Small Victories Now, But a Long Way to Go

I know none of us wanted to have this fight with the Governement. However, the bear has found us and, rather than being a tasty morsel we need to let them know that they have more to lose than gain by intruding into the lives of law-abiding citizens. The good news, however, is that by making our concerns known at every level we’re starting to make some differences.

According to some of the inpection facilities I’ve talked to here in BC, the CVSE have determined that JIS lenses are going to be sufficient in most cases. Also, it has been clearly determined that side-reflectors are sufficient where side-marker lighting from existing lights does not meet standard. Apparently there has been a change on tires too - that as long as they have load-pressure ratings listed, they meet the standard.

I have a meeting Monday with Mike Woods and Brian Kangas from CVSE, and the plan is to get a committment from them to publish a new, clearer set of guidelines for inspection facilities and importers so that we can avoid costly waste and delays.

Louis had a phone conversation with Transport Canada on Friday and, while it seems they are still intent on moving ahead with changing the 15-year rule, in now seems they are willing to allow public consultation BEFORE they send it to he Minister for signing. This is a shift from their earlier position whereby public consultation was only going to take place AFTER it went to the Minister for signing.

Right now, we’re preparing a position paper for submission to the various governments across Canada. Ultimately, I think our strategy should be one of mitigation as much as possible, by pursuing the following strategy in the order of the following preferences:

1. Try to get TC to allow vehicles into Canada that do not meet the CMVSS under specific circumstances, regardless of age.

2. Try to get TC to abandon any changes to the 15-year rule at all.

3. Try to get TC to delay making any negative changes to the 15-year rule.

4. Try to get TC to minimize the effect of any changes to the 15-year rule.

Right now, it seems that #3 is what we’re acheiving, and we can hope to at least accomplish #4. This may mean capping the number of units coming in each year that don’t comply and/or allowing modifications to meet most, if not all, of the CMVSS standards.

That’s it for this week at CAVI. For those of you who have been thoughtful enough to send us their membership fees, a great, big thank you! For the rest of you who are still sitting on the fence, I understand how hard it is to spend money on something you shouldn’t have to, but I really don’t see an option here.

So far, Louis and I are the founding members and Interim Executive. If anyone else would like to step up to the plate and contribute as much time, effort and money as we have, please let me know. I’d love to hand this off so that I can get back to runnning my own business.

Otherwise, your emails and phone calls are greatly appreciated. One of the nice things about being such a small group is that EVERY SINGLE PERSON makes a big difference.

Later,

Dale

Tell Your MP to Support Bill S-5 (if they want your support)!

Almost without exception, we are appalled by the dismal choices, quality and prices of the domestic manufacturer`s offerings. Compared to what other countries around the world allow their citizens drive, our choices offer much lower value. How else do you explain the time, effort and inconvenience thousands of Canadians are willing to endure in order to drive something that more closely fills their needs. And to think we are the envy of supposedly `free` Americans, eh?

Ever since Mike at Rockcrete raised the issue of the NAFTA regulations with me, CAVI has been lobbying the Government of Canada for quick passage of enabling legislation that will bring our vehicle import laws into line with our trade laws. (For those who may not be familiar with the way the system works, enabling legislation in one law does not automatically result in disabling legislation in another area - something that should be the subject of another diatribe elsewhere).

As a result of efforts by both Mike and I, Bill S-5, An Act to amend the Motor Vehicle Safety Act and the Canadian Environmental Protection Act, 1999 (short title: Ensuring Safe Vehicles Imported from Mexico for Canadians Act) was introduced in the Senate by the Honourable Majority LeBreton, Leader of the Government in the Senate, on 14 April 2010.

Since then, the bill has received 2nd reading and sent to Committee where I vigorously advocated for passage, along with some improvements. Third Reading in the Senate, and First Reading in the House followed quickly thereafter. However, before Transport Canada can amend its regulations to start allowing imports from Mexico that are less than 15 years, Bill S-5 needs to go to Commons Committee with the 2nd and 3rd readings to take place. Once the 3rd reading takes place, the Bill will be quickly passed into law through an order in council. That`s when things start to get interesting.

By 2019, the age of vehicles imported from Mexico will fall to 0 years. This means that any vehicle eligible for importation there, which includes UNECE compliant vehicles, will be ultimately eligible for importation into Canada. Initially, some form of trans-shipment will be necessary. Of interest to importers will be the opportunity to skip the Mexico step altogether, thereby allowing newer Japanese and European vehicles into Canada directly.

Therefore it is incumbent upon all importers and import vehicle fans to write their MP and voice their support for quick passage of Bill S-5. For our part, CAVI has been in both direct and indirect contact with Hon. John Baird’s office in this regard, as Transport Canada is the sponsor of this bill, and he is also the Government Leader in the House. Without his continued support, we run the risk that this legislation will die on on order paper this Spring when the government dissolves for a Spring election.

