Dec 25
Our Reply to regulation 215
Please find our reply to the request from Transportation Canada to participate in the Consultation.
cwb-comment-on-canadian-bumper-regulations.pdf
Over the next couple of days add your comments or name to the end of the letter, we will be sending it out On December 28th at 3:00 P.M.
One final thought and maybe we should add it to our letter:
The cost of a Tire Pressure Monitoring system for my snow tires and wheels is around $250.00. The U.S. Mandated the use of these systems in all new cars as of September 1st, 2007.
Three issues:
- Does anyone mention this extra cost added to the U.S. cars when comparing prices in the U.S. and Canada?
- This U.S. regulation appears to prevent blowouts and possibly save lives. It also ensures that cars operate more efficiently. Cars with well maintained tires use less gas and don’t wear out as fast!
- Quebec just implemented legislation to mandate snow tires in the winter, they say it will save lives.
- What do you folks think?
December 25th, 2007 at 10:18 am
Just adding my name to the end of your letter in support. Thank you!
I also agree with your thoughts about the TPMS but I’d leave it out of this particular letter.
December 25th, 2007 at 11:50 am
The concept of self regulation for car mfs is what should not be allowed. They can make small alternations for which a kit may not be available for modification and say that safety and performance are the issues. All US vehicles drivable in North America must be blanchet allowed for import - with the basic safeties as daytime running light, an immobilizer and child restraint systems.
If a car can be driven the North East US (Newyork, pennsylvania, Detroit, Michigan where they have similar climate to Suburban Canada cities. A sightly better alternator,a slightly better … may be just a catch.
The transport mInisty must work witht he free trade Ministry before implemeting any regulation.
The RIV must have a pre approval process where one pays say $ 75 approx and then buys the car. The method of regulations being in effect back dated, is not acceptable. So I must guess the changing RIV list before one buys. There must be a 3 to 6 month grandfathering period for all cases. 3 to 6 months is required by an avergae Canadian to make a buying decision and sell his old vehicle. W e have to live in term as of the life usefulness in our 2000 year times. The car is not a food item with consumable and disposable periods. The Transport Ministry must have restricted a public consultation in major cities and Canadian north about the costs. problems and implementation the people have to incur in our very busy lifes.
May be the government must have each manufacturer have three models, sub compact, medium and large that are to be regulated and sold at a fixed low regulated so that hundereds of Canadians can drive safer vehicles on the road and increase the safety of everyone. Having a new car next to a clunker can be hazardous.
The vehicle driver should get free improvement lessons every five years to improve their driving skills, for it is the not the vehicle but the driver who drives it and his skill level that are important. How about a tax deductible during course or a free government program for a low fee say $ 25 to improve the skill of the young / mid aged and old Diver.
December 25th, 2007 at 2:09 pm
Everyones knows by now !!and after learning that it was BMW and the car Manufacturers that changed the rules for car importing!!!. The Gouvernment listens to the LARGE CORPORATIONS in their decisions. SO NOW YOUR ASKING NOW ABOUT THE MANDATORY WINTER TIRES!!WHAT A JOKE……WHICH MAFIA FIGURE IN THE GOUVERNMENT IS GETTING PAID FOR SELLING MORE TIRES!
December 25th, 2007 at 2:37 pm
I support options 5 or 6 of this proposed amendent.
It’s great to see Transport Canada working on improving vehicular safety. It’s frustrating to see automotive manufacturers abusing existing regulations by using them to make it difficult for Canadians to import comparable vehicles from the US.
December 25th, 2007 at 2:39 pm
I agree with your response to cmvss 215. Add my name to the letter. With regard to the TPMS issue,
I would leave this out as this is not the issue at hand. Manitoba is also looking to mandate the use of proper winter tires. I think this probably not a bad idea.The fact that it will cost those of us with vehicles that have TPMSs more is something we may have to accept. If our main objective here is for complete harmonization and the U.S. decides to make TPM systems mandatory, Canada, given our market size as compared to the U.S. will have to go along.
December 25th, 2007 at 3:20 pm
I strongly support challenging Transport Canada on requiring the vehicle manufacturer to supply the recall letter. As TC has selected CarFax to provide information on an imported vehicle’s history, why not accept the Comprehensive Vehicle History report CarFax generates, or for that matter, why not accept a letter from the authorized selling dealer in the US? Finally, if Canadian Tire has been authorized to complete the importation inspection, why not accept a letter from Canadian Tire indicating the vehicle conforms to Canadian Standards?
