What we heard: public consultation on modernizing the Pleasure Craft Operator Competency Program

Between November 12, 2020 and January 15, 2021, Transport Canada held a public consultation on proposed changes to the Pleasure Craft Operator Competency Program. This report summarizes what we heard during this public consultation.

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Our consultation approach

On November 12, 2020, we published a document describing the proposed changes to the Pleasure Craft Operator Competency Program on the Transport Canada 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 to the National Canadian Marine Advisory Council in November
  • held four virtual consultation sessions with:
    • the National Recreational Boating Advisory Council
    • the Ontario Recreational Boating Advisory Council
    • Pleasure Craft Operator Competency course providers
    • the Atlantic Region boating community

When the consultation closed on January 15, 2021, we had received over 550 comments. Most of these comments were provided through our online engagement website Let’s Talk Transportation. We also recorded comments that we received by email and from marine stakeholders and course providers that participated in our virtual consultation sessions.

We heard from marine stakeholders such as Pleasure Craft Operator Competency course providers, boat rental businesses, marine trade associations, law enforcement agencies, boating safety advocates, recreational boaters and members of the public.

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.

Rental Boat Safety Checklist

Most boat rental businesses strongly opposed the proposed change of no longer recognizing the Rental Boat Safety Checklist (RBSC) as a form of proof of competency. The boat rental businesses:

  • indicated that the RBSC allows them to personalize training so boat renters learn:
    • how to operate a pleasure craft
    • boating safety rules, and
    • geographic features and hazards in the local waterways
  • noted that only few of their customers hold a Pleasure Craft Operator Card or equivalent certification. As such, the RBSC is seen as an essential tool to cater to domestic and international customers
  • felt that Pleasure Craft Operator Card holders often have a false impression of their boating safety knowledge and therefore pay less attention to the on-site boating instruction when completing the RBSC
  • raised concerns about the potential negative impacts on the tourism sector if the RBSC is removed, in particular for boat and cottage rental businesses, lodges, and charter operators
  • indicated that the COVID-19 pandemic has caused unprecedented and devastating financial impacts to the tourism sector, including a major loss of revenue due to partial or complete closures, new expenses and pandemic related restrictions
  • wanted more data from Transport Canada to support the proposed change. For example, the number of accidents caused by boaters who hold a Pleasure Craft Operator Card versus boaters who only completed the RBSC

Participants, including some boat rental businesses and members of the public, offered a range of suggestions in relation to the RBSC:

  • limit the use of the RBSC to:
    • boat renters who are 21 years old or older
    • specific type of boats, including length and power limits
    • inland waterways and lakes during the day
  • make boat rental businesses owners responsible for the quality of instructions given to boat renters
  • develop a certification program for boat rental businesses’ instructors on the use of the RBSC
  • require boat rental businesses to collect a penalty fee from renters who do not hold a Pleasure Craft Operator Card
  • develop detailed incident reporting procedures and requirements for boat rental businesses
  • explore regional solutions to promote safety for boat rental businesses located near busy or dangerous waterways
  • do more outreach with boat rental businesses and the public on the value of RBSC and the importance of good quality, on-water training for new boaters
  • develop a standard training video that would supplement the RBSC
  • develop targeted enforcement and create tougher penalties for boat rental businesses that don’t comply

Pleasure Craft Operator Competency course providers supported the proposed change of no longer recognizing the RBSC as a form of proof of competency but nonetheless suggested that boat rental companies continue to use the RBSC for education and awareness.

A law enforcement agency noted that boat rental safety procedures are often inconsistent, resulting in unsafe behaviour on the water by renters who have never been on the water and who don’t understand the basics of safely and responsibly operating a boat. The law enforcement agency is in favour of requiring a Pleasure Craft Operator Card for anyone using a rented boat and suggested to:

  • maintain a safety list to explain:
    • features and hazards of the area to be navigated
    • how to operate the rented boat
  • increase the level of boat safety skills of Pleasure Craft Operator Card holders
  • implement enforcement measures for boat rental businesses who don’t verify that clients hold a valid Pleasure Craft Operator Card before using a rented boat

Strengthening course accreditation requirements

While we received limited feedback on this theme, the public supported the idea of strengthening course accreditation requirements. They also expected that the proposed changes would make sure that the course providers would spend the necessary time and money to improve their delivery of quality Pleasure Craft Operator Competency courses.

Some course providers agreed with the proposed change of strengthening course accreditation requirements and wanted more information on how it could be done.

Boat rental businesses noted major differences in the competency levels of boaters obtaining in-person Pleasure Craft Operator Competency courses versus those having only completed an online course. They:

  • mentioned that currently most Pleasure Craft Operator Cards are obtained through online learning. This has led to a large number of poorly-skilled boaters on the waterways.
  • indicated that the proposed changes will result in more online courses and tests. They felt this could lead to a drop in the general competency level of boaters.
  • raised concerns about online testing since it’s not supervised or monitored.
  • suggested that the Pleasure Craft Operator Card should be based on a pleasure craft’s size or weight, similar to how driver license classifications work for motor vehicles.

Finally, some participants like boat rental businesses and members of the public wanted to see more data about how effective the Pleasure Craft Operator Competency Program is, like tracking data on the number of Pleasure Craft Operator Card holders involved in boating infractions. They also expected that the Pleasure Craft Operator Competency course providers would assess the practical skills of Pleasure Craft Operator Card holders.

Introducing service fees

Some course providers were against the proposed accreditation application fee of $5,000, payable every five years. They:

  • indicated that additional costs would be passed to students, which could lead to fewer people taking the boating safety course
  • suggested to accredit existing course providers only when changes to the program are made and reduce their accreditation application fee
  • suggested charging an accreditation fee based on the number of Pleasure Craft Operator Cards issued by a course provider
  • expressed concerns regarding potential effects on:
    • small course providers, especially non-profit organizations and those in the Prairies
    • the capacity of course providers to adopt new and modern technologies to deliver courses
    • the ability of new companies to enter the course provider market
    • creation of an oligopoly (a few large companies would get most of the sales) which would lead to high prices for consumers
  • noted that similar renewal accreditation fees in the United States cost about $500

Other participants, including some course providers, agreed with the proposed accreditation application fee of $5,000, payable every five years. They:

  • acknowledged that the accreditation process creates a heavy workload which requires a lot of resources from Transport Canada
  • mentioned that the COVID-19 pandemic will have a negative, long-term impact on government finances, so sharing costs is key to supporting the Pleasure Craft Operator Competency Program over the long term
  • noted that the proposed fees could be justified if course providers receive clear, defined, and published service standards from Transport Canada

Course providers also gave feedback on the proposed maintenance and test materials access fee of $8.50 for each Pleasure Craft Operator Card issued. They suggested that we:

  • phase-in the proposed fee; and
  • make each course provider’s first 250 cards free so that small course providers could absorb the cost of the proposed fee.

Service standard

Course providers welcomed the use of service standards and expected that service standards will measure the effectiveness and the quality of service received from the Pleasure Craft Operator Competency Program. One course provider expressed concerns related to outages of the Pleasure Craft Operator Competency Database System during the summer. A few members of the general public indicated that the proposed service standards weren’t relevant and asked Transport Canada to develop service standards that measure the effectiveness of improving boater safety.

Next steps

The comments received through this public consultation have been recorded and will be considered as we develop the regulations.

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

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