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Industry Self-management

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This issue seems to have dropped dead quickly without too much interest. I have been away for a few days as we did appear at the committee hearings on 02 May and when the minutes are ready we will post the link for anyone interested in reading them.

It was a very interesting excercise. I have been a helicopter engineer for more years than I care to remember but was there in the capacity of our fixed wing company to fight against SMS for 703 operators, unless there is continued and growing TC oversight, rather than self regulation.

We were engaged with MPs and knowledgeable people for three days and I rather suspect that Bill C-6 is in some trouble. At the very least, it is now to be considered for amendements.

We wanted to make several points as a 703 operator and I add below our brief presentation to which the committee has asked us to provide much more.





Here is our brief.



Thank you for the opportunity to speak here today. We must apologize in advance if it seems we have little documentation to present for we only recently found out that our request had been granted.


What we have to offer you is our own experience and frustration in dealing with the present regulatory system.


My name is Kirsten Brazier, and this is my partner Gerry Whalen. Together we own and operate DaxAir – an Air Taxi Service Service operating under CARS 703 and an Approved Maintenance Organization. We presently operate a Beech 18 on floats. Our work involves tourism, service to the northern communities, and transporting trades and utility people to remote areas.


We are representative of many small operators located across the Country who do similar work, and as we stated in our letter to the committee, the most under represented and most affected by Bill C-6.




Prior to starting our company both my partner and I have had experience in operational management positions, so we were both familiar with navigating through and understanding the regulations. While we do feel the CARS were a hand-me-down from 705 and not specifically tailored to 703 the regulations in general are for the most part fair and logical.


It wasn’t until we began the process of certifying both our AMO and Air Operation, and later doing work for other companies, that we began to see major discrepancies between the CARS and how they were being interpreted and applied by Transport Canada.


In certifying our own company we wanted a clear and concise set of manuals that met the CARS – the standard which we must meet in order to have the ability to operate. Because the manuals are legal documents, we did not want the extra liability and confusion from unnecessary policies and procedures We feel that there is no such thing a lesser or greater standard in the CARS – one either meets or does not meet the standard.


Other operators were interested in our approach and asked for our help in ridding themselves of excessive and unnecessary policies and procedures in their own manuals. There seemed to be a general confusion over what the actual standards were.


We discovered that individual inspectors and various regions had different interpretations of the regulations, and accordingly had differing policies to deal with these interpretations.


We discovered that the regulations were not being applied equally and fairly across the system.


When we tried to resolve our concerns as they came up, we discovered a complete lack of due process with Transport Canada. The existing complaint resolution system is ineffective, inaccessible and lacks an independent arbitrator.


We also discovered there is no protection in place for operators who are often bullied by individual inspectors or in some cases departments, to meet individual and regional policies not required by law.




When we started our company, we both agreed we would do our best to abide by the standards and operate safely and responsibly. We knew we were going to have a tough time because of the state of the industry we are in, where cutting corners is common practice.


We are all faced with rising costs and a declining market, so to compete, many Operators continue to overload their airplanes, cut rates and push weather – basically getting more done for less. While this “get more done for less†philosophy may be attractive to the customer, who must pay for the services offered, what the customer doesn’t understand is the risks they are taking by supporting this attitude. This only serves to tighten the market further.


As an example, in our second year of operation DaxAir was faced with this type of choice when one of our customers gave us an ultimatum – either carry the loads he wanted, or he would find someone else who would. Since we refused, he found another operator.


We find ourselves in the position that many others have come to - either cut corners to survive and compete, or go out of business.


While we expected a few challenges in establishing our company and operating principles, we also expected that our “doing it right†approach would be supported by Transport Canada. We have found this is not the case.


In trying to understand why these conditions exist, we began reaching out to other operators across the country and discovered that there were similar problems in many areas and others were concerned that nothing was being done. Most of these operators are afraid to come forward for fear of reprisal from Transport Canada. In speaking publicly about these issues, we too are afraid of reprisal based on our experiences with Transport Canada.


Speaking as a 703 operator we feel that a Safety Management System is a valuable business tool. However, given the state of 703 as we described it, we feel there are root problems with 703. Until they are rectified the air taxi sector is not ready for SMS. The culture of safety cannot be legislated.


Our research has shown that Transport Canada is using sanitized statistics to support their safety claims as we pointed out in our letter of April 22. Transport Canada is telling us we have the safest aviation system in the world. They said this same thing 10 years ago in the SATOPS final report. Yet many of the same issues discussed in that report continue to exist today.


If we are really concerned about safety, and truly want to become the safest country in the world, then we need to start sharing information with a view to discussing and learning from our mistakes.


Instead of sensitizing, and restricting safety information such as the Service Difficulty Reports, Transportation Safety Board (TSB) accident and incident reports, and the CADORS (Civil Aviation Daily Occurrence Reporting System), we need make this information more accessible in its entirety, with industry so we can learn from it. At present, this information is difficult, if not impossible to obtain from Transport Canada and the TSB who continually cite privacy issues as a reason not to make the information available.


As far as we’re concerned, the day an operator receives the right operate, and provide services for the public, they become accountable to the public, to the government, to industry, and to themselves for the way they operate.




In closing, there are many issues we would like to discuss to support our claim, but time being a limiting factor, we have prepared the preceding statements as issues of priority that we as a 703 operator feel must be addressed.


We feel that given a set of clear and concise regulations to follow, and given fair and equitable application of existing regulations by Transport Canada, the industry will by default become safer.


Thank you.





Gerry Whalen (carholme)



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