December 25th, 2007 at 6:32 pm
The manufacturers are required by law, to advise Transport Canada and vehicles owners, of any safety related recalls. Transport Canada, already has this information, yet is pretending that it doesn’t and is forcing Canadians to go begging and in some cases, paying hundreds of dollars to manufacturers, for recall letters, to be presented to the RIV, in order to receive permission to import a vehicle. In addition, we now have Transport Canada instructing us, to pay hundreds of dollars to BMW and thousands of dollars to Mercedes, (it was $5,000.00, with MB, the last time this writer checked), in order for these two manufacturers to fiddle with a few small things and then tell us, that their vehicles conform to Transport Canada standards. Transport Canada already knows, which ones conform, to Transport Canada standards, as it is required by law, that every manufacturer advise Transport Canada of this, in order to import the same vehicles, themselves. As soon as Transport Canada agrees, to recognize all U.S. standards, by harmonizing the bumper standard, the immobilizer standard and very little more, then start providing recall information to vehicle owners, instead of demanding this information, from vehicle owners, then the RIV can be dismantled and eliminated completely, as there will be no standards related barriers to trade and therefor absolutely nothing for the RIV to do, which is exactly what was promised to us, in the Canada U.S. Free Trade agreement, of 1988. Canadians, will then be free to purchase vehicles, anywhere in North America, without any obstacles placed in front of them. Prices will then drop, immediately, which will enable small, independent, Canadian auto dealers, to start exporting again and because of, the lower prices, Canadians will not have to go to the U.S. to buy their cars anymore and will be able to buy them at home. This in turn, will help all Canadian dealers and even the franchised dealers in Canada, to sell more cars, to Canadians. The people who are currently working at RIV, will have to find new jobs, possibly, helping to operate a car finding service, for Canadians and possibly even Americans, who will want to start buying cars in Canada, again. If the bumper standards are eliminated, as one Transport Canada recommendation, suggests, then none of our used cars will be exportable to the U.S., which will then cut off a major source of business and resulting income, for many small Canadian exporters. If the bumper standards, remain unchanged, as another recommendation suggests, then the current problems we are experiencing will remain, unchanged. If the bumper standards and the immobilizer standards are harmonized, as many people are hoping and praying will happen, then virtually all of the negative aspects of the current situation, will evaporate immediately and all of the positive changes, dreamed about, in this letter, will, absolutely and without question, come true.
December 25th, 2007 at 9:03 pm
I fully Support for harmonization of standards for Bumpers with the USA.
December 25th, 2007 at 9:36 pm
I also support harmonization of bumper standards with the USA. Please add my name to the list .
December 25th, 2007 at 11:02 pm
I also support harmonization of bumper standards with the USA.
Please add my name to the list.
Also we need to make BMW Canada bad in the eyes of customer the
way BMW Canada behaving. Surly, Government is backing up…..
Wake up Canadian…
December 26th, 2007 at 11:49 am
If Transport Canada is really interested in our safety why not make it mandatory for a manufacturer to supply a recall letter and a history of repairs related to any recalls to a vehicle owner at the request of the consumer. Surely an argument could be made that this would be more of a safety issue than TCs reasoning for requiring immobilizers. Of course this would have to be backed up with some hefty fines or consequences.
December 26th, 2007 at 12:32 pm
Does anyone know for certain who is making the determination as to whether specific recall letters must come from the manufacturer or an authorized dealer? Is it Transport Canada or is this something that RIV is judging themselves? It seems to me that it is entirely arbitrary whether RIV accepts a recall letter and history of repairs for a given manufacturer.
December 26th, 2007 at 1:33 pm
Recall letter is for safety and security and should be mandatory for manufacturer to provide free of charge and TC and our Government should reinforce this practice.
I also support harmonization of bumper standards with the USA. Please add my name to the list.
December 26th, 2007 at 4:01 pm
re: Quebec’s snow tire regulations. Some of us lucky folks drive south late in
November/January and return early in April. We do it on four season tires. I
hope Quebec will give us a break, not a fine!
December 26th, 2007 at 7:36 pm
First - thanks for reprinting my comment on Edmunds. I’ve been posting over there for a couple of years since I had imported in early ‘06 with no problem and could give advice. At that time Toyota was already blocking sales. But Honda wasn’t. Anyway, the Quebec law requiring snow tires is excessive. Snow tires are better than good all-season tires in the snow but worse on wet roads. Look at the Consumer Reports test results (www.consumerreports.org). Snow tires are a mess to deal with if you have limited space, as is the case with most urban dwellers. All-season tires with reasonable design and tread-depth along with AWD or FWD will provide what is needed. As for braking - being slow and cautious is the most important feature, not snow tires. The Government of Ontario has made it clear that they disagree with Quebec on this one. One more thing on the cross-border shopping issue. Has any resident of Canada who is a US citizen been denied the opportunity to by a car in the US? Would this not make them a second-class citizen? Would a US politician like to get involved? Anyway - congratulations once again on your splendid victory and this excellent web effort!
