Important - Tc Releases Draft Of New Flight Duty Time Regulations

[skullcap]

You are most correct that we need to get information into CARAC. I have sent mine in. It will be up to people with the correct information(bogus science that is) and positive outcome as a goal to provide the regulations as required.

[Brian Jenner]

You are most correct that we need to get information into CARAC. I have sent mine in. It will be up to people with the correct information(bogus science that is) and positive outcome as a goal to provide the regulations as required.

 

Ya never know, maybe if enough individuals send in cards and letters with recommendations that have potential, maybe they will set up a helicopter table - see you there!

[Skidz]

I think this thread illustrates how broad the spectrum of opinions is on the proposed FDT regulations. I certainly hope there will be some amendments, otherwise no one will be happy...

[Skidmark]

I think this thread illustrates how broad the spectrum of opinions is on the proposed FDT regulations. I certainly hope there will be some amendments, otherwise no one will be happy...

I'm sure when its all over and done with there will be amendments, exemptions and ops specs in everyones Ops manuals. Who knows FDT's regs may even resemble something similar to the shifts pilots are currently working.

[Skidz]

Here's the latest from the owner's club regarding the proposed changes to FDT:

 

President’s Message
Flight & Duty Time Update – The Time to Speak Out to Your MP is NOW

 

As you can imagine, there has been a flurry of activity by the Commercial & Business Aviation
Community in the wake of Transport Canada’s most recent proposals for Flight & Duty Time
reform. HAC, and our other nine Allied Associations have formed a Coalition to oppose the
current proposals. Virtually the whole Commercial and Business Aviation community are standing
Shoulder-to-Shoulder on this.

Thank-you to those companies who have offered up testimonials on the impact of the proposals
- we have received dozens, and we will be including many of them in our Coalition submission to
the Minister of Transport.

We have been working with the Minister’s office to emphasis the fact that these proposals will
NOT improve safety, but also to emphasis their catastrophic impact on our businesses, if they
were to move forward in their current form. Our efforts for now, are being focused on urging
Transport Canada resolve our differences through a constructive dialogue - but with the other
Coalition Associations we have crafted an Advocacy Campaign that could see this regulatory
proposal become a campaign issue running in to next year’s Federal Election. We do not believe
that this “Business-Friendly government” wants a fight with Business running in to an election
year.

We are urging our Members and Associates to contact their local MPs and customers on the
phone, by email, in writing - or smoke signals. Invite them to make their views known. If they plan
to do it in writing, ask them to send a copy to fred.jones@h-a-c.ca. Make your views known! We
are also suggesting perhaps that you may also want to use the following key messages and
speaking points in that dialogue. (see below)

The Flight & Duty Time issue will be briefed by HAC’s President & CEO in the Air Taxi Committee
meeting on November 6, prior to the Convention, and in the New Industry Roundtable session on
November 8, just prior to the session with Martin Eley, Transport Canada’s Director General.

 

 

 

 

Key Messages and Speaking Points

1. The Notices of Proposed Amendment (NPAs) to the Flight & Duty Time Regulations presented by Transport Canada on September 15 2014 will cripple the Helicopter industry in Canada, and there is little evidence that they will enhance safety. A number of the changes will erode safety. Initial indications are that they will increase crew costs by 35% - these cost increases will naturally be passed along to customers.

2. Ten aviation Associations have formed a coalition of National and Regional Associations from across Canada. The “Coalition of Aviation Associations and Businesses Opposing Transport Canada’s Flight & Duty Time Reform Proposal”.

 

This coalition’s Association members include the Air Transport Association of Canada; the Association québécoise du transport aerien; Aviation Alberta; the British Columbia Aviation Association; the Canadian Aerial Applicators Association; the Canadian Business Aviation Association; the Helicopter Association of Canada; the Manitoba Aviation Association; the Northern Air Transport Association; the Saskatchewan Aviation Council.

The Coalition represents the interests of virtually all the Canadian National and Regional Associations representing the interests of Commercial and Business Aviation in Canada, today. The National Airlines Council of Canada (NACC) – representing the interests of Air Canada, WestJet, JAZZ, and Air Transat, is not a member of the Coalition.