We can imagine how crappy things would be if there had been no imported vehicles over the past 60 years. It is in our direct interest to ensure our options to keep importing fun, practical and affordable vehicles are kept alive.
Remembering Vimy Ridge

How ironic it is that we recently witnessed our own Prime Minister over in Europe commemorating the 90th anniversary of the assault on Vimy Ridge - just one of the many battles over several wars where decent Canadian men paid the ultimate sacrifice to fight tyranny.

Yet here we are 90 years later, in many ways far less “free” than we were a century ago, living in a society where law-abiding citizens are still subject to the whims and petty antics of an unrestrained, self-serving bureaucracy. A bureaucracy so firmly convinced that without their protection, we would simply be incapable of making responsible decisions about our own lives, even down to deciding what kind of vehicle to drive.

Make no mistake - we’re not talking here about hordes of maniacs racing through the streets on grossly over-powered for the weight, inherently unstable vehicles without basic safety equipment such as seat belts, windshield wipers, bumpers, etc. No, the Hells Angels have no reason to fear loss of their favorite mounts – motorcycles – because the powers that be are fine with that.

What we honest, law-abiding citizens have done to incur the wrath of the regulators is chose to drive and own a range of fun, unique, enjoyable and well-built vehicles from that bastion of great manufacturing prowess – Japan. And we all know what Detroit would have us driving if it hadn’t been for the Japanese, right? “How many tailfins will that be with your Corvair, sir?”

In 1986, Transport Canada decided that it would not be a crime against humanity if hobbyists and enthusiasts were allowed import specialty vehicles for their automotive driving pleasure. After all, who would mind, with so many people enamored by the variety of shapes and purposes for which vehicles are made. Fast forward 21 years or so later, and again we people are re-discovering the cool styling and features of cars from a previous generation. The only thing that has changed is that these cars are much better built, coming from Japan as it were, when compared to the early 70’s stuff from Detroit.

Now, most people would tell you that it’s better to have a well-built car than something of lesser construction. And yet, here we are being told by Transport Canada that we must arrest this trend of nostalgic admiration of bygone years for exactly that reason – the cars are too good! That’s right – as unbelievable as it may seem, our protectors have determined that there really can be too much of a good thing – that too many old cars are a threat to public safety. Right.

And if you find that bit of reasoning a bit hard to comprehend, fasten your seatbelt because the twists and turns of the Government’s argument get even more bizarre. As a remedy for “too many, too good old cars” they have proposed increasing the age of exemption for importing used vehicles from Japan and Germany from 15 to 25 years. You read that right – in Transport Canada’s pretzel logical way of thinking, its safer to have more 25 year-old vehicles on the road than “too good” 15-year old vehicles. Go figure.

Consequently, this being 2007, if the bureaucrats idea to amend the rule allowing individuals to import 15-year old vehicles were amended to only allowing 25-year old vehicles in, the newest vehicle you could import from Japan or Germany would be 1982. Or in other words, you would no longer be allowed to import a 1986 Mercedes as intended you should be able to 15 years hence when the law was originally written. And this, simply because the cars are too good?

When I think back to how those brave young men gave their lives so that we could be free of tyranny, how could they have know the biggest threat to our freedoms would come not from the Kaiser of Germany, but rather, one of a homegrown variety.

WHO’S AFRAID OF THE BIG, BAD GHOST?

Common wisdom holds that people fear things they don’t know or don’t understand. Take change, for example: When change is thrust upon us and the outcomes are uncertain, we tend to fear the worst.

Now, a lot of people I’ve been talking to have been wondering who, exactly, is so afraid of these cute, economical, reliable pre-loved imported vehicles that they want them banned? Many theories abound, from al Queda trying to undermine our economy to Jimmy wanting to limit competition. Only one thing certain here is that SOMETHING BIG is going on behind the scenes that nobody wants to come clean on.

Personally, I’ve kind of narrowed it down to a few likely of culprits:

1. Those poor, over-worked civil servants who just can’t stand the thought of someone else making a buck while it’s the superannuated bunch who have all the real work to do. (If you think that I’m kidding, just remember - they who can’t get laid off already have jobs for life and pensions that last even longer). This could well acccount for the pettiness of their efforts to barricade enthusiasts and those who bring these delightful, foreign vehicles in for them.

2. A more likely scenario, however, is the official effort to cut off the supply of imported vehicles is part of a much larger plot to integrate North America’s economic and security ties. In short, since the USA has a 25-year rule, we must have a 25-year rule. Yes, Virginia, this whole cluster could be something as simple as plain old hegemony. And I’m not even xenophobic!

There’s just one problem with this latter scenario: Even though Canada produces far more energy per capita than the US, thanks to the miracle of higher income and sales taxes, we pay approximately double the price per litre than our American cousins.

