Mr. Chair, honourable members, thanks for the invitation to appear here today as part of the committee's study of Bill C-244, an act to amend the Copyright Act.
The Canadian Vehicle Manufacturers' Association, CVMA, is the industry association representing Canada's leading manufacturers of light and heavy-duty motor vehicles. Membership includes Ford, General Motors and Stellantis FCA Canada. Canada's auto industry is responsible for over $13 billion in annual economic activity, 117,000 direct jobs and an additional 371,000 jobs in aftermarket services and dealership networks in 2020. The industry is Canada's second-largest export sector, with over $36.5 billion in exports last year.
The CVMA has been a strong supporter of the Canadian Automotive Service Information Standard, CASIS, since its inception 12 years ago. CVMA members are industry leaders, providing vehicle repair information and tools to the aftermarket at a level equivalent to their respective independent authorized dealers to ensure that Canadian vehicles are repaired to OEM specification to the benefit and protection of the consumer. Over the past few months, our members have reviewed and submitted recommended updates to the CASIS website to ensure technicians have up-to-date links to our members' respective technical information portals. Regular CASIS task force meetings provide an opportunity to bring forward details about any issue that is being encountered by the aftermarket for further study and collaboration on solutions.
Safety is automakers' number one priority, and OEMs are responsible to ensure vehicle safety systems comply with the Motor Vehicle Safety Act, the MVSA. Vehicle safety technologies provide societal benefit and may save lives, including that of the driver, other passengers and those in the surrounding environment, including other motorists and pedestrians.
Vehicle emissions systems must also comply with federal regulations under the Canadian Environmental Protection Act, CEPA. Modification to a vehicle's emissions system may put a sensor out of alignment, resulting in compliance issues due to increased emissions, and it may also affect fuel consumption. Allowing unrestricted access to vehicle safety and emissions systems software that is not required to complete a repair introduces significant compliance and safety risks in the event of modification resulting in a system not operating as originally designed. CASIS ensures that repairs are done safely and in compliance with the MVSA and CEPA, among other regulatory frameworks that apply to OEMs.
Cybersecurity is another top priority for industry, and data protection and data privacy are embedded from the earliest stages of product development. OEMs invest and include security measures beginning at the design process and throughout the automotive ecosystem, and abide by rules that govern cybersecurity management.
Circumvention of a vehicle technology protection measure, or a TPM, and the modification of vehicle system firmware may undermine cybersecurity protections, making vehicles more vulnerable to hacking. Automated vehicle and connected vehicle technologies, driver-assist systems and the transition to an electric fleet with charging infrastructure require an increasingly vigilant approach to cybersecurity.
The 2020 Transport Canada report “Canada's Vehicle Cyber Security Guidance” notes that “A cyber security breach—either deliberate or accidental—could have adverse consequences, such as compromising vehicle safety, unauthorized access of confidential information, and vehicle theft, among others.”
Context is critical here. The consequences of allowing unrestricted modification of motor vehicle firmware and certain software are more serious than compared to other consumer goods, which we understand is the intended focus of this bill.
As the committee continues its study of Bill C-244, we strongly recommend the committee hear from a cybersecurity expert to receive a briefing about cybersecurity threats as related to vehicle security safeguards including measures to protect the integrity of vehicle systems. We also recommend inviting an appropriate Transport Canada official who can provide input to the committee from a road safety and motor vehicle regulation perspective as well as an Environment and Climate Change Canada official who could speak to the importance of vehicle system integrity related to fuel consumption and emissions compliance.
In closing, the CVMA remains committed to the CASIS model, which has been working for over a decade and may serve as a model for other industries to adopt. We urge the committee to continue its detailed review, hear from the vehicle cybersecurity and safety experts, and continue to engage with CVMA as this study moves forward.
With that, I'll be pleased to take your questions, and thank you again for the invitation.