3. The current proposal will radically affect our operator-members, but virtually all of the
customers and communities they serve, including:

 

• Northern, Remote, and Aboriginal Communities – many of whom rely on air transportation to provide food and medical care – often using air as their only form of access
• Scheduled domestic air operators of all sizes
• The Resource Sector of the Canadian economy
• The MEDEVAC community
• The Oil & Gas Industry in Canada
• Utility companies that rely on air transportation to service and repair the power grid
• Businesses that depend on the on-demand segment of the commercial aviation community to conduct their operations in Canada and internationally
• The mining community
• The tourism industry across Canada
• Wild-Fire Fighting Agencies from across Canada

4. The NPAs will radically distort the commercial landscape for non-unionized commercial and business aviation operators in Canada, by imposing elements of certain airline collective bargaining agreements on many other segments of the Canadian aviation industry. Furthermore, in cases where the tasks can no longer be done by Canadian operators at all, or where increased costs have made them uncompetitive, American Part 135 operators will, in many instances be able to operate the international flights originating in Canada - resulting in jobs and economic benefits moving out of the country. The NPAs appear to the Coalition to be ONLY suitable for scheduled international CAR 705 airline operators represented by the NACC and their unions. The current proposal will move the current regulations much closer to the legacy collective agreements of the NACC carriers, and will serve as a barrier to entry for other low-cost carriers in this market. Air Canada has just this week announced an unprecedented 10-year collective agreement with ACPA.

5. The Department appears to be unprepared to resolve the problems with the NPAs through a constructive dialogue with the coalition of 10 National and Regional associations opposed to the current proposal – virtually the entire Canadian Commercial and Business aviation community, with the exception of the National Airlines Council of Canada. The rest of the aviation community is united in their opposition to the current proposals. During the 18 months of the Fatigue Risk Management Working Group’s deliberations and in the intervening 21 months since the Final Working Group report was tabled, the concerns raised and the proposals advanced by the signatory associations have been ignored. Since the conclusion of the Working Group, the department has refused to re-engage with the Coalition members to explore industry segment-specific solutions – better suited to their operations. It is unacceptable that Transport Canada has allowed Union pressures and unwieldy collective bargaining agreements to drive new regulations, applicable to all sectors.

6. Our Canadian Aviation Regulations were designed to “fit” different segments of a diverse Canadian commercial aviation industry. The aviation community in Canada has evolved to serve a large and diverse country – often between communities and points that are separated by remote uninhabited landscape. The operators of small aircraft, or operators who serve the on-demand market or remote communities cannot be expected to implement complex “Crew Scheduling” departments to simply accommodate bureaucratic airline-type regulations – their work is not nearly as predictable. These companies do not operate from “hubs”, and they often have unpredictable and seasonal demands for their services and for crews. The current proposals simply do not fit their businesses – or their customer’s needs.

7. The Working Group’s Co-Chairs were biased in favour of the interests of the Large Scheduled International Passenger-carrying operators represented by NACC, and they were unprepared to consider proposals that would contemplate the unique operational circumstances of other Canadian industry segments. Our requests to Transport Canada to consider industry segment-specific solutions have been repeatedly rejected. The NPAs are one-size-fits-all.

8. The Transportation Safety Board has not produced reports or recommendations that suggest that the current Flight and Duty time regulations are unsafe, and no Risk Assessment has ever been conducted by Transport Canada to suggest that these NPAs would enhance safety in any way.

9. Transport Canada has relied heavily on controversial European recommendations, the new US FARs, and ICAO SARPS – all of which were intended to apply to large airlines and in the case of the SARPs – to large airlines conducting international flag operations.

10. None of the proposals advanced by operators during the course of the Working Group’s deliberations found their way in to the NPAs – even in a modified form. The interests of the operational community have been completely ignored, notwithstanding the interests of the operators represented by the NACC and their unions.

11. The fatigue-related science - except on a very few points - is ambiguous and has been selectively referenced in support of the proposals that the Department has advanced. There has been little, if any scientific research into the effects of fatigue on CAR 702, 703, 704, and 705 Canadian domestic operations under the current regulations.

12. The NPAs fail to address the issue of “commuting airline pilots” who frequently travel long distances before commencing duty, although the proposals appear to preserve the ability of most unionized airline pilots to work 80-85 hours each month. Airline pilots, who commute from home across multiple time zones to report for duty, will be required to “acclimatize” for days, at their own expense before commencing Flight Duty.

13. The proposals will aggravate the current shortage of experienced flight crews in Canada at all levels of our industry, and will drive operators to hire flight crews off-shore or park their aircraft. As the pool of experienced pilots continues to dry up, there could be degradation in safety.

14. The current proposals are so extreme, they will erode the currency of many on-demand pilots in Canada, who may be flying a small number of hours, but in the context of a full Duty Day. These pilots will be forced to take time-off after a very few days, or operators may be driven to double-crew the aircraft.

 

 

 

[oil pressure]

I would think that reducing the ability for an operator to potentially task flight crew to 42 consecutive 14 hr days would indeed, very much increase safetyin reducing risk.. Keep in mind HAC is very operator oriented and obviously anything that increases operational costs and logistical hurdles would get their, and those they represent, attention.

