Complaint to the SAAQ

RHD-related issues ONLY please (NOT for general political ads!)
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M3ti Compact
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Complaint to the SAAQ

Post by M3ti Compact »

Anyways, on behalf of all RWD owners, I sent this complaint to the SAAQ from their website.
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c. C-24.2, r. 0.00001
Order in council concerning the use of right-hand drive road vehicles on public highways

I am voicing my objection to the fairness of this rule. It is unfair to ban a vehicle from Quebec which can be found compliant on all other roads and laws in Canada.

The main purpose of the law is purported to be safety, however, this concern is not supported by facts, rather a cursory look at the problem and knee-jerk reaction. A look at other international jurisdictions where left and right hand drive vehicles co-mingle (such as various places in Europe and Asia) will show no discernable affect to safety.

As the SAAQ has already been made aware by other right-drive advocacy groups that various studies in Canada that question the safety of right-drive vehicles have material errors in statistical computation which calls the validity of the entire study into question. Right-drive vehicles are as safe as their left-drive counterparts.

Drivers of right-drive vehicles respect them for what they are and understand that they must be driven accordingly. Same goes for drivers of large trucks, busses, and motorcycles – they all must be driven differently. To ban right drive cars from Quebec insultingly insinuates that Quebec drivers lack the skills and intelligence of the rest of Canada to operate these vehicles safely on our roads.

Right-drive vehicles themselves should not be the question. If safety is the goal, the regulation of the driver licensing is what is required, not the banning of right-drive vehicles.
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Re: Complaint to the SAAQ

Post by M3ti Compact »

I received this response
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I thank you for your comments on the ministerial order prohibiting the use of right-hand drive vehicles on the road network. However, I wish to clarify a number of points raised in your email.

Before you claim that the decision is not supported by facts, I suggest you carefully read the research report available on our Website at: http://www.saaq.gouv.qc.ca/en/documents ... _drive.php

In that report you will learn that the increased accident risk of 32% was determined based on accidents that actually happened in 2007 and 2008. This percentage is neither a projection nor an opinion, it is a fact. As for the legitimacy of the decision regarding safety, if you refer to section 633.1 of the Highway Safety Code (excerpt below) you will see that the Minister was able to prohibit the use of right-hand drive vehicles solely because they are a threat to the safety of people and property.

It is clear that accidents are basically caused by drivers. But once you agree with that fact, you have to verify if other factors should be considered into the equation. And as you will be able to see in the report, sex, age, and other factors have also been taken into account in the determination of the 32%. After the elimination of all measurable confounding effects, there is still 32% increase in the risk of being involved in an accident with RHD vehicles. Skipping all these factors would have led to an increase of 120% !!
633.1. After consultation with the Société, the Minister may, by order, restrict or prohibit, for up to 180 days, the use on public highways of any model or class of vehicle that endangers the safety of persons and property. The order must state that any interested party may submit comments to the designated person within 90 days after its publication in the Gazette officielle du Québec. At the expiry of 180 days, the Minister may, by order, make the restriction or prohibition permanent. A restriction or prohibition under this paragraph comes into force on the date the order is published.
Pilot projects.

After consultation with the Société, the Minister may, by order, authorize pilot projects to test the use of vehicles or to study, improve or develop traffic rules or standards applicable to safety equipment. The Minister may prescribe rules relating to the use of a vehicle on a public highway as part of a pilot project. The Minister may also, in the context of a pilot project, authorize any person or body to use a vehicle in compliance with standards and rules prescribed by the Minister that are different from those provided in this Code and the regulations.
Powers of the Minister.

Pilot projects are conducted for a period of up to three years, which the Minister may extend by up to two years if the Minister considers it necessary. The Minister may modify or terminate a pilot project at any time. The Minister may also determine the provisions of an order made under this section the violation of which is an offence and determine the minimum and maximum amounts for which the offender is liable, which may not be less than $30 or more than $360.
Publication requirement.

The publication requirement set out in section 8 of the Regulations Act (chapter R-18.1) does not apply to an order made under this section. An order under the second or third paragraph is published in the Gazette officielle du Québec.
It is obvious that these vehicles are designed to be driven on the left side of the road. It is recognized around the globe that for left hand drive circulation (like in UK, Japan, Australia and many others) sitting on the right side of the vehicle offers a better view of the oncoming traffic especially when the vehicle you’re following is a cube truck !! Conversely for right hand drive circulation sitting on the left side seems to be the best position (In your opinion, is it a coincidence that 99% of vehicles in operation in Canada and the United States are fitted with steering wheels located on the left ? ).
Finally, I’d like to inform you that the study we conducted have been accepted and presented during the 20th Canadian Multidisciplinary Road Safety Conference held June 6-9, 2010, in Niagara Falls, Ontario.

