Good Morning everyone,
I appreciate the opportunity to speak here today.
A Boat is a Boat
Why do our Small Commercial vessels need a special
licence number? A boat is a boat, just like a pickup truck can be purchased and
use for a construction business or a family, or BOTH. A boat must be viewed the
same way or else you create a double standard!
Most of these Small Commercial Vessels under 5gts are
basically recreational boats. There are not many of them that size that have
been specifically custom built for commercial work. Sure you can say that the
majority of the ‘Stanley type’ of barges 30 feet and under are used
commercially...but there are hundreds of them that are purchased by well off
cottagers who live on islands and need a heavy duty boat to haul all the
supplies and machines and people and food and drink that they need to be able
to ‘cottage’ comfortable.
These boats are sold at boat shows around the country alongside
all the other types of boats that exist. And all other types of recreational
boats are pressed into service as commercial boats around the country as well.
I myself would love to own a less than 8m Stanley Barge (I’ll talk about why
less than 8m in a few minutes) but I haven’t been able to justify the cost yet.
Why, because used ‘recreational’ boats are a dime a dozen and cheap! So I have
4 boats from 24 foot down to 16 foot that I use to haul my customers, staff,
food, drink and restaurant supplies as well as construction materials and
garbage. Everything needed to make a small resort run has to arrive and depart
the island on a boat.
But I am no different from anyone else who opens an
island in the area, except I am running a business, a commercial operator. Why
does this mean that my boats must be separately licensed? My boats aren’t
always used commercially, I have friends, not many, but some and I go to their
cottages for dinner in my boat. I love to fish and I get out as much as I can, thats not
commercial. My son is 8 years old so now I take him and his friends out
tubing....the list goes on and on. How is any of this different from the Pickup
truck example? The Government already licences businesses to both regulate and
tax them, is Transport Canada planning to bring in special licence plates for pickup
trucks? I think not!
Transport Canada certification
standards
Currently, in order to drive a Small Commercial Vessel
(SCV) of over 8 meters or carry 7-12 passengers Transport Canada requires the
driver to complete an SVOP course (with prerequiste MED-A3 and a 16hr+ 3hr prov recognized
first aid course).
The SVOP course is a totally theoretical course
covering the following subjects;
- Meteorology
- Radar
- Use of marine charts to execute a voyage
- Canadian buoyage system
- Stability
- Collision regulations
- Pollution prevention
Some of these subjects are irrelevant to our sheltered waters scenario. For example I have owned a small resort on an island for 13 years. The resort is located 5 1/2 miles or nearly 9km from my marina in Parry Sound. I make the round trip from the marina to the Resort 220-250 times per year. On that trip the Vessel is never more than 1NM from shore at any point and in 3 ‘narrows’ situations is only 20-30 feet from shore.
I drive this route in all weathers including at night (which I try to avoid if possible as well as fog and lightening situations). I know the route so well that if I am driving it in the dark I have the ‘back’ of my Nav lights (the areas throwing light INTO the boat) taped over. I also have a cloth that I put over my instrument panel to block the light thrown from that.
The reason for doing this is because it is safest for me to navigate using the skyline because it is familiar and unchanging, checking my position with a spotlight on the spar buoys in the ‘trickier’ spots. Once eyes adjust to the dark and are not bothered by distracting lights such as from the dashboard the range of vision is large. The brain kicks in and provides a map from its memory banks and with all senses working together as they do in the day (including sound as the boats motor noise reflects differently when the shoreline is closer). Even other boats without running lights can easily be picked up as the white water thrown out from the bow almost ‘glows’ in the dark, with a similar effect as phospheresance in the ocean. This method is also a lot safer than an unfamiliar operator using a spotlight as the vision is concentrated within the beam of light thrown by the spot and its reflection on the bow of the boat and the brain, using only one sense, becomes focused only in that pool of light and starts to lose the ‘overall picture’ of the surrounding environment, tunnel vision if you will.
Given my familiarity with this route it is very difficult to see the relevance of SVOP subjects such as ‘Chart work and Pilotage’, ‘Meteorology’, ‘Radar’, ‘The Canadian Buoyage System’ and ‘the use of marine charts to execute a voyage’.
Additional SVOP subjects do have relevance for example ‘shipboard safety’, ‘Stability’, ‘collision regulations’, and ‘pollution prevention’ but these subjects are an integral part of the everyday running of our SCV’s and built into the way our staff are trained and instructed (loading a boat so it is stable, avoiding collisions because you may be killed) and our business’ (if you pollute the lake people will report you and you won’t get any more business)!
