Submission to the Treasury Board of Canada Secretariat Regarding Proactive Publication and Open Government As a Key Element of Access to Information

Dainius Dalmotas President and CEO
D. J. Dalmotas Consulting Inc.

June 28, 2021

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I welcome the opportunity to contribute to this review of Access to Information as it pertains to improving proactive publication to make information openly available.

I am convinced that, by implementing a practice of proactive publication, the federal government could take real and meaningful action towards its espoused principles of transparency and
accountability. This is the most practical and least costly way to be ‘open by default’. In a democracy, citizens should have the right to access most information and data generated and held by their government. Moreover, if applied to all information except that which is exempted for personal or security reasons, this would result in considerable cost savings, and provide an enhanced, much more efficient access to information program.

My experience in requesting information from Transport Canada provides a clear example of how a proactive approach could greatly decrease the need for lengthy, convoluted and costly access to information requests, and provide benefits to both the government and the requesters. In the attached letter sent to the federal Minister of Transport in 2018, (Appendix A.1), I point out how, by adopting an approach similar to the US government, which pro-actively provides full disclosure of results from its vehicle crash test program, Transport Canada would promote opportunities for research leading to greater safety of occupants of motor vehicles both here in Canada and worldwide.

What differentiates Transport Canada’s Motor Vehicle Safety Directorate from their US
counterpart is the latter’s commitment not only to the full public disclosure of their vehicle crash test data and field investigations, but their facilitation of external analysis of the data through user-friendly interfaces and supporting software. The US government recognizes that only a portion of potential analyses can be conducted by internal staff and that the scope of the analyses can be greatly enhanced through external resources. The US approach can be seen to attempt to maximize the value for money provided by their data collection programs.

As stated in my submission to the House of Commons Standing Committee on Transport,
Infrastructure and Communities (TRAN), regarding its study on bus passenger
safety (Appendix B.1), the importance of transparency in the sharing and dissemination of crash testing and safety research findings cannot be overstated. I stand by the need for a shift to a system where the government would proactively publish information that is clearly in the public interest, as called for by the former Information Commissioner of Canada, Suzanne Legault.
Clearly, a lack of transparency has the effect of stifling public debate and the ability to lobby for safety-related changes. By contrast, policies of proactive disclosure allow for more effective and meaningful evaluations of the government’s response to issues of public interest and provide a mechanism to pressure the government to take remedial action to prevent harm and to promote safety.

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The TRAN Committee recognized the importance of transparency in its Report on Bus Passenger Safety presented to the House on June 11, 2019. Its first recommendation was the following:

That the Government of Canada take steps to ensure that all research and results of laboratory or vehicle safety testing conducted by Transport Canada is made publicly available on the department’s website.

There is no evidence that the department has made any effort to implement this recommendation. In fact, an ATIP request to Transport Canada for records relating to changes in policies and practices concerning this recommendation yielded a release with a one-page chart about the department’s vision which was clearly outlined prior to TRAN Report 31, and no records showing any deliberations concerning the recommendation (Appendix B.2). Given that the TRAN recommendation is in line with the current government’s stated principle of asking departments to be ‘open by default’, I find it surprising that a federal government department can ignore this ATIP-related recommendation.

It is my contention that, in the absence of a strong commitment to the principles of ‘open government’ and ‘proactive publication’, together with meaningful oversight and specific accountability mechanisms, simply tweaking the provisions of the Access to Information (ATI) regime is much like rearranging the deck chairs on the Titanic. It will do little to advance improved transparency and accountability, nor will it reduce the ever-mounting burden and backlogs within the ATI system.

I call on the Treasury Board Secretariat to use its mandate to transform the federal government’s modus operandi from an approach that fosters secrecy to one that truly practices proactive publication and promotes transparency for the greater public interest.

Appendices:

Appendix A.1: Letter to Minister Garneau from D. J. Dalmotas Consulting Inc., 2018-03-12, - with Comments on Report 4, Oversight of Passenger Vehicle Safety, of the Fall 2016 Reports of the Auditor General of Canada, sent to the OAG on February 19, 2017
Appendix A.2: Response from Jim Lothrop (on behalf of Minister Garneau), 2018-05-03 Appendix A.3: Letter to Jim Lothrop, 2018-07-10
Appendix B.1: Submission to the TRAN Parliamentary Committee regarding Bus Passenger Safety, 2019-05-07
Appendix B.2: Response to ATIP Request A-2020-00235, 2020-10-01

