Advocacy

Safety is always BCTA’s highest priority. Not only is it right for the industry to follow safe practices in properly maintaining its vehicles and hiring safe drivers, it’s also good business. 

• National Safety Code reform: Convinced Commercial Vehicle Safety and Enforcement to revise or create a new NSC summary document that would be more easily understood by customers to allow them to assess a carrier’s safety.
• NSC application tests: Monitoring status of testing throughout the province and CVSE’s efforts to ensure tests cannot be “gamed.”
• NSC cancellation process: Caused CVSE and ICBC to review the process to seize license plates upon NSC certificate cancellation resulting in greater clarity of responsibility and authority and increased likelihood seizure will take place.
• Legalization of recreational marijuana: Widely advocated a national and coordinated approach to legislation, an amendment to the Criminal Code to include a cannabis impairment offence with a THC cut-off level similar to the one established for alcohol, a zero-tolerance policy for safety-sensitive occupations, and a regulatory framework to allow employers of workers in safety-sensitive occupations to conduct random workplace drug and alcohol testing.
• WorkSafeBC Certificate of Recognition program: Participated in WorkSafeBC’s consultation process to improve the COR program.
• Highway maintenance contracts: Influenced the Ministry of Transportation and Infrastructure to improve and clarify specifications in the 27 new highway maintenance Service Area contracts around BC to be posted and awarded through 2018 and 2019.
• Bulk NSC abstract requests: Following the introduction of a  new online request process in 2016, convinced ICBC to reduce the minimum number for a bulk request by employers from 20 to 5 for March 2017.
• Safety rest areas: The provincial government continues to act on BCTA recommendations for more truck parking and safety rest areas, most recently announcing a new truck parking facility for the north side of Highway 17, below and just east of the Port Mann Bridge, with room for up to 150 trucks.
• Lane markings on BC highways: MoTI committed to investing in more durable lane marking applications for Highways 1, 3, 5, 14, 16 and 97 (high build paint for thicker application and premium glass bead for areas needing improved reflectivity).
• Flatbed driver safety: Supported a Canadian Trucking Alliance campaign by asking WorkSafeBC to assist in promoting safe loading and unloading practices for flatbed trucks and trailers to shippers.
• BC wildfires: Worked with the Red Cross to coordinate their transportation and warehousing needs by identifying members in Kamloops, Kelowna and Prince George and educating Red Cross on hours-of-service rules.
• Notification process for missing commercial vehicle drivers: Championed a coordinated process for sharing notifications of missing professional drivers among provincial associations. 
• Steel storage racks: Continued to identify opportunities to improve the communication and clarify WorkSafeBC guidelines. 
• Highway 1 crash data review: Based on a member’s reported concern, caused MoTI to review the crash data over a three-year period between Salmon Arm and Golden.
• Electronic logging device mandate: Working closely with CVSE to ensure when federal mandate is implemented, BC will be ready to coordinate rules and timeline.
• Highway speed limit review: Requested that MoTI conduct a review given three years of crash data are now available since the speed limit increase was implemented. 

The trucking industry relies on skilled, trained and qualified people – and lots of them. BCTA works to assist employers to attract, retain and train workers to be safe, knowledgeable and productive. Some examples:

• Impending cannabis legislation: Following a member survey about the challenges cannabis represents for industry workplaces, the Canadian Trucking Alliance and Trucking HR Canada developed tools and resources to help members address potential medical or recreational use by employees.
• Commercial Driver Training Program: Following a change in direction by School District #73, engaged the Abbotsford and Mission School Districts in discussions to implement the CDTP, as well as Kwantlen Polytechnic University to consider CDTP for a dual credit program.
• Overtime: Engaged local Employment and Social Development Canada officials following a poorly designed and implemented trucking industry overtime survey that does not accurately reflect industry practice.
• National Occupational Classification: Advocated for amendments to the federal NOC for the truck driver occupation to more accurately reflect the skills, duties and tasks of transport drivers.

BCTA's Industry Human Resources Strategic Plan

BCTA is pursuing the initiatives noted above (and continuing to pursue others) as part of ongoing effort to meet goals we first defined in our Industry Human Resources Strategic Plan in 2006, in response to a 2005 estimate that Canada would need 37,500 new drivers annually (4,500 of those in BC). At the time, BCTA members were already experiencing difficulty finding qualified professional drivers to seat their trucks, and a Conference Board of Canada report released early in 2013 confirmed these projections for 2020 and beyond.

