- Florida Professional Paddlesports Association
- P.O. Box 1764, Arcadia, FL 34266
- 800-268-0083, 863-494-4391 fax
October 20, 2005
Re: Canoe and Kayak Registration
Dear Brevard Board of County Commissioners:
The Florida Professional Paddlesports Association (FPPA), on behalf of its 60 professional business members who offer paddling opportunities to the public across the state of Florida, would like to express its strong opposition to the registration of canoes and kayaks.
To properly consider whether the registration of canoes and kayaks is warranted, there should first be an understanding of how registration would affect Florida paddlers, businesses and well as individuals. Please refer to the attached documents from the American Canoe Association (ACA), the FPPA, and Professional Paddlesports Association (PPA) regarding canoe and kayak registration. The FPPA concerns echo the points made by the ACA and FPPA members have added additional concerns.
Many Florida paddlers have contacted FPPA and expressed deep concern about canoe and kayak registration.
These paddlers feel that the passage of canoe and kayak any registration proposals would result in paddlers shouldering an economic burden that is disproportionate, and would force them to pay fees to an agency that lacks the understanding, ability and desire necessary to serve the recreational and safety needs of paddlers.
The
FPPA has already expressed its willingness to work with the Florida Wildlife
Conservation Commission (FWCC) to build a better relationship with the
paddlesports community and to help address canoe and kayak related safety
issues.
Please consider the concerns and questions the members of FPPA and other
paddlesport enthusiasts have attached. For all these reasons, the FPPA
requests that you do not support canoe and kayak registration. If you have
any questions about the FPPA position on this matter, please do not hesitate
to contact me at 863-494-1215.
Sincerely,
- Rebecca Ann Bragg
- President
- Florida Professional Paddlesports Association
- 863-494-1215
- canoefla@desoto.net
- Received via e-mail on October 14, 2005 from the American Canoe Association (ACA)
- ACA Position on Canoe and Kayak Registration
The ACA is generally opposed to the registration of canoes and kayaks. While we recognize that states have an incentive to register canoes and kayaks, and also acknowledge that paddlers do impose some burden on boating administrators, we believe most legislative and regulatory proposals are excessive because the costs imposed on paddlers would be disproportionate to the services paddlers receive. Here are some of the reasons the ACA opposes registration:
- Canoes and kayaks do not present the same enforcement burden and costs as do other craft. Canoes and kayaks are not capable of breaking speed limits or putting other waterway users at risk. Canoes and kayaks do not require expensive access ramps like larger craft, they do not emit hydrocarbon pollution into our waters, and because they are quieter, they are less likely to disturb wildlife and waterfront homeowners. States should encourage paddling as a non-polluting, healthy, mode of transportation and recreation.
- Vessel registration typically requires the display of 3" registration numbers on the hulls of each vessel. Paddlers sometimes have trouble making these numbers fit on their craft, and also may have trouble making them stick for long periods of time because of the chemicals used in the manufacturing process.
- State boating agencies often resist suggestions that canoe/kayak registration dollars and the resulting revenue received from the Wallop-Breaux Trust Fund be set aside specifically to serve the needs of the paddling community. Paddlers are reluctant to support registration without assurances that state agencies would spend canoe/kayak registration monies on legitimate paddling-related needs.
- Many paddlers own numerous canoes and kayaks in order to accommodate the wide variety of water conditions and paddling objectives. Avid paddlers often own in excess of ten canoes and kayaks. Requiring registration of each canoe or kayak could easily result in a typical paddler paying far more for registration than other boaters.
- In addition to the registration fees, the multi-digit registration numbers often will not stay affixed to canoes and kayaks for more than a year and must be frequently replaced. In some states, registration will also result in the assessment of various local fees. Canoeing and kayaking are boating activities that are available to people of modest income, and the accumulation of used or new canoes and kayaks can stretch over many years. For these paddlers, the costs associated with registration can suddenly make owning/using these canoes or kayaks unaffordable.
- States with canoe and kayak registration unwittingly encourage their resident paddlers to go outside the state to paddle. Testimonials from paddlers in Ohio indicate that they will more frequently paddle in neighboring states to avoid registering all of their canoes and kayaks. This means that a state that enacts canoe and kayak registration can expect to lose some recreation-related revenue to neighboring states. Canoe/kayak registration requirements can adversely impact tourism revenue by discouraging out-of-state paddlers from visiting.
