Thank you, Mr. Chair.

I would like to pay my respects to the members here today.

My name is Daniel Breton and I am the President and CEO of Electric Mobility Canada.

Founded in 2006, EMC is the national membership-based industry association dedicated exclusively to promoting electric mobility as a means of supporting the Canadian economy while fighting climate change and air pollution.

EMC's wide range of member organizations include manufacturers of light, medium, heavy-duty and off-road vehicles; electricity suppliers; infrastructure providers; research centres; tech companies; mining companies; cities; universities; fleet managers; unions; etc.

Among its 160 members are companies that manufacture off-road electric vehicles here in Canada, such as snowmobiles, personal watercraft, ATVs, pleasure boats, airport vehicles and more.

In October 2022, the economic statement delivered by the Minister of Finance announced a refundable 30% clean technology investment tax credit for zero-emission non-road vehicles. However, Bill C‑32, Fall Economic Statement Implementation Act, 2022, did not contain any provision for the tax credit that had been announced.

In November 2023, the economic statement delivered by the Minister of Finance referred to the 2022 economic statement and the legislation concerning the refundable 30% clean technology investment tax credit for zero-emission non-road vehicles, saying that the credit applied to eligible property acquired and available for use on or after March 28, 2023, and before 2035.

Let us now analyze the terminology used in the 2022 statement. It says:

The following types of equipment would be eligible for the credit: ... non-road zero-emission vehicles described in Class 56 (e.g. hydrogen or electric heavy duty equipment used in mining or construction) and charging or refuelling equipment described under subparagraph (d)(xxi) of Class 43.1 or subparagraph (b)(ii) of Class 43.2 that is used primarily for such vehicles.

Regardless of how we may interpret the content of the statement, it is important to understand that this kind of document, just like the announcement of a policy or plan of action or directive, does not have force of law.

Bill C‑59 provides for the addition of section 127.45 to the Income Tax Act. That proposed section contains a new definition of "clean technology property," which refers, under proposed subparagraph (d)(iv), to "a non-road zero-emission vehicle described in Class 56."

It’s important to note that off-road vehicles are a disproportionate source of air pollution. According to ECCC, their combined emissions make up 38%, 15% and 10% of the total emissions of CO, NOx and VOCs respectively. Carbon monoxide and NOx are volatile organic compounds. Emissions come mostly from the household use of gasoline-powered or diesel-powered recreational equipment and lawn and garden equipment and from the operation of agricultural, construction and mining equipment.

Since 2022, however, we have tried without success to get a clear, exhaustive definition of what a non-road zero-emission vehicle is, to the government's mind. After numerous communications with government officials by email, telephone and ordinary mail, we have still not been able to obtain a satisfactory answer.

Since Canada has a growing number of companies that are developing and building these zero-emission off-road vehicles, creating jobs and selling in Canada and abroad a growing variety of them—snowmobiles, watercraft, recreational boats, ATVs, airport vehicles, unregistered vehicles and mining vehicles, all electric and off-road—it’s important to ensure that the definition we propose does include such vehicles so that these Canadian technologies are encouraged that these vehicles and their workers can benefit from the proposed new measures.

What's more, it's vital that the companies purchasing these off-road vehicles be able to obtain this 30% tax credit and that this tax credit be retroactive to March 28, 2023.

Thank you.

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