BCTA Policy Positions

1. Speed Limiters (February 2006)

   • The use of speed limiters on all heavy trucks should be mandated with the maximum speed set to 105 kph.

2. Electronic On-Board Recorders (EOBRs) (March 2010. To reflect a change in terminology, this policy now refers to Electronic Logging Devices or ELDs)

   • All heavy trucks operating within Canada, or into and out of Canada, should be equipped with ELDs to improve compliance and level the playing field with respect to hours of service regulations.

   • All efforts should be made to create a national ELD standard as consistent as possible with the US ELD Rule.

   • Enforcement authorities should work with industry to establish consistent enforcement protocols and to accept electronically produced driver trip inspection.

   • The Canadian ELD mandate, both at the federal and provincial level, should require compliance as soon as possible as the US mandate is already in force, but no later than December 2019. (Added December 2017)

3. Distracted Driving (September 2009)

   • BC’s laws prohibiting the use of hand-held communications devices while driving should be aligned with those in other Canadian provinces.

1. Truck Driver testing and licensing (2008)

   • ICBC should establish a minimum curriculum for driver training schools providing Class 1 driver's licence training.

   • ICBC should raise the minimum standard for instructors of Class 1 driver's licence training.

   • ICBC should raise the Class 1 driver's licence testing standard.

   • ICBC should introduce a Professional Driver endorsement for the Class 1 driver’s licence to identify individuals who meet an industry occupational standard.

2. Truck Driver entry-level and on-going training (May 2012)

   • The National Occupational Standard classification code for truck drivers should be raised from unskilled to semi-skilled.

   • The provincial government should establish a minimum occupational training standard for professional truck drivers based on the new NOS for a Professional Truck Driver.

   • Professional drivers should be required to undergo continuing training/education/professional development throughout their career in order to maintain a Class 1 Professional Driver endorsement.

   • The provincial government, in consultation with industry, should develop mechanisms for financing truck driver training with costs shared by industry, government and the student.

3. Driver Records (2005)

   • A national commercial driver licensing information system should be established that would, at a minimum, possess the following attributes:

     • provide comprehensive driving performance and licence status information on persons with commercial vehicle driver licences;

     • provide a database of drivers who are disqualified anywhere in North America;

     • provide companies with electronic/Internet access to driver abstracts;

     • notify companies of all infractions pending against drivers and owner-operators immediately when a ticket has been issued for a commercial vehicle infraction;

     • notify companies immediately when a conviction has been obtained;

     • include information on Immediate Roadside Prohibitions (IRPs) and other 24-hour administrative prohibitions; and

     • record convictions, crash data and disqualifications on abstracts in a timely manner.

   Until such a national database is available, commercial driver infractions from jurisdictions other than BC should be recorded on driver abstracts. (Note: these are currently recorded on the trucking company’s National Safety Code record.)

4. Alternative methods of disputing violations (August 2001)

   Due to the long-distance nature of work performed by trucking companies and drivers, the provincial government should provide alternative methods for drivers to dispute violations under the Motor Vehicle Act and Commercial Transport Act (e.g., by telephone, video, affidavit or a change in venue to a court closer to their home).

A transportation system that supports the efficient movement of goods and people is crucial to the economic health of the Metro Vancouver region and to its attractiveness as a gateway. As such, the regional transportation system must be planned, managed, and funded in a manner that is cost effective, financially sustainable, and fair to system users and taxpayers. To that end, the BC Trucking Association (BCTA) calls on the public agencies responsible for managing, building, and delivering Metro Vancouver’s transportation system to:

1. Develop an integrated, coherent freight transportation strategy for the region that is based on a sound economic strategy and a unified, integrated, and coherent land use strategy. The freight transportation strategy would inform infrastructure funding needs.
2. Introduce and support policies that encourage more productive use of current road infrastructure by, specifically:

• establishing a region-wide traffic incident and enforcement activity management protocol,
• prohibiting on-street parking on major commercial corridors,
•  removing restrictions and developing incentives to encourage 24-hour use of infrastructure,
•  measuring, monitoring, establishing, and making publicly available minimum levels of service for major corridors, and developing and implementing measures to maintain these levels of service,
• investigating and, where appropriate, implementing Intelligent Transportation Systems (such as more efficient programming of traffic lights) to facilitate smoother traffic flows.

