Question and answer for Low-Speed Vehicles
Q1: What is a Low-Speed Vehicle (LSV)?
A1: An LSV is a class of small, lightweight electric vehicles that was originally introduced to meet the short distance transportation needs of residents of gated communities. LSVs have four wheels and drive at a maximum speed of between 32 km/h and 40 km/h.
Q2: How is a LSV different from an electric passenger car?
A2: The LSV class was created for low speed environments (maximum speed between 32 and 40 km/h). Because they were designed for controlled and protected environments, they are not required to meet any crash test requirements.
The LSV does not have the same legal status as a passenger car, which is a class that must meet strict safety standards. An electric passenger car must meet the standards required by the Motor Vehicle Safety Act (MVSA) that apply to all passenger cars.
Q3: Which safety standards must LSVs meet?
A3: To offer a minimum level of safety, an LSV must meet the following Canada Motor Vehicle Safety Standards (CMVSS):
CMVSS 500 - Defines overall requirements for Low Speed Vehicle class, which include: headlights, turn signal lamps, mirrors, parking brake (but no specifications) and a maximum speed capability. Within CMVSS 500, the following standards must also be met:
- CMVSS 115 - Bear a Vehicle Identification Number, which provides a way to track ownership and identify recalls;
- CMVSS 205 - meets glazing requirements for a windshield; and
- CMVSS 209 - Have seat belt assemblies present, with no requirement for seat belt anchorages.
Q4: Why do LSVs have such a small range of speeds?
A4: The Canadian LSV standard is aligned with the American Federal Motor Vehicle Safety Standard 500. The U.S. rule allows that the maximum speed could be greater than that of a golf cart, but low enough that the risk of injury, if the LSV were to hit a stationary object, would be low. Since LSVs do not offer the same level of occupant protection as passenger cars, higher speeds would greatly increase the risk to their drivers and passengers.
Q5: What roles do the provinces and territories and Transport Canada play in regulating LSVs?
A5: Transport Canada promotes the safety of the travelling public to reduce the risk of death, injury and damage to property and the environment. It does this by updating and maintaining the Motor Vehicle Safety Regulations (MVSR), including the Canada Motor Vehicle Safety Standards (CMVSS). All new and imported vehicles sold in Canada must comply with the CMVSS that applied – at the time of manufacture. And as is the case in the U.S., LSVs must be self-certified by the manufacturer.
Provinces and territories regulate vehicle licensing and the use of vehicles on their roads. This means that even if a vehicle has a National Safety Mark (NSM) issued by Transport Canada, it is not guaranteed to be licensed everywhere in Canada.
Q6: What is a National Safety Mark?
A6: The National Safety Mark (NSM) is a Crown trademark. A company must apply for permission to use it and the Minister of Transport authorizes its use.
New motor vehicles, tires and child restraint systems made in and shipped within Canada must bear the NSM.
The NSM shows that the maker of a vehicle, tire or child restraint certifies that it meets all required Canadian safety standards for a vehicle, tire or child restraint system.
An imported LSV must be certified by the manufacturer to meet all Canadian standards that apply. A compliance label must be affixed containing prescribed wording to indicate that the vehicle complies with Canadian standards for LSVs.
Q7: Which LSV manufacturers currently have the National Safety Mark?
A7: A list of LSV manufacturers currently holding NSM's can obtained on the Transport Canada website.
While having a NSM allows companies to sell LSVs across Canada, that decision is theirs alone.
Q8: If Transport Canada has issued a safety mark for LSVs that indicates they meet safety standards, how can Transport Canada allow these LSVs on the market?
A8: LSVs are safe if used responsibly in environments for which they were designed. If a manufacturer holds and affixes a National Safety Mark for LSVs, then the manufacturer attests that their LSVs meet the three minimal standards that apply to that class, not the 40 standards that apply to the passenger car class. While Transport Canada regulates the safety standards that apply to new vehicles sold in Canada and imported vehicles, the provinces, territories and cities/municipalities have jurisdiction over the appropriate use of LSVs.
Q9: Can I drive an LSV on city roads?
