TC CARAC Notice of Proposed Amendment (NPA) – VFR Weather Minimums
Transport Canada has recognized that the majority of Canadian airspace, whether in Controlled or Uncontrolled airspace, is sparsely populated and offers very little illumination or no illumination suitable to provide pilots with visual reference to the surface during night VFR flights. While the weather requirements for night VFR may be met, the lack of illumination in such areas negates a pilot’s ability to maintain control of an aircraft by external visual reference to the surface. As such, night VFR flying is a combination of day VFR and IFR techniques.”
As a result, Canadian Aviation Regulations (CARs) do not adequately address the safety risks associated with night visual flight rules. Specifically, TCCA has advised that it is proposing to amend CARS 602.114 and 602.115 because the current description and defined requirements are: “inadequate and do not ensure safe conditions for pilots to fly with proper external visual references.” TCCA has gone to some length to redefine the horizon in a weather table in the last pages of the NPA. TCCA wants to mitigate aviation safety vulnerabilities resulting from improper interpretation and application of defined requirements for pilots to safely fly and navigate during night VFR conditions.
It is also very important to note that the process will be in TWO PHASES. This first NPA will conclude when new CARs 602.114 & 602.115 weather limits coming into effect. The second phase will involve the revamping of the Night Rating, possibly into a two-tier rating that would allow “the continuance of night operations in areas close to urban lighting for private pilots and flight training schools.”
Our COPA membership needs to advise us so that we can inform TCCA on how changes to weather minima language will impact GA. This NPA is about weather minima language that addresses GA and helicopter operations at night and the implementation of NVIS in those aircraft. We encourage you to read, understand and formulate cogent proposals on how we can improve the CARs and the improve the safe operations of GA flights at night in both VFR and IFR situations in both VMC and IMC. We encourage you to write to us COPA with your thoughts by June 25th so that we can respond on your behalf with a strong and unified voice. Please send your emails to us at firstname.lastname@example.org.
COPA Response to Proposed Luxury Tax
Along with the announcement of the 2021 proposed Federal Budget came the infamous Luxury Tax. In February 2020, when this tax was first proposed, COPA responded to the then Finance Minister, Bill Morneau, strongly opposing this proposal. On April 22, 2021, we sent a new letter to the Prime Minister, Finance Minister, Transport Minister and opposition leaders with our concerns and proposed recommendations. This letter is available to all our members here.
In our continued efforts to lobby the government to amend its proposal, COPA invites all its members to write to their MPs and copy us at email@example.com. Contact details for MPs can be found on the Parliament of Canada website. We did it last year, and we are asking you to do it again this year! You can use this new template letter as your starting point.
We appreciate all of your constructive feedback regarding this issue, as it affects most of us and rest assured, COPA will continue to Advance, Promote and Preserve our Canadian freedom to fly.
COPA ADVOCACY CYOS Owen Sound Landing Fees
In late March 2021, the City of Owen Sound, despite the efforts of the on-field Flying Club, members of the local COPA Flight and COPA National leadership to take an alternative approach, went ahead and began the collection of a punitive $35.00 (plus HST) landing fee. These fees, which are not discounted for any GA aircraft, are being levied on each arrival, or touch and go, are logged and collected by the airport management staff during their operating hours.
In the last two weeks, some of the hangar owners at CYOS have banded together and are attempting to make representation to City of Owen Sound council and committees to develop alternative solutions. Their efforts have been repulsed by the responsible city staff. The City Council leadership has made it very clear to our COPA members that the landing fees will stay in effect for the immediate future.
COPA leadership is working with affected pilots and operators that hangar their aircraft at CYOS to strengthen their voices and bring more national attention to this freedom to fly issue. COPA welcomes your support to help ensure the operation of CYOS without the use of punitive measures. Follow and share the CYOS “save our airport” efforts on Facebook and Instagram.
Update on 10-Year Propeller Overhauls
TCCA 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 give 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.
Update on NAV CANADA Aeronautical Studies
NAV CANADA has announced that it will maintain air traffic control service to Canadian communities, including Fort McMurray AB, Prince George BC, Regina SK, Saint-Jean QC, Sault Ste. Marie ON, Whitehorse YT and Windsor ON.
We are further committing that there will be no site closures at staffed air traffic control towers or flight service stations across the country at this time. In addition, the Company will suspend Aeronautical Studies currently underway related to remote or northern locations until further notice.
The Aeronautical Studies, which are still in progress, will consider other alternatives to safely streamline operations, including changes to hours of operation. Aeronautical Studies that were related to hours of operation from the outset or that are related to Remote Aerodrome Advisory Services will also continue. Appendix A provides further information on the status of Aeronautical Studies.
