NPA 2023-005

COPA is aware of a recent NPA 2023-005 (Minimum Visual Meteorological Conditions for VFR flight in Controlled and Uncontrolled Airspace) that has been circulated by Transport Canada as part of the CARAC process. COPA feels that this NPA as currently drafted poses a risk that it will impose unacceptable changes to future regulations that will impact our ability to fly VFR in Canada and place additional training and currency requirements on pilots.
The COPA Technical Committee has reviewed the proposed NPA and has summarized the following key changes for your informations.
1. Redefining VFR:
Transport Canada is proposing changing the definition of what constitutes legal VFR for both day and night and is proposing a decoupling of VFR flight conditions from a set of defined meteorological conditions and instead coupling it to flight conditions using criteria such as discernible horizon, cultural lighting, and celestial lighting. The term VMC will be removed from the CARs and replaced with a term “VFC” (Visual Flight Conditions) which has yet to be defined. COPA’s concern is that a new definition of VFC may become excessively restrictive and affect what we now consider normal VFR operations.
2. Training:
The NPA suggests addition of multiple new training elements for airplane, helicopter, instructor, and pilot. These additional training requirements will affect how Flight Training Units operate and are likely to increase the cost of obtaining a licence or rating. It remains unclear however whether the new training requirements will preserve current VFR privileges.
3. Night Rating Recency and Currency:
The NPA suggests that changes will be made to both the Night Rating Recency requirements, and the means of compliance with the Biannual Pilot Currency.
Night Recency:
The NPA proposes that to increase night landings and takeoffs in a 12-month period to 10 and introduce an annual 1 hour of instrument time requirement. The details of instrument time requirement is not included in the NPA.
Supervised instrument is inferred in the document, in which case, the 12-month criteria would become both restrictive and costly. For IFR pilots this requirement exceeds the current 24-month IPC (Instrument Proficiency Check).
24 month Currency:
The NPA as currently drafted proposes to change the existing currency requirements for all licence and permit holders excluding Flight Engineers. The NPA proposes to eliminate the use of Transport Canada Safety Seminars, recurrent training programs, self-paced study programs, and written examinations and add an additional option to include 1 hour of flight training and 1 hour of ground training. This will effectively eliminate all ground based methods of retaining currency leaving only the in-flight training or a full flight review as being acceptable. This change is extremely concerning considering the widespread use of specialty aircraft and the diverse locations in which our members operate.
As you can see, this NPA as currently drafted will be very concerning to GA pilots in Canada. COPA is creating a formal response to this NPA however, we additionally encourage all GA pilots in Canada to familiarize themselves with this NPA, and to provide your feedback in writing to by the July 6th, 2023 deadline.


Transport Canada Enquiry Form for COPA members experiencing issues with Aviation Medicals

As many of you know, Transport Canada has been experiencing challenges with processing Aviation Medicals. COPA is continuing to advocate on behalf of our members on this issue, which includes regular communication with Transport Canada, detailed articles in the COPA Flight magazine and for significantly delayed medicals, formally enquiring with Transport Canada.


If you are experiencing significant delays or issues with processing your aviation medical, please use the following enquiry form found on the Transport Canada website.



TC Registration Fee Proposal

Transport Canada recently published a proposal regarding proposed fee changes for Aircraft Registration services. 

Thank you to everyone who provided input to Transport Canada regarding proposed Aircraft Registration Services Fee changes.

COPA provided the following input.



In late July 2021, NAV CANADA finally confirmed the complete list of sites where Level of Service reviews which were ongoing, are now postponed for the foreseeable future. This is excellent news for all of the affected communities, airports and aerodromes that would have very likely seen a reduction in the level of service.

The postponed list includes the following airports, from west to east:

Port Hardy, BC; Castelgar, BC; Prince George, BC; Fort St. John, BC; Fort Nelson, BC; Peace River, AB; High Level, AB; Fort McMurray, AB; Lloydminster, AB; Buffalo Narrows, SK; Regina, SK; Prince Albert, SK; Brandon, MB; Dauphin, MB; Flin Flon, MB; The Pas, MB; Sault Ste Marie, ON; Windsor, ON; Saint Jean, QC; Sept-Iles, QC; and Sydney, NS.

