lump sum can easily reach a daunting $1000-$2000 range. Furthermore, any time a car goes into a garage there is always the possibility that a mechanic can do more harm than good. These types of situations are very difficult to measure except by anecdote, regarding specific vehicles and specific garages, but that does not mean that things like this do not happen regularly due to the fact that automobiles are very complex and can be unforgiving machines.

The Ontario Environment Minister fails to address that such increases do not have any realistic economic link with taxes, inflation, real wages, or the cost of living. The Disposable Personal Income (DPI) of the average Ontarian has flat-lined for the past 10 years, so for a person whose vehicle fails badly, the $600 in repairs is deducted directly from their DPI, a very limited amount of money. Such a significant lump-sum payment can mean low-income older vehicle owners may simply be forced to delay renewing their plates. Financially, other repair costs on a vehicle may have already happened in a cluster, or some major outlay has already occurred, such as an automatic transmission rebuild. Interest rates are on the rise, and the cost of financing a new or newer vehicle has also gone up considerably since Drive Clean was originally implemented. The legal dangers to all of a struggling Ontarian being forced to drive a car with an unregistered plate can complicate matters, as can cutting corners by driving without insurance. High numbers of drivers without insurance is a very serious problem in Ontario, and will worsen under the proposed changes to Drive Clean as the least fortunate try desperately to stay mobile.

Despite the government hiding behind the old cliche of "driving as a privilege", emissions of an internal combustion engine do not, and should not give the government the right to introduce a new tax on the poor. Global warming is not a sufficient excuse to cut the disposable incomes of Ontario's least wealthy drivers, without some form of positive compensation. The built environment in most Ontario cities has been, and continues to be designed by government planners to serve cars and especially trucks. 40%-60% of urban land is set aside in some way to serve the car. Car ownership remains a necessity of life for many low-income people. This reality does not blend with the government's outdated perspectives, such as those given on the Drive Clean website, that driving can be treated as a tax on some luxurious privilege of the wealthy. The Provincial government wants to make pollution the problem of those who can least afford to pay for it, while the truly wealthy new car owners, the trucking industry, and the government itself pay virtually none of the cost. Most major truck and car fleets in Ontario register outside of Drive Clean zones. For example, the entire Bell Telephone fleet is registered in Thunder Bay, and the entire Greyhound bus line is registered in Alberta.

CONSUMER PROTECTION

Cars were purchased in good faith by Ontarians with the assumption of a 10-20 year life span, and most citizens purchased their cars well before anything like the Drive Clean program was even announced. A certain percentage of a family budget is devoted to transportation each year, the transportation budget coming from after-tax income. New annual emissions charges to operators of a motor vehicle are being increased without remotely adequate concern for lower incomes. Drive Clean symbolizes a continuing blatant disregard for basic consumer protection coming from the Ontario Government. Ample advance warning of Repair Cost Limit increases should be given, in keeping with the simple fact that automobiles are long-term investments. Ample warning must obviously be more than 3 months, it should be 3 years! Reasonable warning also merits a proper advertising campaign, perhaps akin to a small fraction of the ubiquitous Ontario "flu shot" ads. Presently, many if not most Ontario drivers still believe the government is about to phase out the Drive Clean program. The November 18th press release received little attention!

img src="http://www.geocities.com/thecheesefactor/1987civic.jpg" align="left" img src="http://www.geocities.com/thecheesefactor/1991buick.jpg" align="left" img src="http://www.geocities.com/thecheesefactor/1990jetta.jpg" align="left" Of low-income people's older cars, particularly those of the late 1980s and early 90s, many have inherently unreliable or unpredictable emissions outcomes due to the wide variety of ways in which engines age over time. The government, not the consumer, is accountable for the fact that these vehicles were legally approved for sale in our Province years ago, with ample provincial sales tax collected, well before any Drive Clean programs existed. These drivers who unwittingly purchased "at risk" vehicles in good faith, are now being unfairly targeted by Drive Clean without reasonable warning in the last few years of their vehicle ownership, with no offers of compensation.

