Welcome to freecourse.ca!

The following operators must carry proof of competency when operating any kind of motorboat (including Seadoos and jet skis) in Canada:

Any boater (regardless of age) using a any kind of motorboat that is less than 4 metres (13 ft) in length.

By September 15, 2009, all operators of any type or size of motorboat will have to carry proof of competency.

An operator is the person in charge of a vessel. Failure to carry proof of competency carries a fine of $250.

In Canada, the standard accepted proof of competency is a Pleasure Craft Operator Card. A Pleasure Craft Operator Card is not a license; it is simply a certificate declaring that the holder has passed a Transport Canada accredited Operator Proficiency Exam. An accredited Operator Proficiency Exam contains 36 multiple-choice questions. There are three types of exam based on age: 8 to12 years old, 13 to15 years old, and adults (16+). Regardless of which exam you pass, you need not write another; the PCOC is good for life.

To pass the exam, one must answer 27 (75%) of the 36 questions correctly. It is highly recommended to complete an accredited boating safety course before attempting to write the exam. An accredited boating safety course teaches the boater 149 knowledge objectives required by Transport Canada. These 149 knowledge objectives cover subjects such as: aids to navigation, basic safe boating practices, regulations affecting boaters, mandatory equipment requirements, and emergency procedures.

This site hosts a free online course that concisely explains the 149 knowledge areas from which questions are drawn for Transport Canada accredited Operator Proficiency Exams. These knowledge objectives are indicated in bold print throughout the online course.

Transport Canada has announced plans to increase the difficulty of questions on Operator Proficiency Exams. In addition, the length of the exams will be increased from 36 questions (possibly to 50 or 55 questions). These changes are scheduled to come into effect in 2006.

Our free online course is solely for the use of boaters preparing to write the Operator Proficiency Exam at a freecourse.ca testing centre, by mail (proctored exam), or by e-mail (proctored exam). When you have completed studying our free online course, you can write the Operator Proficiency Exam online at this web site or at one of more than 250 freecourse.ca testing centres located in communities across Canada.

We created freecourse.ca to provide boaters with one of the most affordable means to get their Pleasure Craft Operator Card. If you have any questions or concerns regarding our services, please feel free to contact us (the best way to reach us is by e-mail):

Jim Steeves, P.Eng., MBA
Manager - Distance Education Program
freecourse.ca
565 Edison Avenue
Ottawa, Ontario, K2A 1V5
E-mail: support@safetyafloat.ca
Ottawa and Area: (613) 798-4176 m-f, s, s 17h30-22h30 EST
Outside Ottawa: (866) 729-4521 m-f, s, s 17h30-22h30 EST

Accredited Course Providers (ACPs) are not effectively audited or regulated and it is because of this lack of supervision and absence of regulations that the Office of Boating Safety’s (OBS’s) Operator Competency Program (OCP) has been plagued with problems since its inception.

