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Hello all, Since this forum seems to be the most likely way to reach the broadest spectrum of people in the shortest period of time, I thought I would post on here to gauge support for a petition to be presented to the Civil Aviation Regulatory Committee (CARC) before January 31st, 2013. As everyone is aware, unless they are living off the grid and refusing to follow any news of the outside world, Transport Canada decided to review and update the Flight and Duty times regulations a couple of years ago. They formed a committee of stakeholders and met in excess of a dozen times up until quite recently. I attended some of these meetings and all I can say is that the airlines and the airline unions seem to be getting what they want and appear to more or less be in agreement. Unfortunately, helicopter operations have been lumped in with the airlines, and every other mode of flight, so we are looking at radical changes to how we do business. Anyone, all along during the process, that protested the way things were going were accused of not being for "safety". Even now when I read news articles about what is going on the union leaders (who seem to really have the ear of the press) all say that every passenger in Canada deserves the "same level of safety", which I think we are all in total agreement on. The crux of the issue is that we are not in the airline business. Duty time to us is not the same as duty time to them. We fly low altitude and generally only work Day VFR. Much of my duty time over the years has been spent fishing... or napping... or taking pictures... Duty time in the airlines is spent going through security, completing reams of paperwork, sitting trapped in the front of what really is just a giant bus, or waiting for scheduled departure times. I am not denigrating anyone's profession, just stating the obvious. We are not in the same business. Where I am going with this is to say that I believe a misconception exists within the minds of the regulators, the airline personnel (management and labour), and the public that anyone that flies performs the same job as everyone else that flies. Flying an airliner is very much like driving a bus. When you factor in longer flights (YVR to YYZ for instance) the pilots are most closely related to longhaul truckers than to bus or taxi drivers. Fatigue is a real factor in these types of jobs. Sitting in that seat with nothing to occupy your hands, feet and brain is numbing. I think the job that most closely resembles a helicopter pilot's duties is that of a heavy equipment operator, particularly someone running an excavator. So much depends on the hand-eye coordination and the motor skills of the operator or pilot. An airplane (of any size) doesn't require anywhere near the "attention" a helicopter does. This causes a pilot to stay engaged and really does reduce fatigue effects. It is far more tiring to sit around waiting to fly than it is to actually fly a helicopter in my experience. Are there any reports of fatigue causing incidents or accidents within the heavy equipment world? I honestly don't know but that's where I would start to look if I was with TC and wanted a model that was close to the hours, shift and type of work performed by helicopters (obviously I am not talking about scheduled helicopter operations, or EMS, or those types of jobs that make up less than 10% of helicopter operations in Canada). To compare a VFR helicopter operation to an airline is to completely miss the boat on the salient points of comparison. Helicopters and airliners both use the air for their medium of locomotion. There the similarities start to diverge and have scant relationship to each other. I do not believe that any good will be served by choosing a model that works for the airlines and applying it to Day VFR helicopter operations. I know some will disagree with me so I want to propose we take action as an industry with regard to these new proposals. During the Working Group deliberations the airline union representatives pointed out several times that helicopter pilots were not represented during the process. The fact that there were five helicopter pilots there made no difference to them because we were all management, or had been appointed by management or, in the case of Fred Jones of HAC, had been "tainted" by association with management and ownership. I found this offensive but you really are powerless when you stare down the barrel of the union gun with the Chair of the Working Group also being the President of that union. There is strength in numbers for sure! During the recent HAC conference the Director General of Civil Aviation, Martin Eley, was kind enough to attend and listen to various concerns from the helicopter industry. He stated that one of the problems or weaknesses in the process was that there was no representation for helicopter pilots. Essentially without a union or an association helicopter pilots have no say, regardless of how many individually voice any concern. I'm not trying to resurrect HEPAC or anything of that nature but since this is a specific issue I believe we can take action as pilots to make our voice heard. And since any dissents must be made by January 31st I don't think we have much time. I would like to produce a two part petition that can be sent to Ottawa to represent the voice of the Canadian helicopter pilot community. Many pilots probably agree with some of the recommendations that have been made, but many more I feel do not. I would like to allow both sides a chance to collectively voice those opinions. I think we can produce a petition that allows a pilot to "vote" for rejecting the recommendations as they are, so that we don't end up with an unworkable structure that will impact us for many years to come. The 2nd part of the petition would be to allow those who like the changes to express their opinion as well. I would like to capture the demographic of respondents to either side of the petition so we can relate it to industry sector. I feel that a pilot with 20 year's experience who is now flying EMS would probably welcome a lot of the new proposals, whereas a pilot with under ten year's experience who wants to move drills and fight fire probably isn't interested (these are just examples from conversations I have had with people). I'm sure some will say such a petition is just opinion, which is certainly true, but if that can be ignored why did the opinion of the airline unions hold so much weight? If TC really wanted to know what pilots felt they have the address of every pilot who is keeping their medical current in Canada. How hard would it be to mail a questionnaire that must be completed in order to have your medical validated? There are so many tools at their disposal they have chosen not to use. The purpose of this post is to judge the level of interest in pursuing this further. Please let me know by posting a reply or even PM'ing and we will make the decision quite quickly on going ahead. There are online survey tools that guarantee anonymity (although this vote is just for pilots so a name and licence number would need to be provided but "we" the survey holders would not get to see that) if someone wants to vote but doesn't want their thoughts known publicly, while providing a powerful data collection system that produces relevant and fascinating reports. If we go ahead the petition will likely consist of a summary of the proposed changes, followed by basic questions to help identify what "groups" are for or against, and finally some blunt questions on where you, as a pilot, would like to see things go. Since we are down to the wire on fighting either for or against a proposal that may become law, we won't have the luxury to have pilots describe their own perfect system... and with 2700 pilots (or whatever the current number is) we would likely have 2700 perfect systems! Please let us know and tell your friends to also weigh in. There is nothing else I know of in Canada right now that has the potential to affect your life and career like what is contained in these proposals. HV