Is it essential to victimize Ontario's low-income drivers over the next few years? Vehicle technology and emissions systems off the assembly line are obviously catching up with the legislation, but to victimize the poor in their process of their saving up for more advanced vehicles, hybrids, etc. from their rusting Ford Tempos, Dodge Shadows, and Jeep Cherokees, etc. seems to be addressing the emissions problem from the wrong side. There is a trickle-down effect we shall see in the future, as used hybrids and low-emitters begin to come onto the market, but this will take some time as these new technologies have only been made available to consumers extremely recently. While poorer drivers wait a few years for affordable used hybrids, however, forcing potentially disastrous maintenance costs on poorer drivers on the inflexible annual basis can easily work to delay their purchase of a newer, less-polluting vehicle. This is a real outcome that runs directly counter to the stated goals of the Drive Clean program.

INCREASING NON-COMPLIANCE AND POOR TRAINING

img src="http://www.geocities.com/thecheesefactor/pulledover.jpg" align="left"The rapidly increasing costs of Drive Clean make it easier for low-income drivers to end up the wrong side of the law. One example of such an outcome is when those who can not afford to make repairs immediately after failing a test continue to use their car. Sooner or later, such a driver is going to be pulled over for having expired plate stickers. The police officer at his/her discretion will usually issue a ticket ($100 approx.). However, Police can alternatively confiscate the plates, meaning the vehicle must be towed everywhere and/or a temporary permit must be obtained from an MTO office before the vehicle can be driven under its own power. Police also have the power to impound a vehicle until new plates are purchased and it is re-registered. The motorist can now be made responsible for further expenses such as towing and storage charges. Although anything more than a ticket may seem excessive, these penalties exist in Ontario, but may further be disputed by the motorist and ultimately lead to traffic court proceedings. If nothing is done to help low-income drivers pay for Drive Clean upfront, these situations will definitely increase in their frequency. Non-compliance increases like this are caused by two things 1.The considerably higher emissions standards (It is technically 22% harder to pass Drive Clean than it used to be due to raising the bar) and 2. Higher maximum costs to be incurred by drivers facing a failed Drive Clean test.

If the plates have been confiscated, (lost, stolen, or damaged), a Drive Clean information gap comes into effect. The car owner is usually misled that the vehicle can no longer receive a conditional pass without the original plates. It seems like the repair cost limit is not applicable, (as in a change of ownership) despite the fact that ownership of the vehicle has not changed. MTO personnel are ill-equipped to deal with this situation. If anyone believes otherwise I suggest they call a handful of local Ontario licence bureaus, ask them about new plates and RCL eligibility and see how many different answers are given, or for that matter, ask the same of a local police division front desk. They usually don't know. Many mechanics will also not know the answer, leading to perhaps thousands of dollars of expenditure trying to fully pass a vehicle that has not changed owners, and is actually still eligible for RCL.

Realistically, the average Ontario driver is not going to be aware that their plates or entire car can be taken away if they neglect to update their stickers; drivers expect a ticket for this offence. The Drive Clean website currently omits and refuses to include any details regarding aggressive enforcement of the Drive Clean program. When the extreme scenarios above transpire, it can present a huge problem for victims. Many older vehicles to completely pass emissions might need thousands (rather than hundreds) of dollars of work done, and even then a pass may not be guaranteed. In troublesome cases, the cylinder heads must be changed or the entire engine must be rebuilt. In many if not most cases, the cost of fully passing emissions on older vehicles is significantly higher than the value of the vehicle. The simple fact that the plate stickers were not updated on time can therefore result in a total loss of an otherwise operable vehicle, and a total financial disaster for a low-income family. Despite the fact that a vehicle fails emissions, previous general maintenance done may represent a massive investment on the part of the vehicle owner. The entire reason for the RCL is to take into account that drivers on low incomes cannot afford to rebuild engines, etc., but God help them if they forget to renew their stickers. Being misinformed through the Drive Clean information gap they can lose their entire vehicle to a scrap yard, if the repair costs do not get them first.

The above scenarios are purely regressive. Even if plates are lost, or the entire vehicle is confiscated, once any fines are paid, it should be prominently stated in all relevant Drive Clean literature that the option of the RCL will be maintained, and based on the fact that there was no change in the records of ownership of the vehicle. Again, this should be prominently stated on the Drive Clean website, but it is currently omitted. Why? Lastly, MTO and police staff, not to mention Drive Clean mechanics must be trained to give advice and make decisions based on this simple fact. Currently, they do not. All parties involved need to be far better trained to deal with compassion regarding the equity fallout from Drive Clean, which is going to become more serious. It was irresponsible to expand Drive Clean before MTO staff and police were adequately trained to deal with the difficulties related to the sudden increase in the expense of the program to individuals.