The problems include:
Lack of Resources – Because of a lack of staff, OBS policy is that no course provider is investigated unless there is a public complaint or negative media attention. Since the OCP is an extremely unpopular program, there are few complaints.
Lack of Remedies – There are no consequences for wrongdoing by course providers. To our knowledge no course provider has lost accreditation.
Inadequate Supervision of Online Exams – A number of online challenge exam providers gained enormous popularity (and profits) by employing methods to allow cheating on online exams. A reporter proved the inadequacy of online exams by using them to certify dogs and blind people. We estimate (conservatively, we believe) that tens of thousands of boaters have been able to simply pay somebody to write an online exam for them. Reportedly, a single online test provider has been able to test more than 400,000 boaters.
Unacceptable Marketing Gimmicks – Certain exam providers specialise in letting boaters challenge the exam for free; boaters only pay if they pass the test. This is the same as letting someone have an advance peek at the exam. At boat shows, boaters can elect to go from booth to booth trying exams until they finally guess enough answers to pass.
Non-Accredited In-Class Courses – An accredited in-class course should be at least 3.5 hours in length and should cover all 149 knowledge points required by the Office of Boating Safety. One-hour “refresher” courses are being offered for which turnouts can be 100 to 125 people in venues such as Legion halls and taverns. After a 1-hour presentation (covering 36 points), the participants write the official exam, which contains 36 questions. The exams are collected at the end of the exam period but not corrected. There is no requirement that tests be corrected on-site. All participants are given a pass mark and receive the official operator card in the mail. To our knowledge, no provider of refresher courses has ever been audited to verify that they correct in-class exams.
Expensive Replacement Cards – It never occurs to boaters to ask a course provider how much they charge to replace a lost or damaged operator card. The OBS-approved printer in Toronto charges under $3 to print and mail a replacement card, some course providers now charge boaters $25 for replacement cards and these prices are expected to double after 2009.
Black Market for Boater Cards – A person can arrange to be a testing agent with certain course providers and then proceed to sell cards. If only 10% of cards are bogus (estimates range higher), then 90,000 Canadians are using PCOCs obtained without proving they possess the required safety knowledge.
Easy Exams – Some course providers employ easy exams that boaters with little or none of the required safety knowledge can pass with ease. Easy exams eliminate any need for in-class courses. In addition, easy exams transform the pay-if-you-pass testing scam into a gold mine. Over the years, pay-if-you-pass testing, combined with easy exams, has produced potentially a large population of unqualified people carrying cards declaring them to be safe boaters.
Price-Fixing – Certain course providers have been able keep competitors out of important venues (such as boat shows, outdoor shows, and cottage shows) by cutting secret deals with show organisers to buy exclusive rights to a pavilion or the entire show, thus allowing them to set high prices.
Inappropriate Testing Venues – When the OCP was being developed, it was recognised that some boaters would have good boating knowledge and so should be allowed to challenge the operator exam without first obtaining in-class instruction. As a result of this provision, the core business of many course providers is challenge testing and they have little interest in training. To process as many challenge tests as possible, course providers can be found setting up their testing booths in a variety of noisy venues such as boat shows, sports shows, and even parking lots.
Misrepresentation of Facts – The simple expedient of calling one thing something else has created profitable confusion. Accredited course providers regularly describe the Pleasure Craft Operator Card as a “license”, not a certificate (BoaterExam.com’s slogan is: “BoaterExam.com: Licensing Canada’s Boaters”). There is no such thing as a boater license in Canada. In some cases, boaters seem to believe that they are buying a license (like buying a fishing license) rather than earning a certificate.
Misleading Signage – Test providers that operate booths at shows commonly use signs that are misleading. One course provider uses huge yellow signs that say “Transport Canada” in very large letters; below this, in much smaller letters, are the words “Accredited Course Provider”. Understandably boaters visiting such a booth assume that they are dealing directly with Transport Canada and that all practices used at the booth are, therefore, perfectly legitimate.
Misuse of Publicly Funded Educational Materials – For years many course providers have been converting hundreds of thousands of dollars worth of CCG printed materials into advertising for their online exam scams. They do this by applying stick-on advertisements to the covers of the tens of thousands of Safe Boating Guides that they hand out at shows. In fact, this is a primary reason for attending the shows. Testing conducted at shows is mostly to cover the cost of running the booths. The real money lies in the tens of thousands of boaters who take home the guides and then write an online exam. All of this advertising, which goes straight into boaters’ homes, is paid for by the taxpayer and is used to encourage boaters to write online exams, at the expense of in-class courses.

