Last week, Transport Canada (TC) unveiled its latest proposal (the previous one goes back several decades) of a certification regime for water aerodromes – particularly affecting those where scheduled passenger service operates. COPA has been aware for some time that a proposal was in the works, despite the lack of consultation by the regulator with industry associations and seaplane operators. The Notice of Proposed Amendment (NPA 2019-014) was circulated to stakeholders on the Canadian Aviation Regulation Advisory Council (CARAC) in early July, with a public comment period ending on August 22nd, 2019. The proposal names a long list of criteria and conditions a water aerodrome operator would have to meet in order to obtain certification, such as minimum length, width and depth of takeoff/landing channels, identification of the perimeter of the water airport, the establishment of obstacle limitation surfaces and marking of hazardous objects, among many others. The NPA also proposes two different eligibility criteria defining those water aerodromes who would be affected and required to re-certify or obtain new certification:
- All water aerodromes located within the built-up area of a city or town OR those that have scheduled passenger service;
- All water aerodromes located within the built-up area of a city or town OR those that receive more than 14 scheduled passenger movements per day, or those that receive any aircraft providing scheduled passenger service with nine or more passenger seats.
The NPA identifies 6 currently certified water aerodromes who would be required to re-certify under the new regime, including: Montreal’s Boisvert et Fils (CSA4), Hydro Aéroport de Montreal (CHA3), Marina Venise (CST8); Nanaimo’s Long Lake (CAT3); Quebec City’s Lac St-Augustin (CSN8); and Victoria’s Inner Harbour (CYWH).
As well, the regulator has identified at least 48 other registered water aerodromes, both private and commercial, that have been deemed to be within a built-up area OR who have scheduled passenger service, and therefore would be subject to the new regulations. A comprehensive list was not published with the NPA and has not been made public as of yet.
COPA appreciates the regulator’s efforts to improve safety for the fare-paying public, as well as taking the opportunity to position Canada as a world leader in both commercial and private seaplane operations. However, the proposal in its current form has many issues that will not improve safety and that will place an undue administrative burden on water aerodrome operators, as well as putting owners of private or unregistered water aerodromes at significant legal risk. COPA intends to submit written comments ahead of the August 22nd deadline, and in the meantime will work with TC and industry partners to address the major issues within the proposal.
Interested members can read the NPA in its entirety here:NPA 2019-014 WATER AIRPORTS
COPA invites members to submit their comments to us by August 1st, via the form below, for inclusion in our submission and discussions with the regulator.