Appendix A.1

Letter to Minister Garneau dated March 12, 2018

370 Chemin d'Aylmer, Gatineau, QC J9H 1A7 Tel: 819-682-0058	Cell: 819-921-2961
E-mail: ddalmotas@aol.com
Web Site: http://www.djdsafety.com

The Honourable Marc Garneau, P.C., M.P. Minister
Transport Canada 330 Sparks Street Ottawa, Ontario K1A 0N5
March 12, 2018 Dear Minister,

I am seeking a meeting with members of your staff to discuss how increased transparency in information-sharing from Transport Canada’s vehicle crash test program could lead to greater accountability and, more particularly, promote enhanced safety for occupants of motor vehicles.

By way of background, I worked in the Motor Vehicle Safety Directorate for 33 years, retiring as Chief of Crashworthiness Research and, as such, was intimately involved in the development of the crash testing protocols and associated documentation, and subsequent reporting of the results. My firm continues to be actively engaged in automotive safety research initiatives in both Canada and the United States.

It is my firm belief that, by adopting an approach similar to the US government, which pro-actively provides full disclosure of results from its vehicle crash test program, Transport Canada would achieve two key results: a clear public demonstration of the scope and value of its critical work in this area; and, provision of a platform allowing external stakeholders to build on the findings of its work.

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I attended the March and April 2017 meetings of the Standing Committee on Public Accounts, convened to deal with Report 4, Oversight of Passenger Vehicle Safety, of the Fall 2016 Reports of the Auditor General of Canada. Many of the Committee’s questions dealt with the Auditor General’s recommendation that Transport Canada conduct broad consultations with a wide range of stakeholders, not just automobile manufacturers, and
that it commit to greater transparency both in the release of its data from its crashworthiness research program, and with regard to the development of regulations and standards.

It has long been my contention that Transport Canada does extremely valuable research work in the area of motor vehicle crash testing and that it has a considerable body of crash test data that potentially could contribute greatly to advances in the safety of vehicles and protection of occupants both here in Canada and worldwide. However, unlike its US counterpart, it does not enable wide, public dissemination of its research data to interested stakeholders. In fact, the contrast between responses to requests to the American and Canadian governments for information on the results of vehicle crash tests is striking. The US posts on its web site the complete results of its crash tests, including comprehensive reports, photographs, videos and data. Transport Canada maintained similar practices prior to 2006. However, since that time, transparency has been replaced by a culture of secrecy with respect to dissemination of crash test results. Any
meaningful request is referred to Access to Information and then is denied on the basis that it is too difficult to provide the information. This not only limits recognition of Transport Canada’s accomplishments; more importantly, it diminishes opportunities for identifying potential gains in the area of passenger vehicle safety.

This closed approach is also completely inconsistent with the 2015 Liberal platform on Real Change, A Fair and Open Government, which committed to create a new level of accountability for government spending aimed at spurring innovation and economic growth, and emphasized the need for all federal departments and agencies to adopt a principle of open government when it comes to sharing information.

My concerns are outlined in the attached letter sent to the Office of the Auditor General (OAG) of Canada on February 19, 2017 in relation to the findings and recommendations outlined in Report 4. The OAG subsequently informed me that its recommendations are developed strictly from the findings of its audits and that it does not take into
consideration proposals developed by external parties. The OAG suggested that I raise any concerns directly with Transport Canada and Members of Parliament.

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I would therefore welcome the opportunity to meet with your staff to illustrate how a more open approach to sharing the research results of Transport Canada’s vehicle crash
test program would help promote enhanced safety for vehicle occupants both at home and abroad.

Yours truly,

Dainius Dalmotas President and CEO
D. J. Dalmotas Consulting

Attachment: Comments on Report 4, Oversight of Passenger Vehicle Safety, of the Fall 2016 Reports of the Auditor General of Canada, sent to the OAG on February 19, 2017

Attachment

Comments: Report 4, Oversight of Passenger Vehicle Safety, of the Fall 2016 Reports of the Auditor General of Canada

February 19, 2017

The firm of D. J. Dalmotas Consulting, Inc. is pleased to provide the following comments on some of the concerns raised and recommendations made in the Auditor General’s fall report on passenger vehicle safety in Canada. While we are a small automotive safety research firm, we are actively engaged in vehicle research and crash testing initiatives in both Canada and the US. Moreover, almost all the individuals associated with the firm are former employees of Transport Canada’s Motor Vehicle Safety Directorate. As such, we are in a rather unique position to comment on differences between Canada and the US in their respective approaches to addressing road safety research and testing.