Based on research undertaken in 2006, the HR Plan focuses on five areas: Communications and Promotion; Attraction, Recruitment and Retention; Truck Driver Training and Financing; Commercial Driving Licensing; and Strategic Plan Oversight and Renewal (inclusion of this last priority ensures that BCTA continues to revisit and refine the HR Plan over the long term). For a list of the strategies in each area, related activities we’ve completed, and those still underway, please see our Industry Human Resources Strategic Plan Status Update.

The motor carrier industry is highly regulated. BCTA monitors whether regulations or policies make sense and are consistently applied, and, as appropriate, provides support for compliance. We’re also always on the lookout for red tape and ways eliminate or reduce it for labour, time and cost savings. 

• Permit system: Based on BCTA advocacy, the Ministry of Transportation and Infrastructure announced plans to move some of the more low-risk permits into regulation.
• Letters of authorization: We influenced an increase in the term for which LOAs are valid, from one year to five years, for oversized and overweight trucks operating within the Reducible Load Overweight Permitting Policy, reducing the need for repeated review of LOA requests.
• Wheel-on/drum on brake inspections: Following a BCTA request for clarification, CVSE published a bulletin to explain that the onus is on inspectors to decide when it is necessary to remove brake drums during an inspection, with corrections to come in the BC Vehicle Inspection Manual.
• Long wheelbase tractors: In January, we met a longer-term advocacy goal when BC finally allowed the use of long wheelbase, tandem-drive tractors with one or two semi-trailers, increasing the wheelbase up to 7.2 m with one semi-trailer and up to 6.8 m with two semi-trailers (B-train only), with required reductions in the wheelbase of each semi-trailer. There’s room now for emissions control equipment and larger sleeper berths.
• Non-Road Diesel Engine Emission Regulation Bylaw: We surveyed members to address proposed changes (including removing the provision for low-use registration and a deadline change) for those who use these engines in Metro Vancouver (including for reefers, auxiliary power units, and power take off units with a power rating of 25 horsepower or more).
• WorkSafeBC assessable payroll: In an effort to provide “clarification,” WorkSafeBC had inadvertently made distinguishing between a contractor (i.e., owner-operator) and an employee, more confusing. BCTA, with the help of the Employers’ Forum, were able to influence WorkSafeBC to retain some of the guidance it had proposed changing in its Assessment Manual.
• Electronic logging devices: Because of member input at a BCTA panel session in February, CVSE issued guidelines for the use of paper logs to record hours of service at the same time a carrier is testing or training a commercial driver to use an electronic recording device (two logs to be allowed for no more than 14 days).
• Canadian Free Trade Agreement: Effective July 1, 2017, this Agreement includes the creation of a Regulatory Reconciliation and Cooperation Table. BCTA, along with other trucking associations, has long advocated regulatory harmonization for the industry.
• Wheeler policy amendment: Convinced MoTI to amend the wheeler policy to exempt wide wheelers during phase-in of the policy.
• Long combination vehicles: Modernized, in partnership with the western provincial trucking associations, the LCV training material.

Safe, well-maintained, efficient and accessible infrastructure is crucial for the trucking industry - and for BC's economy. Some recent infrastructure-related BCTA initiatives include the following:

• Brunette Interchange, Coquitlam/New Westminster: We recommended separating the main crossing of Highway 1 into two separate corridors for local vs regional and provincial traffic and that all height clearances throughout the project should be at least 5.5 m, and preferably 6 m, to accommodate oversize-overweight vehicles.
• Transportation south of the Fraser: BCTA continues to be consulted with other stakeholders to define specific priorities for provincial infrastructure in this area of the Lower Mainland, including traffic congestion, highway safety and port traffic, among others.
• Six-laning Highway 1, Langley: The Province committed to widening Highway 1 between 216 and 264 Streets, extending six laning for another 8 km beyond the stretch between 202 and 216 Streets, a top priority for BCTA members. The project includes replacement of an overpass and rail crossing, including height increases to remove obstructions for overheight vehicles.
• Vancouver Gateway: We conveyed members’ Top 5 gateway infrastructure projects for federal funding to the Vancouver Fraser Port Authority, including six-laning Highway 91; Brunette Interchange upgrades and road/rail grade separation and crossing closures; the Highway 17 interchange at Plywood Road and Grace Road; the Portside Road overpass and upgrade; and four-laning Blundell Road.
• George Massey Tunnel: Communicated a new BCTA policy to review the number of lanes required for a replacement bridge and opposed the City of Richmond’s recommendations to twin the existing tunnel and restrict trucks during peak periods.
• Highway 1 improvements: Responded to a Salmon Arm request for input on moving signal lights; MoTI expedited a key BCTA member priority of more four-lane sections between Salmon Arm & BC-AB border.
• TransLink Regional Goods Movement: Highly influenced TransLink’s Regional Goods Movement Strategy and top priorities for immediate follow up.
• Langley Township truck route: Coordinated member feedback on proposed truck route changes at Langley Township’s invitation.
• Abbotsford Vye Road Overpass: Coordinated a working group including senior officials from the City and MoTI to ensure the final project design does not restrict movement of extraordinary loads.
• Pattullo Bridge Replacement: Submitted a response to the province’s environmental assessment of the bridge that recommended a 6-lane rather than a 4-lane option. We included the Pattullo as a top infrastructure investment priority in more recent submissions to the provincial and federal governments.
• New Westminster Sapperton Transportation Plan: Opposed the City’s transportation plan because it did not consider the impact of adjacent projects (e.g., Brunette Interchange) and the traffic modelling provided by the City demonstrated that the level of service at critical intersections used by our members would be made worse as a result of the plan.
• Vancouver False Creek Flats: Supported preserving existing light industrial land zoning in this area, which houses several BCTA members and is served by others; convinced the City to reconsider its initial plan for new east-west connection that would have resulted in significant disruption for businesses in area.

