Hi Louanne,

Thanks for your reply confirming that Pacific Rim National Park Reserve requires licensed tour operators and course providers to carry $2 million of liability insurance.

Insurance premiums are already seriously crippling adventure tourism operators and course providers in Canada. It's disgraceful for the Canadian government to continue promoting ever more expensive licensing requirements. The continuation of this trend will result in the failure of legitimate businesses.

When the Canadian government doubles insurance requirements from $1 million to $2 million, numerous results follow:

• Clients of licensed businesses must pay more to register on tours, since insurance premium expenses are ultimately passed on to clients.
• The higher costs will place the tours further out of reach of potential clients who have clear interest, yet can't afford the additional financial expense.
• Legitimate, licensed businesses will fold as a result of the reduced client base combined with higher operating costs.
• Unlicensed "pirate" businesses will converge on the market. These companies are able to significantly undercut prices because they don't purchase insurance and they don't bother to meet the requirements for licensing.

For years, pirate businesses have operated unhindered within Gwaii Haanas National Park Reserve. Unfortunately, Parks Canada seems to have no ability to remove these businesses, because they all operate disguised as "groups of friends" using independent visitor's permits. Clients on these pirate tours are briefed to declare that they are not on a guided tour if they should ever be questioned by a Parks Canada employee. Investigations end with this declaration and the pirate tours continue on their way, with happy clients who saved several hundred dollars each!

As pirate businesses take over the market, the safety nets of licensing businesses, certifying guides and upholding standards will all fall by the wayside. It's clear that further increases imposed to the operating costs of licensed businesses will eventually result in dramatically lower levels of safety for tours within National Parks.

$1 million of liability insurance is more than enough for legitimate tour operators to carry. This amount should be re-established as the minimum requirement for licensing. I ask that you forward this email to the person responsible for making such decisions and I request their timely response to this issue.

The following questions stem from my involvement with the Association of Canadian Sea Kayak Guides (ACSKG) and our history of conducting portions of our guide examinations in the surf off Long Beach in Pacific Rim National Park Reserve.

Please describe the details of the procedure that not-for profit organizations must undergo in order to obtain a permit to conduct surf kayak assessments in the Park.

Also, please indicate if not-for profit organizations must also carry liability insurance in order to qualify for the permit.

Thank you.

Sincerely,
Gord Pincock
Evolution Guide School
www.evolutionguides.com

From: Louanne.Ralston@pc.gc.ca
To: Gord Pincock
Sent: Wednesday, January 12, 2005 10:09 AM
Subject: Business Licensing - Pacific Rim National Park

Gord in answer to your following questions:

Q) The following questions stem from my involvement with the Association of Canadian Sea Kayak Guides (ACSKG) and our history of conducting portions of our guide examinations in the surf off Long Beach in Pacific Rim National Park Reserve.
- Have you been operating under a different name than "Evolution Guides" ? as I can not find your file.

Q) Please describe the details of the procedure that not-for profit organizations must undergo in order to obtain a permit to conduct surf kayak assessments in the Park.
- None profits organizations must undergo the same procedures as any other business that operates in the park. The emphasis is to:

1) ensure that any business, whether for profit or not, is qualified to carry out the activity that they are proposing and have qualified guides/leaders to do this.

2) ensure that they have the necessary insurance coverage. To date you have been the only operator in Pacific Rim to question the 2M insurance. Most companies carry much higher liability insurance than what we require. Where 1M may have been adequate 10 years ago, in today's dollars it really isn't very much. As business licensing is relatively new to Pacific Rim we wanted to start by being adequately covered from inception rather than increasing at a later date. For all of our currently licensed operators:
- none had to change their coverage, or if they did, we were not made aware of it
- they only had to add the clause to indemnify the Queen in the Right of Canada and Pacific Rim National Park

Q) Also, please indicate if not-for profit organizations must also carry liability insurance in order to qualify for the permit.
- please see above. This not only applies for non profits, but also for any one wishing to carry out a special event in the park. i.e. previous surf kayak events, marathons, filming etc.

Louanne