Good afternoon, everyone.
Thank you for your invitation. I am pleased to be here before you today to discuss Bill .
Although I am sure many of you are familiar with CAA, let me begin by providing a bit of background on our organization's role in road safety.
We were founded in 1913 as a consumer advocacy group, not as a tow-truck company. Today, we have 6.2 million members from coast to coast and the services we offer them extend well beyond emergency roadside assistance. From our inception, our organization began advocating for critical pieces of the traffic safety framework in place today in Canada, and from those earliest days, in pushing for stop signs to seatbelts to airbags to campaigns against impaired and distracted driving, CAA has been at the forefront of traveller advocacy for more than a century. Today, we represent roughly one in four adult drivers in this country, and we are recognized as one of Canada's most trusted brands.
We have noticed that consumer protection in Canada has lagged behind other developed countries, and so we are pleased to see that Bill addresses several of the shortcomings.
In the United States, for instance, the National Highway Traffic Safety Administration, or NHTSA, has the authority to require manufacturers to recall vehicles that have safety-related defects or do not meet federal safety standards. Since enacted in 1966, more than 390 million cars, trucks, buses, RVs, mopeds, and motorcycles, and 46 million tires, and 42 million child safety seats have been recalled to correct safety defects.
Here in Canada, CAA believes that for the owners of the roughly 23 million light vehicles on the road today, Bill is a positive step that would strengthen the enforcement and compliance regime to further protect the safety of Canadians. As drafted, we are pleased to see that the minister of transport would be provided with the authority to order companies to correct a defect or non-compliance, and would be given the ability to penalize companies for offences committed under the act.
While most manufacturers live up to the high standards we have set for Canadian vehicles, the fact remains that, even as we speak, Transport Canada has 16 active defect investigations under way. Of these active investigations, 13 date from before 2017. It must be said that there are instances where government intervention may not only be useful, but could even be necessary.
For example, on November 10, 2016, Transport Canada announced it had made a preliminary determination that there was a safety defect involving brakes on 2011 and 2012 F-150 trucks with a 3.5-litre EcoBoost engine; the department had received over 100 complaints about this. In his testimony before the Senate last fall, said the government contacted Ford and was disappointed that the automaker disagreed with the government's assessment. The minister further pointed out that under existing legislation, the effective result at the time was a stalemate. Ultimately, there was a delay of nearly six months of public pressure that finally resulted in the automaker issuing a notice of defect on May 5 of this year. Bill would increase the tools available to the minister to limit delays like this.
Today, the strongest measure Transport Canada can take when dealing with vehicles it believes are a hazard to Canadians is to force the issuance of a notice of defect, which requires a manufacturer to notify owners that their cars are unsafe. That's it. The government does not have the power to force a manufacturer to order a recall and/or to effect repairs. This makes the current Canadian system a veritable, if not literal, paper tiger.
Bill shifts the focus to remedies. It gives the minister the authority to order a company to issue a recall and make companies repair a recalled vehicle at no cost to the consumer. The minister may even prevent them from selling new vehicles in Canada until they are repaired. This matches similar legislation that exists in the United States, finally leveling the playing field in these important areas for Canadian consumers.
Today, Transport Canada's website hosts information about vehicle recalls and encourages consumers to address their vehicle recall as soon as possible. However, we know that is not always in the control of the consumer. Bill is a necessary tool for enforcement when handling vehicle recall cases where the minister deems intervention is necessary, and it would provide positive, added protection for consumers.
For too long, Canadian consumer protection has taken a back seat to the United States. In our view, Bill goes a long way towards rebalancing the situation. It represents a solid advance for Canadian consumers.
Thank you for your attention.
We welcome any questions you may have.
Good day. I'm George Iny, executive director of the Automobile Protection Association. With me is John Raymond. He's a member of the board of the association and also a former auto dealer. He works very closely with us on a number of issues, including vehicle safety.
The Automobile Protection Association, APA, is a not-for-profit organization. It was founded in 1969. It provides a public information service using telephone hotlines and a website.
We are one of the major sources of complaints to Transport Canada on presumed vehicle safety. We also work closely with university research teams across Canada to encourage proper oversight of the vehicles on our roads.
We are a small team. We even do a lot of work with people from the industry because we much prefer realistic solutions, but always while representing the interests of consumers.
I'm here today to go over perhaps some of the measures that are in the proposed Bill . I'll try to give you a little colour or background information to go with it. Currently, there is a database where you can look up vehicle recalls. It's a very good database. It's an old one. But it's not in real time, so you will find out if there ever was a recall for your vehicle, but it will not tell you if your actual vehicle was fixed or not and we would like to have that ability.
