Rising Costs Leads ABCFP Council to Increase Registration Renewal Fees
ABCFP Council approved a one time 30 per cent increase in registration fees that will take effect starting this 2023 registration renewal cycle. The increase equates to about $178 for an RPF and $167 for an RFT.
This increase is necessary for the ABCFP to continue to meet its statutory duties and build a stable foundation for the future. The council has delayed increasing registration fees (other than for inflation) since the Professional Governance Act (PGA) was adopted in November 2018 and instead, the additional workload has been absorbed within existing funding and staffing. After four years, this has become untenable.
Why is an Increase Needed?
Significant cost increases have been incurred as a result of the regulatory burden created by the PGA, a triple increase in the number of complaints, and the highest inflation in recent history.
Compounding rising costs, the revenue the ABCFP collects for RPF and RFT registration renewals has been falling for years as late career professionals retire from professional practice. The retirement rate has outpaced the number of new forest professionals entering the profession. Today approximately 50 per cent of practising registrants are over 50 years of age.
ABCFP staff have tried to contain the financial impact of the PGA and falling revenue from registration renewal. Since 2019, we have raised $1.1 million via additional non-fee revenue streams to offset the near $1.5 million one-time PGA transition costs incurred to date. We have also found numerous ways to contain costs and generated more than $350,000 in annual savings to help offset the $658,000 estimated to be needed each year for new, permanent PGA-related workload.
The ABCFP is not alone in shouldering the financial impact resulting from the PGA; all regulators falling under the Act have found it necessary to raise registration fees, some staged over multiple years and others scaled to the size of the number of registrants.
How Will the New Funds Generated by the Increase Be Used?
The fee increase will result in visible, operational changes in 2023. New staff will be hired to support complaints, which have tripled since the PGA was brought into force. These new staff will also assist the ABCFP in being more proactive on the compliance front, identifying potential areas of practice infringement especially within the hiring practices of municipalities and local governments. We continue to work with our regulatory partners in biology, applied science technology, and agrology to ensure the reserved practice rights of foresters are observed and respected.
The ABCFP will invest in technology to both improve efficiency and contain the costs of using outdated software. In 2023, we will launch a new website that will be much easier for current and prospective registrants to find critical information. We will move to a new registrant database that will make transactional activities, such as registration renewal or applications for new registrants, easier to complete and that will provide a more stable system to host the online learning modules being used by the 768 trainees working right now to acquire independent practice rights.
Moving forward, the ABCFP cannot rely solely on fees from RPF and RFT registration renewals to fund the range of activities required and/or expected to be undertaken. Council has directed the CEO to both continue finding business savings and to create a three-year plan to identify and develop other revenue streams that will help stabilize the future of the organization.
How Did We Get Here?
As we embark on our 75th year of operation, the ABCFP finds itself ushering in a new era in the regulation of the practice of professional forestry. An era with heightened public and government expectations for increased regulatory oversight; expectations for more demonstrable evidence that the professionals caring for and managing our forests are competent to do so, and are being held to account for their ethical and professional conduct. An era propelled by the government’s review in 2017 of the effectiveness of the professional reliance model in natural resource management.
The public and government have maintained our ability to self-regulate and to manage BC forests using a professional accountability model but in exchange has asked more of the forest profession.
Providing these additional public assurances incurs higher operating costs for the forest profession; it also makes us a stronger regulatory body and better poised to maintain the credibility of forest professionals as trusted stewards guiding the care and use of BC forests in the public eye. The ABCFP is a non-profit organization and legislation directs the standard to which we must regulate. A core level of resources are required to regulate at these mandated standards, and our registrant base is below the threshold to be able to keep registration fees any lower.
The public and government alike need a healthy, strong forest profession. The government’s forest management legislative regime is implemented and maintained by forest professionals. There is growing public need for wildfire mitigation and community protection, and for climate mitigation. More than ever, the knowledge, expertise, and experience of forest professionals is needed to meet these challenges.
Forest professionals are well known for problem solving skills, their ability to navigate conflicts, and create shared solutions – expertise demonstrated on the ground in the forest, and in offices and boardrooms.
