Jump to content
Sign in to follow this  
Harmonic_Vibe

Petition To Tc Regarding Flight/duty Time Regs

Recommended Posts

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

  • Like 1

Share this post


Link to post
Share on other sites

HV,

 

I think the first step would be to publish a very short, point-form summary of the proposed changes here. Something like a comparison chart that shows the before and after picture would be best. I've read the HAC memos and stuff, but they're pretty long-winded and, quite frankly, I had a hard time staying focused through all the rhetoric...

 

If you're in any way involved with HAC, don't they have tools to convey information to all their membres ? Shouldn't they be telling their member operators to get the information out to their employees if they're interested in what we the pilot community have to say ?

 

If I were the real cynical type, I'd tend to think HAC isn't too warm with the idea of collecting opinions from the pilot community unless they can control and spin the information to their advantage... ;)

Share this post


Link to post
Share on other sites

I'm not involved with HAC in any official way but I don't detect any attempt on their part to filter or control the information. They have been sending out info to operators for months and also posting on the website. There may be a failure on the part of management to communicate with the line pilots but that wouldn't be anything new! The new proposals are so far beyond what we do now that it's otherworldly. For the record, HAC's position is not to keep the current regs as they are. They have been pushing for changes but nowhere near as the radical changes that the Working Group is proposing.

 

Just a very brief summary of some points from the Working Group proposal are as follows:

 

 

Currently:

 

- A pilot can work 42 straight days of 14 hours duty each day provided they have 5 days free from duty before and afterwards (most companies seem to limit tour lengths to either 28 or 21 days with 14 days off)

 

Proposed:

 

- Option 1 – 1 day off every 8 days with at least 4 days off each 28 day cycle

- Option 2 – “Deployed Operations” allow 5 days off in 20 so a maximum of a 15 day tour could be worked

 

Potential Result:

 

- 2 pilots working back to back tours of 15 days would be required for ongoing projects

- As staffing levels of skilled pilots when the industry is busy are almost impossible now, this will further exacerbate the situation

 

Currently:

 

- There is no requirement for a pilot to record duty hours in order to accumulate them over their rotational tour

 

Proposed:

 

- Pilots would only be allowed to be on duty for 190 hours in 28 days, or 70 hours in 7 days. So in a week they could average 10 hours per day but for their maximum 15 day tour they would only be allowed 140 hours or less than 10 per day

 

Potential Result:

 

- In the summer pilots normally work a 14 hour duty day. The proposals mean that 2 pilots would be required onsite for most jobs between the months of May and October. Winter work wouldn't be impacted too greatly due to short hours of daylight

 

Currently:

 

- Pilots can fly 60 hours in 7 days, or 150 hours in 30 days

- Pilots reset these totals if they are given 5 consecutive days off

 

Proposed:

 

- No weekly limit but duty time already limited to 70 hours so flight time would be much less than this

- 112 hours maximum in 28 days

- No resetting allowed (this means that it’s possible to take 5 days off, come back to work and be limited on hours due to residual from the previous shift)

 

Potential Result:

 

- On some jobs there would be no impact, while others with more flying could (likely) require shorter rotations for pilots. Pilots may need to be swapped out every 12-15 days regardless of allowable tour lengths

 

Currently:

 

- Standard duty day is 14 hours

- 8 hours guaranteed rest per day

 

Proposed:

 

- 13 hour maximum duty day but if the day starts before 7:00 it is reduced further using a matrix

- 10 hours guaranteed rest per day

 

Potential Result:

 

- Probably no impact in Winter flying

- Summer flying, especially on jobs requiring dayshift/nightshift swaps (e.g. diamond drilling) would almost always require 2 pilots

 

The last point is very relevant to my recent experience because we have clients that restrict us to 12 hour duty days. This means that summer drilling requires double crewing. I have yet to find a single pilot that likes this, as they consider it two people doing the job of one. We have had people refuse to work under that restriction which I believe is the likely response of most pilots. Very few pilots want to take days off in a camp.

 

Anyway, that is a brief summation of what may become law if pilots don't raise their voices.

 

HV

  • Like 2

Share this post


Link to post
Share on other sites

So, the impacts can be summed-up as follows:

 

  • Tour duration limits (from 42 & 5 to 15 & 5 w/ travel time included in duty days)
  • Duty day (from 14 hours/day to 13 hours/day with weekly and monthly maximums that would average to less than 10 hours duty per day)
  • Flight time limits (from 150 hours per 30 days or 210 per 42 to 112 hours per 28 days with no resets allowed)

Wow... :o

 

Drilling, heli-logging, firefighting, geophysical, arctic flying. These sectors would be hit very hard. Personally, I like the idea of short tours, but the rest sucks. When you're in the bush, you want to maximize your time and fly your a$$ off.