While both Canadian and US governments express strong commitments to the principles of accountability and transparency, how these commitments manifest themselves in terms of dissemination of government sponsored safety research varies greatly. Nowhere is this more evident than with respect to the dissemination of vehicle crash test data in the two respective jurisdictions. In the US, every crash test carried out or sponsored by the National Highway Traffic Safety Administration (NHTSA) is meticulously documented and every data element (test report, video, photograph, etc.) and all the electronic data captured in the test are organized and made available to the automotive safety community and to the general public on an equal basis by means of the Internet. Historically, public access to crash test data was also provided in Canada. However, this ceased to be the case in 2006. Even the well-established and universally followed practice of documenting individual tests by a stand-alone test report has been discontinued.
This action can be expected to greatly diminish the long term value of the Canadian database.

In the US, NHTSA is constantly attempting to improve the utility of their crash test databases through improved interfaces to render data inquiries more user-friendly. The firm is unaware of any interest on the part of the Motor Vehicle Safety Directorate to undertake similar action in
response to the Auditor General’s fall report. We recently made an inquiry to the Motor Vehicle Safety Directorate which included a request for a list of vehicles by make, model, model year, etc. subjected to frontal compliance testing over essentially the past decade. Even this simple inventory request was rejected. When we commented to the Directorate that this position appeared to be at odds with government policy we were advised to seek access through an ATIP request. This suggestion was advanced when the Directorate would have had full knowledge of the recommendations of the Auditor General’s report concerning the need for an improvement in transparency. This suggests very little desire on the part of the Directorate to reverse the culture of secrecy which has been fostered over the past decade.

Even by international standards, the volume of crash testing sponsored by Transport Canada is significant and represents an extremely valuable asset to further advance global vehicle safety. To this end, Transport Canada should follow the US example and ensure the data are made freely
available and widely disseminated.

Ensuring greater transparency of the Canadian crash data is particularly important in the context of advancing the technical basis of US New Car Assessment Programmes (NCAP). The provisions and safety ratings of the US NCAP programmes, rather than the limiting values imposed in Canadian regulations, drive the safety performance of vehicles sold in Canada. Consequently, ensuring complete transparency of the Canadian crash data is essential to the process of ensuring that Canadian data are considered when scrutinizing the technical merits of procedures and hardware advanced in US testing protocols.

In summary, we believe the recommendation for greater transparency made in the fall report should be expanded to explicitly include a requirement that Transport Canada provide public access to all crash test data the department has conducted, and that approval of any future testing programs be subject to an obligation that it include a requirement for proper dissemination to the public of the results of the testing program. Consistent with best practices, this requirement should include the provision for a stand-alone report for each full-scale vehicle test or a combined report for any series of similar tests (i.e. a sled test series).

Thank you in advance for your consideration of this submission. We would be pleased to meet with your staff to review in more detail any of the comments or recommendations made above.

Appendix A.2
Response from Jim Lothrop (on behalf of Minister Garneau) dated May 3, 2018

Appendix A.3

Letter to Jim Lothrop dated July 10, 2018

370 Chemin d'Aylmer, Gatineau, QC J9H 1A7 Tel: 819-682-0058	Cell: 819-921-2961
E-mail: ddalmotas@aol.com
Web Site: http://www.djdsafety.com

Mr. Jim Lothrop
Director General, Innovation Centre Transport Canada
330 Sparks Street
Ottawa, Ontario K1A 0N5 July 10, 2018
Dear Mr. Lothrop,

Thank you for your May 3, 2018 letter in response to my letter of March 12, 2018 to Minister Garneau regarding the need for increased transparency in information-sharing from Transport Canada’s vehicle crash test program. My contention is that greater openness would lead to
increased accountability and, more particularly, promote enhanced safety for Canadian occupants of motor vehicles.

I am disappointed that you elected not to respond to the various policy and technical issues raised both in my letter to the Minister and in my earlier comments to the Auditor General of Canada
regarding the OAG’s Report 4, Oversight of Passenger Vehicle Safety. As you are aware, I was employed by Transport Canada in the area of crashworthiness research for some 33 years, culminating in the position of Chief of Crashworthiness Research. As such I was intimately involved in the creation and development of Transport Canada’s crash testing capabilities, and believe that I am well positioned to compare differences between past and current practices.
Historically, the objectives of Transport Canada’s research program differed greatly from those articulated in your letter. Rather than being confined to a test validation activity, the thrust of Transport Canada’s research efforts over my tenure was directed at identifying opportunities to reduce the number of Canadians injured and killed in motor vehicle crashes.

