[Amgine]

No, a set of rules must cite the authority on which it is based, and it is on that authority that it may be challenged. If they were going to use a ministerial patent, then that's what they would cite. Clearly their legal advisors believe they're more likely to survive a challenge on 56(1)(b) than on their patent alone.

I personally know of several world cruising Canadians who have hauled back to BC in order to refresh their cruising kitty. One of them was anchored in Nanaimo last summer, had been for a year or so, but was planning to head off again this spring. Another boat I met while anchored there was a commercial charter boat, fairly heavily booked for day charters and weekends during the season but likely spent the winter months nearly abandoned except for maintenance visits. Who am I to say that isn't a 'cruiser'?

Sure, I'd love to show up at my destinations with a large anchoring field empty of other boats sometimes. But I, as a visiting United Stater in Canadian waters, am not at all bothered to tie up at the visitor's dock if the anchorage is full - after all, I'm the guest. I sure don't want to push people out of their homes just for my convenience. And I happen to like interacting with other sailors.

Besides, the docks are cluttered with unused boats as well; I don't hear anyone saying they should be impounded if they look abandoned and the owners do not respond to the port within 30 days. Or that boats in marinas must maintain holding tank logs surrenderable upon any demand, or apply for permission to stay within the port if staying there more than 14 days in 30, or any of the other half-dozen strictures which are going to be applied to anchored boats.

I'm all for getting rid of derelict boats by some fair and reasonable method. This doesn't seem to be it. On the US east coast many PAs have simply outlawed anchoring within the port, but offer very reasonable moorages in tight mooring fields. Seems a much better solution, though I don't know how it might work in practice in BC.