 

Not too sure I like the idea of split-crewing. Having to re-do all of your adjustments every day and all, and spend even more time "lounging" around camp. <_<

 

Imagine when you fly out to a job with say a survey crew that's planning to spend 12 hours on-site. They'll either have to shorten their work day or the pilot will have to return to base to do the crew change at some point, which would double the cost to the customer. The only positive there is I suppose a$$ time would be reduced considerably. :rolleyes:

 

Where are they gonna find all the pilots required to implement this ?

 

What's forestry's take on these changes ? Has anyone gotten their opinions on the issue ? BCFS, ASRD, OMNR, SOPFEU ? They have a major issue on their hands if these changes go through as-is... No way I'm gonna go on IA contracts if I have to split-crew. Whoever gets the morning shift will be screwed !!! :lol:

Share this post


Link to post
Share on other sites

Could there not be some kind of a loophole with the differences of 702 work & 703 taxi vs. 704 commuter?

That was HAC's suggestion from day one. The EASA rules that were proposed (by the ALPA FDT Committee Chair and accepted by the ALPA President in his role of Working Group Chair) specifically exclude helicopter operations but that didn't seem to matter to those running and/or dominating the meetings. They always fall back on "one level of safety" without really comprehending what that means.

  • Like 2

Share this post


Link to post
Share on other sites

HV I am with you with not agreeing with these proposed changes. As helicopter pilots we don't do long haul work typically. Our day is usually made up of short flying tasks then waiting for the next task to come up. What is the ratio flying hours as compared to sitting time. Has anyone asked that it would be interesting. Personally if I fly 20 percent of my duty time that is on the high side. I used to fly around 80 percent when I flew logs. When I was flying logs we were on a 2 and 2 schedule.More time off less duty hours.In a 30 day period. I think some revisions could be done to the Flight duty regulations but this hack job will not help the industry. This is what i think lets talk lets let transport know . We do not have a united voice but i think a petition would be a start. Steve Schulte

  • Like 1

Share this post


Link to post
Share on other sites

HV I am with you with not agreeing with these proposed changes. As helicopter pilots we don't do long haul work typically. Our day is usually made up of short flying tasks then waiting for the next task to come up. What is the ratio flying hours as compared to sitting time. Has anyone asked that it would be interesting. Personally if I fly 20 percent of my duty time that is on the high side. I used to fly around 80 percent when I flew logs. When I was flying logs we were on a 2 and 2 schedule.More time off less duty hours.In a 30 day period. I think some revisions could be done to the Flight duty regulations but this hack job will not help the industry. This is what i think lets talk lets let transport know . We do not have a united voice but i think a petition would be a start. Steve Schulte

Awesome Steve... Thanks for that... I will find what HAC was proposing and post that too... And I have received a few PM's and also a couple of emails already (and so far no one has told me where to go) so I think we'll start working on the mechanics of the survey/petition. I think it's very important to make sure people feel comfortable that it really is the voice of pilots and not "management" trying to get their way.

  • Like 1

Share this post


Link to post
Share on other sites

Could there not be some kind of a loophole with the differences of 702 work & 703 taxi vs. 704 commuter?

 

 

I don't believe there is any "magic bullet" here. And the sad part is, that we will wake up one morning, and these laws will there waiting for us.

 

It's been going on for a long time, and I believe that HAC is fighting for us all. Maybe not specifically for the pilots, but it will be of a benefit to us anyway (in an around about way) because no operator wants this to happen either.

 

There will be some that will (continue) to say: "I'll make my own deal - always have - always will." - but you won't (read can't).

 

But because pilots can't agree on where to go for lunch, not much chance of getting a common agreement on something like this! (I know this because I hate making lunch decisions...)

 

So whether you like it or agree with it, HAC is the only one anywhere near your corner. Maybe it's time to get more involved with them and see what is happening.

 

If TC and the airlines get away with this - a lot of us will be pretty unhappy...

 

Keith Westfall

  • Like 2

Share this post


Link to post
Share on other sites

Join the conversation

You can post now and register later. If you have an account, sign in now to post with your account.

Guest
Reply to this topic...

×   Pasted as rich text.   Paste as plain text instead

  Only 75 emoji are allowed.

×   Your link has been automatically embedded.   Display as a link instead

×   Your previous content has been restored.   Clear editor

×   You cannot paste images directly. Upload or insert images from URL.

Loading...
Sign in to follow this  

×
×
  • Create New...