If things do not change, how can low-income individuals and families in this situation cope with the information gap? Well, if the vehicle owner complains loudly enough, and over a long enough time period, the MTO or officer involved may return the original plates if they still have them (confiscated plates are usually sent back to the MTO to be destroyed), or have them provide documentation to allow a conditional pass at the time plates are lost or confiscated. The problem continues to be that even informal procedures for dealing with this are not printed in any of the Drive Clean literature or on their website. The best solution for the moment is to call Drive Clean's information number directly and complain strongly about the situation, and use this number as your backup if MTO staff or others attempt to deny the RCL when ownership has not changed.

Drive Clean should not be used as a mechanism for unfairly targeting low-income drivers financially by threatening to virtually "steal their cars", however, with the present loophole, this is exactly what is happening to those who give up their cars without a fight.

FINANCIAL ASSISTANCE

Financial assistance for low-income drivers would solve the inequity problem. Emissions repairs can present a real financial burden to those on low incomes, and are difficult to budget for due to the uncertainty surrounding whether a vehicle will actually pass. If the reader visits the "downloads" section of the Drive Clean website then deep within the Eastern Research Group's 81-page assessment of the program the following text can be found...

A Low-Income Repair Assistance Program provides financial assistance to low-income households in performing emissions-related diagnostic and repair services for vehicles that fail their emissions inspection. Program administrators verify the financial need of potential participants (usually based on household income being at or below an established limit for number of residing individuals), as well as approve (or deny) repairs to be made to vehicles. For eligible participants, these approved repairs are subsidized (generally up to a certain pre-set ceiling). U.S. programs generally use tax documents from the prior tax year, paycheck stubs, or other official income verification documents for demonstration of financial eligibility.

Is Ontario going to get this? Don't hold your breath. Is this why on the Drive Clean website, equity issues lie deep in the consultants' PDF report, and nowhere on the main pages? The Ontario government has not tabled or proposed any assistance programs to help low-income drivers deal with a huge increase in Drive-Clean-related repair costs, although assistance programs were strongly recommended by the consultants as follows:

6.2.15.5 Recommendation

We recommend that Drive Clean institute a repair subsidy program, drawing on the experience of similar programs in California and other jurisdictions. This will help mitigate the extra burdens placed on some motorists from limiting the number of conditional passes granted and increasing the repair cost limit.

It follows that the Ontario Government is seeking to replicate emissions enforcement programs similar to those in U.S. jurisdictions, but without a similar financial safety net. Is it any wonder that poverty levels are on the increase in Ontario with this attitude.

CAR HEAVEN ... MORE LIKE CAR HELL

img src="http://www.geocities.com/thecheesefactor/carheaven.gif" align="left" Car Heaven was supposedly founded by The Clean Air Foundation (former website www.cleanairfoundation.org), a 7-employee not-for-profit outfit based in Toronto working specifically on air quality issues in Canada. The Car Heaven Program encourages Canadians to get their "old high-polluting cars" off the road. According to the Car Heaven website, since the launch of the program in June 2000, over 32,000 cars have been "donated" to the program. In 2005, 13,000 cars were taken off the road by Car Heaven, supposedly resulting in reductions of 876 tonnes of smog-causing emissions (NOx and VOCs), 3,619 tonnes of Carbon Monoxide (CO), and 5,922 tonnes of greenhouse gas emissions (CO2e), however, they apparently failed to subtract pollution from the newly purchased vehicles which replaced the old ones in calculating these numbers, not to mention the pollution generated from the economic growth required to generate the surplus funds to finance the expense.

Each participant or "donor" to the Car Heaven program is offered a free tow (for some reason overvalued at $200?, ... seems strange considering most tows cost ~$100) and a choice of receiving a minimum $60 charitable tax receipt or a $1000 incentive coupon towards a brand new GM vehicle. There are also "exciting contests" where donors to the Car Heaven Program can win trips or a brand new GM vehicle.