In the time between when Bill came out and today most carmakers, because there's an American requirement, came on board and are pretty much doing that. This would allow the stragglers to be picked up. It would also allow the government to put in perhaps some minimum information that you would be able to get, because not all of the websites are easy to use and not all of them give you the full information on the recall.
This is an important pre-condition if you want to get used cars corrected before they're resold. It's a big problem, and one of the objections the retailers have, and also the provincial ministries, is that there isn't a standard way to look up that information that's easy. I might add that a provincial safety inspection, which people assume involves a check for recalls, actually doesn't currently. The two systems don't talk to one another. So if this is fixed, in other words, if we have at least standardized, good quality real-time information, then maybe that might be included as part of the inspection process.
Administrative monetary penalties would be a more expedited tool than using the courts. The government doesn't go to court very often and when it does, it loses, so this would be something that we're hoping would be used more. It's a little difficult, because you're giving basically a gym membership to somebody who you don't know is actually going to use it and get stronger, but that's our hope. They would be creating a tool that the government could then use, and in that case it would allow it to have a little more leverage with carmakers that aren't being very compliant.
An important provision that we feel the administrative monetary penalties should have is a set-aside for research in the area of vehicle safety or injury reduction. Most of you are aware that Volkswagen was not so recently found to have cheated on diesel engine emissions, but actually the people who discovered it were working under an award, a research grant, from a previous investigation where a different carmaker or truck maker had been found guilty of cheating. In other words, some of that money if it's collected should be set aside to further the cause of vehicle safety.
On the power to order correction of defects, they've had it in the United States since the early 1970s or late sixties. It's a flaw in our original act that the way the act was written what seemed politically or maybe practically reasonable at the time was a letter by mail. Since then, essentially, events have overtaken our act, so more than 99% of recalls or about 600 a year are happening and, I would say easily 98% roughly are happening with what's called voluntarily. So the repair is being done by the carmaker either because they think they should do it or because they're required to do it in the United States.
We're looking at three, four, five, or six recalls a year where the government really needs more muscle. It's not a huge game-changer when you look at what's happening already.
Thank you very much for your testimony and for being here.
Before I get into questions, for the benefit of my colleagues around the table, I want to put on notice that I plan to move an amendment. I don't have proposed text today, but I want you to understand the spirit of it.
During the minister's testimony, he explained that there was a conversation between the department and stakeholders with respect to proposed section 10.52. This is the Senate amendment. Essentially, I will propose to delete the clause as it exists—and thanks to the Senate for causing me to think about it—and replace it with some language that would do a few things. I want the new language to reiterate with certainty that the same remedies that apply to consumers will apply to dealers when it comes to the repair, the reimbursement, or the replacement of defective vehicles in the event that a recall is ordered, but also make clear that none of this is with prejudice to remedies that may have been negotiated on commercial terms. When I have a translated version of the language, I'll circulate it to the committee.
I am curious about one of the components of the Senate amendment from a consumer protection point of view.
Mr. Jack, you might be well positioned to offer commentary. One of the potential consequences I saw with the amendment was, when there's a 1% interest payment available to dealers, that might motivate a manufacturer to repair vehicles for which there's an economic consequence to not repairing, before they repair vehicles that are on the road today being driven by consumers.
Did you have a position or perhaps thoughts on this asymmetry, which might lead to a strange situation that put Canadians in danger?
Thank you, Madam Chair.
Thank you for joining us, gentlemen.
My first question will go to Mr. Iny, but the other witnesses may feel free to add to his reply if the spirit moves them.
Mr. Iny, in previous testimony before the Senate, you talked a lot about the usefulness and the importance of more investment in road safety research. You talked about it again just now. Earlier this week, we heard from the Auditor General. I must tell you that his testimony on the subject was quite concerning.
You submitted a proposal for an amendment, whereby all or part of the money collected in fines would be redirected to research. What effect would that have? Do you want all or part of the fines invested in research?
Thank you, Madam Chair.
I'm going to dig a bit deeper into some of the solutions. We talked about recalls. Mr. Lobb talked about purchasing a vehicle, whether it be at an auction out of country.... There is a process right now, at least in the province of Ontario, whereby when you do purchase a vehicle, you get the full history of the vehicle. You get a full page of vehicle history. Is that an opportunity to actually identify the vehicles that would have a recall attached to them?