How’s that you say? Well, gas costs approx. 35% less per litre after converting from gallons to litresand converting from US Dollars to Canabucks. Add to that the fact that we pay on average 15% higher income taxes, and before you can say George’s Bushed, you’re paying twice as much pre-tax income for the same unit of motion lotion.

That’s right, folks: It’s our oil, but we get to pay more for it in our essential needs such as transportation. Kind of makes you proud, doesn’t it? After all, it’s the Canadian way.

The solution is quite simple: For gawd sakes, WRITE PHONE CALL your MP and tell him/her/it that since you have to pay world prices for energy, you want world choices for your vehicle needs. Please, don’t be afraid of the Big Bad Government Ghost! Let them know who’s actually paying the bills, and who’s really the employee!

Japanoids in the news

Kudo’s to David Jubb of The Japanoid Auto Store in New Westminster, BC. David managed to steal the airwaves with a feature on CTV highlighting these exciting, economical cars from Japan. If you didn’t have the opportunity to see him on the news, check it out on the link below. Apparently, response to the news item has been so impressive, CTV wants to follow the story as it evolves.

http://www.youtube.com/watch?v=bpXqaPr7mnI&mode=related&search=

Remembering Vimy Ridge

How ironic it is that we recently witnessed our own Prime Minister over in Europe commemorating the 90th anniversary of the assault on Vimy Ridge - just one of the many battles over several wars where decent Canadian men paid the ultimate sacrifice to fight tyranny.

Yet here we are 90 years later, in many ways far less “free” than we were a century ago, living in a society where law-abiding citizens are still subject to the whims and petty antics of an unrestrained, self-serving bureaucracy. A bureaucracy so firmly convinced that without their protection, we would simply be incapable of making responsible decisions about our own lives, even down to deciding what kind of vehicle to drive.

Make no mistake - we’re not talking here about hordes of maniacs racing through the streets on grossly over-powered for the weight, inherently unstable vehicles without basic safety equipment such as seat belts, windshield wipers, bumpers, etc. No, the Hells Angels have no reason to fear loss of their favorite mounts – motorcycles – because the powers that be are fine with that.

What we honest, law-abiding citizens have done to incur the wrath of the regulators is chose to drive and own a range of fun, unique, enjoyable and well-built vehicles from that bastion of great manufacturing prowess – Japan. And we all know what Detroit would have us driving if it hadn’t been for the Japanese, right? “How many tailfins will that be with your Corvair, sir?”

In 1986, Transport Canada decided that it would not be a crime against humanity if hobbyists and enthusiasts were allowed import specialty vehicles for their automotive driving pleasure. After all, with so many people enamored by the variety of shapes and purposes for which vehicles are made, who would mind? Fast forward 21 years or so later, and again people are re-discovering the cool styling and features of cars from a previous generation. The only thing that has changed is that these cars are much better built, coming from Japan as it were, when compared to the early 70’s stuff from Detroit.

Now, most people would tell you that it’s better to have a well-built car than something of lesser construction. And yet, here we are being told by Transport Canada that we must arrest this trend of nostalgic admiration of bygone years for exactly that reason – the cars are too good! That’s right – as unbelievable as it may seem, our protectors have determined that there really can be too much of a good thing – that too many old cars are a threat to public safety. Right.

And if you find that bit of reasoning a bit hard to comprehend, fasten your seatbelt because the twists and turns of the Government’s argument get even more bizarre. As a remedy for “too many, too good old cars” they have proposed increasing the age of exemption for importing used vehicles from Japan and Germany from 15 to 25 years. You read that right – in Transport Canada’s pretzel logical way of thinking, its safer to have more 25 year-old vehicles on the road than “too good” 15-year old vehicles. Go figure.

Consequently, this being 2007, if the bureaucrats idea to amend the rule allowing individuals to import 15-year old vehicles were amended to only allowing 25-year old vehicles in, the newest vehicle you could import from Japan or Germany would be 1982. Or in other words, you would no longer be allowed to import a 1986 Mercedes as intended you should be able to 15 years hence when the law was originally written. And this, simply because the cars are too good?

When I think back to how those brave young men gave their lives so that we could be free of tyranny, how could they have know the biggest threat to our freedoms would come not from the Kaiser of Germany, but rather, one of a homegrown variety.

WHO’S AFRAID OF THE BIG, BAD GHOST?

Common wisdom holds that people fear things they don’t know or don’t understand. Take change, for example: When change is thrust upon us and the outcomes are uncertain, we tend to fear the worst.

Now, a lot of people I’ve been talking to have been wondering who, exactly, is so afraid of these cute, economical, reliable pre-loved imported vehicles that they want them banned? Many theories abound, from al Queda trying to undermine our economy to Jimmy wanting to limit competition. Only one thing certain here is that SOMETHING BIG is going on behind the scenes that nobody wants to come clean on.