Studies being suspended: Whitehorse Tower, Churchill FSS, Inuvik FSS, Norman Wells FSS, Kuujjuarapik RAAS, Blanc Sablon RAAS, Natashquan RAAS
Studies with Potentiel alternate recommendations: Regina Tower, Prince George Tower, Windsor Tower, Fort McMurray Tower, Sault Ste Marie Tower, St. Jean Tower, Peace River, FSS, Lloydminster FSS, High Level FSS, Castlegar FSS
Response to the NAV CANADA Proposed Level of Service Changes
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.
Letter of Support for the Continued Operations of the Oshawa Airport
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 step 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 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 spend 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.
Response to the Red Deer Overnight Air Traffic Level of Service Review
COPA was notified that about an Aeronautical study currently being conducted reviewing the overnight Air Traffic Services being offered at the Red Deer Airport and offers the following response to NAV CANADA’s Aeronautical Studies team. COPA believes that the current overnight level of service currently being provided at the Red Deer airport by the Flight Service Station should remain the same in order to insure the safety of GA pilots who depend on the aviation weather information, runway surface condition reports and safe guidance provided by the FSS in case of disorientation.
Support for Golden Airport in British Columbia
COPA is very pleased to announce that the efforts to advise the municipal leadership that airports such as theirs’s is a viable engine of growth and prosperity has resulted in good news.
The Town of Golden has commissioned a comprehensive review of the current and potential future roles of Golden Municipal Airport. HM Aero Aviation Consulting has been retained to complete an Airport Viability Study. The study will involve the evaluation of airport infrastructure, operations, financial standing, and the identification of potential aeronautical and non-aeronautical business opportunities. Click here for more information.
The current COVID-19 pandemic has taken a drastic toll on aviation operations in Canada and around the world. To mitigate some of the effects and ensure best outcomes for GA pilots, COPA has been working closely with an industry working group to advocate for what we believe are necessary programs and exemptions. You can read our Joint Aviation Leadership letter to P.M. Justin Trudeau here. Many such exemptions have already been put in place, the full list is available on the Transport Canada website for COVID-19 aviation updates. As aviation activities resume, we also recommend consulting our GA aircraft disinfecting tips when returning to flight training or aircraft renting.
COPA ELT Advocacy
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 property 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 favors 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.
ADS-B Mandate in Canada – and ELT replacement
General Aviation aircraft fall under Phase III of Nav Canada’s proposed ADS-B mandate. The proposal is for all aircraft operating in transponder-required airspace to be equipped with 1090ES ADS-B Out. Read our position here. COPA is currently working with Nav Canada on the issue of Antenna Diversity, which would add significant cost to any ADS-B installations. Pilots should note that equipment meeting the FAA’s 2020 mandate for 978UAT (ground-based) ADS-B will not be compliant in Canadian airspace.
ADS-B’s future place in SAR
See this presentation on how satellite-based ADS-B can be the perfect SAR enhancement and potentially replace the requirement for a 406MHz ELT.
Economic Impact of General Aviation in Canada
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 contributes $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.
In response to the new regulations governing aerodrome construction and expansion which came into effect January 1st, 2017, COPA has been working collaboratively with Transport Canada on a new Advisory Circular which will provide clear direction on the requirements for consultation. We look forward to advancing the second phase (see below) of this initiative later this year which will require outside developers to consult with aerodromes and local aviation communities on developments or works which may impact airport operations.
COPA has been actively discussing the BasicMed file with AOPA’s senior staff as well as with senior officials at Transport Canada and establishing an action plan based on what is possible, what is achievable, and what courses of action will best benefit pilots on both sides of the border. In that regard, COPA has developed a proposal that would allow BasicMed operations in Canada that abide by current conditions in place for Recreational Pilot Permit (RPP) holders. In return, we are calling on the FAA to revise the Special Flight Authorization regime to allow Canadian RPP holders to operate Certified, Amateur-Built, and Limited-class aircraft in the United States. Read the full text of COPA’s proposal. COPA has also been working through IAOPA to develop an ICAO medical certification standard. A review has been set in motion which will look at the medical certification protocols of ICAO member countries to find commonalities and develop an ICAO standard for light aircraft medicals.
Remote Piloted Aircraft Systems (RPAS)
RPAS technology is advancing at an incredible pace. COPA is proud to be playing a leading role in Transport Canada’s drone policy development process, advising the regulator on proposed guidelines for airspace usage in and around aerodromes. Visit our RPAS page to learn more.