The second opportunity, of course, is when you buy a vehicle. You also most times do a safety check, whether it's already safety-checked.... Of course, that's another opportunity, again, once the VIN's punched in, to actually identify and recognize that a recall is in order.
Do you think those are two mechanisms that can be used, and/or do you have any other ideas that can be used to actually catch a recall when a vehicle's being sold, whether it be within a country or from another country?
It depends on what kind of framework we're looking at. As you would know, in Bill there's some language that would enable the minister to allow AVs to be tested on Canadian roads. We're very supportive of that.
We need some framework, because things should be happening right now that would be illegal technically, such as testing of AVs. If we want to have any kind of R and D in this country, we obviously need to be able to test those vehicles at some point. I can't imagine it was the intention of those who framed the bill originally that we wouldn't be allowed to do that kind of work. We're very supportive of that part of the framework.
Beyond that, absolutely, there needs to be more of a framework. We testified before the Senate committee, which looked into this issue extensively. We do polling on this issue. We know roughly where Canadians sit: they think AVs are coming, but they're kind of scared of them right now, so there needs to be more talk, public education, and policy work done. We understand there is at this point a DG-level committee in government across a bunch of departments looking at some of the issues, which will inevitably touch on all kinds of departments.
Insurance regulation is very interesting, and the Department of Transport obviously is going to be implicated in this, as well as ISED. It is truly an interdepartmental issue.
Data privacy is an issue we care a lot about at CAA. The Office of the Privacy Commissioner has been looking at this as well. Who controls the data that your vehicle will be collecting about you, or is already potentially collecting about you, as we move into this era of the smart phone on wheels? That's even before AVs. That's in the next 10 to 20 years, before everybody's in an AV; we are going to have vehicles collecting a heck of a lot of information about us.
One, this involves the provinces too, because the vehicle's driving on roads inside their province, so the answer won't be entirely federal.
Two, we shouldn't be shy about borrowing what's been done elsewhere, rather than reinventing the wheel, because we're a middle-sized player. If we can find a large set of rules that work, either in the U.S. or in Europe, we could consider looking elsewhere.
Three, when things are changing so quickly, the answer may not be in legislation right now, but we need to be ready, to have a framework ready, so we can then put the rules in afterwards.
Thank you very much, Madam Chair.
Good afternoon, members of the committee.
I'm here representing Fiat Chrysler, Ford, and General Motors, which are my member companies. In Canada, these companies operate five assembly plants, multiple parts and components plants; as well, each has research and engineering facilities with mandates for advanced vehicle technology development, including partnerships in related software development.
CVMA members remain committed to the development and manufacture of safe automobiles, proactively enhancing occupant protection technologies in the event of a crash, as well as many new and innovative advanced driver crash assistance technologies to improve safety by helping the driver avoid crashes in the first place.
We support Bill . We continue to share the government's objective to advance or enhance the safety of Canadians and provide additional regulatory flexibility to support the introduction of advanced safety technologies as well as innovations as outlined in the bill.
In our written submission, we have identified four areas that have practical and business implications and need reconsideration, particularly since the bill includes the ability to delegate some existing and proposed ministerial powers. Our recommendations do not detract from the safety objectives of the bill.
We offer the following recommendations, which are really there to improve clarity and, in so doing, provide for more effective policy implementation and efficient administration.
The first is with respect to proposed new section 10.61, power to prohibit offering for sale—defect or non-compliance. Manufacturers sell, wholesale, new cars to dealers that are privately owned independent businesses; manufacturers do not sell vehicles to consumers, retail. The proposed language inappropriately holds the vehicle manufacturer or importer, which do not sell vehicles to consumers, criminally and administratively responsible for the actions of another independent business entity, namely the dealer, to sell vehicles under a recall and stop-sale order to consumers.
Vehicle manufacturers and importers should not be held criminally or administratively responsible for the actions of independently owned and operated new car dealers. The proposed language to prohibit offering for sale defective or non-complaint vehicles should more appropriately be applied to dealers, which are the entities that sell vehicles to consumers. Doing that would be more consistent with the United States' responsibilities and requirements.
We would recommend that this provision be revised to give the power to order vehicle manufacturers and importers to issue a notice to the dealers to remedy the vehicle prior to the first sale.