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While I would agree with you that Transport Canada enjoys a solid and well-earned reputation for its research, I would argue that this reputation was gained through the 1990’s and early 2000’s when Transport Canada played a leading role in guiding vehicle safety design. These efforts included pioneering the use of dummies of small stature in both frontal and side impact testing, the depowering of frontal airbags in North America, and assisting in the formulation of the
Insurance Institute for Highway Safety’s (IIHS) Side New Car Assessment Program (NCAP) testing protocol. Over this time period, Transport Canada maintained a completely open data access policy. Indeed, payment of services for crash testing required proof of a publicly available crash test report.

Since 2006, Transport Canada’s influence on vehicle safety design has greatly diminished. Vehicle safety design in North America is now increasingly dictated by new car assessment programs sponsored either by IIHS or the US government. Both organizations are committed to complete transparency and to evidence-based science.

While Transport Canada has the possibility of improving the technical basis of the US-led programs through its research, such action would require adoption of an open and transparent policy towards the dissemination of its crash test data. Unfortunately, although the Department professes to provide “responsible” disclosure, in actual practice, it continues to maintain a culture of secrecy. Conversely, the openness practised in the US benefits industry because it allows manufacturers to review and comment on proposed changes prior to adoption.

It is commonly acknowledged that the ideological leaning of the previous federal government led to a more guarded approach to information-sharing. The current Liberal government was elected with the undertaking to usher in a more transparent government. In keeping with this principle of transparency, Transport Canada should be promoting scientific debate and evidence-based decisions. This is only possible when all parties have equal access to the information in an environment that promotes opportunities for greater research and collaboration.

As we noted in our letter to the Auditor General, what differentiates the Motor Vehicle Safety Directorate from their US counterpart is the latter’s commitment not only to the full public disclosure of their vehicle crash test data and field investigations, but their facilitation of external analysis of the data through user-friendly interfaces and supporting software. The US government recognizes that only a portion of potential analyses can be conducted by internal staff and that the scope of the analyses can be greatly enhanced through external resources. The US approach can be seen to attempt to maximize the value for money provided by their data collection programs.

The lack of full disclosure of the Motor Vehicle Safety Directorate’s crash test data not only limits opportunities to advance safety in Canada; it has the potential to act as an impediment to the advancement of safety in North America. This is due to the highly integrated nature of the automotive industry in North America and the full research potential which would be achieved by pooling Canadian and US crash test data. This can be best illustrated by a current example, the frontal chest protection for belted individuals in North America, which is driven by the US frontal NCAP program.

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Seat belt deployment procedures defined both in NCAP, and in Canadian and US regulatory tests, allow manufacturers to specify the use of the uppermost D-ring location in the case of passenger tests with the 5th female dummy. Transport Canada test data secured via ATIP clearly show that the use of the uppermost D-ring location can be used to “game” the results of the test by artificially reducing the magnitude of the chest deflection measures by 50 percent or more. Had Transport Canada disclosed the results of their testing of seat belt systems, this issue could have been resolved in the 2011/2012 time period. Instead, the magnitude of the chest deflection under- reporting has increased, to the detriment of efforts to reduce chest injury, the leading cause of death and serious injury to older belted occupants in frontal crashes.

The implication that the public release of the crash test data could place some vehicle manufacturers at a competitive disadvantage has no basis in fact. Over the course of my tenure, neither Transport Canada nor any third party attempted to represent the research data as a “public rating”. Nor did any manufacturer ever express a concern that the release of the data would be unfair. Many of the tests did result in the manufacturer making design changes to improve vehicle safety. The suggestion that public safety should take second place to possible competitive disadvantage is puzzling. As you are aware, both the Auditor General of Canada and the Parliamentary Standing Committee on Public Accounts have expressed concern over the suggestion that Transport Canada would place commercial considerations ahead of safety.

No one would disagree that collaboration with industry is vital to the sharing of expertise. However, collaboration does not have to be conducted behind closed doors. In fact, it can be argued that transparency will lead to greater opportunities for increased collaboration among industry, researchers and other interested stakeholders.

