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Important - Tc Releases Draft Of New Flight Duty Time Regulations


Freewheel

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Skidz, I don't disagree with you that this will increase costs, it will for sure. But as I hinted above MAYBE it's time we realigned the tariff rates to make them more realistic? Why does our industry seemingly keep trying to line the clients pockets instead of our own?

 

Are client expectations of pilot experience unrealistic? Again, I'm not sure, but we all had to start somewhere.... Everyone would love to start with a 1000 hours and our clients would all like pilots with a minimum of 5000 hours, both both scenarios are totally unrealistic, but again, we collectively keep bowing to pressure. Whose fault is that I wonder?

 

Again, I sure don't have all the answers, but like most things in life, there are at least two sides to every story. Sometimes neither side is 100% correct and we have to compromise....

 

 

 

Not my words Cambox. Just publishing Fred Jones message to all HAC members.

 

I agree HAC is overreacting. My concern is how these new regs will be phased in. If its done in one hit, and overnight, customers used to paying for one crew change every four weeks, and used to getting 14 hour duty days every day end up having to pay for twice as many crew changes and get 60 hours per 7 days of duty, how are they going to react ?

 

Yes, everyone will adapt over time, but we as pilots are going to be the ones bearing the brunt of customer angst when these new measures come into effect...

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These proposed regulatory changes are exactly that, proposed. One would hope there will be some more discussions, and some negotiations allowing for changes. It happened once before and was modified. What is disconcerting is the lack of reason and negotiations thus far. Not sure why this has happened.

 

As far as the pilot being the brunt, am not sure but think prior to the time the change occurs pilot's will take a lot of s and a. But after the changes take place they will be no more to blame of regulations than now. If one looks at the multiple segments of the proposed changes there will be major disruptions to all those who are involved not one single element will be unaffected. We all see the changes from our existing point of view and we need to allow these points of view to coexist rather than try to prove one is higher priority than another. From my point of view as a single aircraft single pilot operator it will dramatically change our business as I have done many jobs which take my days worked to a near limit. The rules as described are beyond my comprehension which worries me as how do I describe this to my client. The proposed changes in my view are so convoluted they do not allow for any preplanning of time off or relief and thus how do people accommodate the many fluctuations of jobs and even the fluctuations of an existing job do to weather or fuel etc. Thus the safety will be less, if changes are made with this in mind and some alleviations as the regs do now then they have a chance to be positive but I really doubt that we could rely on a flight duty times program to help plan for upcoming relief or time off if they implement the dogshyte they are attempting to.

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What is disconcerting is the lack of reason and negotiations thus far. Not sure why this has happened.

 

Yves Lemieux, FORMER Associate Director of Operations, Ontario, TRANSPORT CANADA: "the future of aviation safety in Canada depends on open and clear discussions between the regulator and industry"... That is what I like to refer to as paying "Lip Service" to National objectives.

The most significant threat to aviation safety in Canada is that the exact opposit is actually happening. The communication between our industry and Transport Canada is at an all time low. Why? because they choose to ignore us. The culture that exists is quite similar to the culture that existed in a plane on the taxiiwAy in

Dryden, Ontario on a snowy day in 1989. You know the one where two off duty airline pilots and a flight attendant chose not to advise the PIC that a dangerous amount of snow had accumulated on the wings because it wasn't approoriate to second guess the pilot in command. We all know how that turned out.

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These proposed regulatory changes are exactly that, proposed. One would hope there will be some more discussions, and some negotiations allowing for changes. It happened once before and was modified. What is disconcerting is the lack of reason and negotiations thus far. Not sure why this has happened.

 

As far as the pilot being the brunt, am not sure but think prior to the time the change occurs pilot's will take a lot of s and a. But after the changes take place they will be no more to blame of regulations than now. If one looks at the multiple segments of the proposed changes there will be major disruptions to all those who are involved not one single element will be unaffected. We all see the changes from our existing point of view and we need to allow these points of view to coexist rather than try to prove one is higher priority than another. From my point of view as a single aircraft single pilot operator it will dramatically change our business as I have done many jobs which take my days worked to a near limit. The rules as described are beyond my comprehension which worries me as how do I describe this to my client. The proposed changes in my view are so convoluted they do not allow for any preplanning of time off or relief and thus how do people accommodate the many fluctuations of jobs and even the fluctuations of an existing job do to weather or fuel etc. Thus the safety will be less, if changes are made with this in mind and some alleviations as the regs do now then they have a chance to be positive but I really doubt that we could rely on a flight duty times program to help plan for upcoming relief or time off if they implement the dogshyte they are attempting to.

If you haven't submitted comments to CARAC, you should copy and paste what you just wrote and send it in

 

Very few of us have the time to actually sit down and consider all of the consequences, then break down every concern we have for each proposed amendment. I'm sure you have day to day duties that take precedence...especially in such short notice.

