Aviation associations issue open letter to Transport Minister over fatigue management

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Representatives of nine aviation associations have issued an open letter to Transport Minister Marc Garneau on the subject of proposed fatigue management regulations. The text of the letter is below.

Dear Minister,

Four Canadian pilots’ unions have spent a large amount of money to create a colourful website with many fine graphics, bullet points and an earnest call for support from the public. Boiled down, it’s got a clear message that the current fatigue regulations are unsafe, and must be changed. Canadians and Parliamentarians alike are being steamrollered. And it’s time that all the facts came out.

a Summit Air Dornier 228 overflies an idyllic rural scene.
Key aviation leaders are concerned about how proposed fatigue management regulations will impact smaller commercial operators. Here, a Summit Air Dornier 228 overflies an idyllic northern scene. Jason Pineau Photo

We are a coalition of nine regional and national aviation associations, representing commercial air operators from across the country who are trying to push back against the biased information propagated by the airline pilots’ unions.

We represent the aircraft operators who get lost in the noise–commercial aircraft operators flying where scheduled service does not, regional and northern services providing lifelines to hundreds of communities and hamlets, search and rescue, medevac and more. We land on gravel, ice and water, as well as paved runways, with our turboprops, helicopters and jets. We go where people need us, when they need us. We are part of the infrastructure that makes Canada, with its vast size and small population, a major trading nation and the envy of the world.

We are not ultra long-haul scheduled airlines.

The pilots’ unions have lost sight of this. In order to make a point with dubious facts they have tried to convince you that any commercial flight requires the same type of fatigue rules as long-haul international flights, with their oft-repeated mantra “a pilot is a pilot is a pilot.” But, repetition doesn’t make it true.

The truth is that anyone flying an aircraft for a purpose other than touring around with friends and family needs a commercial pilot’s licence–even if it’s someone who takes people into a seasonal fly-in fishing site in northern Ontario, supplies a northern hamlet or fights fires.

Just as there are specialized licences for different vehicle drivers, there are many types of pilot’s licence. Transport Canada recognizes that a “pilot is not a pilot is not a pilot,” providing nine different types of licences, with nine additional ratings. If the simplistic refrain of “a pilot is a pilot is a pilot” were valid, your department officials could save themselves a lot of time by simply issuing a single one-size-fits-all airline transport pilot licence to everyone.

Of course, that would be absurd, like forcing a car driver to certify to drive semis, school busses and tow trucks. But it is no more absurd than where we are today with the proposed new fatigue management regulations. These rules are designed to manage fatigue on flights that can last 12 hours or more, but Transport Canada wants to impose the exact same rules on the fly-in fishing camp pilot.

Transport Canada’s direction is even more inexplicable because this one-size-fits-all regulatory approach defies its own entrenched policies in the Canadian Aviation Regulations, which consist of regulations tailored for different aviation segments.

Transport Canada has also turned a blind eye to the measured and well-received Canada Transportation Act Review panel recommendations of 2016 which state that regulations should be developed to fit different segments of the aviation community. Transport Canada has refused to step back from this blunt instrument approach and released its intended regulations at the end of March 2017. Ironically, even the unions are unhappy with what Transport has proposed.

This is the inevitable outcome of a one-size‐fits-all approach: it is a compromise that, at the end of the day, fits no one. Not the small businesses and communities who would be hurt by unnecessary over- regulation, and not the unions which are now demanding more regulation. The only thing this approach seems to accomplish is to simplify the amount of internal work for regulators, who only have to produce one single set of regulations.

But, as everyone knows, there is no such thing as simple answers to complex questions. Is our safety being compromised because Transport Canada does not have the motivation to get it right? Canada already has one of the safest commercial aviation systems in the world–but these proposed new regulations will not make it any safer for anyone–only more complicated for pilots and costlier for the traveling public.

Minister, we have a solution: press “pause” and then when really ready, “restart.” Yes, this process has been going on for seven years and everyone is fatigued‐with‐fatigue. But it was a flawed process from the start, with weak or false assumptions leading to even worse proposals and decisions. It is difficult to admit that we’ve been heading down a wrong path, but that is what we have done. If nothing changes, the result will be something that no one wants: one regulation that doesn’t fit our diverse Canadian commercial aviation needs; fewer flights and costlier service to many small communities, and a shortage of pilots.

The unions don’t have a monopoly on safety. Lives are precious to all of us. Safety is the first priority for all of our associations, and the primary concern of every aircraft operator, many of whom are pilots themselves, flying their own aircraft. To suggest otherwise is deliberately misleading. Canadians deserve better than that–they deserve the whole truth. They deserve to fly safe, with appropriate regulations on fatigue.

Minister, we stand ready to continue to work with your officials until we can all be sure we have it right.

Signed by:

Les Aalders, executive vice-president of the Air Transport Association of Canada

A.D. (Bram) Tilroe, director, Alberta Aviation Council

Jean-Marc Dufour, president and CEO, Association Quebecoise du transport aerien

Heather Bell, chair, British Columbia Aviation Council

Rudy Toering, president and CEO, Canadian Business Aviation Association

Fred Jones, president and CEO, Helicopter Association of Canada

Ed Ratzlaff, executive director, Manitoba Aviation Council

Glenn Priestley, executive director, Northern Air Transport Association

Janet Keim, president, Saskatchewan Aviation Council

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