I did'nt send in a penny for my upgrade from PAL to RPAL, (and if u're right that just makes me feel better.. hehe), but on a more serious the section says
"If you have previously held a firearms licence under the
Firearms Act, do not enclose a fee" and the PAL is a firearms license under the firearms act. The one you're lookin at is the last para in the first column on page 3, and that is only for "new" and not for upgrading. The guy testing me also told me that it wont cost me anything to upgrade... I took the test in BC