 

At least let them know your paying attention and you are concerned.

 

Today is the deadline.

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From: CARAC Feedback <CARRAC@tc.gc.ca>
Date: September 30, 2014 at 7:46:35 AM CST
To: CARAC Feedback <CARRAC@tc.gc.ca>
Subject: Deadline Extension: CARAC Notice of Activity #2014-019 - NPA - Flight Crew Fatigue Management / Date limite prolongée: Avis d'activité CCRAC #2014-019 - APM - Gestion de la fatigue des équipages de conduite

Le français suit

 

Good morning,

 

Due to the numerous requests received for an extension for the comment period on the Notice of Proposed Amendments for Flight Crew Fatigue Management, the comment period has been extended to Friday, October 17, 2014. We thank those of you who have already submitted comments and look forward to receiving more submissions.

 

Bonjour,

 

Nous avons reçu de nombreuses demandes pour prolonger la période de commentaires sur l’Avis de proposition de modifications sur la gestion de la fatigue des équipages de conduite et prolongeons la date limite au 17 octobre 2014. Nous remercions les intervenants qui nous ont déjà fait part de leurs commentaires et sommes dans l’attente de recevoir vos soumissions additionnelles.

 

 

Mélanie

Mélanie Drouin
A/Manager, Civil Aviation Regulations Advisory Council | Gestionnaire par intérim, Conseil consultatif sur la réglementation aérienne canadienne
Transport Canada | Transports Canada
Place de Ville, 330 Sparks Street, AARBH
Ottawa, Ontario K1A 0N5
melanie.drouin@tc.gc.ca
Telephone | Téléphone 613-990-1415
Government of Canada | Gouvernement du Canada

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One interesting thing that stands out to me, is that this esteemed group of people use the FAA and CASA as examples of other aviation regulatory bodies that have employed the "one size fits all" methodology relating to F & D times. What they don't say is that both of those organizations explored that option, but never implemented the practice, deciding instead to set aside helicopter and general aviation operations, and not regulate them in the same manner as airlines conducting scheduled and long haul operations.

 

I have worked in the US alongside other helicopter and fixed-wing fire operations, that have F & D requirements similar to those being proposed that are actually USFS enforced. The most restrictive is the requirement for 2 days off after 12 on, which results in pilots being deployed away from home for periods of up to 4 or 5 months, taking the required days off in the field. This schedule is sometimes sarcastically referred to by the air crew as "12 on and laundry".

 

I also work in Australia, which has very restrictive F & D regulations, unless of course you are involved in firefighting or agricultural operations which are allowed "special dispensation", which grants longer duty periods and greater flight hour limits.

 

I guess my point is that other organizations have examined the one size fits all approach, and decided to treat helicopter and general charter ops differently. I'm not saying we don't need a change, because 42 and 5 is just plain stupid, although I haven't seen that personally for many years. The world won't come crashing down if the new regs are implemented as proposed, but it will be open to abuse, much like the current regs are. Transport needs to grow some balls and actually define where a day off can be taken, and also take the grey area out of the suitable accommodation statement.

 

The thing that really pisses me off though, is the arrogant attitude of the Director General, stating that because helicopter pilots don't have a union or association, we don't have a voice. I call bullshit because when I go and vote in a municipal, provincial or federal election, I don't get asked if I belong to a union. 1 voice, 1 vote, simple.

 

Change is needed. Change dictated by an organization that is obviously being driven by the airlines and is hungry to recover its public image after things like the train disaster in Lac Megantic, is not good for the industry.

 

Kevin McCormick

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I think you may wait some time before the government will regulate where you take a day off "yes Paul you cannot stay in the Cowichan Inn for your time off, you MUST go home". Perhaps not, but am thinking right around when they make drug testing mandatory for folks of welfare, probably the same day they put a tag in your ear to determine which planet you are from....just guessing.

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Now there is a prime example, of the disparity that can arise between an owner(s) and employee(s), depending on the structure and size of the company. It depends on what side of the fence your sitting looking back!!???!!?!

 

I remember all too well, loading an aircraft, and not coming home for 3-4 months and ready to quit upon return....but as an owner, flying my own aircraft, I would have prayed for those kind of tours.

 

Nobodies right.....nobodies wrong....:)

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Beg to differ on the 42 and 5. It's not about lifestyle, it's about the possibility of working 42 days in a row, on duty for 14 hours every day and flying everyday up to 210 hours, then taking 5 days off and hitting it again, and expecting to be at your best. That is silly. Not going to argue about this one small point as it clouds the bigger picture.

 

My point has nothing to do with lifestyle, money or who'd rather do what. We are all individuals with different levels of tolerance; physically, mentally and financially. What I have a problem with is how our regulatory body has gone about proposing new rules while ignoring a significant segment of the industry simply because we don't have an association.

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