The second recommendation concerns proposed new section 8.1, power to order tests, analyses, or studies. We recognize that this unique-to-Canada power is proposed to collect information quickly for the purpose of verifying non-compliance or defects in certain cases where information is not voluntarily provided. We believe, however, that the proposed language is very broad and risks being misused beyond the specific intent, with the potential outcome being to order any test, analysis, or study in any scenario, potentially downloading Transport Canada's compliance and audit responsibilities onto companies in lieu of the department's oversight responsibilities.
This wording needs to be updated to clarify the intent of the provision, which is to order tests, analyses, or studies to verify non-compliance, and to include the notion of “reasonableness”.
Our third recommendation concerns proposed new subsection 10.4(1), correction date. CVMA members strive to provide the most accurate and up-to-date recall information to vehicle owners. The act currently requires that an initial recall notification letter be sent to vehicle owners no later than 60 days following the notification to Transport Canada. If the parts required to repair the vehicle are not immediately available at the time of the first notice, a follow-up notification letter is sent when parts become available.
At this preliminary stage of recall, information on availability of repair parts may not be available, and estimates of the date for parts availability may be revised multiple times. The end product of this, of course, is that you could end having multiple letters going out to consumers. Consumers tend to become less sensitive, or desensitized, to those notices. It loses its importance, and they tend to avoid the importance of that notice to begin with. This undermines public confidence in the system. We don't want that, and we don't believe Transport Canada wants that.
Prescribing the requirement in the act also prevents the leveraging of communication technologies that may be better suited for providing information in a more timely manner, such as manufacturer web-based recall lookup tools that our members already have in place.
This additional requirement is not needed in the act and can be addressed under section 15 of the motor vehicle safety regulations, which define all the information required in the notice to the minister and the notice to vehicle owners.
Our last recommendation concerns dealer compensation. Based on Mr. Fraser's description of the proposed amendment that he plans on introducing, we would welcome such an amendment that satisfies the concerns of both dealers and OEMs, original equipment manufacturers. CVMA members currently address compensation for new vehicles under recall with their independent dealerships in a fair and equitable manner, both in Canada and in the United States. We will continue to do that, and we continue to be open to further discussions to deal with their concerns.
Madam Chair, those are my remarks. I would be glad to answer any questions. I am hoping we can get some support for our recommendations in this specific case.
Madam Chair, committee members, I appreciate the opportunity to be with you today to discuss the important issue of motor vehicle safety and the proposed amendments to the Motor Vehicle Safety Act, as contemplated in Bill . I am not going to bore you with the details of the promotional spiel on our association, but suffice it to say that we represent the international automakers in the Canadian marketplace—essentially, everybody but Mark's members.
At the outset, I want to say that safety is of paramount importance to each and every one of the GAC member companies. As I noted before your colleagues in the Senate last fall, our members have consistently been at the vanguard of the introduction of advanced safety technologies, such as the three-point seat belt, electronic stability control, and advanced lighting, currently the subject of CMVSS 108, which I also made reference to in my testimony to the Senate, and for which we are still looking for a final regulation from the department.
I was pleased to be at Tuesday’s meeting of the committee on Bill for part of the time. A number of the committee members expressed concern about the rapid pace with which technological innovation is happening in the automotive industry. I concur with you that the pace of change is both unprecedented and disruptive. In this regard, the Global Automakers of Canada supports the flexibility being afforded by Bill S-2 to accommodate adjustment to this rapid change with respect to propulsion, connectivity, and automation technologies. This flexibility, used prudently, should allow Canada to better stay at the forefront of new technological advancements and any regulatory regime required to support them.
I also want to comment briefly on the sections of the bill that are intended to bring Canada into greater regulatory alignment with the United States. The members of the Global Automakers of Canada support the recognition of U.S. standards across the NAFTA region, as our plants in the three countries are geared to serving the larger U.S. market, and building once for all three countries has the benefit of reducing complexity and yielding economies of scale.
That being said, vehicles meeting the UNECE global standards are similarly safe and often incorporate advances not yet adopted in the United States. We therefore believe that Canada should retain the flexibility to recognize other advanced standards, in addition to FMVSS, in order to deliver the greatest benefits to Canadians and to ensure that we are able to meet our CETA obligations.
Without such consideration, Canadians are being shortchanged. Transport Canada not only faces increasing regulatory irrelevance but also misses an opportunity to play a leading role in the North American regulatory framework, not by adopting a unique Canadian standard but rather by critically assessing standards in the rest of the world—i.e., the UNECE standards, as well as those of the United States—to ensure that Canadians are not being denied leading safety or environment technologies simply because the U.S. is unprepared or unwilling to embrace such standards. Canada can be, and frankly should be, innovative in its regulating, as well as capitalizing on the regulatory co-operation provisions with respect to regulations and standards in both the United States and the EU.
