May 15, 2024 | Circular No. 11667

Dear Member,

As reported on June 6, 2023 in CL 11531, Transport Canada is advancing the transition of the existing private pilotage systems in the ports of Sept Illes, Port Cartier, Havre St. Pierre and Baie Comeau to a public system under the Pilotage Act. Transport Canada’s intention was to use an Interim Order as the regulatory instrument for the transition. Working groups and a Regulatory Committee, led by Transport Canada,  were established for each port to discuss the geographical limits of the compulsory pilotage areas, location of pilot boarding stations, size of ships subject to compulsory pilotage, pilot ordering times and details related to pilotage licenses and certificates for each port. The Federation and a working group of the Pilotage Committee have been heavily involved in this process to date, including engagement with the Laurentian Pilotage Authority, who will be delivering the service when the transition is completed.

Transport Canada’s intended time line was to have the Interim Orders for each port issued in February 2024. However, on April 12 Transport Canada advised industry that they are abandoning the Interim Order process and have opted to follow the Governor in Council (GiC) process for a full regulatory review of the situation.  The first two steps of this process are to complete the Regulatory Impact Analysis Statement (RIAS ) (a statement to the public and to Cabinet that justifies the regulatory action that they wish to take) and to complete a Cost-Benefit Analysis (CBA) to ensure that regulatory proposals and decisions are based on evidence, robust analysis of costs and benefits, and the assessment of risk, while being open to public scrutiny. Transport Canada have advised that both of these processes are now underway and they expect to publish the proposed regulations in Canada Gazette I  some time this Fall. Once published, the formal public consultation process would commence, however Transport Canada has not shared the duration of the consultation period.

The Federation and the working group of the Pilotage Committee remain engaged in the process and updates will be provided as necessary. Please contact the undersigned with any questions or comments.


Chris Hall,
President & CEO