Between June 13, 2022, and August 11, 2022, we held a public consultation on changes we proposed for aircraft registration services. This report summarizes what we heard during this public consultation.
On this page
Our consultation approach
Modernizing fees is a multi-year undertaking, and we are engaging stakeholders to seek their feedback throughout the process before regulations come into effect. For example, beginning in 2018, at different sessions of the Canadian Aviation Regulation Advisory Council (CARAC), we outlined our multi-year plan to update existing fees and introduce new fees for many of our civil aviation services.
In February 2022, we informed stakeholder associations of our progress to update fees in the aircraft registration sector and our plan to engage with stakeholders on proposed service fees.
In June 2022, we published a document titled Fee modernization proposal for aircraft registration services on Transport Canada Let’s Talk Transportation website to solicit feedback from stakeholders. The document describes the context, policy rationale and analyses that informed the proposed changes.
To encourage comments and feedback, we:
- emailed a link to the online consultation to people and organizations on the CARAC's email distribution list, and
- promoted the consultation on social media
During the consultation, we received 260 comments from Canadians:
- general public
- owners of non-commercial aircraft
- private aircraft pilots
- associations, and
- aviation businesses
We received most of these comments online, through the Let’s Talk Transportation website, but we also received some through CARAC’s email.
Feedback grouped by theme
The themes that arose from the comments are listed below.
Proposed fees
An association acknowledged that fees for aircraft registration haven’t changed since 1996. Another association noted that new proposed aircraft registration fees may make sense for large transport category aircraft and recommended lowering them for small aircrafts.
Few participants agreed with the proposed fees. Those who did noted they would support higher fees if we deliver faster services.
Participants who disagreed with the fee proposal expressed a range of reasons. They:
- noted that the proposed fee increases are between 300% and 400%
- were concerned that the proposed fees could negatively affect the Canadian general aviation population by:
- discouraging young people to become private pilots
- adding more costs to own and operate an aircraft
- reducing the number of people flying in Canada which could negatively affect small communities
- discouraging compliance with aircraft related regulations
- felt that the taxes they pay should be enough to cover the costs for aircraft registration services
- asked that we review associated processes to modernize and streamline those processes before modernizing fees
- expected that fees should be reduced because of the perceived cost savings with our new virtual work environment
Furthermore, some participants were concerned that the luxury tax on the sale or import of an aircraft priced over $100,000 could add to the impact of the proposed aircraft registration fees. They expect that the money collected from this tax and other aviation related taxes should be used to fund our Civil Aviation services.
A participant noted that, unlike Canada, other countries have annual or 3-year renewal fees for aircraft registration services. Other participants felt that the proposed fees were higher compared to other countries. Some participants suggested that Canada should use the United States’ fee model for supporting the aviation industry. And others noted that the proposed fees don’t include a phase-in implementation over time.
Some participants made suggestions, like:
- using a different registration fee structure based on the type of aircraft (like a balloon) as well as aircraft’s weight and usage (private, commercial)
- exempting certain types of aircraft from the fee proposal such as ultralight, home built, kit built, antique, previous military aircraft as well as aircraft operated by museums and non-profits
- adjusting fees every 5 years instead of every year
- lowering fees for a new certificate of registration when the ownership of a shared aircraft is transferred and where at least one owner doesn’t change
Service standards
An association welcomed the use of service standards for aircraft registration services. Another association supported the proposed service standard for domestic aircraft.
Most participants mentioned that the number of days in the service standards were too long and recommended reducing delivery times. They:
- questioned the proposed fees when we haven’t been consistently meeting our service standards
- expected faster services and a reduced costs for using digital and online tools
- compared the ease of registering a car or other vehicle in minutes with the lengthy process of registering an aircraft
- shared examples of other services where delivery times are long (for example: medical certificates)
Some participants suggested ways to improve the service standards, including how we deliver aircraft registration services. They suggested we:
- waive fees if the service can’t be delivered within the service standard
- delay the payment of a fee until we deliver the requested service
- create a web portal, linked to our databases, that would allow users to enter the information needed to register an aircraft and upload scanned documents
- privatize our registration services through the Canadian Owners and Pilots Association
- looking for ways to issue activation keys faster. These keys grant access to online general aviation services
Public-private benefit assessment
To determine the proposed fees, we considered the level of benefit that clients receive from aircraft registration services, beyond the benefit received by the public, among other factors. An association was of the opinion that we, and other public agencies, receive substantial benefits from having aircrafts registered because:
- the data and information from the aircraft registry help our investigations
- Nav CANADA uses owners’ addresses from the aircraft registry to bill them for services
- search and rescue agencies can use the aircraft registry information to aid their searches
- the Transportation Safety Board uses the aircraft registry information in their investigations
- law enforcement uses the aircraft registry when they want information about an aircraft or owner
- the media uses the aircraft registry anytime an aircraft is in the news
Some participants noted that taxpayers benefit from aircraft registration services through the development of new pilots working in the aviation industry. A few participants noted that the costs for aircraft registration services should be fully paid by taxpayers like services to roads, hydroelectricity, oil transportation and high-speed internet networks. As a result, they indicated that the private benefit to aircraft owners should be 20% and the public benefit should be 80%.
Consultation approach
Some participants questioned the timing of this consultation during the summer and noted that it didn’t allow enough time for proper thought and responses. They indicated that our online engagement website, Let’s Talk Transportation, is cumbersome and not user-friendly.
An association mentioned that presenting at various CARAC sessions doesn’t satisfy normal consultation requirements. Some aircraft owners also wanted more opportunities to get involved during consultations.
Other suggestions
Some participants offered other suggestions related to civil aviation regulations, namely:
- including ultralight balloons in the ultralight regulations to reduce the regulatory burden on such small aircraft
- removing the requirement to have constant speed propellers overhauled every 10 years, regardless of use
Next steps
The comments we received through this public consultation have been recorded and will be considered as we develop the regulations.
The next round of consultation will occur when we publish the proposed regulations in the Part I, of the official newspaper of the Government of Canada called Canada Gazette. At that stage, stakeholders and the public will have an additional opportunity to provide feedback before regulations come into effect.