The association’s members support amendments to the Motor Vehicle Safety Act that would provide meaningful improvements to public safety. However, additional regulatory burden without benefits to the motoring public should be avoided.
The question was raised by a member on Tuesday with respect to whether the collection of more data would assist in improving safety. The members of the GAC are not against the provision of additional data, provided it is reasonable and useful, and ultimately improves safety. The experience of the United States has demonstrated that the identification of safety defects is often a very complex task and data alone is insufficient for that task. The U.S. gathers a tremendous amount of data, but that data did not help with respect to the early identification of some of the defects related to recent high-profile recall situations.
In this regard, our members do have a concern with respect to proposed subsection 8.1(1), which Mr. Nantais also referenced, which provides the minister with the power to order a company to “conduct tests, analyses or studies...to verify compliance with this Act, that the Minister considers necessary”. This is a wide-ranging, Canada-unique power that provides the minister with unfettered discretion to order these tests with no consideration as to the cost to the company, nor the potential charter implications of asking a company to conduct and pay for work that may subsequently be used by the government against the company.
This clause is problematic, and if the language cannot be tightened up in the legislation, then we believe regulations should be developed to provide guidance as to what conditions would justify such a request, what framework would be used to standardize expectations over how those requests are filled, and who would assume the costs of such tests.
There are other sections in this bill as amended by the Senate that raise concerns for our members, but my time has expired. Based on conversations amongst the committee and two years spent on this bill, I think time has expired in terms of moving the bill forward as well.
Thank you, Madam Chair, and thank you all members of this committee.
My name is Michael Hatch, and I'm the chief economist for the Canadian Automobile Dealers Association, CADA. We're the national association, as many of you know, for franchised new car dealers and truck dealers in Canada, with more than 3,200 across the country in virtually every town and community, employing over 150,000 Canadians in well-paying jobs.
We greatly appreciate the opportunity to bring the voice and concerns of our dealer network to this committee as it considers Bill , which is a very important bill for our industry, both the retail and the manufacturing levels, as you will see this afternoon.
I'll say off the top that CADA supports this bill and hopes that it becomes law in a timely manner. We supported a similar bill under the previous government, and we appreciate the multipartisan support that it appears to enjoy.
I'm going to begin with a few points about recalls in general. First of all, recalls are increasingly common in today's vehicle market. That's no secret. It is a function of many factors. More cars are on the road. There's greater complexity in the components of new vehicles, and there's an improved system within the industry to identify issues that could necessitate a recall. These are all good things.
The volume of cars on the road and their complexity will inevitably lead to more not fewer recalls in future. The vast majority of them are handled well by manufacturers and dealers, and consumers' problems with their vehicles are solved in a timely and efficient manner.
Our proposed amendment to this bill in the Senate had four components: to ensure that manufacturers will continue to be responsible for the recall process; to ensure that dealers face no new obligations under the act; to extend buyback provisions to dealers in the event that a vehicle cannot be repaired; and, finally, to provide for manufacturer-paid reimbursement of dealer carrying costs in the event of long and lasting recall situations. I'll get into a little more detail on that last point.
We expect that the amendment to be moved at this committee will accomplish most of these objectives, and I thank Mr. Fraser for his comments earlier referring to that very amendment. We look forward to the specific language that it contains.
Dealers don't sell their inventory on consignment. The moment that a car arrives at the dealership, it becomes the property of the dealer, who must finance and maintain millions of dollars worth of inventory at any given time. When a vehicle is rendered unsellable due to a long-lasting recall where a fix is not immediately available, dealers bear a significant cost. Inventory must continue to be financed and maintained, and in these low-frequency cases—admittedly low-frequency—yet high-impact cases, dealers can be stuck with cars for months or more.
Imagine, for example, paying a mortgage on a million-dollar home every month, but you can't live in it or rent it out and you still have to pay the property taxes and keep the lights on. This, in effect, is the situation that dealers face when inventory is rendered unsellable for months or more on end due to long-lasting recalls. Again, these cases are rare, but very high impact when they do take place for our dealer network, which again consists primarily of small and medium-sized businesses across Canada.
Our amendment, among other things, sought to address this by providing for manufacturer-paid reimbursement of dealers' carrying costs over the period of the recall according to a formula. We arrived at this formula by consulting with our American counterparts where such dealer protection is enshrined in federal law.