A9: You must check with your province or territory to see if you can drive your LSV on public roads. They will decide if, how and where LSVs should/may operate.
Q10: Will Transport Canada require extra safety features for these vehicles as some parties have recommended? Are LSVs safe in a collision?
A10: The recent update to the LSV class definition indicates that low-speed vehicles are intended for environments appropriate to their design.
As in the U.S., Canada's LSV class was created to allow the manufacture and sale of small, lightweight vehicles that could not meet safety standards appropriate for larger, faster vehicles. These vehicles were originally designed for low-speed, short distance transportation needs of residents of retirement or other planned, gated communities (e.g. residential areas, university campuses, parks, military bases). Driven under these conditions, LSVs do not pose a major safety risk to the occupants.
The Canadian LSV amendment is closely aligned with the U.S. standard, and a LSV manufacturer is able to build one LSV for the North American marketplace.
Q11: Does Transport Canada support the use of LSVs?
A11: Yes. Transport Canada welcomes new technologies that reduce smog and greenhouse gas emissions. When used as designed, LSVs can offer a safe and effective form of clean transportation.
Q12: Does Transport Canada believe that only fossil-fuel powered vehicles are safe and appropriate for the Canadian road environment? What is Transport Canada doing to introduce clean vehicles such as the LSV?
A12: Transport Canada encourages automakers to design and make electric vehicles that meet all of the comprehensive safety standards required of by mainstream fossil-fueled motor vehicles. Such vehicles would offer the same level of protection, without tailpipe emissions harming local air quality.
Transport Canada is committed to reducing the risk of death, injury and damage to property and the environment. That is why:
- Transport Canada created specialized classes for certain low emission vehicles including the LSV class in 2000, and the power assisted bicycle class in 2001;
Through the ecoTECHNOLOGY for vehicles (eTV) program and the Transportation Development Centre's projects, Transport Canada:
- Encourages Canadian vehicle manufacturers to design and build electric vehicles that meet all the safety standards for mainstream cars and trucks.
- Promotes advanced clean vehicle technologies and assesses them for safety and environmental performance. This includes plug-in hybrids and fuel cell-, diesel- and electricity-powered vehicles.
Q13: Why did Transport Canada not allow low-speed trucks sooner?
A13: The United States amended its regulations to allow low-speed trucks in 2005, and followed with an amendment in 2006 to increase the weight of a LSV.
Transport Canada then began to thoroughly examine the various U.S. amendments, which include the addition of low-speed trucks to the LSV definition and other technical changes such as windshield safety glazing requirements. This has required due diligence, including extensive stakeholder consultations, to determine which aspects of the various U.S. amendments were required to meet Canadian needs.
The resulting Canadian LSV amendment closely aligns the Canadian standard with that of the U.S. standard, and a LSV manufacturer is able to build one LSV for the North American marketplace.
Q14: Why can a low-speed vehicle meet the requirements for its vehicle class and yet not be as safe as a conventional vehicle?
A14: Conventional passenger cars must meet up to 40 safety standards, whether they are powered by electricity, gasoline, diesel, propane or natural gas. This is not the case for low-speed vehicles, which must meet only three minimal standards.
The marked difference in requirements between the two classes is due to the fact that LSVs were intended for use in controlled low-speed environments, where the risk of colliding with larger and faster motor vehicles is much lower.
In terms of occupant protection, vehicle crash dynamics are complex and appropriate measures to manage the energy encountered during vehicle collisions must be designed into the vehicle by the manufacturer.
Q15: Are low-speed vehicles safe, when used in gated or other planned communities and at low speed?
A15: Low-speed vehicles are considered safe when used within controlled low-speed environments as intended by the original regulation. It is less safe when used in urban traffic.
Q16: Would'nt low-speed vehicles be quite safe for use in slower congested city areas?
A16: While low-speed vehicle use is safer in slow speed environments, speed in city areas is often determined by the amount of congestion. This in turn depends on the time of day, the weather, and the day of the week. In non-rush hour traffic, other vehicles may be traveling above the posted speed limits, which could cause serious injury and/or death to occupants of a LSV in the case of a collision.
