Summary of the issue
- Transport Canada is proposing changes to night VFR, VFR meteorological conditions, training, and currency requirements amongst other subject matters that affect pilots via NPA 2023-005 that was circulated by Transport Canada as part of the CARAC process.
- COPA has reviewed the proposal and feels that this NPA as currently drafted (as of July 2023) poses a risk that will impose unacceptable changes to future regulations, impact our ability to fly VFR in Canada, and place additional training and currency requirements on pilots.
- In response to the NPA 2023-005, COPA submitted the following letter to Transport Canada on July 5, 2023.
COPA has summarized the following key changes for our members:
- 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.
- 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.
- 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.
Overall, this NPA as currently drafted will be concerning to GA pilots in Canada. COPA encourages all GA pilots in Canada to familiarize themselves with this NPA.
Additionally, if you are referencing the issues as outlined above, please link back to COPA.
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