Personally, I’ve kind of narrowed it down to a few likely of culprits:

1. Those poor, over-worked civil servants who just can’t stand the thought of someone else making a buck while it’s the superannuated bunch who have all the real work to do. (If you think that I’m kidding, just remember - they who can’t get laid off already have jobs for life and pensions that last even longer). This could well acccount for the pettiness of their efforts to barricade enthusiasts and those who bring these delightful, foreign vehicles in for them.

2. A more likely scenario, however, is the official effort to cut off the supply of imported vehicles is part of a much larger plot to integrate North America’s economic and security ties. In short, since the USA has a 25-year rule, we must have a 25-year rule. Yes, Virginia, this whole cluster could be something as simple as plain old hegemony. And I’m not even xenophobic!

There’s just one problem with this latter scenario: Even though Canada produces far more energy per capita than the US, thanks to the miracle of higher income and sales taxes, we pay approximately double the price per litre than our American cousins.

How’s that you say? Well, gas costs approx. 35% less per litre after converting from gallons to litresand converting from US Dollars to Canabucks. Add to that the fact that we pay on average 15% higher income taxes, and before you can say George’s Bushed, you’re paying twice as much pre-tax income for the same unit of motion lotion.

That’s right, folks: It’s our oil, but we get to pay more for it in our essential needs such as transportation. Kind of makes you proud, doesn’t it? After all, it’s the Canadian way.

The solution is quite simple: For gawd sakes, WRITE PHONE CALL your MP and tell him/her/it that since you have to pay world prices for energy, you want world choices for your vehicle needs. Please, don’t be afraid of the Big Bad Government Ghost! Let them know who’s actually paying the bills, and who’s really the employee!

Japanoids in the news

Kudo’s to David Jubb of The Japanoid Auto Store in New Westminster, BC. David managed to steal the airwaves with a feature on CTV highlighting these exciting, economical cars from Japan. If you didn’t have the opportunity to see him on the news, check it out on the link below. Apparently, response to the news item has been so impressive, CTV wants to follow the story as it evolves.

http://www.youtube.com/watch?v=bpXqaPr7mnI&mode=related&search=

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CAVI would like to thank the following businesses for supporting our efforts to secure freedom of transportation choices for all Canadians:

• Adventure Imports
• JDM Wholesale Canada
• Canamoto.com
• Maximum Overdrive
• DJ Auto Imports
• Japanoid
• West Shore Auto
• Outback Imports
• Pace Setters
• Custom Car Imports
• Intercontinental Motor Corporation
• Brave Auto Internationsal
• Mustang Connection
• 4 Wheel Auto
• JDM Connection
• Bonsai Rides
• Abbotsford Japan Auto
• Rocky Mountain Imports

ICBC and the Right Hand Drive Report

Whose Interest is Really Being Served?

(Vancouver, BC) ICBC recently commissioned and published a study titled “The Safety of Right-Hand-Drive Vehicles in British Columbia.” This study claims that right-hand drive (RHD) vehicles are 40% more likely to be involved in an accident. According to an ICBC spokesman, they endeavored to eliminate any bias in the study. However, IVOAC and CAVI believe ICBC’s actions themselves are part of a calculated smear campaign intended to discredit RHD vehicle drivers and discourage individuals from purchasing imported used vehicles - especially those who would rather do so themselves than going through Government sanctioned car lots.

The situation here in BC is one of drivers operating RHD vehicles in familiar territory on the side of the road they are used to operating on. This is nothing new. Hundreds of millions of kilometers have been safely accumulated by fleets of North American built right-hand drive vehicles operated by the postal services of both Canada and the US, even though we operate primarily on the right side of the road.

For years, Japanese drivers have been able to purchase vehicles in both left and right hand configuration directly from dealer’s showrooms, even though they primarily operate on the left side of the road. Interestingly, ICBC appears to have made no effort to include either of these relevant experiences into their study.

Rather, ICBC inappropriately cites examples of Korean drivers operating in Japan, an unfamiliar country operating on the opposite side of the road they are use to as evidence of the inherently greater risk RHD vehicles pose for the motoring public in BC. Also, ICBC makes reference the situation regarding European tractor/trailer units operating in the UK, but chooses to ignore the fact that the Chunnel currently transports over 2 million cars per year between England and France where drivers operate on opposite sides of the road with seemingly little difficulty.

There does not appear to be any effort by either Transport Canada or BC Transportation to outlaw RHD vehicles; neither has ICBC bothered to increase the insurance premiums for these supposedly high-risk vehicles. What is apparent is that a certain stridency has entered their vocabulary: we don’t have an increase in RHD cars – we have a “proliferation.” Nor, it seems, do people have accidents anymore -any reportable fender dent or door scrape is now called a “crash.” For some reason, ICBC is using it’s highly-refined PR machinery to scare people away from purchasing economical innovative and entertaining vehicles that seemingly no North American car company could ever imagine building.

