Re: Quebec RHD Ban
Posted: Wed May 06, 2009 9:40 pm
This is what I wrote to Kate (and also sent to my MP, Keith Martin). I'll be sure to post her response, should she send one...
Ms. Poirier:
Having recently been presented a copy of CADA's missive on RHD vehicles, I feel compelled to point out a number of errors. Also, keep in mind, that since you've forwarded this pamphlet's contents to our Members of Parliament, I'll be forwarding this email to my MP as well.
I will be countering the points in the pamphlet in order, as follows:
First: there is no "loop-hole" particular to RHD vehicles in the import regulations "allowing" these vehicles into Canada. The regulation simply states that ANY vehicle can be imported as long as it is more than 15 years old to the month of manufacture. There is absolutely no reference to the handedness of the vehicle.
Second: the Swedish changed on which side of the road they drove more for the reasons of economics than for reasons of safety. As an emerging car manufacturer selling their product to countries which drove on the right, and having a relatively small domestic market, it no longer made sense to produce LHD vehicles in greater numbers for export and RHD vehicles for domestic sales.
Third: the benefit of sitting on the left-side of the vehicle in order to better see oncoming traffic has been demonstrably proven to be less safe when involved in a head-on collision - ask any front passenger who was in a head-on collision. When one considers that most head-on collisions are left-side-front-corner-to-left-side-front-corner, it doesn't take a scientist to determine that it would be safer to have the driver on the right-side of the vehicle.
Fourth! (and this one really grates on me): imported vehicles are NOT exempt from the Motor Vehicle Safety Regulations. Our vehicles must meet the regulations of the year in which they were manufactured. My 1990 Mitsubishi Delica does not require a Centre High Mount Stop Light, while the recently available 1994 models do require one. Some of us have had to have the headlights changed, extra marker lights added, and a functional brake/clutch release mechanism installed, all as required.
Fifth: Transport regulations do not dictate which side of the vehicle the driver is to be positioned. While the regulations do indicate that the vehicle is to be driven to the right-side of the highway, there is absolutely no requirement for where the driver must sit. The only reference to RHD vehicles is to require "electrical or mechanical signaling devices" for a driver on the right (presumably because they would not be effectively seen should they try to use hand signals). What about centre-seated drivers, like backhoes, and tractors, and motorcycles? Their seating position is not clearly identified in the transport regulations, should we move those operators over to the left side or eliminate those vehicles?
Six: the pamphlet indicates that the 15-year rule was to allow classic and collector cars into the country in "low numbers" and in the chart on that very same page, the number of "likely RHD" vehicles entering Canada in 2007 is listed as only 1934 - what is the crisis? Your organization is worried about 1900 cars? Wow, you guys are in deeper trouble than is being let on in the media. And the statement "likely RHD": you don't even know if the vehicle is RHD? What is the basis for the speculation to identify it as RHD?
Seventh: "The negative impacts of RHD vehicles are demonstrated by important government studies." Which studies? Are the MPs so intimately knowledgeable of these studies that CADA doesn't even need to reference them? I have a statement for you: "Car dealers are hucksters just trying to get you to buy a vehicle you don't really want." A completely unsubstantiated statement which you can not refute nor I support.
Eighth: "The risks associated with RHD vehicles are recognized worldwide." Has CADA consulted with the Japanese on this one? Anybody called England recently? What about Australia, all the way at the bottom of the world? Do any of these countries know how dangerous RHD vehicles are? Again, another unsupportable statement used more for shock value than any valid reason.
Ninth: while ALL the vehicles are being imported under the 15-year rule are, well, 15 years old, what data do you have that a 15-year-old RHD is more of a polluter than a 15-year-old domestic vehicle. This is the stand your paper has taken, would you please indicate how your organization has made this determination. Am I to understand that CADA would be comfortable with my purchase of a domestic vehicle that spewed a cloud of blue smoke that would put a smelting plant to shame? I drive past a couple of those every day in my diesel van, and simply put, I defy you to say my van is less clean than those vehicles.
AND TENTH (and this one is definitely my favourite): so the argument goes, "15-year-old vehicles are unsafe, so we should modify the import rules to only allow for 25-year-old cars to enter the country." Am I missing something? Have vehicles gotten less safe with the passage of time? Are older cars more safe than newer cars? This would seem to be the basis for the argument CADA is making. If you're going to use the safety argument, the import restrictions should be lessened to something like 5 years, that way we would be able to import vehicles that are more closely aligned to our current safety requirements. And what makes an 1994 Honda from the USA more safe than the same model year from Japan? Why are ALL models of Honda on the RIV? Does CADA have a problem with the RIV, and if not, why not?
I am more than willing to further correspond with you, especially in anticipation to read your replies to my points. Please contact me at the email provided.
