Thank you, Mr. Chair.

Thank you to the committee for having us.

My name is Constance Ramacieri and I'm president of the Fédération québécoise de défense des lacs et cours d'eau. I'm here with Claude Sicard, administrator.

Incorporated in 2022, the federation is relatively young, but it already has nearly 150 members from 11 of Quebec's administrative regions. Its mission is to give a voice to associations and municipalities that are interested in navigation and the protection of water bodies in general.

It was at the insistence of our members that we participated in the last online consultation on the vessel operation restriction regulations, commonly referred to as VORR, and submitted three opinions, which were co-signed by 35 lake protection associations.

We would like to take this opportunity to share with you three observations that are at the heart of our thinking and our commitment to recreational boating.

The first observation is that we must avoid a democratic deficit. I think that this is an important and central issue for any democracy. I have to say that, when we talk about the democratic deficit, we're talking about what it means for small municipalities in Quebec not to have access to federal navigation regulations. I also have to say that when I'm not the president of the federation, I'm a municipal councillor. I'm sure you'll understand that this issue is of great interest to small municipalities in Quebec.

The September 2024 Canada Gazette reported that, on average, Transport Canada receives three applications each year under the vessel operation restriction regulations. At that time, there were 1,104 municipalities in Quebec, 700 of which have fewer than 2,000 residents. There are more than 500,000 lakes in Quebec. Three applications a year will take a long time. We would never suggest that Quebec municipalities want to regulate navigation, but our young federation receives far more than three applications a year.

According to Transport Canada's 2023 impact analysis, it is estimated that local governments would need 2,380 hours to complete a single application under the regulation, at an estimated cost of $100,000. You will understand that the vast majority of small municipalities in Quebec and Canada don't have the kind of resources it takes to make an application to the federal government. Naturally, this discourages local elected officials from availing themselves of the lake protection measures offered by these regulations.

The fact that it is next to impossible for most of Quebec's municipalities to avail themselves of a federal regulation constitutes a significant democratic deficit.

We believe it is Transport Canada's responsibility to ensure that local authorities can access the benefits of federal regulations without delay, undue hardship, or restrictive costs.

That is the first observation.

Our second observation is that threats to the environment must be recognized as the main driver of a restriction. The modernization of the vessel operation restriction regulations must be undertaken from the perspective of environmental protection. While security and peace of mind issues remain important, environmental threats and their consequences are increasingly serious. For example, several bodies of water, particularly where human activities are more intense, show signs of accelerated eutrophication, that is, accelerated aging.

Although the degradation is multifactorial, there are numerous scientific studies linking some boating activities to the significant effects observed on water quality. We talked about it, and we will continue to talk about it. We could send you the 2017 study on Lac Noir. It clearly demonstrates the link between navigation and water quality. This study is co-signed by Rosa Galvez, who in her spare time is a senator in the Parliament of Canada.

The federation believes that the updated vessel operation restriction regulations should incorporate the recognition of environmental threats as the primary driver of a restriction and that, consequently, it must be accompanied by a review of the allocation standards in order to prioritize responses to an environmental emergency. You're as familiar as we are with environmental emergencies, whether it be the risk of introducing aquatic invasive species, the frequency of cyanobacteria outbreaks or the protection of threatened or vulnerable species.

The third observation is that responsible government leadership is needed. We wanted to talk about the Vermont example, but it came up on Tuesday. So we decided to talk to you about the economic impact. This was also discussed on Tuesday, but we would like to share with you some economic impacts that are less recognized—