The suspended studies are listed below.

COPA is very pleased to announce that because NAV CANADA is very optimistic that increased air traffic levels are “just around the corner” it, therefore, makes sense from a staffing workload perspective to suspend many more studies that were begun in Fall 2020. We can confirm that the Studies for Whitehorse Tower, Churchill FSS, Inuvik FSS, Norman Wells FSS, Kuujjuarapik RAAS, Blanc Sablon RAAS, and Natashquan RAAS, are being suspended. The studies for these sites were suspended because of the CANSCA northern or remote status.

Aeronautical Studies that were started in 2021 for Abbottsford and Nanaimo, as a result of the Vancouver Area Modernization Program, are safety-related and will therefore continue. An Aeronautical study concerning Primary Surveillance RADARs (PSRs) at seventeen sites across Canada has also recently commenced and COPA will be engaging with NAV CANADA regarding the potential impacts on GA flight operations. We will invite member inputs once COPA completes initial discussions with NAV CANADA.



COPA continues to lobby the government and advocate on behalf of our members regarding the luxury tax.

You are encouraged to register for the upcoming webinar – The Aircraft Luxury Tax, Tips for buyers and sellers taking place May 16, 2023 at 1:00pm EDT. This free webinar will be hosted by Steven Sitcoff, a Partner with McMillan LLP, who specializes in aviation and tax law.





Canadian Community Airports Profile

COPA has increasingly observed community airports across Canada being subjected to numerous challenges that threaten their future viability. Ensuring the continued availability and vitality of Canada’s community airport infrastructure is inseparable from COPA’s mission.

In response, COPA has commissioned the preparation of the Canadian Community Airports Profile with HM Aero Aviation Consulting. This new study has been developed to serve as a comprehensive body of information for anyone interested in learning about the value of community airports.

Click here for more information.


A Primer for the Canadian Owners and Pilots Association
By Glenn Grenier, Co-Chair Aviation, McMillan LLP, 2022

This Primer (updated and expanded from a similar article published in 2018) is intended to assist the reader in understanding what is meant by the exclusive federal jurisdiction over aeronautics, its extent and limits, and review cases where provincial/municipal officials have (or have not) been found to have encroached in terms of impermissibly attempting to regulate aeronautical activities. In doing so, readers will look at cases concerned with, for example, the location of aerodromes (which term includes heliports and water aerodromes), the construction of hangars, carrying on aeronautical businesses, noise and environmental concerns.

To read more, please click here.


COPA has received the latest version of the Aircraft Owners and Pilots Association (AOPA) Guide (version 8) Guide for Cross-Border Flying. The perspective of the document is USA-centric, covering flights outbound from the USA and returning. The images of USA Airports of Entry are southern-focused but the procedures and information sources are equally applicable for northern destinations in Canada.

For COPA this perspective is not problematic to our intended use. Flights from Canada to the USA or beyond to the Caribbean or Mexico will still need to comply with all of the procedures and regulations that govern flights to the USA.

For Canadians returning to Canada, the advice in this excellent document is equivalent to what AOPA is telling their members they need to depart their home airfields. The document is easy to follow and provides all of the information in a very user-friendly format.

COPA welcomes this new version of the AOPA document and commends it for reading and thorough study to all Members who are planning a flight to the USA or beyond in the coming months.

The document can be accessed via the link here.


Click here to read COPA’s 2017 study that highlights the economic impact General Aviation contributes to Canadian communities and to the national economy. The study, compiled by Vancouver-based InterVISTAS, estimates that General Aviation operations in Canada contribute $9.3 billion in economic output nationally and directly accounts for almost 36,000 full-time jobs in communities across the country. The report also highlights the benefits that General Aviation operations bring to communities in terms of tax revenues, direct, and indirect employment.



