Dec 24
Requesting Comments on Bumpers 215!
- For the Use of CWB members and supporters. We plan to provide our comments to Transport Canada just prior to the closing period December 31st, 2007. Please feel free to use the comments section of this post, all input will be considered by the members of our team preparing the submission.
- Notice requesting Comments on the intention to amend section 215 , “bumpers” of the Motor Vehicle Safety Regulations
- standard215.pdf
- Link to TC site as well
December 24th, 2007 at 8:37 am
The following statement in the Notice ….
“This is why the Department needs to ensure that there is a demonstrated net benefit to Canadians if pursuing a non-harmonized approach.” is consistent with their efforts to ensure that there will be no harmonization. Mr. Kash is on record as having stated that there are certain standards which TC is unwilling to harmonize. Why we need a different standard than the Americans is beyond me. How does one get the Fifth Estate to do a story on the decisions of Transport Canada.
I think the following is window dresssing….
“The Department’s purpose in publishing this notice is twofold: first, to summarize the evolution of the Canadian bumper standard since it was first introduced in 1972, including the explanation for why the Canadian bumper standard is currently in disharmony with the U.S. and European requirements; and second, to outline the various options to rectify this and provide an opportunity for the Canadian public and other stakeholders to comment on potential amendments.”
Who supported harmonization and who specifically opposed the change…is the identity of those in support and those in opposition public information or for TC use only? “On May 14, 1983, Transport Canada published in Part I of the Canada Gazette a proposal to partially harmonize its bumper requirements with those of the United States by lowering the velocities of the barrier and pendulum bumper impact tests to the same values as those of the United States. This would have also brought the Canadian speeds for the pendulum tests closer to those of ECE Regulation No. 42. However, the Department received significant opposition from the provinces and territories, the public, the media and the insurance industry with respect to the proposed lowering of bumper impact velocities. This opposition resulted in the Department withdrawing its proposal on August 3, 1985, and the Department not harmonizing its bumper standard impact test speeds with those of the United States and the UNECE. This divergence still exists today.”
On a positive note the Notice states…
“A harmonized world bumper standard would reduce the burden on industry by allowing manufacturers to design, test and produce products to one set of standards.”
Existing standard is not supported by TC so expect some change but will it result in harmonization…. “From a cost-benefit perspective, Transport Canada has been unable to justify why the Canadian bumper standard should continue to be more stringent than those of the United States or the UNECE. In the absence of evidence that the benefits of the Canadian bumper standard exceed the cost to society resulting from it, maintaining the standard unchanged would not appear to constitute an appropriate solution.”
December 24th, 2007 at 12:22 pm
See Transport Canada’s position…..
“Canada has unique bumper requirements (damageability) and is not currently planning to harmonize this standard.”
which has been enunciated as late as May 4 2007 in its role in the
Canadian Automotive Partnership Council
Regulatory Harmonization Working Group
Progress Report - May 4, 2007
http://capcinfo.ca/english/reports/documents/2007/RegHarmon_e.pdf
and
Vehicle Manufacturers in the North American Environment
Security and Prosperity Partnership of North America
Canadian Automotive Partnership Council
June 2005 http://capcinfo.ca/english/reports/report_jun28_05.html#impact
(2) CMVSS 215 – Bumpers
May 4, 2007 Report
- Canada has unique bumper requirements (damageability) and is not currently planning to harmonize this standard.
- This requirement has precluded products from the Canadian market; these are generally low volume or cost sensitive products.
June 2005 Report
- There is no evidence that (ed. Canadian motor vehicle) bumper standards provide any measure of on-road safety and therefore the standard is simply a damageability requirement that provides no safety benefit.
- In order for manufacturers to build a vehicle for both the Canadian and U.S. markets, it must be tested to both standards. This increases vehicle development cost and in some cases can and does result in limiting the choice of vehicles for Canadian consumers, particularly when projected Canadian sales volumes do not justify the additional engineering and testing resources to certify to the unique Canadian requirements.
- Canadian standards stipulate an impact to the front or rear of the vehicle at 8 km/h (5 mph) and pendulum impacts on the corner of the vehicle at 4.8 km/h (3 mph). The Canadian test allows for minimal exterior damage as long as there is no damage to or degradation of the performance of the overall vehicle safety systems or vehicle performance.
- The U.S. standard, by comparison, requires front and rear impacts at 2.5 mph (4.0 km/h) and pendulum corner impacts at 1.5 mph (2.4 km/h) - only half the speed of Canadian tests. The U.S. test permits no damage or permanent deformation of the vehicle, other than cosmetic scratches on bumper covers and sight shields.
What can we each do to convince Transport Canada to accept whatever the US is doing and not have a regulation created that will create another non-tariff barrier that is not in the best interest of the Canadian citizen?
I am emailing my MP, the Minister of Transport, et al. What else.
We need more articles like the Globe and Mail article. The content of local papers is heavily influenced by the auto dealers advertising dollar.
December 24th, 2007 at 2:19 pm
Those Canadians who imported Corvettes (2005 to 2007), (as documented on the Corvetteforum.com) a bumper modification was needed as per RIV. The parts in Canada (consisting mainly of new foam under the bumper covers) from a Canadian dealer cost consumers about $800 plus two or so hours labour to install while the same parts were available from US dealers for $250.