3. Given the public and economic benefit of an efficient road transportation network, establish an appropriate and fair proportion of financial support that should be provided by individual user groups.
4. Given that public transit is a necessary component of an efficient urban transportation network, ensure public transit is a convenient, accessible, and safe option for personal travel, and is delivered in a financially sustainable manner.
5. Develop a clear and transparent understanding of road user taxes and fees currently collected in Metro Vancouver, including fuel taxes, vehicle registration fees, parking taxes, traffic fines, and tolls.
6. Determine in a transparent and understandable fashion, the appropriate annual budget for operation and maintenance of major and critical road infrastructure and public transit in Metro Vancouver.
7. Ensure that revenue collected from road users is primarily dedicated to operating, maintaining, and upgrading major and critical road infrastructure, and that any use of revenue collected from road users to support other modes has a measurable benefit to road users.
8. Incorporate funding for new infrastructure into a mobility pricing scheme given that project tolls (i.e. tolls on a specific bridge or roadway) are likely to cause diversion to non-tolled routes.
9. If a gap between how much is collected and how much is required is identified, determine the most practical, fair, and efficient mobility pricing scheme under which:

1. road users that have no modal choice (e.g., freight transporters) would pay an appropriate share,
2. road users that have a modal choice (e.g., single occupancy vehicle operators) would be encouraged to pay an appropriate share AND incented to use other means of transport,
3. all road users, including those based outside the region, would be subject to mobility pricing in the region.

10. Ensure that the system for collecting road user fees under a mobility pricing scheme is administratively simple, transparent, reliable, cost effective, and integrated across different levels of government that own transportation infrastructure in Metro Vancouver– municipal, regional, provincial, and federal.

(April 2015)

1. Permit fees (2005)

   • Permit fees should relate directly to the additional “consumption of infrastructure” in the case of overweight loads, but other over-dimensional load permits should be priced to reflect the government resources required to issue a permit (e.g., time required for a permit request to be reviewed and the administrative cost of physically issuing a permit).

2. Provincial Permit Policies and Conditions (December 2012)

   • Provincial permit policy and permit conditions that apply to Oversize/Overweight vehicles should be amended to:

     • add pre-approved North-South routes for overall height up to and including 4.88 m in the Lower Mainland and change the OAH range on CVSE1010 from 4.30 m to to 4.87 m to a range of 4.32 m to 4.88 m;

• expand vehicle dimension envelopes for T-Forms to shift some approvals out of the Extraordinary Load Approval Process;

• Extraordinary Loads are vehicles/loads that:

• exceed 64,000 kg on non-approved overload routes (load must be stripped or fully reduced in order to obtain an approval);

• exceed 85,000 kg;

• do not comply with policy limits specified in the Commercial Transport Procedures Manual;

• are an oversize non-reducible load travelling more than 110 km;

• exceed 4.4 m wide, except on pre-approved routes described in the CVSE1001, 1002, or 1003 forms;

• exceed 4.88 m high (5.33 m in the Peace River Region), or exceed any policy height limit;

• exceed 40 m in overall length (except Lower Mainland).

• change the outer vehicle envelope dimensions to align more precisely with imperial conversions;

• for pilot car travel requirements, focus on physical infrastructure characteristics (such as the number of lanes on a highway), rather than prescribing a time of day or night;

• streamline and where possible, reduce the minimum number of pilot cars required for the movement of a particular vehicle combination; and

• increase operating hours for oversize/overweight loads and Extraordinary Loads by amending travel time restrictions. 

3. “60 foot” trailers (March 2016)

   • The use of extended length semi-trailers up to 18.45 m (60.5 foot) long, which are also commonly referred to as “60 foot” trailers, should be subject to a permit requirement under BC’s Long Combination Vehicle (LCV) Program.

     • The LCV program provides an additional level of oversight and control to ensure safe operation (by requiring the driver to have a minimum level of experience operating articulated vehicles, requiring additional driver training, certification, and periodic re-certification, and requiring the carrier to be in good standing with the National Safety Code).