BCTA identifies and supports practical options for reducing fuel consumption and smog and greenhouse gas emissions, ranging from regulatory changes that encourage more efficient practices to technological solutions (and opposes those that don’t make sense), as well as for upcoming rules governing hazardous materials spills from trucks. 

• New generation wide-based single tires: Convinced MoTI to amend the regulations to allow the use of NGWBST by end of year 2017/early 2018 rather than conduct a pilot project with limited scope.
• Smart lift axles: MoTI committed to work with BCTA to test fuel-efficient, “smart” lift axles on trailers, in alignment with long-term BCTA environmental policies.
• Heavy-duty tires: Through CTA, Transport Canada asked members provide input on tire requirements, following a proposal by Environment and Climate Change Canada to further reduce GHG emissions from heavy-duty vehicles, including via the use of low rolling resistance tires.
• Heavy Truck GHG Regulations: CTA provided comments on a Clean Fuel Standard discussion paper to Environment and Climate Change Canada, maintaining the position that any mandate must consider accepted, market-proven technologies that complement Canadian operating conditions and standards.
• Spill Preparedness and Response:  Convinced ICBC to work with BCTA to establish a coordinated spill response process between base-plated BC insured carriers, ICBC staff and pre-approved ICBC environmental consultants to help carriers comply with new BC spill response regulations.
• Environmental Protection Act: Received acknowledgement of three key CTA recommendations (technology should be tested and proven, consultation on the extension of “limp” mode, include penalties for tampering) in a report of the Senate Standing Committee on Environment and Sustainable Development.

The industry can’t escape taxes and fees, but amounts should be fair and their administration and collection should be simple. 

• Federal excise tax refund: BCTA supported a campaign by the Canadian Trucking Alliance to convince the federal government to retain the excise tax refund for diesel used to generate electricity from temperature-controlled trailers, power take-off units, auxiliary power units, and in-cab heaters. Although the campaign did not succeed, it achieved notice in a report by the opposition to the Finance Committee, specifically regarding anti-idling devices.
• Mobility pricing: Actively participated in consultation, including arranging for private meetings involving the BCTA Board and the Lower Mainland Infrastructure Transportation Issues Committee.
• Diesel prices: With CTA, provided an online diesel price mapping tool for industry members to look up and compare current wholesale diesel prices across Canada.
• PST Input tax credit: Reminded the provincial government of BCTA’s position that trucks, trailers and related equipment should be eligible for input tax credits.
• Federal small business tax: Supported CTA’s efforts to promote a national industry e-mail campaign to assist members in voicing their concerns directly to the federal finance minister about proposed changes to the small business tax regime, which are now being reconsidered.

We provide timely information on US or Canadian requirements and initiatives and find solutions for challenges that may arise on either side of the border, often in cooperation with the Canadian Trucking Alliance.  For example:

