What We Heard Report — Public Consultation on Transport Canada Introducing a Fee for Marine Insurance Certification Services
Preliminary Feedback Sessions
In November 2018, Transport Canada (TC) held an engagement session with stakeholders to explain the department’s plan to introduce a fixed fee of $98 for the provision of marine insurance assessment and certification services. This represents a change from the current approach, which places the burden on Canadian tax payers to cover costs associated with ensuring that ship owners provide valid proof of insurance or financial security. TC asked for feedback on the proposed fee design and amount.
The fee design and pricing were presented at the Canadian Marine Advisory Council (CMAC) meeting in November 2018. Stakeholders were given an overview of the cost and fee design methodology, policy considerations and the Service Fees Act requirements. No questions or issues were raised.
Consultation on Fee Proposal
TC developed a Fee Proposal for Marine Insurance Certification Services with detailed information on how we determined the proposed fee.
Between February 13 and April 12, 2019, TC held public consultations on the Fee Proposal for Marine Insurance Certification Services and published it on the 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:
- Contacted all Marine Insurance Certificate holders by mail to let them know about the Consultation on Fee Proposal; 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. However, they were concerned about staying competitive and suggested we consider the wider cost of Canada's entire fee regime, compared to other jurisdictions (e.g. United States).
Participants suggested that we consider a fee consistent with similar marine insurance certification programs in Australia ($68 per vessel) and the United Kingdom ($53 per vessel).
They asked that consideration be given to what the cumulative effect of introducing new or increasing existing fees will have on the marine sector.
Participants noted that the proposed fee is the same for both new and renewal vessel applications. They suggested a tiered approach where a certificate renewal fee is 50% less than a new vessel application.
Participants expected that Marine Insurance Certification Services would be offered online. They suggested fee payment procedures such as:
- Issuing the invoice at the same time as the certificate; and
- Listing multiple vessels registered to the same owner on a single invoice.
Participants mentioned that the service standard of 10 working days to issue the certificate is too long, as they expect services to be completed in less time. For example, outside of the busy session, stakeholders called for a 12-hour service standard once a completed application is accepted and a service standard of 5-7 days as a standard in lieu of 10 working days.
Stakeholders expect that new fees would enable TC to deliver marine insurance services faster.
Stakeholders would also like to see a more efficient process, digital/online, for members to apply for and receive marine insurance certificates.
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.