The ABCFP has a proud past, and will continue to have a bright future. Forest professionals have shown a commitment to working in the public’s interest, and Council recognizes they are carrying the increased burden of the professional regulatory model.
The ABCFP will continue to offer a monthly payment plan for registration renewal fees. More information is available on the ABCFP website on the Registrants/Steps to Renew page. Note that application for monthly payments must be submitted by November 15.
A backgrounder with additional information follows. Please direct email inquiries about this change to email@example.com.
Background on Registration Fee Increase
What new workload pressures and obligations has the PGA generated for the ABCFP?
One time costs to transition the ABCFP operations from operating under the Foresters Act to the PGA legislative regime have totaled almost $1.5 million between 2019 and 2022. These PGA transition and implementation costs include:
- Legal service fees for bylaw development, regulation & Act consultations;
- Policy development to fill gaps and align programs with PGA requirements;
- Designing new standard operating procedures to realign internal operations;
- Registrant and public communication products to provide information on changing obligations under the PGA;
- Developing registrant training products; e-courses, webinars, and practice guides to support understanding of new obligations under the new Code, about practice rights and other changing professional responsibilities and expectation; and
- Technology improvements and supports; revamping an online register, developing online CPD reporting, and updating learning and exam content in the online system used by trainees.
Year-over-year operating costs have increased in excess of $650,000 annually in order to meet the PGA requirements and the standards of good regulation set by the Office of the Superintendent of Professional Governance. The net new regulatory workload with year over year funding needs include:
- New or revamped statutory committees (Audit & Practice Review, Nomination);
- Transition to mandatory CPD reporting and related monitoring and enforcement;
- Formalization of a Practice Advisory Program;
- Bylaw upkeep and new bylaw development;
- OSPG Standards of Good Regulation; responding to OSPG audits on standards, annual reporting requirements;
- OSPG and regulator monthly meetings, participation in Professional Governance Advisory Committee, and OSPG task groups;
- Enhanced reporting and communication standards related to complaints and discipline;
- Shift from reactive to proactive practice infringement monitoring;
- New permanent joint practice panel with applied biologists to manage interplay in professional practice; and
- Technology improvements to support and meet OSPG standards of good regulation and support delivery, monitoring, and reporting of regulatory programs.
Are Other Regulators Under the PGA Raising Fees?
Other regulators covered by the PGA are facing similar workload and cost pressures. For example, the BC Institute of Agrology (BCIA) increased its fees in 2022 by 26 per cent; since the onset of the PGA, BCIA registration fees have increased from $400 to $600.
In 2022 the Applied Science and Technologists of BC (ASTTBC) increased registration fees 16 per cent.
The College of Applied Biologists increased registration fees by over 35 per cent since the introduction of the PGA, while realizing a 33 per cent increase in its practising registrant base.
The average registration fee of PGA regulators is $596 per year.
The average registration fee of natural resource sector (NRS) regulators is $648.
The average registration fee of BC regulators across all sectors is $910.
What Has the ABCFP Staff Done to Contain Costs?
Since 2019, staff raised $1.1 million to offset the near $1.5 million of one time PGA transition costs by successfully acquiring $810,000 in grant funding, revamping some service charges, and increasing conference attendance.
Since the advent of the PGA, ABCFP staff also began seeking ways to contain costs by stopping lower priority work and streamlining existing work. These business efficiency efforts generated more than $350,000 in annual savings and now offset the estimated $658,000 of new PGA driven workload. Examples include:
- elimination of paper-based registration renewal and election options;
- moving to an electronic-payment system;
- renegotiating service contracts;
- scaling back on frequency and cycle of some reoccurring work;
- reducing production of BC Forest Professional magazine to four issues per year from six;
- disbanding and/or combining former committees;
- reducing and replacing in-person meetings with virtual meetings; and
- halting and eliminating association-related activities falling outside the core mandate of the PGA such as providing financial and administrative support to the Canadian Institute of Forestry, providing affinity programs, and supporting the mediation of conflicts between professionals.