Federal law only requires states to register motorized vessels. Many states have also required that sailboats above a certain length also be registered. Beyond that, the decisions become much more arbitrary. Canoe and kayak registration seems to be largely driven by the realization that there are a significant number of canoes and kayaks in operation. State boating agencies associate those large numbers with revenue potential and the need and demand for services such as law enforcement and rescue personnel.
Registration categories are often established by vessel length. In the non-motorized realm, using boat-type and length to determine which craft should be registered is problematic. Canoes and kayaks come in a wide-variety of lengths, and any length-based registration law is likely to require some paddlers to register while ignoring others. Also, registering canoes and kayaks raises the question of whether such registration requirements are fair unless surf skis, sail boards, rowing shells, surfboards, rafts, and wave skis are also required to be registered.
What
is the ACA position on canoe/kayak registration?
The ACA believes that states should encourage and support canoeing and
kayaking as healthy, non-polluting activities. Most canoe/kayak registration
proposals that ACA has seen to date are onerous plans that would have the
result of discouraging participation in canoeing and kayaking. These
registration proposals typically reflect a lack of understanding about
paddlesports and a lack of research into the potential impact on paddlers.
State boating agencies should have a clear record of collaborating with, and serving the needs of the paddlesports community prior to seeking funding support from paddlers. Registration or any other legislative proposal affecting paddlers should be the result of collaboration between paddlesports clubs and organizations and state boating officials. Paddlers as well as state boating agencies should oppose registration efforts that are not the result of such collaboration.
The ACA will judge the merits of any registration bill that results from such collaboration on a case-by-case basis. ACA will oppose any proposal that fails to address the following issues:
- The merits of the registration proposal must outweigh the bureaucratic and financial burden to paddlers;
- The proposal must enjoy widespread support from paddlers in the state and be endorsed by a majority of the state's paddling clubs;
- The proposal cannot require the placement of traditional boat numbers;
- The proposal should have a fee structure that reflects the lower enforcement, access, and pollution costs associated with canoes and kayaks;
- The proposal should ensure that registration is convenient and affordable for paddlers that own multiple canoes and kayaks; and
- The proposal must include adequate guarantees that the funds derived from registration will be used to effectively serve the needs and interests of the paddlesports community.
- Above sent by:
- Paul Sanford, Director
- Stewardship and Public Policy
- American Canoe Association
- 7432 Alban Station Blvd. Suite B-232
- Springfield, VA 22150-2311
- Phone: 703.451.0141 ext. 20
- Fax: 703.451.2245
- www.americancanoe.org
- Canoe & Kayak Registration-FPPA Talking Points and Concerns
- Florida Professional Paddlesports Association (FPPA)
- In 1995 or thereabouts, a national initiative to fund wildlife conservation called “Teeming with Wildlife” started. The intent as we understand it was to add an excise tax to wildlife viewing related items such as backpacks, hiking boots, bird seed, canoes and kayaks. As of 2005, this initiative is still active and looking to gain momentum and FWCC is the main contact for the State of Florida. Is this another source of funding for FWCC from canoes & kayaks? Would this excise tax be levied against motorized vessels? Canoes and kayaks would pay registration plus an excise tax?
- Paddling as nature-based tourism is a clean and family oriented industry. Tourism is the number one industry in the state of Florida with nature-base tourism a huge component. Paddling promotes nature-based tourism, paddling supports tourism.
- As business owners we pay tangible tax on each and every canoe and kayak we own. We pay tax.
- Most outfitters and paddlers are property owners in their county of business and/or residence and therefore pay property tax which goes to support county boat ramps/accesses and parks.
- 99% of the outfitters buy and use fuel for their buses and vans and therefore pay fuel tax. Customers drive to the outfitters and therefore pay fuel tax. Therefore paddlers are contributing to the fuel tax distribution that FWC receives.
- As rental operations we collect sales tax on every rental therefore contributing to the economy of the state. We collect sales tax on each and every rental except tax exempt groups.
- We pay sales tax on our equipment. Most outfitters buy new canoes and kayaks each year to replace old equipment. Lifejackets, boat cushions, whistles, and paddles are usually replaced on an annual basis. As outfitters we continually support the boating industry and the economy of the state.
- Many paddlers have fishing licenses, they just choose to fish out of paddlecraft instead of motorized boats. Most paddlers are already contributing to FWC through fishing licenses. Paddlers fish, paddlers pay.
- Many outfitters already have to pay to use County Park accesses.