COPA was advised that Jasper National Park, administered by Parks Canada, undertook a review of the requirements to maintain an aerodrome as part of the Park’s infrastructure. COPA has publicly supported the continued existence of this airfield in the past and we are very aware that the seasonal-use grass airstrip at the eastern edge of the Town of Jasper is a vital link in the regional network of aerodromes in the Foothills area of Alberta.

COPA made this point to the Jasper National Park Superintendent in the letter that was sent to him. We also reminded the Superintendent that the aerodrome is used for Medical evacuations to trauma centres and is also an access point for eco-tourists using smaller non-commercial aircraft. The document can be accessed via the link here.

COPA received a response letter on September 27th, 2021 from the Jasper National Park Office of the Superintendent. The letter stated that they are currently reviewing all feedback that they gathered in regards to the 2020 Jasper National Park Draft Management Plan and their office will publish a report in the coming months with a summary of the feedback. The letter can be read here.


Earlier in 2020 COPA addressed a letter to the Minister of Transport, the Honourable Marc Garneau, to show support to the Oshawa Executive Airport regarding the surrounding resident noise complaints, specially targeted at flight training. The City of Oshawa leadership has taken steps to make it clear to all that they consider the noise associated with flight training operations at the airport to be a significant problem.

On February 8, 2021, at approximately 17:10 the Oshawa City Council members in attendance voted unanimously to direct the Airport Manager, in consultation with the Commissioner of Development Services, to engage a qualified, independent consultant with the familiarity of the requirements of Transport Canada Advisory Circular 302-002 to manage the process that would result in the creation of TC-controlled Noise Abatement procedures at the Oshawa Airport. The City has committed to spending up to $60,000 exclusive of H.S.T to complete this project. The various stages of the process (11 in total) detailed in the Advisory Circular are designed to ensure that equity and fairness are observed and that consultation with the affected parties is completed.


COPA is very pleased to announce that the efforts to advise the municipal leadership that airports such as theirs are a viable engine of growth and prosperity have resulted in good news.

The Town of Golden commissioned a comprehensive review of the Golden Airport in 2019, retaining HM Aero Aviation Consulting. Click here for more information. HM Aero Aviation Consulting presented its plan in March 2021.

At the end of July 2021, the Federal Government announced that under the Regional Air Transportation Initiative (RATI) nearly $12 million will go towards helping 11 regional airports across B.C. recover from the impacts of COVID-19. The Golden Airport, as well as the airports in Comox, Sidney, Bella Coola, Nanaimo, Kamloops, and Cassidy, will receive funding.


shutterstock_462029731On January 1st, 2017, the rules for building a new aerodrome or airport in Canada changed significantly when CAR 307 – Aerodromes – Consultations came into effect. Both new aerodromes and making substantial modifications to an existing aerodrome were impacted by these new regulations.

As a result of these dramatic changes, COPA and TCCA collaborated to clarify the new consultation process. An amplifying Advisory Circular, AC 307-001, was issued later that year and became effective November 10, 2017.

Anyone who is considering creating a new private aerodrome or modifying an existing aerodrome must follow the mandatory Consultation process. All are strongly encouraged to familiarize themselves with this process. A link to this important Advisory Circular can be found here.



Medical Appointment Doctor - Free photo on PixabayIn a consolidated effort to advocate for the acceptance of BasicMed pilots’ ability to enter into and operate in Canadian airspace, the COPA and AOPA have authored a joint letter to the Canadian Minister of Transport, the Honourable Omar Algbara. Read the full text of the letter to the Minister here.

The letter urges this acceptance based on the safe record of BasicMed Pilots and the fact that many American aviators do want to travel to Canada for a variety of purposes. COPA and AOPA want to remove this barrier to travel for thousands of US GA pilots.

COPA is also working with TCCA CAME staff to revamp the Category 4 medical certificate with the hope that it can eventually become recognized by the FAA so that holders would be able to operate Certified, Amateur-Built, and Limited-class aircraft in the United States.