Possible remedies to the above-mentioned problems may include:
Prohibit Pay-If-You-Pass Offers – Implement a regulation enabled under the Canada Shipping Act that proscribes the practice of pay-if-you-pass testing.
Limit Challenge Exams – The OBS policy provision that recognises that some boaters should be able to challenge a proficiency exam allowed opportunists to hi-jack the operator competency program. Challenge testing should be limited by proscribing it from implausible venues such as boat shows, cottage shows, shopping malls, and parking lots.
Introduce Better Exams – Introduce standardised exams of sufficient difficulty and length (50+ questions) to encourage boaters to obtain training. This single measure will have important beneficial effects:
-   It will make it difficult to use the pay-if-you-pass scam at boat shows since unprepared boaters will be less likely to challenge the longer exam; and
-   It would encourage boaters to obtain training, either self-directed or via an in-class course.
Introduce Standards for Testing Venues – The OBS should introduce minimum standards to eliminate unacceptable venues such as noisy boat show, shopping malls, and parking lots.
Limit the Impact of Challenge Exams – The availability of challenge exams online and at boat shows has significantly reduced demand for formal in-class instruction. Placing a moratorium on online tests would mitigate this problem Because of the high numbers of testing agents and eligible proctors available (several in virtually every Canadian community) there is actually little need for online exams. If online exams are to be allowed to continue, then their impact should be curtailed, this can be done quite simply with two small changes: 1) Make the exam an open book exam to be completed in four parts over a period of four days; and 2) Limit the service to only those boaters who have a credit card with a name (first, last, or both) that matches the name that will appear on the PCOC. Alternatively, the OBS can take over the provision of all online exams. This can be done by letting interested course providers participate in a TC-operated online exam system. This is a viable solution; in one fell swoop the OBS can:
-   Eliminate controversy surrounding the provision of online exams;
-   Eliminate variations in pricing;
-   Centralize all data collection, thus eliminating price gouging for replacement cards, as well as make it easier for boaters to replace lost or damaged operator cards; and
-   Generate revenues to support worthy projects such as the Coast Guard Auxiliary and OBS-directed educational efforts.
Reduce the Potential Size of the Black Market for PCOCs – The black market for PCOCs exists because many boaters are afraid to write the exam. Remove this fear and demand for black market PCOCs will also be removed. Showing boaters that the exam is not so bad can remove the fear. This can be done through an online exam system where an open-book exam is written in four or five parts over four or five days. The system would allow any boater to attempt lesson one and part one of the exam any time free of charge. Boaters would discover that it is in fact easy to prepare for and then pass each part of the exam and would not then wish to buy a black market PCOC.
Establish a central record – Protect boaters from price gouging by establishing a central record so that boaters can obtain replacement cards from any accredited course provider. This can be done under the Privacy Act by declaring ACPs to be agents of Transport Canada.
Prevent Refresher Courses – Any course provider that is caught offering a refresher course should lose its accreditation. Any in-class course offered by any ACP must be registered with the OBS at least 2 weeks in advance of the scheduled course date to facilitate the OBS operating a program of random inspections to catch dishonest ACPs. Any ACP caught offering a course for which no course date was registered loses accreditation.
Require In-Class Exams to be Corrected On-Site – All exams offered to the public, either challenge tests or tests following an in-class course, must be corrected at the testing site (on-site) immediately following completion of the test. Any ACP not correcting tests on-site risk loosing accreditation.
Prevent the Conversion of Safe Boating Guides Into Advertising – Any test provider that affixes advertisements onto Safe Boating Guides should lose accreditation, or lose the right to distribute the guides, or both. The OBS should add a border to the Guide with a message telling the public that any advertisement affixed to the cover is prohibited. The border message should refer the reader to more text inside that explains how the public funded guides are being abused. The OBS must also add a banner ad to the cover of the Safe Boating Guide advising that 1.) The OBS recommends boaters take an in-class course, and 2.) The OBS encourages boaters to look up the full list of course providers at www.tc.gc.ca.
Prohibit Practices that Support Price Fixing – The OBS should inform Consumer & Corporate Affairs Canada (CACC) of the practice of paying show organisers to keep competitors out of shows. Both the OBS and CCAC should explain the problem to show organisers and ask each of them not to participate in this illegal practice. The OBS should run advertising to advise consumers that they have a choice.
Specify Allowable Signage – Allowable signage should be specified; misleading term’s such as “Licensing Canada’s Boaters” need to be eliminated from materials associated with an ACP.

As stated by the Office of Boating Safety, the Operator Competency Program was designed on the assumption that participating course providers would be honest and adhere to both the letter and the spirit of CCG policies related to the program.

But this is not the case. The fact is that the enormous profit are possible by pursuing questionable practices, and certain course providers have proven their determination to use every questionable means possible to make their fortunes. And if given the chance, they will. Thus, the entire Operator Competency Program should be redesigned and heavily audited with dishonest course providers in mind. And until a better program can be implemented, a moratorium should be placed on boater testing.

So in summary:
-   Enormous incentives exist for unethical course providers to pursue questionable practices that have destroyed the integrity of the Operator Competency Program and compromised public safety.
-   This situation is possible because of a lack of enforceable rules and an absence of auditing.
-   This situation will continue unless auditing that is both widespread and truly effective is undertaken from now until the foreseeable future.
-   Mere lip service regarding auditing will not suffice; significant new funds must be committed now so that truly effective auditing may begin immediately.
-   Any ACP failing to comply with OBS policy must face a real and credible risk of suspension or loss of accreditation.