A practice of open-by-default dissemination does not preclude maintaining certain tests confidential if these tests involve proprietary hardware. That being said, my experience is that industry will not evoke disclosure considerations in the case of near-term proprietary hardware as they recognize the value of public disclosure. The most significant “proprietary” hardware incorporated in Transport Canada’s testing took the form of depowered airbag units which were installed in modified TC vehicles with the assistance of industry. Neither of the manufacturers who participated in this collaborative initiative (General Motors and Ford) requested an exemption from the full disclosure policies in effect at Transport Canada at the time.
Furthermore, the suggestion that a manufacturer might withhold any information vital to the “safe conduct” of a test, if it involved research rather than a compliance test, runs totally contrary to my experience.

Moreover, the arguments advanced in support of the present non-disclosure practices ignore the liabilities associated with non-disclosure. The latter have been the subject of debate both in Canada and the US. Probably the most eloquent spokesperson on this issue was Suzanne Legault, the former Information Commissioner, who long argued that full disclosure of government information should be mandatory, (subject to privacy or legal considerations), where this information impacts on public safety. Full disclosure is vital to scientific debate, to developing public awareness and pressure for safety initiatives, and to ensuring government accountability.
These considerations are reflected in the full disclosure practices of the US government, not only with respect to cash test data, but also in regard to field collision data, reports and presentations.

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It is encouraging to learn that Transport Canada’s new Innovation Centre is exploring future opportunities to expand testing and to make the department’s research more publicly accessible. However, you point out that this is “subject to available resources”. It should be noted that the US places a high priority on the dissemination of information and consequently attaches the necessary funding to this activity, ensuring follow through. Presumably were Transport Canada to give similar priority to information sharing, it would allocate resources for this activity in its annual budget.

In closing, I would like to reiterate my willingness to meet with you at any time to discuss how increased transparency in information-sharing from Transport Canada’s vehicle crash test program could lead to greater accountability and, more particularly, promote enhanced safety for occupants of motor vehicles. Moreover, given the reasonable argument that the lack of transparency is adversely affecting public safety in Canada, I believe this issue should be exposed to public and media scrutiny. As noted in the OAG’s Report 4, Transport Canada has not frequently consulted stakeholders, other than manufacturers, and needs to subject its research findings and regulatory proposals to increased public consultation. In the interest of furthering greater openness and public input, I would be pleased to participate in any Transport Canada forum that aims to promote increased safety of motor vehicle occupants.

Yours truly,

Dainius Dalmotas President and CEO
D. J. Dalmotas Consulting

Enclosure:	Letter of May 3, 2018 from J. Lothrop to D. Dalmotas, on behalf of Minister Garneau

cc:	Minister Marc Garneau
Deputy Minister Michael Keenan
Assistant Deputy Minister Lori MacDonald

Appendix B.1
Submission to the House of Commons Standing Committee on Transport, Infrastructure and Communities regarding Bus Passenger Safety

May 7, 2019

Submission to the House of Commons Standing Committee on Transport, Infrastructure and Communities
regarding Bus Passenger Safety

Dainius Dalmotas President and CEO
D. J. Dalmotas Consulting, Inc.

May 7, 2019

I welcome the opportunity to submit comments to the House of Commons Standing Committee on Transport, Infrastructure and Communities.

By way of introduction, I joined the Road Safety and Motor Vehicle Regulation Directorate of Transport Canada in 1972, where I occupied a variety of positions, including Chief of Crashworthiness Research from 1998 to 2005. I remain actively engaged in vehicle research and crash testing initiatives as a consultant. Moreover, several individuals associated with the firm are former employees of Transport Canada’s Motor Vehicle Safety Directorate. As such, we are in a position to knowledgably comment on differences between Canada and the US in their respective approaches to addressing road safety research and testing.

While most of the submissions to the committee are expected to focus on the technical issues associated with achieving improved bus safety in Canada, my submission will address the role of government transparency and timely disclosure of information in achieving this objective. The shortcomings of the current government policies and practices in this area were highlighted in a recent CBC The Fifth Estate exposé addressing school bus safety initiatives at the federal level. Much of the programme focussed on lack of public access to information; in particular, they noted the absence of information on Transport Canada’s website.

The importance of transparency in the sharing and dissemination of crash testing and safety research findings cannot be overstated. My firm stands by the need for a shift to a system where the government would proactively publish information that is clearly in the public interest, as called for by the former Information Commissioner of Canada, Suzanne Legault. Clearly, a lack of transparency has the effect of stifling public debate and the ability to lobby for safety-related changes. By contrast, proactive disclosure policies allow for more effective and meaningful evaluations of the government’s response to issues of public interest, and they provide a mechanism to pressure the government to take remedial action to prevent harm and to promote safety. My firm has reiterated these arguments in letters to the Minister and Deputy Minister of Transport Canada (copies enclosed). Moreover, The Auditor General, in Report 4, Oversight of Passenger Vehicle Safety, of the Fall 2016 Reports, called for Transport Canada to initiate broad consultations with a wide range of stakeholders.

