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Freewheel

Important - Tc Releases Draft Of New Flight Duty Time Regulations

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All we have to do is lobby TC to creat an ops spec that allows current regulations for us. The fixed wing guys get to work as little as possible and we get to carry on as if we were normal...even if we aren't. It's the only way around this I'm my eyes. We can do 150 now instead of 120 in a month. Why not a similar arrangement?

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I made my submission today raising points about the flight duty period having to include all before and after flight activities, commuting, home base and most importantly that as we attempt to reduce fatigue we increase stress and distraction.

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Remember in all of this, that the dissenting organizations had been making alternative suggestions for to the working group throughout the meeting process from August 2010 to december 2011. Their opinions and suggestions have been excluded from the Working Group final report and the Notice of Amendment.

 

We should look at who the participants were to understand the bias of the end products.

 

The working group had 13 members from different organizations when it was created in 2010:

  1. Co-Chair= Transport Canada
  2. Co-Chair = Airline Pilot's Association International
  3. Air Canada Pilot's Assocition (ACPA)
  4. Airline Pilot's Association (ALPA)
  5. Air Transport Association Canada (ATAC)
  6. Helicopter Association of Canada (HAC)
  7. Manitoba Aviation Council (MAC)
  8. National Airlines Council of Canada (NACC)
  9. Northern Air Transport Association (NATA)
  10. Canadian Business Aircraft Association (CBAA)
  11. Teamsters (Canada)
  12. Transport Canada Civil Aviation (TCCA)
  13. West Jet Pilot's Association (WJPA)

The two Co-Chairs authored the August 2012 Working Group report to CARAC that did not include any dissenting opinions (which it was obligated to do by the terms of reference).

 

In January of 2013, 5 of the Working Group members; ATAC, HAC, MAC, NATA, & CBAA (underlined above) were joined by 4 other associations;

  1. Association Quebecoise du Transport Aerien (AQTA)
  2. Aviation Alberta (AA)
  3. British Columbia Aviation Council (BCAC)
  4. Saskatchewan Aviation Council (SAC)

in writing a dissenting document that disputed the findings and recommendations of the report. They contended that the report and the conduct of the working group did not abide by Terms of Reference, and ignored alternative proposals (which should have been included in 'Appendix 6 - Working Group Member Submissions Following Final Meeting' or 'Appendix 7 - Working Group Member Comments/Dissents'). Both Appendices were empty in the report written by the C0-Chairs.

 

The current complaints brought forward by the dissenting organizations are not arguing for retaining the current regulations. They actively participated in the process to create change. They simply dispute the September 2014 "Notice of Proposed Amendment". They state that the NPA was created by a biased segment of the working group. The process & report on which the NPA is based did not adhere to the Terms of Reference of the Working Group that it pretends to represent and it should be rejected.

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There was an hour long question and 'answer' session with the the TC Director General Martin Eley that was very unsatisfactory. I suspect he was working from briefing notes supplied by his staff and that he had not read the various dissenting documents that have been sent to him. Most of his responses were vague and he left the clear message that TC fully intend to proceed to Gazette 1 with the NPA.

 

I don't believe he was prepared for the type of comments and questions he received. He will be attending the ATAC conference next week in Vancouver and is likely to be taken to task again there at the plenary session on Tuesday. If anybody is going it would be very informative to find out if he changes his tune or is better informed on this issue.

 

Another problem is that the TC Minister Lisa Raitt is in hospital for surgery and is expected to be away from work for an unknown time. So addressing this through political means may be difficult.

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It would be nice to see the media get a hold of the issue, they have the means and ability to hold some feet to the fire and follow-up until someone resigns, responds to, or resolves the issues. Of course since we only represent ourselves and not a few hundred voters per flight, I don't think they (media or politicians) would be interested in the story.

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It is to be expected that within 2 weeks the now ten "Coalition" associations and councils will reaching out to their members to start a publicity and letter-writing campaign (focused on key MP's) to bring this problem out in the open in as public a fashion as possible. The public/government relations firm; Temple Scott and Associates, has been retained to assist in this process.

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CARAC was listening. Sorry TC and ALPA. "One size doesn't fit all". Curious to see what industry specific rules they come up with moving forward

 

http://www.labour-reporter.com/articleview/25084-small-airlines-exempted-from-pilot-fatigue-rules-after-lobbying

 

Thats an interesting report Freewheel.

 

It looks like TC actually listened to the pilots and companies and appear to coming up with a compromise. I think most clients can work their schedules with a 12 hour duty day and most companies don't need their pilots working 42 days in a row. Maybe a 28 day cycle and 12 hour duty days would be a compromise. Perhaps 5-7 days off after 28 days, or something like that would still work relatively well for seasonal pilots trying to make a buck. Thoughts?

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