Jim Steeves, BA, B.Eng., P.Eng., MBA
freecourse.ca
565 Edison Avenue
Ottawa, Ontario, K2A 1V5
Phone: (866) 729-4521
E-mail: support@safetyafloat.ca

cc:
-   Hon. Jean Lapierre, PC MP, Minister – Transport Canada
    Telephone: (613) 991-0700
-   Gerard McDonald, Director General, Marine Safety –Transport Canada
    Telephone: (613) 998-0610, E-mail: mcdonag@tc.gc.ca
-   Patricia Sommerville, Project Manager – Transport Canada
    Telephone: (613) 991-2277, E-mail: sommerp@tc.gc.ca
-   Daniel Haché, Manager, Office of Boating Safety – Transport Canada
    Telephone: (613) 990-5887, E-mail: hacheda@tc.gc.ca
-   André Begin, Chief, Operator Competency – Transport Canada
    Telephone: (613) 990-4826, E-mail: begina@tc.gc.ca

RESPONSE TO DISCUSSION PAPER ON
CSA 2001 – REGULATORY REFORM PROJECT:
COMPETENCY OF OPERATORS
OF PLEASURE CRAFT REGULATIONS

PREAMBLE

The main challenge facing Transport Canada is that its Accredited Course Providers are not effectively audited or regulated and it is because of this lack of supervision and absence of enforceable rules that the Operator Competency Program remains plagued with problems. This situation will continue unless the rules are given teeth, and auditing is implemented that is both widespread and truly effective. Mere lip service regarding auditing will not suffice; significant new resources must be committed now so that truly effective auditing may begin immediately.

TEST ADMINISTRATION

Testing environment
Under the Operator Competency Program (OCP) boaters may challenge the Operator Proficiency Exam without first obtaining instruction. Providing challenge tests in various public venues is extremely profitable and the core business of many course providers is challenge testing (they have little or no interest in providing training). To meet and test as many boaters as possible, challenge test booths can be found in a variety of questionable venues such as boat shows, sports shows, cottage shows, RV shows, hunting & fishing shows, shopping malls, fairgrounds, and parking lots. freecourse.ca fully supports Transport Canada’s proposal that accredited course providers (ACPs) be required to administer tests in an appropriate environment and we recommend that the Department introduce minimum standards to eliminate unacceptable venues such as noisy boat show, shopping malls, and parking lots.

Ban on testing in private residences
Under the proposed ban, although a licensed professional engineer can sign Canadian passport documents at a private venue, she may not supervise an operator exam under the same circumstances. Also, under this rule a course provider can presumably still deliver a formal course of instruction at a private venue but now he or she cannot then administer the test. It is not the location of a test that should be a concern, what is important is:
1.   That the person challenging the test, through experience or study, is prepared; and
2.   That the supervisor is honest.

freecourse.ca supports the decision that a private residence is no longer an appropriate environment for a person to challenge an operator exam (but we propose an exception be made for licensed professionals and persons eligible to sign passport documents). Many of our testing agents are licensed professionals but many are not. One of our agents, for instance, has no professional qualifications, but both the Northern Alberta Institute of Technology (NAIT) and the Southern Alberta Institute of Technology (SAIT) regularly engage him to supervise exams at his home in Prince George. These exams are for graduate- and post graduate-level courses leading to university degrees in disciplines such as engineering.

