The following is a copy of the letter sent on behalf of Paddle Canada and all its members, to Transport Minister Chuck Strahl.
March 16, 2011
To: Chuck Strahl – Minister of Transport
cc – Diane Cosentino, the Chief Registrar Transport Canada
& Kevin Monahan, Project Manager Regulatory Services and Quality Assurance (AMSX) Transport Canada
Re: Kayak & Canoe Vessel Registration
Dear Minister Strahl,
On behalf of Paddle Canada’s 12 provincial board of directors, its 8 provincial member paddling associations and its 1300 individual members, I would like to thank the ministry of transport for addressing the issue on kayak/canoe registration this month. Paddle Canada, as you know, is in favour of the new regulations surrounding ‘guided excursion’. From early on (2005), Paddle Canada was involved in the public consultation process and discussions around such regulations. Our concern however, along with many other paddling industry groups, lies with the kayak/canoe registration process and the designations & wordings in the Transport Canada documents (Small Vessel Regulations and the Canada Shipping Act).
After careful review, Paddle Canada sees no benefit to registering a leader’s boat whether used for commercial purposes or not. It does not improve safety and simply adds an administrative burden plus the small fee to an already fragile paddling industry that relies heavily on tourism.
The registration process and fee is like an unfair tax system with no measurable benefits. The paddling industry in Canada is world renowned for the quality of service. Voluntarily, our industry has developed and implemented strong safety and risk management policies and procedures. There is nothing in this proposed regulation which contributes to the paddling industries effort to provide safe paddling in Canada.
We are therefore asking, alongside with other national groups such as Scouts Canada and Girl Guides Canada, to advocate for an exemption of the human-powered vessel registration process. We are asking Transport Canada to consider that every leader’s boat on any “guided excursion” (whether used for commercial or not-for-profit purposes) be considered a “pleasure craft”, thus exempting the boats from the registration requirement.
Thank you for your time and consideration,