(Note: policy positions 1 thru 6 were adopted in 2008)

1. Education and Outreach

   • The provincial government, in cooperation with industry, should:

     • facilitate the distribution of reliable, factual information on best practices and products to attain maximum fuel efficiency;

     • establish a database of fuel-efficiency devices and engine performance with a focus on applicability to BC and independent test results, and coordinate the database with similar programs across North America;

     • develop a fuel advisory program (similar to LiveSmart energy advisor for homeowners) to allow trucking companies to have a baseline understanding of their fuel consumption and opportunities to reduce fuel usage;

     • provide access to expertise, technical specifications and products (telephone, storefront and mobile demonstration centres);

     • offer driver training sessions (town hall meetings and focused workshops);

     • develop a carrier recognition program to recognize operators with “best in class” fuel-efficiency programs, including an outline of “best practices” to be made available to the industry; and

     • work with the shipper community to help improve freight movement efficiency and reduce delays and idling through such things as improved scheduling and off-peak delivery opportunities.

2. Incentives for Fuel-efficiency Devices

   • To help the trucking sector overcome financial barriers to investing in new technologies, the provincial government, in cooperation with industry, should offer a financial incentive program for the installation of fuel-efficiency devices such as auxiliary power units (APU), heaters, and aerodynamic units.

3. Taxation and Fee Strategies

   • To encourage fuel efficiency in the trucking sector, the provincial government should implement the following tax and fee incentives:

     • tax credits for fuel-efficiency training courses and for purchasing learning tools for fuel-efficiency training;

     • provincial sales tax exemptions for fuel-efficiency devices, including APUs, tire inflation systems, wide based or low rolling resistance tires, and lightweight tire rims;

     • consider issuing over-height or over-width permits on a fleet basis, rather than per truck, to encourage productivity;

     • ensure that tax exemptions are considered for new fuel-efficiency enhancing technologies as they are brought to the market; and

     • implement vehicle licensing fee exemptions for newer model trucks.

   • The provincial carbon tax collected from the trucking industry should be used to provide incentives to help the industry adopt fuel saving technologies and strategies.

   • The federal government should implement tax measures to accelerate the acquisition of new trucks and after-market fuel-efficiency technologies, including:

     • accelerated capital cost allowances for new tractors and trailers;

     • rebates for hybrid and liquified natural gas (LNG) trucks; and

     • GST exemptions for aftermarket technologies and hybrid and LNG trucks.

4. Regulations and Policies

   • The provincial government should review the following proposed regulatory and policy changes to identify the financial and greenhouse gas (GHG) benefits and costs, the impacts on provincial infrastructure, and implications for the Trade, Investment, and Labour Mobility Agreement (TILMA):

     • Promote increased utilization of fuel-efficient Long Combination Vehicles (LCVs) by establishing standard criteria for evaluating new LCV routes, and by making infrastructure upgrades where necessary to meet the established LCV route criteria.

     • Permit new generation single wide-based tires (also known as “super-single” tires) at full axle weights (8,500 kg) rather than the current limit of 7,700 kg.

     • Introduce a more flexible reducible-load permit policy to take advantage of opportunities where trips can be reduced by allowing trucks to carry more width.

     • Establish more flexible rules on non-driving axles for tridem drives and manual lift/pin-up axles to allow truck owners to maximize the fuel efficiency of their vehicle.

     • Provide a limited-time weight allowance of up to 250 kg, above current maximum weights, for the particulate filter traps required on 2007 and newer trucks, in order to encourage the purchase of newer, less polluting trucks.

     (Note: the following policy positions were adopted in September 2015)

     • Extend tractor wheel-base limits to a maximum of 7.2 m for single semi-trailer combinations and a maximum of 6.8 m for double trailer combinations (wheel base offsets may be required).

     • Extend engine “limp mode” standard to allow drivers sufficient time to travel to a safe destination prior to engine shut down.

     • Increase steering axle weights from 6,000 kg to 6,300 kg for single semi-trailers and 6,700 for double trailer vehicle combinations (i.e., B-trains).

     • Adjust weights and dimensions regulations to account for the additional weight and space required to use batteries as an anti-idling strategy.

     • Require Original Equipment Manufacturers to provide plug-ins as standard equipment to accommodate use of shore power.

     • Research and test new light-weight trailer material and manufacturing methods to ensure there are no unintended negative consequences such as shorter trailer life or unreasonably higher costs. No specific material should be mandated.

     • Jointly research with industry and manufacturers the GHG emissions reduction impact and the suitability of using 6X2 axle technology and “smart” lift axles on straight trucks and tractors as well as trailers.