- Many outfitters already have to pay to use State Park accesses.
- Many outfitters already have to pay to use Division of Forestry accesses.
- Many outfitters already have to pay to use NPS accesses.
- Most outfitters do not use FWC boat ramps. There are only 200 in the state. Examples are: in DeSoto County, the larger outfitters do not use the one FWC boat ramp next to the DeSoto Marina. In Hardee County the FWC boat ramp is called “Bloody Bucket” because it is used as dumping ground for dead animals. Once a year the outfitters use that ramp because they cannot use the County ramp in Zolfo Springs because of a festival. Both ramps are not in the best of shape.
- Paddlers use conventional boat ramps but not by choice. Existing concrete ramps damage canoes and kayaks. Paddlers try to avoid standard ramps. Canoes and kayaks don’t need expensive boatramps. Canoes and kayaks do not “power load” at boat ramps so there is no danger of them causing damage to a boat ramp.
- Canoes and kayaks do not pose any sort of threat to manatees, sea grass beds, other boaters, or to the environment or boating in general.
- Many paddlers own numerous canoes and kayaks in order to accommodate the wide variety of water conditions and paddling opportunities. As being required to register each of these vessels could easily result in paddlers paying far more for registration than other boaters.
- Registration would require some sort of sticker. Stickers will not adhere to the “dimpled” finish of many canoes and kayaks. Stickers would not be visible on many kayaks because of the design.
- The manpower to remove and add stickers to large fleets of canoes and kayaks on an annual basis would be cost prohibitive including the accompanying paperwork. Titles taken by the state years ago will have to be retrieved. Many canoes and kayaks don’t even titles.
- Canoe and kayak retailers would need a “dealer” tag/sticker to be able to “demo” canoes and kayaks.
- If canoes and kayaks are to registered, what about bikes? Both are recreational modes of transportation and exercise. The only difference is that bikes use roads, sidewalks, and paths that require public funds to build and maintain. Canoes and kayaks utilize existing waterways that require little maintenance and that already exist.
- The proponents of canoe and kayak registration like to point to the number of canoe and kayak fatalities as a rationale for canoe and kayak registration. As the members of FPPA have not experienced or seen proof of these numbers, we do not hold that canoeing and kayaking fatalities or accidents are as dramatic as the boating industry would lead us to believe in the state of Florida.
- Canoe and kayak registration is being pushed by motorized boating interests who do not represent the paddlesports industry or individual paddlers.
- Compiled by
- Rebecca Ann (Becky) Bragg, President
- Florida Professional Paddlesports Association (FPPA)
- P.O. Box 1764
- Arcadia, FL 34265
- 863-494-1215
- 863-494-4391 fax
- www.paddleflausa.com
- www.canoefla@desoto.net
- Professional Paddlesports Association (PPA)
- In October 2002, the PPA Board passed the following resolution:
- "At this time PPA
opposes canoe registration legislation but would like to participate with
[the National Association of State Boating Law Administrators] NASBLA in
creating a model bill. PPA will work with NASBLA to create of a model
bill for canoe and kayak registration that takes into account key issues
to the paddlesports community, including stickering, multiple boat
ownership, and funding for paddlesports programs."
The purpose of this resolution and the creation of a model bill would be to draw a line in the sand with regards to what issues our industry would have to have assurances on in order for us to support a bill. No model bill has been drafted as a result of this resolution. For the time being, PPA remains opposed to canoe and kayak registration.
Matthew E. Menashes, Executive Director - Professional Paddlesports Association, Inc.
- 7432 Alban Station Boulevard, Suite B-232
- Springfield, Virginia 22150
- Phone: (703) 451-3864
- Fax: (703) 451-1015
- matt@propaddle.com
- www.propaddle.com
- Brevard County Commissioner, Ron Pritchard's response to FPPA Letter of Opposition to Registration
- "Boaters pay a registration why shouldn't you...after all, you're using the waterways and all it's amenities...it's not a question of "taxing" it's a matter of paying your fair share...additionally, last year in Florida 21% of all boating fatalities involved canoes/kayaks/row boats - all un-powered..." via e-mail, Oct. 21,2005 from Ron Pritchard, Chairman, Board of County Commissioners, Brevard County
- Note: Mr. Pritchard's numbers on boating fatalities is skewed to make the numbers look worse that they actually are. Mr. Pritchard is also past president of Citizens for Florida Waterways, a motor boat group pushing for registration.