While both Canadian and US governments express strong commitments to the principles of accountability and transparency, there is great discrepancy in how these commitments are manifested. Nowhere is this more evident than in regard to the dissemination of vehicle crash test data in the two respective jurisdictions. The US government adheres to a strict “full-disclosure” policy with respect to its regulatory developments. This is achieved by means of a “docket” which is opened for each significant regulatory initiative and this docket acts as a central and permanent depository to store any research carried out in support of the initiative as well as for any comments or data provided by stakeholders. In addition, the US government adheres to a “full-disclosure” policy regarding any laboratory or vehicle safety testing it carries out. Both the docket system and the safety testing are accessible to the public via the internet.

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Not only does the US approach recognize the need for full-disclosure of the activities it carries out, but equally importantly, it recognizes that the regulatory development process is inherently an evolutionary process. Orderly progress on any safety issue requires complete and timely access to the available research material by all involved parties so that research priorities and research programmes can be continuously adjusted and
updated based on currently available evidence. While Transport Canada’s record in recent years has been weak, within the past year, we have seen some positive movement towards greater transparency. For instance, in response to The Fifth Estate exposé, they now dedicate a portion of their website to the results of school bus safety initiatives.
Also, upon request, compliance test reports can now be obtained. Access to the underlying electronic data, test photographs and videos remains problematic.

Transport Canada has taken initial steps to address the need for transparency but it needs to go a lot further. By adopting an approach similar to the US government, which pro- actively provides full disclosure of results from its vehicle crash test program, Transport Canada would achieve two key results: a clear public demonstration of the scope and value of its critical work in this area; and, provision of a platform allowing external stakeholders to build on the findings of its work.

To this end, we encourage the committee to strongly recommend that Transport Canada adopt the “full-disclosure” principles adhered to by its US counterparts with respect to the dissemination and full public access to safety research and testing carried out by the department.

Enclosures:

Enclosure 1: Letter to Minister Garneau from D. J. Dalmotas Consulting Inc., 2018-03-12,
- with Comments on Report 4, Oversight of Passenger Vehicle Safety, of the Fall 2016 Reports of the Auditor General of Canada, sent to the OAG on February 19, 2017

Enclosure 2: Letter to Deputy Minister Keenan from D. J. Dalmotas Consulting Inc., 2017-04-10

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Appendix B.2

ATIP Request: A-2020-00235
Covering Letter and Release October 1, 2020

Access to Information and Privacy (ATIP) Office Transport Canada
Place de Ville, Tower C, XMSP 330 Sparks Street
Ottawa ON K1A 0N5

Your File

Our File
A-2020-00235 / SL

Dainius Dalmotas 370 chemin Aylmer
Gatineau QC J9H 1A7

Dainius Dalmotas:
This is in response to your request under the Access to Information Act (ATIA), received by Transport Canada on September 1, 2020, for the following information:
“Provide all records pertaining to deliberations and correspondence related to possible changes to Transport Canada’s policies and practices in response to Recommendation 1 of Report 31 of the House of Commons Standing Committee on Transport, Infrastructure and Communities on Bus Passenger Safety, presented to the House on June 11, 2019, which states, “That the Government of Canada take steps to ensure that all research and results of laboratory or vehicle safety testing conducted by Transport Canada is made publicly available on the department’s website. In the specific case of compliance test reports, provide details of all changes to the scope and the specific information included in the reports, following the above recommendation, including but not limited to: (1) all directions provided to PMG Technologies regarding the preparation of test reports; and, (2) any records addressing departures in the format of the compliance reports in response to ATIP requests. ”
We have now completed the processing of your request. You will note that the record is released in full.
Please be advised that you are entitled to submit a complaint regarding the processing of this request to the Office of the Information Commissioner of Canada, 30 Victoria Street, Gatineau, Quebec K1A 1H3. The ATIA allows a complaint to be made within 60 days of the receipt of this notice.
Should you have any questions, you may contact Sylvie Lamontagne at 343-572-2950 or via e-mail at sylvie.lamontagne@tc.gc.ca.

Yours sincerely,

Angie Belsher
Chief Access to Information and Privacy Enclosure: one page