Q17: Can low-speed vehicles be bought and used in other countries such as the U.S. without restriction?
A17: Licensing of vehicles is the responsibility of the jurisdiction where the vehicle is to be operated. In the U.S., the situation is the same as in Canada. The U.S. federal government regulates the safety standards of low-speed vehicles and advises the states on their safety limitations. The states determine appropriate road use.
Q18: Are other countries concerned with the safety of small vehicles not meeting the safety standards of mainstream vehicles?
A18: The National Highway Traffic Safety Administration (NTHSA) in the US has cautioned the public on the reduced occupant protection of these vehicles. Many US States, based on environmental objectives, have decided to allow them on certain roadways.
Due to growing concern over the safety of a similar class of vehicle in Europe called the quadricycle, the UK has recently performed safety testing which confirmed reduced occupant protection in these vehicles and not meeting the safety requirements of mainstream vehicles.
Q19: What is Transport Canada's position on the creation of a Medium-speed vehicle class?
A19: It is important to first note that the low-speed vehicle class was created to allow for the manufacture, importation and distribution of small, lightweight vehicles that are otherwise unable to comply with the compulsory safety standards for larger and heavier mainstream vehicles. As they are not required to comply with the full suite of Canada Motor Vehicle Safety Standards, Low-speed vehicles are intended for restricted use only where the risk they pose to the traveling public is very minimal. Low speed vehicles are limited to a maximum speed of 40 km/h.
The kinetic energy of a vehicle increases with the square of the speed, and therefore a vehicle traveling at 60 km/hr has more than twice the kinetic energy of the same vehicle traveling at 40 km/h. In the event of a collision involving a vehicle which is compliant with the full suite of Canada motor vehicle safety standards, much of this energy is dissipated before it reaches the occupants by virtue of its design attributes. Hence, the occupants of a vehicle that has the limited crashworthiness protection level of a LSV would be at increased risk of injury or death if they were travelling at speeds greater than 40 km/h and then entered into a collision.
Under the Motor Vehicle Safety Act, vehicles may use any type of energy or fuel, provided that the overall vehicle complies with the Canada Motor Vehicle Safety Standards and applicable environmental standards (the latter are governed by Environment Canada). Vehicle manufacturers are presently designing and manufacturing fully safety certified vehicles for mainstream use, propelled by various sources of energy including zero tailpipe emissions battery powered electric vehicles. As such, Transport Canada does not feel it is necessary, nor in the best interest of the safety of the traveling public to create a medium-speed vehicle class.
In order to enable trade in vehicles and in international travel within North America, it is important for Canada and the United States to define and permit the manufacture of similar classes of vehicles. At this time both Canada and the United States have a federally defined low-speed vehicle class, but not a medium-speed vehicle class. The National Highway Traffic Safety Administration (NTHSA) in the US was recently petitioned to create a Medium Speed Vehicle class. NHTSA came to the same conclusion as Transport Canada; that such a class was not required and was not in the best interest of the safety of the traveling public. Details of their decision can be found in the US Federal Register, Vol. 73, No. 188, September 26, 2008.
Q20: Why is Transport Canada only now releasing crash test videos?
A20: The videos were released to inform Canadians of the inherent risks of using LSVs in environments in which they were not intended (i.e., on regular roads, rather than in controlled environments). Until recently, when the price of gasoline rose to high levels, Canadians had expressed little interest in purchasing LSVs or electric vehicles to Transport Canada. Now that interest in these vehicles is quite high, the Department would like to make Canadians aware of the potential risks of LSVs when used in environments in which they were not intended. As well, provincial and territorial governments have expressed a desire that Transport Canada make Canadians aware of the risks of LSV misuse. Transport Canada was unable to release the crash test videos until now, because of the need to complete comprehensive testing.
Q21: Why did Transport Canada test only a limited number of makes of these vehicles?
