What we heard: Public consultation on modernizing pleasure craft licensing

Between November 12, 2020 and January 15, 2021, Transport Canada held a public consultation on proposed changes to pleasure craft licensing requirements. This report summarizes what we heard during this public consultation.

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Our consultation approach

On November 12, 2020, Transport Canada published a document describing the proposed changes to the pleasure craft licensing requirements on the Let’s Talk Transportation webpage for a 65-day public consultation period.

To invite comments and feedback from stakeholders, we:

  • emailed the link to the Let’s Talk Transportation webpage to individuals and organisations included on the Canadian Marine Advisory Council's distribution list, among others.
  • presented the proposed changes at the November 2020 National Canadian Marine Advisory Council (CMAC) meeting, and
  • held three virtual consultation sessions with the:
    • National Recreational Boating Advisory Council
    • Ontario Recreational Boating Advisory Council, and
    • Atlantic Region boating community

To get feedback from the public and recreational boaters, we also promoted this public consultation on social media. Several boating associations informed their members about the consultation.

When the consultation closed on January 15, 2021, we received about 900 comments. The vast majority of these comments were provided through our online engagement website Let’s Talk Transportation. We also received comments through emails and recorded the comments from the marine stakeholders that participated in our virtual consultation sessions.

We heard from:

  • Canadians across the country (including recreational boaters);
  • marine stakeholders like marine trade associations;
  • law enforcement agencies;
  • boating safety advocates;
  • pleasure craft dealers;
  • associations that represent cottagers; and
  • associations that represent anglers, hunters, trappers and recreational fishers.

Feedback grouped by themes

The themes that emerged from the comments are presented in the following sections. The themes are listed in no particular order.

Introducing a service fee

About half of Let’s Talk participants had no opinion or agreed to the principle that those who directly benefit from a service should pay a bigger share of the costs. They:

  • indicated that a $15 fee to process an application for a new pleasure craft licence seems reasonable and represents a small cost compared with the costs to own and operate a pleasure craft
  • indicated that a $15 fee seems low to implement the proposed changes to modernize the pleasure craft licensing program and expressed concerns that the costs of the proposed pleasure craft licensing changes have been greatly underestimated
  • expected that recovered costs from the proposed $15 fee will be used to improve government services for recreational boaters in aspects such as:
    • boating safety education and outreach
    • boating infrastructure
    • management of abandoned boats
    • aquatic invasive species prevention, and
    • further enforcement of boating safety regulations
  • expected an increase in transparency about how recovered costs from the proposed $15 fee will be managed
  • expected pleasure craft licensing services to be easy to use when submitting an application, online and otherwise

In contrast, about half of Let’s Talk participants opposed to the proposed $15 fee. They:

  • did not agree with the proposed $15 fee to renew a pleasure craft licence when the pleasure craft’s owner personal information has not changed
  • expressed concerns regarding how the proposed $15 fee could discourage compliance
  • suggested to look for ways that pleasure craft licensing holders could update their personal information themselves
  • expressed concerns regarding the potential negative effects that could occur in the tourism sector. Participants like anglers, hunters, trappers and recreational fishers expressed concerns regarding the cumulative effects of extra expenses for outdoor activities
  • expressed concerns that the proposed fees for the Pleasure Craft Operator Competency Program (part of a separate consultation) could add to the impact of the proposed $15 fee
  • indicated that recreational boaters already assume government costs through taxes and were concerned about potential increases of the proposed $15 fee over time
  • suggested in some instances to exempt senior citizens and existing grandfathered lifetime licences from the proposed $15 fee

For their part, during the virtual consultation sessions, marine stakeholders were mostly neutral with respect to the introduction of the proposed $15 fee.

Service standard

Let’s Talk participants recommended that Transport Canada retain the existing service standard where a new, renewed, transferred or duplicate pleasure craft licences will be emailed or mailed within five business days of receipt of application, provided the application is complete and all supporting documentation is attached.

Validity period

A small number of Let’s Talk participants provided feedback on the validity period of a pleasure craft licence and the associated renewal process. Of these:

  • most participants opposed the proposed change to reduce the validity period for pleasure craft licences to five years. They indicated that reducing the validity period for pleasure craft licences to five years will increase the program’s costs resulting in a higher pleasure craft licence service fee.
  • some participants prefer a validity period for pleasure craft licences of 10 years. They indicated that, in general, most pleasure craft owners keep a vessel for an average of 15 years.
  • some participants suggested that expiration notices to pleasure craft licence holders be sent in advance to renew their pleasure craft licence. They indicated that Transport Canada could send out postage paid return envelopes to further enhance compliance and suggested that any pleasure craft licence notification returned without having the address confirmed or updated should result in the pleasure craft licence being cancelled.
  • some participants, indicated that the outdated information in the Pleasure Craft Electronic Licensing System is due to pleasure craft owners not being aware of pleasure craft licence requirements. For example, they noted that most transfers of pleasure craft ownership are done through private sales where pleasure craft licence requirements are ignored or unknown.
  • some participants expected that the modernization of pleasure craft licensing will take advantage of digital technologies to allow pleasure craft owners to update their personal information, printing duplicates and cancelling their pleasure craft licence online.
  • some participants suggested to link the pleasure craft licence to a car driver’s licence renewal process and to adopt a system such as the Ontario trailer licensing system.