5. Alternative Energy Sources

   • The provincial government should encourage the transition to alternative fuels in the trucking sector by considering the implementation of the following policies:

     • continuing to exempt biodiesel and other alternative fuels from provincial motor fuel tax and set up a mechanism to allow for automatic consideration of tax exemptions for new alternative fuels as they are discovered; and

     • creating fuelling infrastructure for alternative fuels.

6. Improved Utilization of Existing Infrastructure

   • The provincial government should maximize the efficiency of BC’s highway network by:

     • continuing the development of the 85,000 kg heavy haul corridor to allow for the efficient movement of super-sized and overweight loads;

     • developing and implementing a provincial freight transportation plan that considers ways to mitigate the impacts of congestion on truck movements, including truck-only lanes, traffic incident management, incentives for freight shippers and receivers to extend hours of operation, and by working with municipalities to support goods movement through improved bylaws and designated truck routes; and

     • working with Port Metro Vancouver and its terminal operators to reduce number of empty trips and identify reservation policies that cause idling and wait times for trucks.

7. Dismantling environmental equipment (May 2012)

   • The federal ministers of Environment and Transport should take steps to understand the extent of the practice of disengaging environmental controls on heavy duty diesel engines, and identify the appropriate enforcement activities and penalties for those companies and individuals engaged in this illegal activity.

8. Heavy duty vehicle emissions testing (1994)

   • AirCare type emissions testing should not be applied to heavy commercial vehicles on the grounds that it would be onerous and costly to the industry, and unnecessary because a) as older vehicles are retired and replaced with newer, less-polluting equipment, emissions will naturally decline and b) experience elsewhere suggests the failure rate would be less than 5 percent.

9. Biodiesel – Renewable Fuel Requirement (September 2008)

   • BC should adopt a standard of 2 percent biodiesel aligning it with the federal standard. Failing that, the provincial government should set the provincial bio-diesel standard at no more than 5 percent, as opposed to a province-wide average of 5 percent.

   • All available fuels should be as energy intensive as possible to allow the industry to be as fuel-efficient as possible.

   • Fuel retailers should be required to label the bio-diesel on pumps to allow commercial vehicle operators to make informed decision regarding choice of fuel.

10. Low Carbon Fuel Requirements (September 2009)

    • The regulation should not result in any unintended negative consequences for fuel users.

    • The low carbon fuel mandate should not negatively impact the operation of engines or void warranties.

11. Glider Kits (October 2012)

    • Trucking companies should retain the right to use glider kits for their intended purpose of repairing or rebuilding a significantly damaged vehicle.  The federal government should develop a regulation that prohibits glider kits from being used to circumvent emissions regulations by, for example, installing an older-model engine while retaining the original Vehicle Identification Number and other original labelling and documentation.

1. Infrastructure development

   • The provincial government should continue to invest in improving BC’s highway network and give priority to the investments that will generate the greatest economic and safety benefits.

2. Rest stop development and maintenance (September 2011, updated March 2015)

   • As rest stops are essential to the health and safety of commercial vehicle drivers, the provincial government should improve the availability and quality of rest stop facilities on main highway and arterial corridors around the province. Rest stops should:

     • be provided within 50 km from urban centres and at a maximum of 150 km intervals thereafter. Ideally, the interval would be 80 km, which was determined to be a suitable distance based on US and Australian research;

     • be clearly marked with signs that indicate distance to the rest area, and in the event that it is located off-route, directions to the rest area, as well as the distance to the closest next rest area;

     • have sufficient parking to accommodate commercial vehicles for short rest-stops and longer over-night stops;

     • have truck parking bays that are well separated and clearly marked when combined with general purpose rest areas;

     • have truck parking bays that are arranged parallel to each other and at an angle to ease access and to maximize the number of spaces; and

     • should include basic amenities such as washrooms, food service, tables, internet access, and facilities that provide protection from the elements (shade, rain cover, etc.).

   • The provincial government should consider public-private partnerships and other ways to facilitate and incent the development of new rest stops.

3. Roundabouts (December 2012)

   • The provincial government should consult the trucking industry on all roundabouts proposed for provincial highways.

   • Roundabouts should be capable of accommodating all vehicle types expected to use the roundabout, including oversize/overweight vehicle combinations, to allow them to move through the roundabout safely, efficiently, and without damaging the vehicle or the load.

