To start with the first issue, with the exemption from the standards, the purpose of this particular clause is to allow us to have the flexibility to allow new technologies to come in. We have a proposed subsection, captioned “Conditions for granting exemption”, that would fall after these proposed amendments. It says it
must only be granted...if the exemption would not substantially diminish the overall safety performance
of the vehicle. There is, then, that safety test.
One concern I have with the way the wording is here is that it may not be decision that should be based on an existing standard. We're dealing with the unknown unknowns as we move forward.
I'll put forward one example that we could potentially come across as we move forward. We may have a vehicle brought forward for which there was no steering wheel, but the collision avoidance systems within the vehicle were so significant that you would not need a steering wheel. In the way this amendment is written, however, since that configuration would not meet the steering wheel safety standard, we wouldn't be able to allow it in.
The ideal is that we want to look at the deal holistically and not just say that you must meet every standard. There could be some standards that provide a greater level of safety than other standards. If I had a standard whereby something better might be in the airbags but the labelling wasn't as strong, the way this is worded, I'd have to do it standard by standard. What we were trying to accomplish when we wrote the original wording was to look at it holistically: we would assess every standard, but there would be an opportunity to weigh something against it if the overall safety for the vehicle was not affected.