The first problem with Car Heaven is the vehicle replacing the old one must be purchased brand new. Most drivers simply cannot afford to purchase brand-new vehicles. Secondly, the vehicle purchased must be a General Motors brand car or truck. In the past year, GM has been close to bankruptcy due to lack of sales, mostly due to this company's overinvestment in large gas-guzzling vans, pickups, and SUV-type vehicles. Other problems with GM have been their lack of reliability versus other companies' vehicles, and their failure to enter the hybrid technology club. img src="http://www.geocities.com/thecheesefactor/intakegasket.jpg" align="left" There is (link now dead a href=https://www.ctv.ca/servlet/ArticleNews/story/CTVNews/20060330/whistleblower_gm_060406/20060406/) a very serious flaw in GM V6-equipped vehicles sold between 1995-2003, where the intake manifold gasket prematurely decays during normal use, allowing coolant to leak into the main oil compartment in the engine. The result is usually a seized engine, which costs $3000-$5500 to repair. Although the problem has apparently been corrected by GM since 2003, who knows what similar defects might await future GM customers. GM is doing little or nothing to help victims of this intake gasket design flaw, refusing to admit to the true nature of the defect, and refusing to recall affected vehicles for a ~$700 preventative gasket replacement. Victims of seized or seriously damaged engines due to failure of the faulty gasket are being similarly abandoned by GM. Due to GM's continuing denial of the inherent problem, it is not until major internal engine problems occur that the majority of GM owners find out about the factory defect.

How much do participants get for their old cars in the Car Heaven program? Close to nothing. Cars that are 12 years and older have a set value of a mere $60. A tax receipt is issued, which will be a minimum of $60 or a bid value of the car accomplished by some means between different government-approved scrap yards, whichever is the greater.

The Car Heaven website is currently out of date, still referring to the now cancelled federal One-Tonne Challenge program, implying that buying a large GM SUV may work to reduce harmful exhaust gas emissions in some form. Interestingly, the other corporate sponsor of Car Heaven is Esso.

CONCLUSIONS

More development needs to be done on Drive Clean before it will ever be fair and efficient in reducing emissions. The proposed expansions draw it further in the wrong direction. In the past, poor planning and major complications with implementing the Drive Clean program have meant that the government is well advised to drastically change the approach this time. It needs to seriously rethink its past procedures, not simply expand them. Presently on the Drive Clean website in particular, I do not see enough evidence of new thinking. The 81-page Eastern Research Group report succeeds in some ways, but it is only one report. It must be read, interpreted, and implemented properly, not via an "internal review" done behind closed doors by the McGuinty government. As we see above, there is a strong potential for more of the same Drive Clean problems without more flexibility, more research, and in particular, training of staff, police, and mechanics associated with designing, implementing, and enforcing the program. By implementing only a few of the consultants' recommendations and dismissing others, Ontario will end up with both a socially skewed and fraud-ridden emissions program, a whole new way to aggravate existing social and economic problems.

Ontario's smog levels and fossil fuel consumption continues to increase. This is partly because Drive Clean's move to target older cars is not working in the big picture. Drive Clean does not account whatsoever for how much less small cars pollute than SUV's and big trucks. The trucking industry is a powerful political force, unlike "John Doe, 1989 Honda Civic owner, trying to get to work". It is the same with aircraft. Aircraft are massive polluters, yet huge government subsidies are spent to construct bloated airport infrastructure (except for a Subway link to the airport of course). Drive Clean is no more than a band-aid solution on the backs of the most vulnerable "polluters", Ontario's working poor. It is a backward-looking negative strategy, which has had a relatively limited impact over time. If nothing changes, the poor will get poorer as Ontario simultaneously embarrasses itself by failing miserably to reach its Kyoto targets.

img src="http://www.geocities.com/thecheesefactor/hybrid.jpg" align="left" A forward-looking, positive, progressive strategy would be to introduce provincial (and hopefully matching federal) tax incentives towards the purchase of the most fuel-efficient, least-polluting new vehicles. This will ensure that fewer fossil fuels are being burnt per capita. This may have just the effect Drive Clean was looking for all along, and at considerably less administrative cost. PST/GST-exempt "Smart Cars", hybrids, electric cars, Segways, low-emitter vehicles, etc. would ensure that larger numbers of non-polluting type vehicles are put on Ontario roads. Presently, hybrid vehicles cost about $5000-$8000 more than their conventionally-powered counterparts. This price difference needs to be seriously considered to account for environmental impacts in the future. Similarly, a slightly higher tax on conventionally-powered SUV's could be levied to reduce the overall burning of fossil fuels. Benefits from more low-emitter vehicles sold in Ontario would last for 10-20 years, or as long as the vehicles themselves. Such a program would yield superior results in terms of air quality in the long term.