A21: There are roughly two dozen makes of LSVs in North America and none of them are required to meet crash safety standards. Transport Canada decided to test two makes of LSV cars and two makes of LSV trucks. The Department is not trying to single out any company. Rather, the Department’s concern extends to all makes of LSVs. Due to the similarity in the designs of many of these makes, and the fact that they are not certified to meet comprehensive safety standards that mainstream cars are required to meet, Transport Canada believes that there was not much benefit in testing additional makes of LSVs at this time.
Q22: Were these tests deliberately skewed, given that the low-speed vehicle was tested against much bigger and faster vehicles?
A22: No. One side impact crash was conducted with a crossover vehicle at 40 km/h, while the second side impact crash was conducted with a subcompact car at 50 km/h. The subcompact used is very close in weight to the low-speed vehicle. It is important to assess the risks posed to LSV occupants by other vehicular traffic (cars, etc.) that share our roads. The reality is that other four-wheel vehicles are heavier than LSV and operate at higher speeds. Transport Canada has provided the manufacturers with the results of its crash tests on their vehicles.
The rear impact crash involved a compact car. It represents a low-speed vehicle that is stopped, and is struck from behind by a small car travelling at 50 km/h. The speeds and vehicles selected were representative of typical intersection crashes in urban settings.
Q23: Are the crash tests presented in the videos exaggerated? I thought that they were safe to drive, otherwise, why would they be available on the market?
A23: The crash videos reflect the actual response of the vehicles and the occupants under realistic conditions. However, it is possible that passenger vehicles may be travelling at much higher speeds, such as 60 km/h, and that collisions may occur in other configurations (e.g., a head-on or an offset frontal collision between a LSV and a regular passenger car). As it is not possible to test all of the possible types of crash situations that could occur, Transport Canada tested some of the more common crash situations. LSVs are safe to drive in environments they are suited for, such as gated communities, and in areas where the ingress of heavier and faster vehicles is controlled by local road authorities.
Q24: How many vehicle tests does Transport Canada conduct, on average, per year?
A24: The Crashworthiness Research Division of Transport Canada conducts approximately 100 crashes per year to evaluate the protection of both small and large drivers, as well as child and adult passengers, seated in the front and rear seats of motor vehicles.
Q25: What is the process for sharing information with the manufacturer?
A25: The data is shared with manufacturers either through regularly scheduled research meetings or at any time a safety concern is identified by Transport Canada.
Q26: Do manufacturers typically make improvements after they’ve seen results of crash tests?
A26: Transport Canada has developed a strong collaborative relationship with the research divisions of suppliers and manufacturers. Manufacturers have been extremely responsive, introducing corrective measures when needed. As a result, the public benefits from improved safety measures over and above the regulated requirements.
Q27: The province of British Columbia changed its regulations to allow LSV usage on all streets posted at 40 km/h and allow towns and cities to set their own usage rules for streets posted at up to 50 km/h. Manitoba is set to follow BC's lead. Is Transport Canada opposed to BC's allowance of LSVs on public roadways?
A27: The use of vehicles on roadways is determined by the jurisdictions that own and operate the roadways, not by Transport Canada. The Department has provided information to all the provinces and territories on the risks inherent in using LSVs in the presence of fully safety-certified faster motor vehicles.
Q28: The provinces of Québec, Ontario, and Alberta have pilot demonstration programs underway for LSV use on roads. What is Transport Canada's position on these demonstration programs?
A28: Transport Canada supports these programs. These provinces have designed carefully controlled demonstration programs that are intended to manage the risks associated with LSV use, while gaining experience with the safe use of LSVs for their respective jurisdictions. These programs will inform the need for legislative changes to allow the use of LSVs on their roadways. The Canadian Council of Motor Transport Administrators, which has representation from all 14 departments of transport, is also examining the conditions under which LSVs can be safely used.
Q29: Some provinces already allow LSVs to be used on regular roads and there haven't been any reports of serious accidents involving these type of vehicles. Why is Transport Canada against the use of LSVs on regular roads?
A29: Transport Canada is informing provinces, territories, municipal governments and licensing authorities, as well as Canadians about the safety limitations of LSVs so that they can take appropriate measures to ensure that the level of risk remains manageable.
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