The real question in many mind is, what’s the real motive behind ICBC’s propaganda campaign against unique vehicles at a time when it’s coffer’s overflow from unintended profits? On a recent radio talk show, ICBC’s spokesman Peter Cooper may have let the cat out of the bag when he revealed that the 200 cars a month coming into BC aren’t the real concern, but rather, it is the potential for thousands of cars a month coming in over the years to come that has them concerned. Apparently we should all fear for the well-being of millionaire car-dealers who need bigger yachts, rather than the needs hard-working citizens of this province who are simply looking for a vehicle better suited to them than the usual schlock being pumped out by Detroit.

After all, if BC drivers are going to be faced with world prices for gas and climate change, should we not also have the freedom to choose from the world of vehicle options with which to respond to our crises? Apparently, ICBC thinks not.

Background

IVOAC (Import Vehicle Owners Association of Canada) is a group of Canadian import owners who are working together on the issue of imported vehicle safety and legality in Canada. For more information, please visit our website at www.ivoac.ca or contact Mike Bain at (604) 649-3871.

CAVI (Canadian Association of Vehicle Importers) was formed to represent the interests of vehicle importers and the rights of Canadians to freely chose the type of vehicles that best suit their individual needs. For more information please visit our website at www.cavi.ca or contact Dale Leier at (250) 920-9955.

Organization Formed to Fight Imported Vehicle Rule Changes

New group urges Minister of Transport not to sign off just yet

Renfrew, ON, Feb. 26, 2007. The Canadian Association of Vehicle Importers (CAVI) has been formed in response to actions being taken by Transport
Canada to unfairly limit vehicle choices for Canadian motorists. For several decades now, Canadians have been allowed to import unique and
collectible vehicles for their personal use without having to comply with costly regulations required of major manufactures. These regulations,
know as the Canadian Motor Vehicle Safety Standards, are currently waived for vehicles 15 years of age or older – an exemption known as the 15-year
rule. Imported vehicles are still required, however, to pass appropriate federal and provincial safety inspections prior to highway use.

According to Louis Skebo, Interim Chair of CAVI, the reasons behind government efforts to prohibit importation are questionable. “Despite working
reasonably well for so many years, the Canadian Council of Motor Transport Administrators (CCMTA), of which Transport Canada is a member, has proposed
amending the 15-year rule by extending the age of vehicle that may be imported to 25-years. This change is being pushed through by despite the absence
of:

• Public demand to increase the age of exempt imported vehicles.
• Any evidence that such a change is necessary.
• Research into the full impact that this change will bring about.
• Consultation with all key stakeholder groups.
• Consideration of alternatives to meet the, as yet, unstated objectives.”

CAVI is concerned that the CCMTA’s efforts to push through changes to the 15-year rule for sign-off by the Minister of Transport before proper public
consultation has taken place is inappropriate. As Skebo says, “Changes to the 15-year rule have negative consequences, not only for vehicle owners who
want greater transportation choices at a time of rising fuel costs and environmental concern, but also could affect relations with major trading partners
such as Japan. By arbitrarily restricting Canadians’ access to the widest possible range of vehicle choices, we are being denied world-class solutions to
the twin challenges of diminishing oil reserves and global warming.”

Imported vehicles have always played an essential role in providing Canadians with effective, safe and efficient vehicles. CAVI believes that through proper
consultation and dialogue, the genuine interest of Canadian motorists can be preserved while ensuring the integrity of our shared public highway system.
Therefore, CAVI has asked the Minister of Transport to postpone approving the changes being requested by the CCMTA until proper consultation with stakeholders
and a review of alternative strategies for accomplishing mutually beneficial goals has taken place.

About the Canadian Association of Vehicle Importers
CAVI is a not-for-profit organization formed earlier this year to represent the interests of over 30 small and medium enterprises involved in the purchase,
importation, sale and distribution, modification and maintenance of imported vehicles, primarily from Japan. The impetus for the organization is efforts of
unelected government officials pushing for changing the rules currently allowing imports in the absence of any clear need for any such change or consultation
with key stakeholder groups. CAVI believes that Canadian drivers, facing world-prices for energy and concerns for global warming, should continue to enjoy
the right to import world-class vehicle solutions.

For more information, visit our website at www.cavi.ca, or contact:

The following information is required for your business to become a sustaining member of the Canadian Association of Vehicle Importers. For more information on CAVI, including our Vision and Mission, please click here.