Today the on the revised RIV, the comment for 2008 Corvettes is inadmissible due to bumpers. Those who checked found that the same parts that fit a 2007 will fit a 2008. So again it’s a scam by GM for not declaring or TC for not understanding.
The point is, bumpers can be easily modified.
As for the reason for differences, why bother. At those parking lot speeds we are not talking safty but rather levels of damage. At almost any low speed modern urathane bumpers are damaged and need expensive repaire for a deept scratch or tear. What is the value of having a different standard?
December 25th, 2007 at 11:10 am
I’d like to know why we are constantly being bombarded by country-specific requirements that simply drive up the cost of our vehicles?
The Canadian market is 10% that of the US one and as such the administrative costs of maintaining a country-specific requirement for a vehicle is ten times that of the US on a per-capita basis. Additionally manufacturers will require a separate set of compliance tests - all passed on to the consumer.
Does gravity and momentum affect bumpers in the US differently than Canadian gravity and momentum? If not, then why do we need a separate set of standards? Different parts will cost more than their US counterparts because of the short production runs involved, so what’s the point of mandating bumpers that survive slightly faster collisions better?
Will lives be saved as a result of this proposed change If yes, what is the overall administrative cost and extra cost to society of the vehicles?
If no, why are you messing with something that isn’t broken?
Has ANYONE provided an overall cost-benefit analysis? What percentage of cars will benefit from the improved standards? In other words, how many bumpers will be saved by changing the standards. How much more will cars and the repairs cost when compared with maintaining the US harmonised one?
Looking at the overall population of cars, it makes little sense to charge everyone more money for their cars AND more emoney in the event of a repair in order to save a small number of drivers the need to repair their cars after a low speed contact.
Government is paid for by the people. For our much higher taxes we deserve an EFFICIENT burocracy. It is high time that our supposed representatives started to manage OUR resources in a cost-efficient manner FOR US and, where our neighbouring country has a standard and, unless maintaining that standard can be scientifically demonstrated by an interested party to put the population at somehow increased risk it should be automatically adopted for Canadian vehicles.
In this way we can benefit from US research and US DOT testing and enforcement, saving Canadian citizens the cost of duplicating the administration of these standards.
As things stand, about the only risk that we as Canadians will suffer is that of higher costs, taken directly from our bottom lines.
It should be official policy that Canadian vehicles meet US general standards - for example, what’s this stupidity of Quebec somehow planning to mandate that cars THERE meet California emission standards? Isn’t this a Federal mandate? That’ll kill interprovincial car sales and jack up costs even more for Quebecois - only the highest taxed jurisdiction on the continent.
We need LESS regulation, not more.
Yes, I know it goes against Government’s concept of ‘we need to employ as many people to do as little work as possible’, but it IS my money you’re spending.
December 25th, 2007 at 2:48 pm
Canadians must realize that our government,in particular, Transport Canada, started many years ago, to deliberately deharmonize standards, to stop individuals and small independent dealers from importing and exporting. What needs to be better known, is who, within Transport Canada are the individuals who started this process, who are the individuals, at the various auto companies, who influenced them and what renumeration was, received, by whom, in exchange for doing this. Someone needs to start calculating and adding up the extra profits these companies have made out of this, going back many years. By preventing individuals from accessing certain regions of the marketplace, where prices are lower, whether, it be in Canada, as it was, for a few years, or the U.S., where prices are currently dramatically lower, the manufacturers can and are, at this time, holding up incredible markups of, in many cases, $20,000.00-$30,000.00 extra profit on each vehicle. Multiply these amounts, by the numbers of vehicles sold, going back, for example, twenty years and then try to determine how much money has been available, out of these extra profits, to influence and or, bribe government officials. The numbers are staggering. As has been posted this morning, on this website, VW was fined $111,000,000.00 in Europe, for doing exactly the same things, over there, as are being done here. The government of the European Community was, in that case, looking out for the interests and wellbeing of the people of Europe and acted, to protect it’s people, from the unscrupulous, dishonest and illegal behavior of certain auto companies. It raided the offices, of not only VW, but of several major car manufacturers, seized documents, laid charges, prosecuted and fined these companies many millions of dollars, each. In Canada, however, it is the government, that has actually been involved, for more than thirty years, in helping the manufacturers to stop people, who live in one region, from buying cars in another region. It should be with no surprise therefor, that our government has, so far, remained absolutely silent, on it’s own involvement in this corruption and has so far made no moves, whatsoever, to put a stop to this illegal activity,for it is the government itself, that is a part of this activity. Canadians deserve and must have, a properly conducted public inquiry, to uncover the long standing corrupt activity that has taken place. Such an inquiry must address the enormous profits made by the corporations involved in this corruption and give some serious consideration to using substantial fines and the money derived from such fines, to compensate Canadians. Many small independent auto dealers in Canada have been seriously hurt, by being literally cut out of the market place, unable to import, or to export. Thousands of Canadians citizens have been hurt, by being denied access to lower priced vehicles, by being forced to pay, artificially inflated prices, for vehicles and parts and by having no alternative to paying even higher premiums for insurance, due to having to insure, at higher values. Canadians are beginning, to find out, thanks to this website, that there has been much more going on behind their backs, than they ever realized. It is time for Canadians to act.