Online Testing
Because of dishonest practices by online exam providers, potentially hundreds of thousands of boaters hold a PCOC yet are unable to pass an operator exam. Further, the large numbers of boaters tested by online exams (and thus removed from the market) has reduced significantly the numbers of boaters interested in-class instruction. The market impact of online exams may be remedied readily by banning online exams immediately. Because of the high numbers of testing agents and eligible proctors available (several in virtually every Canadian community) there is actually little need for online exams. In those few instances where a real need exists, such as in remote communities, the same service that is provided by online exams (i.e. remote access to a testing service) can be provided using printed exam materials forwarded to a verified proctor.
If online exams are to be allowed to continue, then their impact should be curtailed; this can be done quite simply with two small changes:
1)   Make the exam an open book exam to be completed in four or five parts over a period of a few days; and
2)   Limit availability of this service to those boaters who have a credit card that matches the name that will appear on the PCOC.
Alternatively, the Transport Canada can take over the provision of all online exams. This can be done easily by letting any interested course provider participate in a TC-operated online exam system. This is a viable solution; in one fell swoop the OBS can:
-   Eliminate controversy surrounding the provision of online exams.
-   Eliminate variations in pricing.
-   Centralize data collection, which will eliminate price gouging on replacement cards and make it easier for boaters to replace lost or damaged operator cards.
-   Generate revenues to support safety education efforts.

Longer Exams
This is a wonderful idea. freecourse.ca fully supports a longer exam; preferably 50+ questions in length. This is perhaps the single most important reform that Transport Canada can make. This single reform will make it harder for boaters to guess their way through challenge exams and create more demand for real providers to provide real courses.

Standardised Exams:
Another wonderful idea; the exams used by some CPs are too easy. freecourse.ca fully supports a standardised exam to ensure that all course providers and challenge test providers use assessment tools of equal difficulty. We caution, however, that measures will be needed to encourage course providers to ensure that these exam materials do not enter the public domain. Reportedly, in the past at least one course provider was caught circulating its exam materials to the public (so that their exam would be the one preferred by boaters considering whose test to write).

ACCREDITATION OF COURSE PROVIDERS

Course Manual
We are concerned with low-quality content and unnoticed errors that go out to the public in some course manuals but we do not recommend that Transport Canada take over creating course manuals. To do so will:
- Encourage more low-quality potential course providers to seek accreditation and, in the long run, reduce the quality of training available to the public.
- Reduce the diversity and innovation in training materials that has arisen from healthy competition between competent course providers; and
- Reduce the need for course providers to keep themselves up to date or to improve their educational materials.

freecourse.ca believes that the ability to at least create a course manual should remain a basic requirement of accreditation. Some potential course providers cannot or will not create a high-quality manual and providing them with a ready-made manual will not change the fact that they are sloppy educators who should not be in the training business (and who may simply be interested in the challenge testing business). Producing a manual for them, thus speeding them on their way toward accreditation as a challenge test provider does no favours for the public. Such a move will, in fact, encourage more low-quality entrants into the testing market. We further propose that course providers be allowed to correct and improve their course manuals without loss of accredited status for that manual as is now the case.

Course Protocol
freecourse.ca fully endorses the requirement of a course protocol. We recommend that a protocol would be required to include: a course syllabus, a copy of the in-class presentation, copies of in-class handouts, and copies of teaching aids used. The protocol should also specify the duration of the in-class course, and the maximum class size. Please note that dishonest course providers can obtain these materials from accredited course providers, modify them, and use them as their own to obtain speedy accreditation. We would like to receive guidance on this subject.

Instructor Qualifications
freecourse.ca endorses in principle the requirement that providers must present an instructor’s qualifications; we would like to receive guidance on minimum standards for acceptable instructor qualifications.

Instructor Training
freecourse.ca endorses the requirement that providers must create both a lesson plan and manual for instructor training. But we do not believe that this will improve the quality of training available to the public; dishonest course providers can obtain these materials from accredited course providers, modify them, and use them as their own to obtain speedy accreditation. We would like to receive more information and guidance on this subject.

Test Protocol
freecourse.ca endorses the requirement that providers must draft and submit a testing protocol. We would like to receive more information and guidance on this subject. To inform our work in this area, we encourage Transport Canada to create a model or template testing protocol.

Internal Audits
freecourse.ca endorses the requirement that providers must conduct internal audits. We would like to receive more information and guidance on this subject.

Documentation
freecourse.ca endorses the requirement that providers must maintain required documentation. We would like to receive more information and guidance on this subject.

Surveillance and External Audits
This is a wonderful idea. freecourse.ca fully supports Transport Canada’s proposal for external audits of course providers. The main challenge facing Transport Canada is that its Accredited Course Providers are not effectively audited or regulated and it is this lack of supervision and absence of enforceable rules that the Operator Competency Program remains plagued with problems. This situation will continue unless the rules are given teeth, and auditing is implemented that is both widespread and truly effective. Mere lip service regarding auditing will not suffice; significant new resources must be committed now so that truly effective auditing may begin immediately.