COPA has addressed a letter to the Minister of Transport, the Honourable Marc Garneau, to urge the Government of Canada to support air navigation services in Canada throughout the COVID-19 global pandemic. COPA indicated the importance of the 30 locations currently under review, noting that their closure would impact the post-pandemic recovery and could cause an increase in aviation incidents and accidents.

In addition to this, COPA has sent separate letters to NAV CANADA expressing concerns with the proposed changes in levels of service. Thank you all for the valuable feedback you provided to assist us in our response.



COPA has provided input to Transport Canada’s recently-announced plan to implement a Canadian Automatic Dependent Surveillance–Broadcast (ADS-B) Out mandate. We are encouraged that Transport Canada has reached out to solicit input from industry and the opportunity to provide feedback. It is hoped that this commitment to meaningful consultation is the start of renewed collaboration between Transport Canada and industry partners nationally and internationally, To read the full response, click here.


COPA submitted a consolidated response to CARAC – the TC Policy department – to register our concerns and objections regarding the Notice of Proposed Amendment (NPA) regarding Visual Meteorological Conditions for VFR Flight.

The NPA evolved from a flawed consultation process that did not seek inputs from anyone outside of the commercial helicopter community. COPA was not consulted. As a result of a heavily biased approach, the NPA was suggesting that the solution to preventing further accidents while flying at night was to not only revise the definitions for night VFR but also to propose that Night Vision Imaging Systems (NVIS) such as Night Vision Goggles (NVGs) would be part of a two-tiered solution.

COPA advised CARAC that this proposal was reliant on unproven technology, would be preposterously expensive but would also come with an onerous training requirement. It would, therefore, severely restrict GA night operations for those who did not have access to this technology. COPA made several recommendations, many of which concluded that COPA should be part of any initial discussions regarding changes in night VFR minimum weather requirements.

Most importantly, COPA did not accept the amendments to CARs 602.11 and 602.115 as proposed because the risks of night flying would not be eliminated. COPA also concluded that TC must rightfully engage with COPA on aircraft equipage, pilot training, PDM, proficiency, and any other proposed regulatory amendments that impact general aviators’ freedom to fly.

Read COPA’s response here.


In November 2020 Transport Canada was permitted to implement a significant change to CARs concerning the application of the 406 ELT for all aircraft flying in Canadian airspace. In brief, except for local flights that do not go beyond 25 nm from the point of origin, and for specific types of aircraft such as gliders, balloons, ultralights and gyrocopters, the rest of the operators must have a properly installed 406 ELT fitted to their aircraft(s) by November 2021 for commercial operators, and November 2025 for private, recreational operators.

While COPA’s position remains that this locating technology has a poor track record of activation in a crash to be able to broadcast its position, we are satisfied that most GA operators will have several years to comply. COPA favours the adoption of new and emerging technologies, such as ADS-B (see below), to serve as a reliable and more effective alternative. COPA’s president has written several op-eds in various media on this topic. If your aircraft has an ADS-B Out system with antenna diversity, you can help us to gather data on the topic. Fill out your information here if you are equipped or share this form with someone who is.


shutterstock_176833685TCCA Operational Airworthiness thoroughly analyzed and reviewed the data received from propellor manufacturers and FAA sources and concluded that there was too much risk of a system failure due to corrosion in critical blade retention components if the current limit of ten years was extended further. One small compromise was provided in that the current limits published in CARS Standard 625; Appendix C could be extended up to 10%. TCCA IPB 2020-11 and a Draft Industry Memo have been published by TCCA Operational Airworthiness staff within the last year that gives technical details on how to request the 10% extension. You can request a download of the IPB 2020-11 document here. The TCCA download system requires that you provide your email address. You will receive two emails from TCCA, one of these two emails will have the requested PDF document as an attachment.