Is Transport Canada planning to introduce a special driving course for pickup trucks so in order to own one you have to pass the ‘pickup truck test’? I think not!
Should there be a ‘driving test’ for boats, absolutely! We have the PCOC card, available online, to anyone who can use a computer. A 100% theoretical test, it gives no practical driving skills to the boater. Yet it allows a person over 16 years old to drive a boat of ANY length and ANY power! I see the impact of that test every day in the summer where from my resort property I watch large boats with enormous power go by my docks at great speeds, often stupid and unsafe speeds! I also watch boats go by my docks to slow, ploughing along sending great walls of water 3-4 feet high into my docks, throwing moored boats around, knocking people off their feet and damaging the dock structures themselves, sometimes ripping the ramps right off. These drivers have a PCOC card but no idea how to drive a boat. If the bow wake is particularly bad and I have the time I sometimes chase them down and I ask them if they have any idea of the damage they are causing behind them. The majority of them are very receptive, they are almost all men, 50-60 years old, obviously very excited about their new toy, and they have no idea about the wave they are putting out behind them, they have no idea about how much extra fuel they are burning by driving that way and it’s not their fault. They were never taught properly, or at all, by parents who were boaters. They never had time as young parents or business people, to buy and use a smaller boat and learn ‘the ropes’. They are told by Transport Canada that all they need to drive this great big boat legally is a PCOC card, available online.
But look at the burden on me. I have to take all these time consuming and expensive courses, MED-A3, SVOP to learn how to put on an immersion suit (which I will never see again) and get into a helicopters rescue basket. I need to know how to navigate by the stars and use radar (never owned one, doubt I ever will) as well as Chart work and pilotage and planning and executing a voyage. All subjects I will never use 1NM maximum from shore.
As a commercial boater I have vastly more experience than any recreational boater. I would easily spend 150 hours a year on the water and probably over 200 hours. The average recreational boater would spend MAYBE 50 hours. My experience and the percentage of time I spend on the water puts me in many situations that I have to help other boaters. They break down and run out of gas and I tow them to a dock. I help them when their boats don’t start at the dock and give them advice on maintenance and safety and I tell them when their young kids are driving their boat unsafely and affecting others. I have pulled a number of people out of the water and in a few cases, saved their lives.
I have no problem whatsoever with safety training courses but they must be practical and relevant to the boating that we are doing. Why, with all my boating experience, do I need to do boat safety courses but recreational boaters don’t have to do anything practical? Why are there lives less important than mine? Why can they drive 9 or 10 people in their huge boat with no boating experience and I need 5 days of courses?
BUT, the real issue with the TC standards for SCV’s is not so much the ‘over education’ of the SVOP course (it is VERY difficult to argue with having TOO MUCH safety training) but rather the lack of training and inherent danger in the TC standards for driving SCV’s of UNDER 8m or 1-6 passengers. It is here that TC has made a fundamental mistake!
The regulations state that all a boat driver needs to drive 1-6 commercial passengers is a PCOC card!!! A qualification availed over the internet that requires no practical boat driving experience!!
So, according to TC regulations, I can hire a 16 year old kid with a PCOC (because at 16 years and over the holder of the PCOC can drive a vessel of any power) and no boat driving experience and put him/her into my 24’ passenger boat powered by a 225hp outboard and send them off with my 1-6 resort guests!
The liability aspect of this scenario is mind boggling to say the least! For a government department charged with providing the public with safe means of transport throughout Canada to suggest this is safe is laughable.
It is obvious that these polar opposites in regulatory standards need to be revised.
Let us, The SCVA and other similar organisations help TC to come up with relevant and meaningful standards for the SCV industry. We want to be safe as well!!
Please give us a ‘stay of execution’, a moratorium on the present regulations until at least the spring of 2013 so we can revise these standards together and avoid the financial hardship at the grass roots level that these regulations will surely create!
Recommendations
-
A ‘stay of
execution’ on these regulations until spring 2013. Many people are not even
aware of them yet as you have not publicized them.
-
Abolish the
commercial numbering system completely – under 5GTs a boat is a boat
-
In
conjunction with the industry develop a relevant, practical and meaningful
training course for boating safety in sheltered waters, a MED-A4 if you like
for all operators - our association is willing to help in any way with the
development of that course
-
Develop a
more relevant and meaning full life jacket standard
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