1. Joint Action Plan review (September 2017)

   • The 2014 Joint Action Plan requires a comprehensive but rapid review to develop a long-term, sustainable solution, in consultation with all stakeholders.

   • This review should incorporate data transparency and mutual accountability of all supply chain participants with the goal of optimizing efficiency and cost competitiveness for the entire supply chain, rather than its individual components (as is the case today).

   • An updated Plan should also address emerging issues and/or provide a mechanism for modifications to the Plan to ensure maximum supply chain efficiency.

2. Marine container terminal performance standards and accountability (September 2017)

• A regulatory or policy solution should be developed to ensure a level playing field between marine container terminal and trucking companies. This should include:

  • establishing transparency related to marine container terminal charges and fees;

  • a mechanism to develop, measure and enforce performance standards for servicing drayage trucks; and

  • a mechanism for dispute resolution between marine container terminals and trucking companies that is unbiased and transparent.

3. Elimination of economic regulation for the container trucking sector (September 2006, updated September 2017)

• As a long-term goal, and once the drayage sector is sufficiently stable, economic regulation for the drayage industry should be eliminated as it does not exist in any other part of the trucking industry, nor does it address the underlying cause of a withdrawal of services by employee drivers or owner-operators.

1. ICBC risk-based pricing

   • ICBC should move more aggressively towards a system of risk-based premium pricing for commercial customers.

2. Anti-indemnification (September 2011)

   • Transport Canada should examine the federal Conditions of Carriage Regulations with a view towards amending it to protect federal carriers from anti-indemnification clauses.

   • The BC government should consider amendments to the provincial Motor Vehicle Act and its Regulations to protect BC-based trucking companies from anti-indemnification clauses.

Project Tolls (December 2015)

Tolls on highways, roads, and bridges outside Metro Vancouver should be considered only where the following conditions are met:

• Tolls are used to pay the capital costs of new infrastructure. When the infrastructure has been paid for, tolls should be removed.
   
• Candidate infrastructure must be of significant provincial or national importance.
   
• Project tolls are not to be placed on existing infrastructure.
   
• An alternative route – free of tolls – must exist for any proposed toll route.
   
• Under no circumstances would trucks and motor coaches be forced to use the toll route.
   
• Tolls would be applied to all vehicles – cars, trucks, etc.
   
• Tolls would be collected using the most advanced, available and standardized technology to avoid the inefficiencies associated with tollbooths, etc.
   
• Tolls should be set at different levels for peak (i.e., daily rush hour) vs. non-peak traffic.
   
• Provincial or federal fuel and/or other user taxes and fees should not be collected for distances travelled on a toll route.
   
• Tolls on trucks and motor coaches must apply equally to all carriers regardless of domicile.
   
• All financial details regarding the costs and revenues associated with a toll route should be fully disclosed to the public.

Safety: National Safety Code (2010)

• The National Safety Code (NSC) program should be based on the following principles:

  • NSC standards and processes are designed, implemented and managed to ensure that, from a safety perspective, only knowledgeable and responsible carriers are allowed to enter and remain in the trucking industry.

  • Government should be responsible for developing and maintaining fair and reasonable NSC standards and keep industry informed and up-to-date. It is industry’s responsibility to develop and maintain a sound knowledge of, and to adhere to, these standards. Ignorance of the NSC should not be an acceptable justification for non-compliance.

  • Enforcement of the NSC standards should be based on a level playing field amongst carriers regardless of domicile, fleet size or industrial sector.

  • The cost (consequences) of non-compliance with the NSC should be greater than the cost of investing in safe practices, drivers and equipment.

  • Potential economic and financial consequences associated with NSC penalties and cancellations should not be mitigating factors in NSC disciplinary processes. Carriers and shippers who, by commission or omission, make poor choices regarding matters of public safety should live with these consequences.

  • Reasonable but firm expectations imposed on new NSC entrants at the application stage should relieve the burden on the downstream monitoring, enforcement and disciplinary stages.

Cross Border: Aldergrove Commercial Port of Entry (May 2009)

• After the new facility at the Aldergrove Port of Entry is complete, Canada Border Services Agency (CBSA) should maintain commercial operations and consider expanding commercial operations in the long-term to accommodate increased cross-border truck volume as Fraser Valley’s population and economy grow, and as commercial trucking companies increasingly locate their base of operations further inland.