UPDATE – Federal: Your feedback required on Transport Canada’s proposed fee hike for container requalification facilities registration
During the week of May 24, 2021, the General Policy Advisory Council (GPAC) met to discuss industry specific items for those that transport dangerous goods. Transport Canada (TC) raised an issue during the meetings that affects propane: its intent to propose a fee hike for container requalification facilities, startlingly similar to TSSA’s. Instead of issuing a separate invoice for actual services rendered – as what is currently taking place – TC is intending to charge a flat rate.
TC’s presentation on the fee hike can be found here. While previous versions were deemed problematic by industry, the newest scheme looks to lump all services concerning registration of inspection facilities into a single fee. This fee is reported to be based on an average of facility fees previously paid. However, when examining the proposed costs, it seems TC has averaged the most expensive categories, which would significantly increase the registration costs for small facilities.
For example, on slide six of the presentation, the numbers indicate that a Category 1 facility currently pays $750 for registration and an added $750 or more for any amendments.
Under the new scheme, a typical facility would be charged a $2,000 registration fee but with no additional future costs for amendments. Therefore, even if a facility does not change any of its services, it would now be charged the full $2,000, essentially paying for amendments it may never submit.
This proposed rate hike is in the beginning stages and the CPA needs your feedback to provide industry-specific implications of this new scheme. We are specifically looking for information on whether the fees currently being paid as indicated by TC accurately reflect your costs and if the proposed fee changes are an acceptable increase based on your past payments. Email your concerns to Robert Loenhart, Vice-President, Regulatory Affairs and Safety at robertloenhart@propane.ca.