I would note also, as all of you know no doubt, that part of the government's rationale for pursuing this bill is legislative harmony with the United States. Our amendment was inspired by the same motivation.
Our proposal was straightforward. Under a recall scenario, the manufacturer would be compelled to either make the fix available in a timely manner or buy the vehicle back from the dealer at the original dealer invoice price. In rare cases where the fix was delayed, the manufacturer would be compelled to reimburse the dealer for carrying costs over that time period for the vehicles affected, as is the case in the United States.
In subsequent discussions with the government, alluded to by the minister here a couple of days ago, on Tuesday, we arrived at a compromise position that we hope to be reflected in the new amendment to be tabled at this committee. Again, we look forward to the debate of this amendment in this forum.
Ultimately we want this bill to pass as the important piece of consumer safety legislation that it is. We will continue, as dealers and dealers associations, to pursue a legislative solution of the fundamental imbalance that exists between manufacturers and dealers in the context of long-lasting recall situations, but not as part of this bill.
As I've said, recalls will continue to increase in frequency, so this problem for dealers is not going to go away. We support the bill and don't want to stand in the way of its eventual passage, but we will continue, again, to pursue a legislative solution to protect dealers saddled with inventory when recalls drag on for months or sometimes even years.
Thank you very much to all members of this committee. I look forward to any questions that you have and I will do my best to answer them.
I think that's a valid point. As we were speaking about in the last session with the witnesses, there has to be more communication between the different levels of government to actually look after some of these things, otherwise the water falls through the cracks, and that's not a good thing.
I want to go back to the technologies again. We've had this discussion in the past whereby, let's face it, five years, 10 years, probably sooner rather than later, down the road we're going to see smart phones on wheels, and, with that said, a lot of factors with respect to safety.
Mr. Adams, you made the comment in your presentation that “flexibility, used prudently, should allow Canada to better stay at the forefront of new technological advancements and any regulatory regime required to support them.” Can you elaborate on that?
Since it's one of my members, I think in this particular case it is unusual for sure. Whether it's the subject company or other companies, in remote areas of the country like that, sometimes they'll approach it in different ways.
Sometimes they'll send an actual certified mechanic up there, but it's important through.... We generally do them through dealers, because we have certified technicians. Sometimes these are safety related. Delegating that work off to sort of an after-market mechanic or something like that.... Sometimes it means either compliance or not with the Motor Vehicle Safety Act, and they will not allow it to go to after-market service repair. They will either send somebody up to that location or, as you mentioned, freight the vehicle down to where there is a dealership. I think in this particular case, Chrysler dealt with that.
That's really the issue here. You need to have the right person to do the work, particularly in this situation where you have a safety recall, and have it certified that it meets all the requirements of the law, and obviously compliance with satisfying the recall.
Voices: Oh, oh!
Mr. David Adams: With respect to your comment about the technology, my understanding is that in a lot of those cases with respect to lighting, the technology is already existent on the vehicles that are in Canada, but has just been programmed off. There are other elements of that technology that meet the Canadian standards, but other elements that could be switched on aren't, because of where we're at with our dialogue on the lighting issue.
Technically, I think you are correct. If Canada did decide to go down that road with this and a consumer took a vehicle with that advanced lighting to the U.S., theoretically they probably could be stopped at the border and told that the vehicle was not compliant. Would that happen? I'm not sure that you would find anybody who would be able to determine whether it is compliant or not. In any event, the technology is such that it could be switched off again, so it's not in any way a hindrance to trade back and forth across the border.
I think we have to be very careful here in getting ahead of the U.S. Canada is not a large enough market to drive vehicle design. Also, there's this perception that we're behind other jurisdictions in terms of safety. When we talk about regulatory co-operation, harmonization, and alignment of our standards with those of the United States, we need to be clear that we are harmonizing and aligning with the higher common denominator, one of the highest common denominators in vehicle safety in the world, if not the highest.
We're much better off in aligning our standards on a North American basis. In Canada, we produce vehicles primarily for the United States market. There are other technologies that will evolve in other markets. Our view is, certainly, make them available in North America, but review them in the context of North America. If it's deemed to be the same level of safety or better, then we should adopt those as a harmonized standard in North America.
That's the way we do it, but if Canada alone.... We're not necessarily behind because we're already harmonizing with the United States, which is that higher common denominator. Also, we have to be very careful. If we put unique standards on Canada—we've been through this phase—ultimately we will minimize or constrain product choice. It's not a large enough market to drive that vehicle design, so ultimately a consumer may not get these types of vehicles.