RELATED ISSUES

Databank of Questions
The databank of questions should not be carved in stone. We recommend that questions in the databank should be updated periodically to adopt proposed improvements to the wording of questions.

Boating Safety Course Standard
freecourse.ca fully supports Transport Canada’s proposal to modify the Boating Safety Course Standard to place more emphasis on basic safety issues. For instance, a boater does not need to know under which particular regulation(s) certain safety requirements are administered.

National Database of Cardholders
freecourse.ca fully endorses creation of a central record that can be used by accredited course providers to ascertain whether or not a boater has passed an accredited operator exam. This will protect boaters from price gouging by allowing them to obtain replacement cards from any accredited course provider. Creation of this database can be facilitated by having all boaters sign a waiver when they write their test. It can also be done by declaring ACPs to be agents of Transport Canada and that the data they collect is the property of the government of Canada.

ISSUES NOT ADEQUATELY ADDRESSED

New Burdens
While we applaud efforts to reform the OCP, we caution that implementing more rules may have little effect on those course providers that will simply break them just as they do with existing rules. We further caution that honest providers who take the time to develop programs and materials that meet all Transport Canada requirements will be significantly delayed in offering their services to the public. No such burden will delay a dishonest provider who will always be able to obtain the course programs of accredited course providers, modify them, and use them as their own to obtain speedy accreditation. Currently, the OBS does not check to see if course materials submitted for accreditation are merely copied from an accredited course provider. In addition, increasing the administrative burden for course providers with many new costly requirements may not generate an improvement in the quality or accessibility of instruction. In fact, the opposite may occur if these new burdens are so costly that small, honest course providers decide that they can no longer compete. Thus, we recommend that existing and proposed rules be tested to assess their impact on one overall objective:
-   Increasing the number of carded boaters who can actually pass a real operator proficiency exam.
If dishonest companies can copy material and finesse the rules (as they now do with impunity), then these reforms gain nothing. And if higher costs force small outfits to shut down, then these reforms may result in the boater training market becoming further dominated by dishonest course providers, with no improvement in the percentage of carded boaters who can pass an operator exam.

Code of Conduct
We propose that all problems plaguing the OCP stem from the participation of dishonest course providers. A simple solution may be to simply bind all course providers to a code of ethics and conduct, violation of which would result in having accreditation placed on probation. A second infraction would result in loss of accreditation. We recommend that course providers must publicize the code and we further recommend that a reward be offered to the public for information that catches banned practices by a course provider. The course provider would be required to pay for the reward and would have its accreditation placed on probation. A second infraction would result in loss of accreditation.

Class Sizes
We recommend that class sizes be limited to 35 people or less.

Refresher Courses
We recommend that any course provider that is caught offering a refresher course have its accreditation placed on probation. A second infraction would result in loss of accreditation.

Random Audits
We recommend that the date, time, location, and size of any in-class course offered by any ACP must be registered with Transport Canada 2 weeks in advance of the scheduled course date. This would facilitate operating a program of random inspections to catch dishonest ACPs. Any ACP caught offering a course for which no course date was registered would have its accreditation placed on probation. A second infraction would result in loss of accreditation.

Correcting of In-class Tests Onsite
We recommend that all exams offered to the public, either challenge tests or tests following an in-class course, must be corrected at the testing site (on-site) immediately following completion of the test. This measure would improve boater understanding of the rules as well as help prevent the sale of PCOCs to boaters who cannot pass the test. Any ACP caught not correcting tests on-site loses accreditation.

Challenge Exams
The CCG policy allowing challenge tests was based on the supposition that a small percentage of boaters, either through experience or study, are prepared to challenge an Operator Proficiency Exam without first taking formal in-class instruction. Highly profitable enterprises have based their businesses not on training boaters but on providing challenge tests. These outfits are not course providers (CPs); they are test providers. They exist because of the policy allowing challenge tests. These outfits have little or no interest in providing training and do little or nothing to promote formal in-class instruction. Instead, they concentrate their efforts on delivering as many challenge tests as possible, in as many ways as possible, and in as many venues as possible.