Please fax, mail or email your completed application with $300* membership fee to the addresses below. You can also pay your membership by Paypal (which also processes Visa and MC) at dplconsulting@shaw.ca, or fax to 1.866.625.8743. (*no gst, pst or hst required)

Letter to the CCMTA - Clarification Requested

April 25, 2007

Mr. Shaun Hammond, President
Canadian Council of Motor Transport Administrators
2323 St. Laurent Blvd.
Ottawa, ON K1G4J8

Dear Mr. Hammond,

According to recent communications we have received, the CCMTA has taken an official position to recomnend changes to the 15-year rule exempting imported vehicles from complying with the Canadian Motor Vehicle Safety Standards. As associate members, we are anxious to learn a bit more about how the CCMTA arrived at this position, and how it views it’s position in
relation to other regulations in the future. For example:

1. Can you please illuminate the process by which the CCMTA came to adopt it’s position on the 15 year rule? For example, who introduced this issue to the CCMTA? Did the CCMTA undertake a study of it’s own to understand the implications of changes to the rule? Was a committee tasked with researching the issue and recommending a position to the board? If so, was there a vote
held, and how did the various members vote?

2. According the Transport Canada, the CCMTA feels that it is important for Canada to harmonize it’s rules with the USA, and this is a reason why Canada should change from a 15-year to a 25-year rule regarding import expemtions. Can you please tell us why Transport Canada is saying these things about the CCMTA? Is the pursuit of regulatory harmonization with the US an officially adopted position of the CCMTA? If so, can you illuminate us associate members on why this is a good policy for Canadians?

3. Apparently the CCMTA is sufficiently concerned with vehicle safety that it proposes the 15-year rule be replaced with a 25 year rule. Can you please explain the mechanics behind the presumed increase in safety to be realized from increasing the age of exemption? Again, if you have any studies to backup the position that 25 year old vehicles are safer, our conulting engineers would be fascinated to review them.

4. Can you clarify if the recommendation to amend the existing 15-year rule would apply to all vehicles imported into Canada, or just vehicles from certain countries?

5. Finally, if harmonization with the US is a goal with perceived benefits, may we assume that the CCMTA is equally in favor of harmonizing all the motor vechicle regulations? If not, which regulations would the CCMTA favor keeping distinct from those written in the USA, and why?

Thank your for taking time to address these very topical and important issues.

Sincerely,

Dale Leier
A/National Secretary
Canadian Association of Vehicle Importers
909 Matticks Wood Lane
Victoria, BC V8Y 3H6
T: (888) 999-1801
F: (866) 625-8743
www.cavi.ca

The CCMTA Makes It’s Position Clear (even if it gets its facts wrong)

December 18,2006

Mr. Marc Gregoire
Assistant Deputy Minister
Safety & Security, Safety & Security Group
Transport Canada
330 Sparks Street
Place de Ville, Tower C, 12th Floor
Ottawa ON K1AON5

Dear Mr. Gregoire:

Re: Transport Canada 15 Year Rule and Non-U.S. Imported Vehicles

On behalf of the CCMTA Board of Directors, I am writing to express our concerns about the escalating risk to Canadian road users arising from increasing requests received by Canadian jurisdictions to register and licence imported vehicles that are over 15 years old for on road use.

The vehicles in question, which were manufactured exclusively for the Asian market, include right hand drive passenger cars, right hand drive light commercial vehicles and motorcycles. As increasing numbers of these vehicles are operating on Canadian highways, there is an increased risk to the safety of Canadian motorists who may be operating these vehicles, or other motorists sharing our highways. The safety concerns shared by CCMTA member jurisdictions include the following:

Right hand drive vehicle issues:

· The driver has limited visibility when leaving a parked position and entering the roadway, as well as when passing another vehicle because we drive/park on the right and pass on the left in North America. These vehicles also present safety concerns when making left hand turns due to restricted visibility.

· Because of the right hand drive, the headlamps are not properly aimed for the North American roadway. They have the potential to “blind” oncoming drivers.

General issues with 15-year-old vehicles:

· Most, if not all, of these vehicles do not meet crash worthiness standards as per Canadian Motor Vehicle Safety Standards (CMVSS).

· Occupant restraint systems and seat belt anchor systems are different in other countries and may not be compliant with CMVSS; e.g. no 3-point seat belt in the rear outboard positions.

· Bumpers and bumper assemblies may not meet CMVSS crash thresholds.

· Tires on these vehicles may not meet Canadian standards. While they may be replaced, the removed tires will add to the Canadian pile of unwanted rubber.

· Windshield and other vehicle safety glazing may not conform to CMVSS.

· Lamps, lenses, bulbs and reflex reflectors may not meet CMVSS as well as SAE or DOT standards and are not marked as required.

· Front and rear side marker lamps and reflex reflectors are missing.

· Catalytic converters and neutral switches are missing.

· Daytime running lamps are missing.

· High mounted stop lamps are missing.