Yours truly,
Mark Baril, ingénieur
Service de l'ingénierie des véhicules
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Re: Complaint to the SAAQ

Post by M3ti Compact »

Unsatisfied with the expected response I wrote back this
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Hi Mr. Baril

I thank you for your response.

I have read the study previously and I stand by my assertion that the study is not based on facts and is a cursory look at the problem.

The study is a cursory look at the problem because it was a purely academic statistical analysis conducted in a lab. The study finds discrepancy between the number of crashes involving both LHD and RHD based on a comparison group. There is minimal value of this number as the study is unable to answer the main question of why- is it in fact the technical aspect of a vehicle being right hand drive that was the primary contributing factor leading to a crash. No reasoning is given as to how RHD played a role in the accidents. It could have simply been a bad driver who would have crashed regardless of if the car was LHD or RHD.

The study is not based on facts as the nature of all statistics are that they are averages, not absolutes. Regardless, the comparison group of vehicles used to determine the final percentages were not the exact LHD Canadian equivalents to their RHD Japanese counterparts they were being compared to. Obvious direct comparisons between specific models which are exactly the same except by name and placement of the steering wheel (eg: Toyota Soarer to Lexus SC, Mazda Roadster to Mazda Miata, Toyota Celsior to Lexus LS) were strangely omitted. Even more perplexing is the inclusion of comparables from the USA, Korea, and Germany, and vehicles as new as the 2004 model year (5 years old) to compare with Japanese vehicles of at least 15 years old. It is reasonable to expect newer cars have made large advances in performance and safety over old ones. This is a cause for question of the overall result when it is considered that the study only counted crashes involving bodily injury where those that didn’t were excluded. The omissions and inclusions show that the comparables were not researched thoroughly or were chosen selectively to skew results.

Yes, RHD is optimized for LHD roads and they must be driven differently to compensate, however, it is not to the point where it’s exclusive; the difference in driving style and driver placement does not make RHD incapable of being driven safely on LHD roads. Arguments for the safety advantages of RHD can also be made: In making right turns in a RHD vehicle, it is easier than in a LHD to see the curb and notice any approaching pedestrians or bicycles from the rear. RHD also offers better view down the road for obstructions when changing lanes to the right. Parallel parking with a RHD is noticeably easier and drivers can exit onto the curb without having to open the door into oncoming traffic and bicycles.

With no answer to if crashes were caused because of RHD, and questionable comparison of the gross ratio of crashes between RHD to LHD, the only thing which can be concluded from the study is that RHD cars get into accidents - just like LHD ones do. This study alone, especially when it can be so easily picked apart, is not thorough enough to support the argument that RHD is more dangerous, and definitely not enough to support such as heavy handed approach as an outright ban.

I very much appreciate your time and your response. Right hand drive cars are generally misunderstood by the public. Awareness and driver training is what is needed. Not a ban. I hope that more knowledge can be gained about RHD and that Quebec reconsiders this ruling which keeps these amazing cars out of the hands of genuine automotive enthusiasts (whereas the rest of Canada (except PEI) gets to enjoy them).

PS: Why 99% of cars in North America have left hand drive is for the same reason why 99% of subways, helicopters, and boats are right hand drive. And before you ask, I drive a left hand drive German car. I don’t have a RHD car. I dislike when any good car is unjustly vilified under the guise of safety when the focus should be the driver.
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Re: Complaint to the SAAQ

Post by M3ti Compact »

I received this response. It's more of the same again.

I think if more people were to complain, perhaps our voice would be better heard.

https://secure.saaq.gouv.qc.ca/en/reach ... _email.php


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I thank you again for your additional comments and questions,

Please find information that could solve some of your remaining questions.

As you could have read, comparable vehicles list have been proposed by the APVIQ which is an Imported car owners Association (particularly RHD vehicles) . We used it integrally for our calculation of the publicized risk, but we have redone all calculations with a more elaborated LHD vehicles list, including sports car such as Porsches, Audi S series, BMW M series, Mercedes CL 55, 63, Corvettes, Vipers, Lamborghinis, Ferraris, V8 Mustangs an Camaros, etc… The risk increased from the publicized 32% to more than 50%. Conclusion: all these powerful LHD vehicles are less involved in car crashes (than the LHD vehicles considered for the study). Also, for the 20th Canadian Multidisciplinary Road Safety Conference we‘ve explored what would be the figures if mileage had been taken into account. Based on relatively simple assumptions (number of vehicles owned by each owner) risk also increased from 32 to more than 50%. This proves that the 32% is a very conservative value.

On page 2 of the report it is clearly indicated which accidents must be reported to SAAQ. “the data bank on accidents contains information on accidents with bodily injury and certain accidents with property damage only”. This applies to both observed groups of vehicles, RHD and LHD and we do not see how it could affect one group more than the other one.