Almost one million Canadian boaters now hold a PCOC. The CCG policy on challenge tests assumed that the percentage of “prepared” boaters would be small. But in fact, perhaps more than half of the 1 million boaters certified to date obtained their certification through a challenge test in venues such as boat shows. To suggest that all of these boaters were eligible to challenge the test (i.e. through experience of study, they were “prepared”) is statistically implausible. It is more than likely that most were unprepared (ineligible) and managed to guess their way through a pay-if-you-pass test. Such an exam is not a challenge test, it is a lottery where the participant sees if he or she can guess enough answers to pass, thus producing yet another carded boater who really does not know how to operate a motorboat safely.

Thus, it is not the venue that is important; what is important is that there be evidence that the examinee is a “prepared” person, which is plausible if:
-   The exam is longer (50 questions or more);
-   The boater pays for the exam in advance of writing; and
-   The boater declares that he or she is prepared on the basis of experience or study.

One can forget about whether or not a boat show is an acceptable venue and instead concentrate on what constitutes an acceptable candidate for a challenge test. An acceptable challenge test candidate is the kind of boater originally envisioned by the CCG (i.e. a boater who, from experience or study, is prepared to write the test.)

Pay-if-you-pass Testing
The acid test for a challenge exam should be whether or not the person asking for the test can reasonably be assumed to be a prepared person, where “prepared” means that the boater either through experience or study is prepared to write the test. It is implausible that any significant percentage of the thousands of passers-by who write pay-if-you-pass tests at a boat show are “prepared”. On the other hand, it is clear that when someone calls one of our testing agents to arrange a test date, it is usually because they found our online program of study, they have reviewed our online course, and they are prepared (pass or fail) to pay for the test. To allow pay-if-you-pass testing to continue represents a gap in logic that can be illustrated by this proposition:
-   If pay-if-you-pass schemes are acceptable for exams delivered at boat shows, then they should be equally acceptable for exams delivered online.

Creation of Monopolies
We recommend that Transport Canada examine its policies, practises, and rules to assess whether they may aid the creation of monopolistic market conditions. For instance, a ban on testing in private residences represents a significant advantage to any course provider that can secure exclusive use of public venues for testing. BoaterExam.com, for instance, reportedly sought and obtained an agreement that makes them the sole provider of Internet-based boater tests at Industry Canada-funded Community Access Centres in New Brunswick and Nova Scotia. If such an agreement exists, then BoaterExam.com has obtained a large network of taxpayer supported public venues, all equipped with taxpayer-funded computers featuring taxpayer-funded high speed Internet access. Although we support partially the proposed ban on testing in private residences, we encourage Transport Canada contact the Community Access Program at Industry Canada to question the appropriateness of the exclusivity agreement with BoaterExam.com.

Prevent the Conversion of Safe Boating Guides Into Advertising
Any test provider that affixes advertisements onto Safe Boating Guides should lose accreditation, or lose the right to distribute the guides, or both. Transport Canada should add a border to the Guide with a message prohibiting affixing ads. In addition, a banner should be added the cover of the Safe Boating Guide advising that 1.) The OBS recommends boaters take an in-class course, and 2.) The OBS encourages boaters to look up the full list of course providers at www.tc.gc.ca.

Specify Allowable Signage
Allowable signage should be specified; misleading terms such as “Licensing Canada’s Boaters” need to be eliminated from any materials associated with an ACP.

CONCLUSION

As stated by the Office of Boating Safety, the Operator Competency Program was designed on the assumption that participating course providers would be honest and adhere to both the letter and the spirit of CCG policies related to the program. But this is not the case. The fact is that significant profits may be gained by pursuing questionable practices, and some course providers have proven their determination to use questionable means to make their fortunes. Thus, the Operator Competency Program should either be:
- Supervised by extensive auditing that is truly widespread, continuous, and effective; or
- Completely re-designed to allow integrated learning systems employing open-book tests that do not need to be supervised.

To anyone who has read this entire document, thank you very much for your time and attention.

Sincerely,

Jim Steeves, BA, B.Eng., P.Eng., MBA
freecourse.ca
565 Edison Avenue
Ottawa, Ontario, K2A 1V5
Phone: (866) 729-4521
E-mail: support@safetyafloat.ca