· In the near future there will be some additional issues related to the recent addition to CMVSS: anti-theft immobilizers, brake-shift interlock, clutch-shift interlock, child seat anchorage, etc.

Additional issues relate to jurisdictions’ Graduated Driver Licensing programs, in that due to their distinctive styling, with lower cost and increased fuel efficiency, these vehicles may appeal to newer drivers at the learner’s stage. If these drivers accumulate their initial driving experience on right hand drive vehicles or vehicles with unknown safety features, there is potential for increased accident rates when they switch to Canadian specification vehicles at a later time. Also, there are driver testing issues for road tests conducted on right hand drive vehicles.

Therefore, CCMTA is requesting Transport Canada to change its current position with respect to not regulating vehicles that are 15 years old and older and suggest that, as in the U.S., vehicles 25 years or older would be a more appropriate criterion. This change would also result in these imported vehicles being required to meet federally mandated, uniform vehicle safety standards that can be applied consistently across our member jurisdictions as well as harmonization with the U.S. vehicle age thresholds for their federal safety requirements.

Yours truly,

Shaun Hammond,
President

Meanwhile, Transport Canada Couldn’t Agree More

January 26, 2007

Mr. Shaun Hammond
President
Canadian Council of Motor Transport Administrators
2323 St. Laurent Blvd.
Ottawa, ON K1G4J8

Dear Mr. Hammond:

Subject: Transport Canada 15-Year Rule and Non-U.S. Imported Vehicles

This is in reply to your letter of December 18, 2006, in which you expressed the concerns of the CCMTA Board of Directors about the escalating risk to Canadian road users arising from the increasing requests received by Canadian jurisdictions to register imported vehicles that are over 15 years old for on-road use. Your letter is also requesting Transport Canada to change its current position with respect to not regulating vehicles 15 years and older and is suggesting that we adopt the same 25-year age limit as in the U.S.

I am pleased to inform you that work is already underway to examine the impact that vehicles 15 years old and older have on road safety in Canada. The results of the analysis seem to indicate that a 25-year limit might indeed be appropriate. We anticipate being able to publish a notice proposing to make the appropriate amendment to the current rule in Part I of the Canada Gazette in the second quarter of 2007.

I should mention that the results of our study on 15 years old and older vehicles suggest that problems associated with aging vehicles are not limited to those being imported into Canada, whether from the U.S. or elsewhere. Given the shared responsibility for road safety between the provinces, territories and Transport Canada, I would urge the jurisdictions across Canada to also consider appropriate measures to deal with aging in-use vehicles, such as at the initial licensing stage or at license renewal. Similarly, the jurisdictions may wish to consider appropriate measures to discourage right-hand drive vehicles, at the licensing stage, regardless of age, if such vehicles pose a safety risk in the respective jurisdictions.

Should you require further information or clarification, please do not hesitate to contact Kash Ram, Director General, Road Safety and Motor Vehicle Regulation Directorate at (613) 993-6735.

Yours Sincerely,

Marc Gregoire
Assistant Deputy Minister
Safety and Security
Transport Canada

Email from Transport Canada Spokesman

Dear Mr. Leier,

As mentioned by Mr. Claude Roy (Director, Motor Vehicle Safety and Enforcement, Transport Canada), consultations are part of the rulemaking process in the Federal government. The government has consulted with the CCMTA, which represents the provinces, territories and Federal Government.

Transport Canada is now preparing documentation to change the 15 year rule to 25 years, which will be submitted for ministerial approval. The anticipated timeframe for submission of the documentation to the minister’s office is spring 2007. Once the minister signs off on the proposal, the proposed amendment will be sent to Treasury Board for review and Privy Council for approval. Subsequently, publication of the draft amendment will appear in the Canada Gazette Part 1, and a 75 day comment period will be given so that the public can provide comments. Information on how to submit comments will be included in the publication. Comments would then be addressed prior to passing any legislation and publishing in the Canada Gazette Part 11. Publishing in the Canada Gazette Part 1 is anticipated this year, and could also be as early as the spring.

In regards to the 15 year rule, it was originally implemented to allow an exemption for the importation of collectible vehicles for hobby and occasional use. At that time, as most of the vehicles 15 years old and older being imported were typically collectors items, 15 years was considered to be an acceptable age limit for exemption. As the number of 15 year old vehicles being imported for every day use has increased, the government along with the CCMTA no longer consider 15 years to be adequate.

I hope this helps. If you have any further questions, they can be forwarded directly to me.

Regards,

Matt Coons, P.Eng.,

Standards and Regulations Division

Letter to the Minister

February 11, 2007

The Hon. Lawrence Cannon
Minister of Transport, Infrastructure and Communities
House of Commons
Ottawa, ON K1A 0A6

Dear Hon. Cannon:
Re: Changes to the 15-Year Rule
It has come to our attention that, as a result of recommendations from the Canadian Council of Motor Transport Administrators (CCMTA), Transport Canada is preparing to revise regulations currently exempting imported vehicles15 years and older from complying with the Canadian Motor Vehicle Safety Standards.