• US order banning foreign nationals: CTA and BCTA kept members informed about a US ban on nationals from seven Muslim-majority countries, including details from the federal government.
• Team Canada coalition: At the recommendation of CTA, the Canadian Chamber of Commerce called a meeting of 20 national business associations in January to discuss strategies and a common approach to deal with the Trump administration in the US and potential trade issues.
• Cabotage: In response to input from BCTA, CVSE has been working with the Canada Border Services Agency to develop guidance for CVSE staff to better recognize cabotage as well as a process to involve CBSA where further investigation or enforcement is required.
• Electronic logging devices: Continued to support members in the transition to ELDs by providing information such as a brief Electronic Logging Device FAQ.
• eManifest Release Notification System: CTA worked with CBSA the regarding issues related to the deployment of eManifest system updates on in March 2017 without sufficient warning that affected RNS and eManifest notices, providing guidance to members for changes and assistance for those receiving Administrative Monetary Penalty System fines related to the change.
• CBSA system outages & AMPS: Supported CTA in encouraging CBSA to address continued system crashes as well as mitigation of outage impacts, including a 90-day truck turnaround plan for trucks arriving at the border without notice as an alternative to issuing AMPS fines and a review of all fines potentially related to outages.
• North American Free Trade Agreement: With member feedback, CTA submitted comments to Global Affairs Canada to help frame Ottawa’s discussions with the US involving the modernization of cross-border trucking.
• BC-Washington State border crossings: Surveyed members to gather information about commercial border ports and their processes for use in advocating potential service or infrastructure improvements.
• Automated Commerical Environment e-manifest for empty trailers/containers: Worked with CTA to provide feedback to US Customs and Border Protection about the impact of a change in its current policy not to require e-Manifest for empties.

BCTA closely monitors issues related to the Port of Vancouver, a major economic driver for the province.  We provide support to drayage members through frequent information updates about the BC Container Trucking Act, regulations, and periodic government announcements and by organizing member-only meetings with the Trucking Commissioner. In addition, we made submissions on the following:

• Deltaport & Vanterm issues: Responding to BCTA requests from November 2016, Global Container Terminals adjusted its policy to allow at least 72 hours notification about Saturday gate cancellation, so companies can obtain new reservations for the following week and, for unexpected gate closures (due to weather or other conditions), proposed a transparent amendment for adjusting reservations based on the length of the delay.
• Financial transparency of the Truck Licensing System. At BCTA’s request, VFPA released information and provided detail on the costs it attributes to the TLS. 
• Wait-time penalty payments: VFPA finally collected and released outstanding 2016 wait-time data from terminal operators and issued related payments to Truck Licensing System carriers in February 2017, for distribution to owner-operators, and, thanks to BCTA advocacy, promised to provide these payments monthly going forward.
• Truck tag system: In March, BCTA provided a list of member recommendations for reforming the current truck tag system to the Office of the BC Container Trucking Commissioner, promoting fewer restrictions for both carriers and independent operators, including on the management of truck tags and truck licence and tag allocation, among others. We also generally recommended economic deregulation of the Port of Vancouver, a long-held BCTA policy, including eliminating the TLS. A consultant’s report confirmed virtually all BCTA recommendations.
• 2014 Joint Action Plan: BCTA is promoting a review to the federal government and others, citing numerous changes at the Port of Vancouver and unintended consequences influencing the effectiveness the Plan, especially given the power of marine terminals over the reservations system and the lack of any performance standard for servicing container trucking companies. Some of these have now been addressed, but we continue to support an overall review.
• TLS cost consultation: Represented members’ views regarding proposed Vancouver Fraser Port Authority options for cost allocation of TLS.
• Marine container re-manifesting: Convinced CBSA to resolve backlog and provide guidance to reduce future re-manifesting delays.
• Marine container examinations: Provided feedback to CBSA on improving turnaround times for container examinations.

BCTA represents the vast majority of private sector motor coach companies operating in the province and works on national issues jointly with Motor Coach Canada. For example:

• BC Motor Coach Safety Review: Organized a meeting with members at CVSE’s request to convey industry best practices for incorporation in the final report for the Review, expected later this year.
• Potable Water Regulations for Common Carriers: A member survey indicated most members would not be affected by modernization of these regulations, but we still worked with MCC to inform the responsible federal agency.
• Seat belts: Confirmed our support for a proposed federal seat belt mandate for certain new motor coaches and buses, but reiterated our recommendation to remove bus driver liability for seat belt use by passengers.
• Accessibility: Provided feedback with Motor Coach Canada to the Canadian Transportation Agency about existing policies and practices for accommodating persons with disabilities and potential impact of new federal accessibility regulations.

We monitor issues related to ferry services closely, since decisions made regarding everything from scheduling to rates can affect motor carriers that depend on BC Ferries to operate.

• Ferry service levels:  We provided feedback on service levels for commercial vehicles between Horseshoe Bay and Langdale and Horseshoe Bay and Bowen Island. 
• Drop Trailer Service: Following our submission during a public consultation about this service, we were invited to make a second submission to the BC Ferries Commissioner, along with only 7 others, to comment on issues of concern.
• Contingency planning: BC Ferries followed up on a 2014 BCTA request by supplying a contingency plan to the Commissioner to ensure sufficient service for carriers during a scheduled 2016 upgrade to Spirit Class vessels.

• Oversize loads: On behalf of the Manufactured Housing Association of BC, reached an agreement with BC Ferries to establish a new guideline for oversize loads travelling on the major routes.