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 aviator’s freedom to fly.
Read COPA’s response here.
COPA Response to Proposed Luxury Tax
The Federal Budget Implementation Act, Bill C-30, was passed by the House of Commons on June 23, 2021 by a vote of 211 to 121 with the support of NDP and Bloc Members of Parliament, while the Conservatives voted against the legislation. Bill C-30, which contained the luxury Tax, was passed by the Senate without amendment on June 29, 2021. Needless to say it was very disappointing to read the Budget Implementation Bill, 2021, No. 1 Third Reading—Debate with no mention of the tax. Thank you to all our members who signed the petition. We had close to 3000 signatures.
In 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.
Owen Sound Update: Campaign to save CYOS airport
Here is the link to the City’s announcement in the Owen Sound Sun Times newspaper. Mr. Jim Farmer presented an excellent consolidated assessment on options for the Region and the Airport on August 30th. The presentation can be reviewed on the Save Owen Sound Airport Facebook page and you can also read it here. We continue to oppose the City of Owen Sound’s decision to close or sell their airport because of the negative impact on the businesses and hangar owners at the airport. COPA remains committed to supporting all efforts to support all GA pilots and their Freedom to Fly
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
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.
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.
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 are a viable engine of growth and prosperity has 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.
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
Under the original plan mandate ADS-B equipage in Canadian airspace, General Aviation aircraft fell under Phase III of Nav Canada’s proposed ADS-B mandate. Under the original schedule, this phase would have begun no sooner than 2023 and was subject to additional stakeholder consultations and the advent of additional benefits for GA, neither of which has occurred. The proposal as it currently stands lays out a requirement for ADS-B equipage in aircraft operating in A and B airspace, however, those timelines have also shifted and have yet to be shared with stakeholders.
Outside of Class F and G airspace, all aircraft operating in controlled airspace will need to be equipped with certified 1090ES ADS-B Out including antenna diversity, although proof of its necessity has also not been tested and shared with stakeholders. COPA continues to have reservations over several aspects of the performance requirements as well as the cost/safety benefits that will come with the implementation of space-based ADS-B. You can review our original position on ADS-B here.
One of the most debatable issues for general aviation aircraft equipage is the requirement for antenna diversity. By current definitions, this requirement can only be satisfied by installing two emitting antennae in two locations., typically, a roof-mounted and belly-mounted installation. In all aircraft, this is a very expensive proposition (close to $15,000 CAD) but in addition, for some GA aircraft, this dual mounting can be expensive. There is however an increasing amount of reliable data that most smaller GA aircraft can provide very satisfactory reporting with one tail-mounted dipole antenna. This is a step in the right direction that can assist in resolving this thorny and expensive issue.
COPA was recently advised by Transport Canada that NAV CANADA continues to evolve its mandate for ADS-B equipage in low-level controlled airspace. Although, as mentioned earlier, no new consultations have taken place with any stakeholders, the new proposed date for ADS-B mandate implementation is “not before 2026.” This has not been shared in any public capacity. This new date recognizes that performance requirements along with equipage specifications are not yet finalized.
Pilots should note that equipment meeting the FAA’s 2020 mandate for 978UAT (ground-based) ADS-B will not be compliant in Canadian airspace. Also, at present the one tail-mounted system, uAvionix tailBeaconX has demonstrated similar performance to a diversity transponder setup. A report on the results of recent trials using the Aireon space-based ADS-B orbital network can be found here.
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.
On 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.
Remote Piloted Aircraft Systems (RPAS)
Transport 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 a SFOC-RPAS be issued for certain circumstances which Part IX of the CARs does not yet regulate.
An SFOC – RPAS permits operations of a RPAS for a specific purpose, location and time frame. 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.
DRONE ZONE NEWSLETTER
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.