If Drive Clean were scrapped entirely, as has been proposed in the past, the 1988-2001 vehicles it is concerned with will retire soon enough at the end of their useful lives, and with some money still left in the pockets of hard-working Ontarians towards the purchase of their next (considerably less-polluting) vehicle. The question is whether the Ontario government wants to replace (or at least combine) Drive Clean with serious action. Action such as to help promote new cleaner-burning vehicles that will have an immediate and long-term impact on daily pollutants. This would be versus a preference to keep a greater percentage of traditional internal combustion vehicles (barely) on the road over the next few years to extract revenue from via annual Drive Clean testing. Low income drivers will continue to suffer, being forced to gamble limited transportation budgets with various models of vehicles, trying desperately to find something that can pass Drive Clean easily and also keep them mobile. img src="http://www.geocities.com/thecheesefactor/equipment2.jpg" align="left" img src="http://www.geocities.com/thecheesefactor/equipment1.jpg" align="left" Keeping some traditional vehicles on the road, but tested annually, will serve as a cash cow to pay off all of the expensive Drive Clean testing machines, by about 2014. This may explain the otherwise pointless annual testing idea for cars 12 years and older, to make the testing machines' extreme cost ($50,000-$80,000) seem more justifiable. Recouping the original financial investment in the Drive Clean program equipment should not be a major goal, since the Drive Clean program's goal should not be to turn a profit or break even. However, it is quite clear that paying off these machines is an extremely major goal. Cars made since 1998 have onboard OBD-II emissions computers that threaten to make the Drive Clean dynamometers largely obsolete by... and this is probably no coincidence, about 2014, by which time virtually all cars on the road will be 1998 or newer.

"We believe that a licence to own a vehicle is not a licence to pollute," said current Ontario Minister of the Environment Laurel Broten. However, the fact remains that all internal combustion vehicles are going to pollute whether they pass a Drive Clean test, or not; even hybrids. Only full electrical vehicles can truly be considered air-pollution-free. The point of view of the Minister is curious at best. This oversimplified thinking may explain why there is a widening gap between the goals of Drive Clean and the transportation budget realities for the Ontario driver. Most of us do not drive a car 5-years old or newer, most of us do not earn over $90K per year, and most of us do not live and work in downtown Toronto 50 metres from a subway or streetcar stop.

img src="http://www.geocities.com/thecheesefactor/scrapyard.jpg" align="right" If things progress, we can expect fewer older cars on the road, and most cars will be getting less overall mileage. Older cars scrapped at a faster rate will encourage a throw-away culture of vehicles. Drive Clean's website does not indicate any worry about this impact, and continually infers cars are easily disposable, going a step further with their "Car Heaven" concept, as if cars go to some magical abstract place (Michigan?). In reality, they are actively encouraging the premature disposal of older vehicles. Cars are of course not easily disposable, which is why we have to pay those extra fees when we dispose of bald tires or even when we get the oil changed. Cars damage the environment substantially when they go off the road (just have a look at your local wrecking yard). Where does all that plastic go? Vehicles today already contain more toxic non-recyclable and non-biodegradable plastics (instead of recyclable metal) than in the past. Landfills will be facing more automotive waste if average car lifespans shrink. Similarly, the environment is polluted each time a new car is manufactured. Consider the amount of pollution created when an entirely new car has to be built and paid for instead of keeping one old vehicle on the road until the end of its useful life? Many environmentalists have written screeds on the negative impacts of the throw-away society, so without going off on a tangent at this point I refer the reader to them for further information.

Charging low-income drivers such a potentially hefty annual fee may also tip the balance towards increasing neglect of outstanding safety-related repairs such as tires, brakes, and steering components. The poor's inexpensive cars score less than average in high-speed accident survival tests. Reduced safety will impact on auto insurance rates, already very inflated in our province. Higher insurance rates take still more money out of people's pockets as the circle continues. There may be drivers who will drive without insurance in order to recoup funds for otherwise unnecessary emissions-related upgrades insisted upon by Drive Clean. None of the above is desirable, but it is really time the Drive Clean Program admitted to and accounted for the existence of several real-world externalities. Drive Clean is an issue to ponder during the next Provincial election, or if you cannot wait until then, it may merit a letter to your local MPP.