Interpretation Policy
Interpretation Policy
An interpretation policy is an overarching document that outlines the commitments, practices, and tools to be applied by a department or agency when providing Canadians and businesses with information and guidance on regulatory obligations to be met. It also identifies the conditions under which written responses to questions will be provided.
Agency Context
The Canadian Transportation Agency (Agency) is an independent, quasi-judicial tribunal and economic regulator. It makes decisions and determinations on a wide range of matters involving air, rail and marine modes of transportation under the authority of Parliament, as set out in the Canada Transportation Act and other legislation.
As such, the Agency applies rules of natural justice and affords a fair opportunity for applicants and stakeholders to be heard.
This Interpretation Policy clarifies expectations and increases predictability for the many Canadians, particularly businesses, who must seek permission from the Agency to either conduct a regulated activity or be exempt from it, or must meet other regulatory requirements.
Predictability
Plain language commitment
The use of plain language in developing regulatory guidance and information can help avoid ambiguities and facilitate greater awareness and understanding. Making regulations and compliance requirements easier to understand reduces the administrative burden on Canadians and businesses in particular, who might expend unnecessary resources to interpret regulations (including paying third-party experts). The Agency is committed to using plain and clear language in developing guidance and providing interpretation.
The Agency launched its new Web site on June 4, 2014. The site has a completely new information architecture and navigation structure, developed through extensive user testing. Its content has also been fully reviewed and, in some cases, restructured in collaboration with subject matter experts from across the Agency. The result is user-friendly and clear content that is easy to find.
The site features plain language information, organized in a simple and intuitive way – all based on comments from its stakeholders and clients. Each page also features an online feedback button, which allows site users to provide instant feedback on the site as they browse through it.
The Agency is in the process of systematically reviewing all its public-facing content – from forms to guidance documents – to ensure it is provided in as plain language a format as possible.
To assist, the Agency has drafted plain language training modules for its employees. These drafts will be finalized and launched Agency-wide next fiscal year.
Providing Guidance and Building Awareness
The Agency is committed to consistent internal and external communication on compliance requirements and interpretations. As such, a number of publications such as application guides, guidelines, codes of practice, interpretation notes, and other resource tools are available.
Responding to Questions
The Agency welcomes your questions, comments and suggestions. You can contact the Agency by e-mail, mail, telephone or fax and it will address your concerns as quickly as possible, and usually in the same method as you contact the Agency or in the method you request, such as in writing.
The Agency has set in place high service standards to ensure that it provides efficient and transparent service. Each year, it publishes its performance results against these standards in its Annual Report. The Agency's published target is to answer 85 percent of client inquiries within five business days.
Service
Service Commitment
Excellence in service is expected by Canadians and is central to the Values and Ethics Code for the Public Sector.
The Agency is committed to deliver a reliable, professional service to businesses, stakeholders and Canadians in the area of interpretation.
The Agency’s service standards are based on and reflect our current Performance Measurement Framework. The Agency welcomes feedback in relation to posted service standards, and each year, we publish our performance results against these standards in our Annual Report.
Service Accountability
The Agency is committed to seeking feedback from stakeholders in regards to client service, which is one of the key priorities of the Agency. To gauge its success as a client-centred organization, the Agency has developed and implemented a comprehensive, multi-year client satisfaction survey program. Since its launch in 2009, the program has generated valuable feedback from transportation service providers and users which have informed initiatives to improve the services the Agency provides.
The Agency encourages you to share your views on our service. The Agency welcomes all comments and suggestions on what it has done well and how it might improve.
Staff training
The Agency is committed to ensure that our staff have the necessary skills and technical knowledge to provide quality service and accurate regulatory guidance.
The Agency is building on its efforts and successes to maintain a sustainable, expert workforce. The implementation of workplace communication training for employees supports this objective.
Stakeholder Engagement
Commitment to Stakeholder Engagement
Stakeholder engagement and meaningful consultation are long-standing policy requirements of the federal government. The Agency is committed to engaging stakeholders, as appropriate, when developing, reviewing or refining practices and materials for providing information and guidance on regulatory compliance and answering questions.
Stakeholder Engagement Practices
Through consultations, the Agency gains a greater understanding of the perspectives of a wide range of citizens, industry, stakeholders and experts and therefore develops more informed and effective services and service delivery for Canadians.
To support this goal, the Agency has developed "best practice" guidelines to assist its employees in holding transparent, structured and accessible consultations with clients and stakeholders. The Agency also strives to provide feedback on comments received, so that stakeholders and clients are aware of the manner in which their input was considered.
In addition, since its launch in 2009, the Agency's client satisfaction survey program has generated valuable feedback from transportation service providers and users that have informed initiatives to improve the services the Agency provides.
Improvement
To facilitate understanding, awareness and compliance with its regulatory approvals and to inform further improvements in the interpretation of its services, the Agency consulted with stakeholders via the Agency's website and through targeted e-mails to frequent applicants of the licensing process and of the wet-lease, code-share and blocked-space arrangements processes to assess the effectiveness of current interpretation practices.
Licence and Financial Requirements Forms and Guides
The Agency has developed new licence application and financial requirements forms and guides with the aim of simplifying the licensing application process and further clarifying the requirements for air carriers:
- Canadian Air Carrier Licence Application Guide;
- Licence application form for Canadian carriers;
- Financial Requirements Guide for Canadian Air Carrier Licence Applicants;
- Non-Canadian Air Carrier Licence Application Guide; and
- Licence application form for non-Canadian carriers.
The changes were made after the Agency conducted a comprehensive review of its licensing application process, including considering comments the Agency had previously received from industry and industry associations. Results of previous client satisfaction surveys also called for improving the clarity.
When it released its new guides in 2014, the Agency reached out to frequent applicants of these processes to inform them of the new guides and forms and of their benefits and solicited their comments and opinions on the effectiveness of the new guides with respect to ease of understanding and facilitation of the application process.
Feedback confirmed that stakeholders are overall quite pleased with the ease of comprehension of the new guides. Constructive feedback was received regarding the forms, and was generally related to the ease of use.
Wet-Lease, Code-Share and Blocked-Space Arrangements
The Agency also improved the application process for the approval of wet-lease, code-share and blocked-space arrangements in order to make client interactions more efficient and transparent.
To facilitate the efficient processing of these applications, the Agency recently created two new guides and application forms to aid applicants:
The Agency conducted targeted consultations and provided advance copies of the guides and forms to frequent applicants of these processes. The Agency received feedback on the effectiveness of the guides with respect to ease of understanding and facilitation of the application process.
Feedback confirmed that stakeholders are overall quite pleased with the ease of comprehension of the new guides, and some editorial refinements were incorporated to finalize the guides. Constructive feedback was also received regarding the application forms, generally related to the ease of use. The majority of the suggestions were incorporated.
Improvement Priorities
The Agency is committed to continuing to receive and address feedback as appropriate with respect to the above-mentioned application forms and guides, and with respect to any of our interpretation and guidance materials.
This will be achieved by way of monitoring application trends and engaging stakeholders in periodic surveys and targeted consultations, the outcomes of which will be posted on the Agency website by March 31, 2017.
Additionally, the Agency is currently exploring moving from on-line forms to Web-based forms. All comments received from users of the on-line forms will be considered in the development of the Web-based materials.
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