December 27th, 2007 at 12:47 am
I support your letter but the comment about charging up to $500 for a recall letter
is inaccurate. I can name 6 manufacturers now who are charging in excess of $1,500
just for the letters. If you fancy a used Ferrari as an example, bloggers are saying
that Fiat is charging $5,000!
December 27th, 2007 at 9:37 am
I live close to the border and witness thousands upon thousands of US residents travel freely across our Canadian highways in US vehicles built to US standards. I do not believe they are imposing danger to myself, other fellow Canadians drivers or, are traveling in any less safe vehicle than I. Transport Canada allows entry to these travelers and will continue to do so. I fully support harmonization of bumper standards with USA. Please add my name to this list. Please stop this ridiculous method of discouraging importation.
December 27th, 2007 at 3:48 pm
Completely agree with the bumper rule harmonization. I believe US also wants to introduce mandatory VSC (Vehicle Stability Control) systems on each car in the future. Studies have shown that this feature saves lives and I would really like to see it on each car in Canada as well. As for the winter tires I have them on one of my cars and can tell the difference. However, if you drive slowly and the winter is not as harsh as this one they are not really that necessary. It really depends where you live.
December 27th, 2007 at 5:16 pm
Harmonizing with the US is not enough, there are plenty of European manufacturers that could offer vehicles in our market if we harmonized primarily with UNECE standards. But I feel that we should go further by rescinding the entire Canadian bumper regulation. As Transport Canada said there are many modern countries which do not have bumper regulations for the benefit of pedestrian safety, these North American standards come from the 70’s (do you remember what bumpers looked like back then). Transport Canada said that bumpers only absorb up to 15% of an impact if you are fortunate enough to use the bumper in a collision, I think vehicle crash-worthiness has come a long way since the 70s and bumpers regulations are no longer necessary. Canadians should support government deregulation in the auto industry as much as possible and this is a prime opportunity.
December 27th, 2007 at 8:06 pm
I support the comment from Christian Beyak, harmonizing with the U.S. is not enough. Transport Canada must harmonizing his bumper standard with the UNECE Regulation No. 42 or rescind the Canadian bumper standard or only regulate the lower leg requirements of the gtr on pedestrian safety as either mandatory or optional.
If the Canada adopt the UNECE regulation on bumper, the vehicles from the U.S. with bumper that are comply with the standard from National Highway Traffic Safety Administration (NHTSA) will be accepted for import into Canada. The UNECE standard on bumper is compatible with requirements of the NHTSA standard but on the other hand the NHTSA standard is NOT compatible with the UNECE as it have more severe requirements. One of these requirements that really made a considerable difference on bumpers design is about the device used for the corner impact tests of each bumpers:
- Under the UNECE standard, the same devise is used for the longitudinal impact tests and for the corner impact tests.
- Under the standards from NHTSA and Transport Canada, a different devise is used for the corner impact tests. Because of this devise, the bumpers have to be longer on the corners on cars manufactured for the Canadian and U.S. markets. This have the disadvantage to add blind spots on the cars which could lead the drivers to make a small collision during a parking handling and others situations. The car manufacturers have to make a intense redesign of the bumpers to comply with the corner tests and this have the consequence to limit the choice of models offered to the Canadian.
The other reason why Transport Canada must adopt the UNECE standard on bumper or completely rescind his standard, is because under the SICE (the Organization of American State’s Foreign Trade Information System, the Canada have agreed to gradually remove the prohibition or restriction on imports from the territory of Mexico of originating used vehicles starting 2009 until 2019 as the follow:
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Source: http://www.sice.oas.org/Trade/NAFTA/anx300a1.asp
Because Mexico does not have bumper standard and have a considerable number of models sold in his territory that meets the UNECE standard, for these vehicles be admissible for import in Canada in the coming years, Transport Canada must adopt now the UNECE standard on bumper or completely rescind his standard.
December 28th, 2007 at 12:44 am
Robert and Serge,
Your letter to Transport Canada regarding harmonization of bumper standards with those of the US is well written.
The theme of the input is “harmonization of standards” and therefore, I do not feel that you have to add any comments regarding the Tire Pressure Monitoring System.
December 28th, 2007 at 2:49 pm
Robert and Serge:
Please add my name to your letter. I suggest that the reference to TPMS be deleted.
Curtis
December 28th, 2007 at 2:51 pm
Please add my name to your letter. The TPMS is not the subject of the request for comments as published in the Canada Gazette on Oct 13.
December 28th, 2007 at 3:13 pm
Please add my name to your letter.
December 28th, 2007 at 3:16 pm
Please add my name to your letter.
December 29th, 2007 at 5:25 pm
Pleas add my name to your letter. I believe its an excellent idea to harmonize the bumpers with the US. It will allow for import for a great number of vehicles previous cited “inadmissible” as well as benefit the consumers with possibly cheaper car MSRP’s.