The Federation of Ontario…

The Federation of Ontario Cottagers’ Associations (FOCA) respectfully provides the following input with respect to the proposal to amend Ontario Regulation 161/17, Public Lands Act with respect to floating accommodations (ERO number 019-6590 https://ero.ontario.ca/notice/019-6590#proposal-details ).

FOCA is in support of the proposed exclusions, whereby floating accommodations or float homes are not considered as "camping units" and thusly cannot be placed and used for overnight accommodation on water over public land.

FOCA remains concerned about the enforceability of such measures, with respect to being able to reasonably identify what is a floating accommodation and what is not. We would offer that the definitions of floating accommodations as defined elsewhere by Transport Canada be included in the regulation to clarify who is and is not implicated in the prohibition. In the Transport Canada "Standards for float homes and liveaboard vessels in Victoria Harbour", a float home means a structure incorporating a flotation system intended for use or being used or occupied for residential purposes not primarily intended for or usable in navigation and does not include a watercraft designed or intended for navigation." This prohibition should include barges or rafts with residential units or camping facilities.

Further, and without otherwise restricting the right to anchor a vessel which is part of the common law right of navigation and the provisions of The Canada Shipping Act, 2001 or otherwise, FOCA encourages MNRF to include provisions in this regulation related to minimum separation distances from developed shorelines, limits to the number of days that a person can camp on water at one location, and the distance that a person(s) must move their camping unit to a different location.

Respectfully,

Terry Rees
on behalf of FOCA