Just sent a modified version of that in.

It sounds like a terrible public infrastructure project.

David J.

I can't wait for it. You guys making the trek south to Toronto for it this year?

David J.

Here is the full link from Graham since it seems to be broken. http://www.paddlecanada.com/latest-news/331-updat...

David J.

That's really going to change the paddling scene in Ottawa.

David J.

I agree with you 100%. That's why I was so attracted to this trailer. Rather then the jumpy footage that is often with whitewater footage to try to generate excitement it uses the absolute beauty of the region they were filming to handle it. It also looks there is a very good story also tied into the production as well.

Cheers,

David J.

No sure what you mean. Are they going to be exempt from the regs? No.

I would say they would fit under the same regulations as any other canoe or kayak. The regulations only mention canoes and kayaks being used in competitive races as being exempt from the regulations mentioned above (they have their own set of regs to follow).

David J.

Wow, that's amazing. The price really ads up indeed!

David J.

I do agree with you that it's ironic about the government priding itself on cutting the red tape indeed!

You are totally welcome to cross post the comments over on the CCR site or you can link them over here if you want.

I really appreciate the conversation. Over the years I have dropped out from many forums because I find the levels of conversation and debate at a grade 1 level. I often find that people tend to post emotionally before thinking or researching so this has been a lot of fun indeed!

If people have questions they are welcome to pop by and say hi. Not sure if I can answer ever scenario but if they have ultra specific examples then they would do best and ring up TC directly and get it straight from the horses mouth.

Cheers,

David J.

Hey there.

To your first point. Sadly I don't think it's going to be much clearer. It's a classic case of civil servant thinking when they developed the new regulations. The closest example I can give is with the commercial fishing industry. You register what type of boat you own and follow the prescribed regulations accordingly based on that boat. It's assumed (and pretty likely) that everybody in that boat class will have the same level of daily participation, crew size, income and business operation size. With that in mind I can see where the idea of type of regulations works for them. The whole thing is much more uniform across Canada generally speaking.

When TC were reviewing the regulations with the light of canoes and kayaks they assumed the same scenario was in place. It didn't occur (at the time) the scenario of volunteer clubs or the occasional instructor or the fact that participants could possibility show up with their own boats. To them, teaching ='s commercial in a canoe so follow these rules.

When the regs were first released, we submitted several scenarios which included examples similar to your scenario looking for clarification and it hadn't even occurred to them. The problem is that regulations are very difficult to change after the fact. It requires approvals almost to the highest levels of government. From what I understand they are working to come up with possible solutions within the working framework. It won't work for every situation that's for sure so we will need to wait and see.

Quick aside. The fist time I talked to them with the question about participants and their own boats I was told that yes, all participants in the course needed to register. The idea that the entire package of vessels on the water was commercial because technically it is. I talked to them and explained that it's a scenario that just wouldn't work in 10,000 years. How could a business owner ever expect her students to register their boats. It just wouldn't work and commerce would grind to a halt. After some discussion they adjusted the focus that just the instructors boat itself would be views as the commercial element of the group of boats.

For your second question I can't give a solid answer. It depends. There are a couple of outer clubs out there that organize trips (transportation, food, etc) but don't provide any type of leadership when people actually push off on the water. TC has come back and said in that scenario it wouldn't fall under their jurisdiction. If a club wanted to operate that way then they will need to make people doubly aware that they don't offer any type of on-water leadership because if an accident happened and lawyers got involved, a good smart lawyer would only need to look at the scenario from the perspective of a guided excursion and then look up the regs only to discover that they didn't follow them. You could think about it as the, looks like a duck, must be duck idea. Of course nothing has been proven in court and maybe the above won't ever happen but it easily could.

Does that make sense with the second part of your question? My own personal opinion is that if clubs are working to see how close to the line they can get without crossing it would be better off just complying and moving on. I just think it's to dangerous for them to follow.

Of course the whole thing could be looked at from the perspective of real-life enforcement. The program is brand new and there has been zero public education (so far) and TC is still reviewing options. With that all in mind I just can't see any type of actual real life enforcement. I just can't see anybody checking boat tags in the back woods of northern Alberta. The only place that I see a possibility over the next couple of years is groups working in National Parks (eg. West coat of BC) or groups working in urban environments. And even if they get inspected, I can't imagine anything more then an education lecture for the next couple of years.

Paddle Canada is encouraging compliance as instructors should be setting an example and following the laws of the land just as we would for PFD usage in a canoe or kayak but remember there is textbook and real life. They often don't match up.

Does that help?

David J.

When regulations were maintained by the Canadian Coast Guard canoe & kayaks always flew under the radar when it came to commercial registration. I'm not sure if it was something they officially ignored or if it was because they had their hands full with bigger boats but when regulation responsibilities switched from CCG to Transport Canada they did a full review of all the regulations they were not responsible for. At the time they realized that people were using boats with paddles in commercial ventures and these boats were not registered as other commercial vessels were.

I agree with you that there are still lots of grey areas for sure and lots of scenarios that demonstrate that one set of regulations don't really work for all the different type of scenarios in the paddling community. It will be interesting to see how it all gets sorted out.

I'm sure on paper somewhere there is a feeling within TC that registering guides and instructors canoes/kayaks will make things safer but it's really much more to bring this type of commercial activity on the water inline with other industries.

I guess one could argue that registration would make somebody safer if they used it to remember to bring the proper gear but that's a pretty thin argument as we all know gear doesn't make people safer. Safety is in the mind and proper training. Neither which is addressed in registration alone.

David J.