Reply to Comments on the Proposed On-Road Vehicle and Engine Emission Regulations - Transportation Systems Branch

The Canadian sales mix of passenger vehicles is different from that of the U.S. Data indicate that, in recent years, Canadians tend to purchase more passenger cars and fewer light-duty trucks¹ than Americans. The percentage difference varies depending the data source used, but typically ranges with Canadians buying 2 to 8% more passenger cars than Americans. Automotive News², ³ forecasts that this trend will continue and the percentage of passenger cars sold in Canada will level off at 53%, which is approximately 5% greater than their forecast for the percentage of passenger cars sold in the U.S.

There are also notable differences in the sales mixes of subcategories of passenger cars and light-duty trucks. The following graph shows the percentage of vehicles sold in each subcategory in Canada and in the U.S., according to Industry Canada data⁴. The data presented are derived by averaging annual sales over the years 1995-1999.

Figure 1: Average Sales Mix by Vehicle Category, 1995-1999

The figure shows a bar chart comparing the percentage of vehicles by class that were sold in Canada, averaged over the 1995 to 1999 period, compared to the percentage sold in the U.S.

• The percentage of compact cars sold in Canada is 23 and in the U.S. is 14.
• The percentage of intermediate cars sold in Canada is 23 and in the U.S. is 27.
• The percentage of full-size cars sold in Canada is 4 and in the U.S. is 5.
• The percentage of luxury cars sold in Canada is 5 and in the U.S. is 8.
• The percentage of pickup trucks sold in Canada is 16 and in the U.S. is 19.
• The percentage of sport utility vehicles sold in Canada is 10 and in the U.S. is 16.
• The percentage of vans sold in Canada is 18 and in the U.S. is 11.

The original image of the Figure is available in the PDF version.

The graph shows Canadians generally buy more compact cars (23% vs. 14%) and more vans (18% vs. 11%) (particularly mini-vans) and fewer of the vehicles in all of the other categories (i.e., intermediate cars, full-size cars, luxury cars, pickup trucks and SUVs).

For the purposes of emission certification, all passenger cars are considered as a homogeneous class, whereas light-duty trucks are classified into four separate categories based on weight-related features. These features include: the "gross vehicle weight rating" (GVWR), which is the rating specified by a manufacturer as the maximum design loaded weight of a vehicle; the "loaded vehicle weight" which is the vehicle's curb weight plus 136.1 kg (300 lb.); and the "adjusted loaded vehicle weight" which is the average of the vehicle curb weight and the GVWR. The following table summarizes the four classifications of light-duty trucks based on these features.

To evaluate the effect of differing vehicle preference in Canada on the Canadian fleet average emission rate, the sales mix must be disaggregated into the light-duty vehicle (LDV) (i.e., passenger car) and light-duty truck 1 through 4 (LDT1-4) classes. This was accomplished by using 2000 model year Canadian registration data together with U.S. EPA 2000 certification data to allocate vehicle class (i.e., LDV and LDT1-4) to each vehicle model listed in the registration data⁵. The allocation of vehicle models to LDV and LDT classes is presented in Appendix A. The number and percentage of vehicles by class is presented in Table 2.

¹Light-duty trucks include vans, pickup trucks and sport utility vehicles (SUVs).
²Automotive News, 2002 Market Data Book, May 27, 2002.
³Automotive News, 2001 Market Data Book, May, 2001.
⁴Industry Canada, "Statistical Review of the Canadian Automotive Industry: 2000 Edition."
⁵Data from the Canadian Vehicle Manufacturers' Association (CVMA) and the Association of International Vehicle Manufacturers of Canada (AIAMC) were used to verify and, in some cases, correct vehicle model allocation to appropriate classes.