You stated “It is reasonable to expect newer cars have made large advances in performance and safety over old ones”. That’s interesting and from a road safety standpoint it is preferable that 12 years old domestic vehicles be replaced by vehicles equipped with the latest safety features and meeting more recent Canadian safety standards in order to improve the global safety level of the fleet. We believe that massive importation of 15 years old and older vehicles (RHD and LHD) go against that goal of maintaining (or improving) the global safety level of the Quebec’s fleet. For the same amounts of dollars, you can buy a 2005 Honda Civic, a 2004 Volvo S40 or an imported 1992 Nissan Pulsar !!

Best regards,

Mark Baril, ingénieur
Service de l'ingénierie des véhicules
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Re: Complaint to the SAAQ

Post by William »

This guy is great at talking in circles ( not the OP ). Good to see you posting this here. Please do continue to post what else he says. All of this stuff is going to be used against him in the end.
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Re: Complaint to the SAAQ

Post by thedjjack »

I sent him an emailing asking to explain how comparing a $200,000 sports car to a $10,000 sports car seemed like a good comparison.

And a few more questions like what peer review support did he have that new cars are safer??
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Re: Complaint to the SAAQ

Post by tonydca »

As a BC owner of a similar of the 81 minivans that would be banned along with the "sports cars", I had a read over the report, and here is one key point they failed to address; their comparison of RHD "sports cars" to LHD "sports cars" is far from apples to apples:

They failed to drill down one more level of data in the cars they were comparing. Let's have a look, shall we?

******

The most common RHD sports cars in Quebec are Nissan Skyline, Nissan Fairlady, and Nissan Silvia (totalling approx 970/2130 RHD sports cars in the final year - from the report itself)

An online check for cars for sale - indicative of the population as a whole, the most popular versions of these cars for sale for the years in question are (*stock* trim):

Skyline GT-R: 276 hp/ 3100 lbs curb weight
Skyline GTS-4: 212 hp/ 3100 lbs curb weight
Silvia S15: 247 hp/ 2600 lbs curb weight
Fairlady: 222 or 300 hp (non-turbo/turbo)/ 3200 lbs curb weight
(courtesy of Wikipedia)
******

The most common LHD sports cars are Honda Civic Si/SiR and Acura Integra type RS (totalling approx 14.5K/26.1K cars - again, from the report)

Specs for Civic Si/SiR for that model year: 112 hp / 2300 lbs to 160 hp/2600 lbs
Specs for Acura Integra Type RS: 142 hp / 2700 lbs
(from Wikipedia)

******

Hence the attraction of these cars; way more horsepower for your dollar. Which gets back to the real issue: the drivers and improved training, not the vehicle itself. But then we already knew that...

And in the end, they are concerned about 2300 vehicles out of 4.1+Million on the road? This is the "massive fleet of imports" he is worried about? Please...

OP, feel free to check any of these facts out yourself and stick them in a reply email. Be interesting to hear his response to that...

Cheers,

Tony.
Cry "Havoc!" and let slip the elementary-school-aged boys...
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Re: Complaint to the SAAQ

Post by mararmeisto »

I still stand by some of my original observations regarding this ban and its specific targeting of 10 years' worth of vehicles. The ban against registering is for RHD vehicles that are over 15 years old (those those available to be imported under the federal rules), but the ban is not in effect for RHD vehicles over 25 years old. So, if RHD registration is being banned on the underlying concern of "safety", and SAAQ agrees with the OP that newer cars are "safer" than older cars, how exactly is a 25 year old car "safer" than 15 year old cars?

Further extending that argument into the future, is the 1995 RHD that is being banned today, somehow "safer" in 2020? What makes for its increased "safety" in ten years' time? How does that RHD vehicle become "safer" without the manufacturer being invovled in applying new safety features that were not initially implemented?

And finally, how is it that RHD vehicles currently excluded from the ban (those with a GVWR over 3000kg, those used for work, those used by municipal/provincial/federal operators) are "safer" than those vehicles which do not meet those uses? Are the drivers of these vehicles given special RHD-training in order to allow them to "safely" operate these "dangerous" vehicles? Are those drivers compensated through their employer for having to operate "unsafe" vehicles, and if not, why not? For example, the postie who drives to work in their LHD vehicle, do they get extra training/compensation for driving around a RHD postal truck all day? And again, if not, why not? SAAQ feels that RHDs are "unsafe" except for all of these vehicles that are excluded - what is the basis for the exclusions?

Those are my thoughts...
JPL
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Re: Complaint to the SAAQ

Post by RichD »

IMO, they should be increasing insurance rates for sports cars, not banning vehicles based on the position of the steering wheel.
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Re: Complaint to the SAAQ

Post by thedjjack »

call me crazy but my motorcycle seems more dangerous then my Delica??

Why are motorcycles not being banned?

Not sure how much safer new cars are based on what? Peer reviewed papers show ABS increase your chances of being in an acident. And airbags kill people my height?

I would take a 15 year old Japan car over 2005 Civic driven in Quebec salt!
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