This all seems a little reactive in that, had the operators put as much effort into providing a solution over the last year or two, as they did reacting to the potential changes (petitions etc.) we may be farther ahead.

The new proposal seems extreme to some....which may be the case...however, again, the current is not good enough and change is needed. NOBODY understands fatigue management issues and their uniqueness to each individual than those of us managing it (pilots and engineers) in the field day to day. We all know consecutive 14hr days are ridiculous, let alone 42 of them in a row.

I agree with Skidmark in that all of this will work out....im sure when regulation said you could only fly 120hrs in a 30 day period (not withstanding the ops specs to increase) and had to have 3 off in 30 and 13 off in 90, the logistics seemed overwhelming for operators. With a few ops specs it was workable....the same will happen here...operators will have to work to get variations etc that will accommodate the uniqueness of the VFR utility helicopter market in Canada.

This is not about money, customer inconvenience, or logistical difficulties. This is about mitigating potential fatigue issues amongst flight crew and possibly allowing crew to make better, sound decisions that hopefully could reduce the risks of day to day operations....I think that trumps the horrible sounding by products.

[Freewheel]

...operators will have to work to get variations etc that will accommodate the uniqueness of the VFR utility helicopter market in Canada.

Ohh will they ever have to work...

 

Good luck trying to explain the uniqueness of the VFR helicopter market in Canada to TC. They aren't having of that in the rule making process. What makes you think it will different when trying to get "variations"

The person you deal with will likely have a strictly airline background and mentality. Maybe we can ask them about carry-on baggage requirements, cargo restraint, how to log flight time in a helicopter, passenger safety briefings, cabin safety card requirements and low flying permits.

On second thought maybe we better not ask. You probably won't believe the answer you get (and it will likely be entirely different than the answer I get).

[Brian Jenner]

[quote

President’s Message

Flight & Duty Time Update – The Time to Speak Out to Your MP is NOW

 

....

We have been working with the Minister’s office to emphasis the fact that these proposals will

NOT improve safety, but also to emphasis their catastrophic impact on our businesses, if they

were to move forward in their current form. Our efforts for now, are being focused on urging

Transport Canada resolve our differences through a constructive dialogue - but with the other

Coalition Associations we have crafted an Advocacy Campaign that could see this regulatory

proposal become a campaign issue running in to next year’s Federal Election. We do not believe

that this “Business-Friendly government” wants a fight with Business running in to an election

year. ...

 

I can already imagine front page news across he country

 

CONSERVATIVES ABANDON BUSINESS FRIENDLY POLICY

 

Conservative Government is forcing a marginal increase in costs, on Consumers of Canadian helicopter services, just to save lives by adhering to international standards for pilot flight and duty times. The new rules include allowances for any operator to essentially make their own rules, based on necessity and their ability to assure an equivalent level of safety but many operator representatives claim that can't be done! They add that cost increases in the helicopter industry will be the first step toward another Great Recession

[Skidmark]

TC is up against the wall after Lac Magantic. Duty times and SMS are under severe scrutany, rightfully so. How willing do you think TC is to back down on this issue? Wouldn't CBC love to do a story about how truck drivers and train conductors operate under tighter, safer regulations and guidelines than all of the aviation industry. On the world stage TC has been left in the dust on these issues. Look at what the FAA has been up against with regards to pilot fatigue after numerous accidents where fatigue was a contibuting factor, such as the 2009 flight 3407 crash that made international headlines. How willing do you think the regulators are to back down on this side of the border because some owners are worried about extra plane tickets and hiring extra crew.

[Brian Jenner]

TC is up against the wall after Lac Magantic. Duty times and SMS are under severe scrutany, rightfully so. How willing do you think TC is to back down on this issue? Wouldn't CBC love to do a story about how truck drivers and train conductors operate under tighter, safer regulations and guidelines than all of the aviation industry. On the world stage TC has been left in the dust on these issues. Look at what the FAA has been up against with regards to pilot fatigue after numerous accidents where fatigue was a contibuting factor, such as the 2009 flight 3407 crash that made international headlines. How willing do you think the regulators are to back down on this side of the border because some owners are worried about extra plane tickets and hiring extra crew.

TC is not the problem, it's the politicians. The "business friendly Conservatives" faced with the towering menace of electionearing on the part of industry associations must be shaking n their boots. Afterall there must be at least a couple dozen customers that will be up in arms over the cost of new FDT rules - what the heck lets go for a gross - and then multiply by 10 so as to inlude their minions - plus operators, their families and managers - this thing could involve as many as 5000 votes, if everyone on the calamity side of the issue is interested enough to care and provided the other parties aren't promising even more strigent FTD rules or in favour of gun control.