At first glance it may appear that the proposed change, which is to increase the age of vehicles exempted to 25 years, can only serve to increase highway safety. However, our organization believes that there is a danger that these changes, if implemented, may actually achieve the opposite of their intended results. Furthermore, we believe that these changes unnecessarily and unreasonably deprive Canadian motorists of valuable transportation choices at a time when concerns over fuel economy and the environment are at an all time high.

For your reference, New Zealand has faced similar challenges recently with balancing the concerns of both regulators and the public. However, rather than blanketing the entire field with a rigid and overly restrictive embargo on imported vehicles, they used the opportunity to review the situation and delivered an intelligent domestic solution for meeting the needs of the greatest number of stakeholders. In fact, the New Zealand experience has shown that in some cases it has been beneficial to the public good to actually reduce the age of vehicles permitted entry. By allowing the entry of vehicles that are as young as 8 years of age, better and more efficient vehicles are being imported and replacing older, less efficient vehicles.

While we understand that is may be in the interest of administrators to implement simplistic and restrictive policies, there are undoubtedly better solutions that protect the safety concerns of the general public while preserving the rights of Canadians to make intelligent choices in meeting their vehicle transportation needs.

Therefore, given the enormous potential impact on the safety, economy and convenience of the vehicle-operating public of proposed changes to the 15-year rule, and at a time when Canadians are in great need of less polluting and more efficient vehicles, we request that implementation of any changes to the 15-year rule be postponed pending a period of consultation with all stakeholders.

By sending you this letter, we anticipate that a new round of dialogue between persons responsible for recommending changes to the regulations and those who are most directly affected by changes will commence. At the end of the day, it might be said that a Government that works to serve the needs of its major constituents has the greatest chance to serve the longest. After all, almost everyone drives a car.

Sincerely,

Louis Skebo, Chairman Dale Leier, Secretary

A look at the Canadian Association of Vehicle Importers

CAVI was formed to ensure that the interests of those involved in supplying the marketplace with products and services outside the scope of major manufacturers is reflected in the laws and regulations covering such activities. All Canadians share an interest in the benefits of a safe, economical and efficient vehicle transportation system. Frequently, however, some of the most effective vehicle solutions of the highest quality products have not originated in North America. CAVI believes that if Canadians are to be faced with world prices for energy while making meaningful contributions towards protecting our global environment, they should be allowed access to vehicle choices from around the world. Furthermore, these goals need not conflict with the need for reasonable levels of public safety regulation.

• CAVI’s Vision

  

  To ensure Canadians are afforded the widest possible range of choices for meeting their vehicle needs.

• Mission

  

  CAVI’s mission is to ensure that the needs of the motoring public are not overlooked when laws and regulations affecting vehicle operators are being implemented

Accountability

CAVI is accountable to those involved in the importation and distribution of vehicles and associated components, and makes recommendations to the Canadian Council of Motor Transport Administrators, Deputy Ministers and Ministers responsible for Highways and Transportation Safety.

Strategic Goals and Objectives

• To review existing legislation and regulations to ensure that the needs of stakeholders are not being unnecessarily deprived as a result of being poorly conceived or inconsistently applied.
• To raise awareness of impending changes which may threaten the existing rights of stakeholders from enjoying the widest possible range of vehicle choices
• To work with agencies responsible for researching, proposing and implementing current and planned legislation which limits the choices of vehicle operators by ensuring that:
  • All applicable rules and regulations represent the minimum level necessary to ensure that the overall integrity of the highway transportation system is maintained or enhanced.
  • That any proposed changes be well researched to ensure that any impact on the freedom of Canadians to choose their vehicle options are limited to the minimum necessary.
  • To propose alternative approaches to achieving the specific stated goals of agencies responsible for public safety.
• To ensure that the changing needs of Canadians for vehicle transportation are understood and voiced in a way that is responsible and effective with the goal of expanding the widest possible range of choices.

No one questions the notion that it was imported vehicles, principally supplied from Japan that changed the face of driving in North America for the better. Ironically, current changes being proposed by the CCMTA would prevent vehicles far newer and improved over those original imports from reaching our shores. CAVI is concerned that if stakeholders are not sufficiently involved in the regulatory process, they will be deprived of very effective vehicle alternatives. Therefore, CAVI is working to raise awareness of the challenges and opportunities for all stakeholders in encouraging an efficient marketplace for the supply of vehicles that meet the needs of drivers in a safe, efficient and economical manner. If you believe that choice is an integral part of freedom, and you wish to become a member or an associate member, please click here to join.