Preliminary Feedback Sessions
In June 2018, Transport Canada (TC) held sessions with stakeholders to explain our plan to modernize Marine Cargo Services fees. This modernization aims to simplify the fees associated with cargo inspections and verification of international shipping requirement compliance. We asked for feedback on broad fee structure changes, including:
- Introduction of non-certificate and certificate day fees;
- Elimination of the stand-by fee in its current form; and
- Possible pricing ranges and service standards.
Here's what we heard from participants:
- In general, they support simplified fee structure.
- They want opportunities to see how some services could be streamlined and made cheaper.
- They want to be advised before the new cost recovery regime is put in place.
We considered these comments as we developed the Fee Proposal for Marine Cargo Services. The Fee Proposal contains detailed information on the proposed changes to the fee structure. The comments received during the preliminary feedback sessions are summarized in the engagement section of the Fee Proposal.
Consultation on Fee Proposal
Between February 13 and April 12, 2019, Transport Canada held public consultations on the Fee Proposal for Marine Cargo Services and published it on the Transport Canada (TC) Let's Talk Fee Modernization webpage.
To encourage comments, we emailed the Fee Proposal to 1,210 marine stakeholders included in the Canadian Marine Advisory Council's distribution list. We also:
- Held face-to face meetings with marine stakeholders in Vancouver and Montreal; and
- We consulted industry and stakeholder working groups to encourage review and solicit comments.
At the end of consultations on April 12, 2019, we had received three submissions from stakeholders.
In no particular order, the emerging themes from the feedback were:
Participants understand that TC needs to modernize fees and welcome a simplified fee structure for Marine Cargo Services. However, they see Canada's inspection regime as complicated when compared with other jurisdictions. They want opportunities to reduce the regulatory burden without compromising safety.
Participants worry about the combined effect that multiples fees and other governmental measures would have on Canada's marine sector. They suggested the fee increase be phased-in over time.
When creating a cost recovery rate for services, participants suggested that we consider the overall economic benefits that Marine Cargo Services provide to Canada's economy (e.g. moving goods to international markets).
Participants are concerned about fees based on a calendar day. Instead, they recommended using a 24-hours system.
Participants explained that on the West coast, it is common for two types of cargoes to be loaded on the same vessel, with each requiring its own set of readiness and fitness certificates. They asked for:
- a fee that allows a number of changes or combination of cargoes;
- a non-certificate day fee for certificate amendments; and
- a fee cap for Marine Cargo Services.
Participants recommended that the inspection requirements for timber deck and concentrate cargoes be reviewed and compared with other jurisdictions to determine if the current program can be eliminated or simplified.
Participants support current TC's inspection practice of hazardous goods shipments.
Participants noted that there will be no change from current service standard despite increasing fees. They are calling for a 12-hour service standard to provide a certificate after an inspection is completed, and a 12-hour service standard to assign an inspector after a request is received. They also expect that once the shipper procedures have been verified, TC should issue a letter of approval within 12 hours.
Participants also expect that certificates and letters of approval be issued in an electronic format once the inspection is complete.
Comments received through this process have been recorded and will be considered as we develop the regulations.
The next round of consultation will occur when the proposed regulatory changes are pre-published in Canada Gazette Part I. TC will notify stakeholders when this proposal appears in the Canada Gazette.