Expanding the application of the Small Vessel Regulations

While we received limited feedback on this theme, Let’s Talk participants had mixed views about the proposed changes to expand the application of the Small Vessel Regulations to more pleasure crafts.

Most of the Let’s Talk participants who provided feedback on this theme supported expanding the application of the Small Vessel Regulations to all motorized watercraft, like jet skis and pleasure crafts with electric motors.

Most of the Let’s Talk participants who provided feedback on this theme opposed expanding the application of the Small Vessel Regulations to non-motorized pleasure crafts like sail-alone vessels.

Reducing the timeframe for owners to notify changes

A few Let’s Talk participants indicated that reducing the timeframe to 30 days is too short for pleasure craft owners to notify Transport Canada about change name or address, especially when a third party sells the pleasure craft.

In contrast, a few Let’s Talk participants suggested that there should be no time lag when pleasure craft owner’s information changes.

Some participants indicated that they would prefer the onus be on the seller to transfer the licence and receive notification or confirmation that the licence was successfully transferred to the new owner.

A law enforcement agency supported the proposed change to reduce the timeframe to 30 days for pleasure craft owners to notify of a name or address change. The law enforcement agency indicated that the proposed change would be beneficial when addressing the issue of theft and concealment of pleasure crafts and suggested to increase the fines in the event of an infraction in order to have a real deterrent.

Allowing for the easier cancellation of pleasure craft licences

Let’s Talk participants want more attention paid to the enforcement aspect of regulations and called for a comprehensive federal approach to administer and enforce the Small Vessel Regulations. For example, they suggested to:

  • request an external display showing current year compliance of a pleasure craft such as the decals used for motor vehicles. These decals should also have a bar code to enable digital read out of the data in the Pleasure Craft Electronic Licensing System for emergency responders and for salvage purposes.
  • introduce stronger penalties for non-compliance.
  • provide federal agencies with the fiscal and physical resources necessary to enforce compliance.

A law enforcement agency supported the proposed change and indicated that having the most accurate information possible will improve law enforcement response times and the quality of their investigations.

Wrecked and abandoned vessels

Although it wasn’t directly asked about, Transport Canada received several comments about wrecked and abandoned vessels.

Of these, the majority of participants indicated that abandoned vessels represent an issue, especially in British Columbia and Ontario. They supported the proposed $15 fee if it will be targeted to address abandoned vessels, inadequate black water disposal facilities and mooring buoys. Furthermore, they suggested that vessel owners maintain a liability insurance covering aspects such as salvage and vessel disposal costs as a condition for obtaining and maintaining a pleasure craft licence. They urged Transport Canada to engage in consultation with the insurance industry on the topic of liability insurance for pleasure crafts.

A few participants mentioned that most derelict vessels in the ocean are from out of country so the proposed changes may not address this issues. They indicated that wrecked and abandoned vessels can’t be properly dealt with until federal, provincial and municipal responsibilities are clarified.

Additional suggestions

Let’s Talk participants and marine stakeholders offered a range of additional suggestions in relation to pleasure craft licensing:

  • Transport Canada should implement an advertising campaign to encourage pleasure craft owners to update their pleasure craft licence information before the proposed changes come into force.
  • Transport Canada should do outreach to educate recreational boaters about pleasure craft licensing services. For example, many participants in the Let’s Talk discussion forum confused the pleasure craft licence and the Pleasure Craft Operator Card.
  • Transport Canada should engage with anglers, hunters and trappers to better understand the socio-economic impacts of the proposed pleasure craft licensing changes on them.
  • Transport Canada should consider partnering with marine trade associations to administer the Pleasure Craft Licensing Program, for example, using the model for snowmobile permits in Ontario.
  • Transport Canada should collect data on pleasure craft sales and usage as part of its pleasure craft licensing services.
  • The proposed changes should come into force in time for the 2022 boating season.

Next steps

Comments received through this public consultation have been recorded and will be considered during the development of the regulations.

The next round of consultation will occur when the proposed regulatory changes are pre-published in Canada Gazette Part I.

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