Staff have managed the PGA workload within existing operating budgets since the act received Royal Assent in November 2018. This approach compelled innovation and streamlining, and enabled staff to be able to identify workload that was transitional versus a permanent resource capacity pressure. Working this way is not a sustainable, long term operating model. This approach does not leave appropriate capacity to mitigate organizational risks and places too much dependence on a few critical contributors.
Has the ABCFP Considered Eliminating or Relocating its Vancouver Office to Save Costs?
The ABCFP cannot operate at this time without a physical office based on the needs of the business. The ABCFP currently leases a class C office space which is the lowest class of office space, typically defined by an older building, in a less desirable area, and includes buildings often targeted for redevelopment. Including rent, property tax, and building operating costs, the ABCFP pays approximately $150,000 a year for its office space, which is approximately five per cent of our annual budget.
Staff and finance panels have previously considered multiple times the pros and cons of changing the geographic location of the office to generate cost savings – whether in Downtown Vancouver, the Greater Vancouver area, or compared with offices in other larger rural centres such as Prince George, Nanaimo or Kamloops. Consistently these detailed reviews have found no or negligible benefits of making a shift.
The current office lease is set to expire October 31, 2024 and the current contract did not include a renewal clause. It is possible the ABCFP might be able to renew at the same location and avoid the significant moving expense and productivity impacts. However forced to move, the ABCFP would continue to look for the best possible class C office space in Vancouver.
What Other Factors are Driving Increased Operating Costs?
The PGA ‘Duty to Report,’ and related ABCFP Bylaw Code Standard 9 (Reporting) came into force in February 2021. In the six years prior to 2021, an average of five complaints were received each year. With the advent of the PGA and new bylaws, the complaint volume has more than tripled, jumping to 17 in 2021 and exceeding that to date in 2022. This trend is expected to continue as a typical annual volume.
Each complaint received is reviewed and either dismissed, or recommended to proceed to an investigation. Complaint cases that are investigated typically take one to one-and-a-half years to conclude and require a significant amount of time and effort from staff as well as consultant investigators and legal counsel. The cost and time required to complete a case is highly variable depending on the complexity but cases completed since 2015 have cost an average of $33,000 each, excluding staff time.
According to Statistics Canada, as of July 31, the rate of inflation in BC was 8.0 per cent.
Over the past several months, the Bank of Canada has been taking extraordinary steps to control and reduce inflation though the impact of those actions are only now starting to be seen. In its July 2022 monetary report, the Bank forecasts inflation to reduce to three per cent by the end of 2023, and stabilize at the long-term goal of two per cent by the end of 2024.
Over the past decade the ABCFP has periodically implemented inflationary fee increases. The total fee increase over the last 10 years has been 16.2 per cent. The total change in BC’s CPI during the same period was 15.2 per cent.
Aging Capital Infrastructure
The ABCFP’s registration software was adopted in the early 2000s. The software has been extended beyond its lifespan and is no longer supported by the vendor except for security patches.
The aging software incurs high maintenance costs, is experiencing failures, and has limited built in functionality to support the business needs of a regulatory body versus a member-orientated association.
The operations of the ABCFP have become increasingly technology reliant. Most paper driven processes have transitioned to electronic, and technology horse power versus volunteer horse power is now primarily relied on to deliver workload such as administering registration and certification examinations, adjudicating elections, and accepting/processing applications.
How is the ABCFP’s Revenue Being Impacted by Registration Numbers?
Fees collected for registration renewals are the primary revenue source of the ABCFP’s operations.
In 2013, 95 per cent of the ABCFP’s revenue came from registration renewal fees. In 2022, 85 per cent of the operating revenue continues to come from fees paid for registration renewal, primarily fees of RPF and RFT’s.
Over the past seven years, while the total number of registrants has remained relatively stable, the number of full-fee paying, practising registrants has steadily decreased. The number of practising RPF and RFT’s has fallen by more than 800 in the past decade.
Year over year, there are on average:
- 63 fewer practising registrants (RPF, RFT);
- 44 more trainees (FIT,TFT, ASFIT, ASTFT); and
- 33 more non-practising registrants (Ret, LOA).
At current renewal fee rates, the registration trends equate to $52,000 in lost revenue each year. That annual shortfall has been redistributed across the remaining registrants, in addition to any operational cost increases.