To: Ministry of Energy, Mines and Low Carbon Innovation 

By email: cleantransport@gov.bc.ca 

From: BC Sustainable Energy Association 

Date: 5 April 2023 

Re: Input Toward a BC Clean Transportation Action Plan 

The BC Sustainable Energy Association (BCSEA) is pleased to submit these  comments toward the development of a BC Clean Transportation Action Plan  (CTAP).1 

BCSEA welcomes the Provincial Government’s development of an action plan  that will introduce new measures, and strengthen existing measures,2 to reduce  GHG emissions from BC’s transportation sector. As stated in the Ministry’s  consultation document, transportation is the largest source of GHG emissions in  BC and emissions in this sector are rising. BCSEA considers that achievement of  the Government’s GHG reduction target for the transport sector3 will be critical to  the overall success of BC’s climate action work. 

In this letter, BCSEA makes four general comments, and then addresses the  questions in the consultation document. 

1.General comments 

First, BCSEA supports the broad definition of the transportation sector set out in  the consultation document: “The transportation sector comprises all classes of  on-road vehicles, and off-road vehicles such as those in mining, agricultural,  forestry, port/airport, and construction, domestic marine vessels, domestic  aircraft, and domestic rail.” Notably, this definition includes the movement of  goods and materials as well as the movement of people. And the definition  includes off-road, marine and air modes in addition to road transportation.  

Second, BCSEA supports the multi-faceted themes identified for the  transportation actions in the Roadmap: “Reduce distances traveled (vehicle                                                          

1 (Consultation Document). 

2 E.g., Zero-Emission Vehicles Act, Low Carbon Fuels Act, Active Transportation  programs, initiatives to integrate transportation and land use planning, and the suite of  Go Electric programs. 

3 A transportation sector GHG emissions reduction target of 27-32% by 2030, relative to  2007.

kilometers traveled (VKT)), Shift to more efficient modes, Improve vehicle  efficiency, Adopt zero-emission vehicles (ZEVs), and Use cleaner fuels.”4 

Third, regarding the target reduction of 25 percent in vehicle kilometres travelled  (VKT) BCSEA commends to the Ministry the BC Climate Solutions Council’s  recommendation to prioritize policies that have the greatest promise to deliver  not just reduced VKTs but also the GHG reductions need to meet B.C.’s target.5 

Fourth, BCSEA suggests that the action plan should address the “resiliency” of  the BC transportation system. This would include: 

• identifying climate-related and other threats to BC’s transportation system, • developing resiliency criteria for BC’s transportation system, and • Developing a vision and conceptual framework for resiliency planning for  BC’s transportation system. 

Responses to Questions 

1. Reduce Distance Traveled and Increase Mode Shift  

a) What are the key Provincial policy actions that need to be considered to  achieve the VKT reduction and mode share targets, including in relation to the  built environment/community design? 

BCSEA suggests that the BC Government should: 

• prioritize its support for transit, active transportation, micro-mobility and  walkable communities, and reduce its spending on highways; • strengthen its measures aimed at increasing the compactness of urban  and suburban design; and 
• increase its support for inter-regional bus and rail connections for  passengers, for example, passenger service on the Vancouver-Whistler  rail line and on the Victoria-Courtney rail line.  

b) What are the barriers, if any, in achieving these targets? 

BCSEA highlights the following barriers to reducing BC’s VKT and shifting  transportation modes: 

• It takes time to reduce VKT through densification and reducing urban  sprawl. 

4 Consultation Document, p.1. 

5 Mind the Gaps: Accelerating the Implementation of the CleanBC Roadmap to 2030,  2022 Report of the BC Climate Solutions Council:  

• Implementing multi-mode transportation systems and shifting the focus land use planning requires coordination and buy-in from many different governmental and non-governmental entities. 

• Meeting the provincial targets for reducing VKT will require education and motivation of the general public. 

c) What are the key actions your organization or sector can do to help achieve  the VKT reduction and mode share targets, including actions in relation to the  built environment/community design? 

BCSEA can help reduce BC VKT by providing information and public discussion  of climate change and energy transition issues that can help to build a social  consensus of the need to change. For example, BCSEA provides the Cool It!  Climate Leaders program in middle and high schools; BCSEA provides public  webinars on topical issues; and BCSEA advocates for sustainable energy in BC  Utilities Commission proceedings. 

2. Adopt ZEVs  

a) What are the key Provincial policy actions that need to be considered to  achieve the ZEV targets? 

BCSEA suggests that the BC Government should: 

• Increase the effort to reduce GHG emissions from short range commercial freight transport and heavy duty freight and material movement. This  would include electrifying drayage and the increased use of short-sea  shipping (electrified if possible) as an alternative to road transportation.  Support this work with incentives and tax credits; 

• Increase ZEV rebates and purchase incentives for new light, medium and heavy-duty ZEVs; and 

• Expand the EV fast charging network in the Province in accordance with  the goals set in B.C.’s Electric Highway to ensure full coverage in rural  and remote communities as well as urban and suburban centres. 

3. Use Clean Fuels  

a) What are the key Provincial policy actions that need to be considered to  achieve the low carbon fuel target? 

BCSEA recommends that the BC Government: 

• Continue work to decarbonize liquid fuels,  
• support the development of low carbon liquid fuels, and  
• develop a vision and concept for the end game for liquid fuels, i.e., how  the necessary GHG emissions reductions beyond 2030 will be achieved  and how liquid fuels will fit in.

4. Prioritization of recommended actions 

Which of the actions you have identified in questions 1-3 should be prioritized  and why? 

BCSEA would prioritize: 

• Shifting taxpayer spending toward transit and active transportation and away from highway expansions. 

• Developing a convenient multi-mode provincial transportation system, focused on transit, active transportation and walkable communities, with good connections between modes. 

• Extending the ZEV Act to cover larger pick-up trucks and medium duty commercial vehicles.  

5.  Affordability and equity  

Do you have any suggestions to help improve affordability and equity in British  Columbia as part of the CTAP? 

BCSEA considers that the best way to improve affordability and equity for clean  transportation in BC is to foster a convenient multi-mode provincial transportation  system, focused on transit, active transportation and walkable communities, with  good connections between modes. 

Sincerely,

Tom Hackney, Policy Advisor