J. Paul Lang
Proud driver of a 1990 Mitsubishi Delica
Ms. Poirier:
Having recently been presented a copy of CADA's missive on RHD vehicles, I feel compelled to point out a number of errors. Also, keep in mind, that since you've forwarded this pamphlet's contents to our Members of Parliament, I'll be forwarding this email to my MP as well.
I will be countering the points in the pamphlet in order, as follows:
First: there is no "loop-hole" particular to RHD vehicles in the import regulations "allowing" these vehicles into Canada. The regulation simply states that ANY vehicle can be imported as long as it is more than 15 years old to the month of manufacture. There is absolutely no reference to the handedness of the vehicle.
Second: the Swedish changed on which side of the road they drove more for the reasons of economics than for reasons of safety. As an emerging car manufacturer selling their product to countries which drove on the right, and having a relatively small domestic market, it no longer made sense to produce LHD vehicles in greater numbers for export and RHD vehicles for domestic sales.
Third: the benefit of sitting on the left-side of the vehicle in order to better see oncoming traffic has been demonstrably proven to be less safe when involved in a head-on collision - ask any front passenger who was in a head-on collision. When one considers that most head-on collisions are left-side-front-corner-to-left-side-front-corner, it doesn't take a scientist to determine that it would be safer to have the driver on the right-side of the vehicle.
Fourth! (and this one really grates on me): imported vehicles are NOT exempt from the Motor Vehicle Safety Regulations. Our vehicles must meet the regulations of the year in which they were manufactured. My 1990 Mitsubishi Delica does not require a Centre High Mount Stop Light, while the recently available 1994 models do require one. Some of us have had to have the headlights changed, extra marker lights added, and a functional brake/clutch release mechanism installed, all as required.
Fifth: Transport regulations do not dictate which side of the vehicle the driver is to be positioned. While the regulations do indicate that the vehicle is to be driven to the right-side of the highway, there is absolutely no requirement for where the driver must sit. The only reference to RHD vehicles is to require "electrical or mechanical signaling devices" for a driver on the right (presumably because they would not be effectively seen should they try to use hand signals). What about centre-seated drivers, like backhoes, and tractors, and motorcycles? Their seating position is not clearly identified in the transport regulations, should we move those operators over to the left side or eliminate those vehicles?
Six: the pamphlet indicates that the 15-year rule was to allow classic and collector cars into the country in "low numbers" and in the chart on that very same page, the number of "likely RHD" vehicles entering Canada in 2007 is listed as only 1934 - what is the crisis? Your organization is worried about 1900 cars? Wow, you guys are in deeper trouble than is being let on in the media. And the statement "likely RHD": you don't even know if the vehicle is RHD? What is the basis for the speculation to identify it as RHD?
Seventh: "The negative impacts of RHD vehicles are demonstrated by important government studies." Which studies? Are the MPs so intimately knowledgeable of these studies that CADA doesn't even need to reference them? I have a statement for you: "Car dealers are hucksters just trying to get you to buy a vehicle you don't really want." A completely unsubstantiated statement which you can not refute nor I support.
Eighth: "The risks associated with RHD vehicles are recognized worldwide." Has CADA consulted with the Japanese on this one? Anybody called England recently? What about Australia, all the way at the bottom of the world? Do any of these countries know how dangerous RHD vehicles are? Again, another unsupportable statement used more for shock value than any valid reason.
Ninth: while ALL the vehicles are being imported under the 15-year rule are, well, 15 years old, what data do you have that a 15-year-old RHD is more of a polluter than a 15-year-old domestic vehicle. This is the stand your paper has taken, would you please indicate how your organization has made this determination. Am I to understand that CADA would be comfortable with my purchase of a domestic vehicle that spewed a cloud of blue smoke that would put a smelting plant to shame? I drive past a couple of those every day in my diesel van, and simply put, I defy you to say my van is less clean than those vehicles.
AND TENTH (and this one is definitely my favourite): so the argument goes, "15-year-old vehicles are unsafe, so we should modify the import rules to only allow for 25-year-old cars to enter the country." Am I missing something? Have vehicles gotten less safe with the passage of time? Are older cars more safe than newer cars? This would seem to be the basis for the argument CADA is making. If you're going to use the safety argument, the import restrictions should be lessened to something like 5 years, that way we would be able to import vehicles that are more closely aligned to our current safety requirements. And what makes an 1994 Honda from the USA more safe than the same model year from Japan? Why are ALL models of Honda on the RIV? Does CADA have a problem with the RIV, and if not, why not?
I am more than willing to further correspond with you, especially in anticipation to read your replies to my points. Please contact me at the email provided.
J. Paul Lang
Proud driver of a 1990 Mitsubishi Delica