NAV CANADA has now published a NOTICE OF AUTOMATIC DEPENDENT SURVEILLANCE – BROADCAST OUT PERFORMANCE REQUIREMENTS MANDATE IN CANADIAN DOMESTIC AIRSPACE (AIC 2/22) – mandating the equipage of ADS-B in Class A and B airspace commencing 23 February 2023, and no earlier than 2026 in Class C, D, and E airspace. The requirement on Class A and B airspace is intended to be enabled through airspace classification designation and an amendment to transponder airspace requirements, as described in the Designated Airspace Handbook (DAH), TP 1820E. 

Transport Canada has indicated to COPA that consultation on the changes to existing standards for Class A and B airspace will be held in the fall of 2022 for the change intended in February 2023. COPA and industry partners believe this timing is too short to allow any meaningful consultation or changes to the proposed mandate. NAV CANADA and Transport Canada have both indicated that further consultation is intended before changes in Class C, D and E airspace will be implemented. Timing for this additional consultation has not been communicated. TC has also indicated that CARs changes are likely before implementation in Class C, D and E airspace yet continues to indicate that CARs changes are not necessary for changes to Class A and B airspace. 

COPA and 12 additional aviation associations have indicated their concerns with both the mandate and the process used by Transport Canada to implement the announced changes. A joint industry letter was sent to the Minister of Transport in March 2022 indicating the concerns with the mandate and the request for further dialogue and consultation before any changes are implemented. 

The main areas of concern with the mandate, as published, are:

  1. Under what authority is the mandate being enabled? Is this a NAV CANADA or Transport Canada mandate?
  2. Lack of regulatory consultation and process
  3. Short notice of consultation before February 2023 deadline
  4. Different processes/requirements to enable changes to Class A and B airspace versus changes to Class C, D and E?
  5. The requirement to transmit to space and ground receivers (It is understood some ground-based infrastructure is needed for the system to operate safely.)
  6. The difficulty of industry to equip to meet 2023 deadline
  7. Costs to equip ($10-15,000 CAD per aircraft)
  8. Lack of Cost-Benefit analysis for the aviation community
  9. Misalignment with US system – access and cost impacts to cross-border operations (978UAT and 1090ES Ground-based not compliant in Canada.)
  10. Safety and security issues with ADS-B system and ADS-B reliance on GPS.

COPA continues to advocate change to the published mandate to ensure that ADS-B deployment balances costs in the industry and is based on a comprehensive surveillance strategy that leverages ground-based infrastructure to complement space-based ADS-B, and supports potential benefits to all stakeholders that may be realized from a combined system.


See this presentation on how satellite-based ADS-B can be the perfect SAR enhancement and potentially replace the requirement for a 406MHz ELT.



shutterstock_560504689Transport Canada Civil Aviation (TCCA) has recently issued two very important Advisory Circulars (ACs) for RPAS operators and constructors.

The first AC is AC 903-001. It focuses on providing manufacturers and operators with guidance on how to complete an RPAS Operational Risk Assessment. This document offers guidance for assessing the risks associated with one or more of the operating situations listed in CAR 903.01. These situations require a risk assessment for a Special Flight Operations Certificate (SFOC) – RPAS application. The link to request a download from the TCCA library is here.

The second AC is AC 903-002. It focuses on providing operators with more guidance on how to and when a Special Flight Operating Certificate (SFOC) is required for RPAS flight operations. Again, CAR 903.01 requires that an SFOC-RPAS be issued for certain circumstances which Part IX of the CARs does not yet regulate.

An SFOC – RPAS permits operations of an RPAS for a specific purpose, location and time frame. The link to the TCCA online PDF document is here.

COPA strongly encourages ALL RPAS operators to review both of these advisory documents before flight operations are carried out. Safety of Flight is paramount and our members are ambassadors for the smooth integration of RPAS flights with traditional aircraft operations.

Be sure to visit COPA’s RPAS page to learn more.


Every two months, the Transport Canada RPAS Team puts out a newsletter called the Drone Zone. The newsletter features recent updates, safety reminders and the number of registered drones in Canada and RPAS pilot certificates issued by Transport Canada.

To read the most recent version, click here. To receive the newsletter in your inbox, click on this link to subscribe.