Summary of the issue
- Transport Canada have released their first Notices of Proposed Amendments to the Canadian Aviation Regulations this year (NPA 2024 – 001).
- NPA 2024 – 001 outlines new registration fees, changes to ultralight licensing and aircraft registration, and changes to hang glider weight definitions.
- The NPA outlines a proposed increase of existing registration-based charges and the addition of new charges for certain registration procedures.
- COPA strongly opposes changes that affect the flying community that are made without proper consultation. The latest NPA did not involve direct consultations with COPA or the Ultralight Pilots Association of Canada (UPAC).
- COPA members are encouraged to comment on NPA 2024 – 001 by February 7, 2024.
New ‘ultralight aircraft’ definition
In addition, the NPA changes the definition of an ‘ultralight aircraft’ from an aircraft with a certain stall speed and maximum takeoff weight, to any aircraft with a “C-I” registration. This is a contradiction of the current definition of a “Basic Ultra-Light Aeroplane” in Subpart 101 Part 1 of the Canadian Aviation Regulations, which provides the definition of “an aeroplane having no more than two seats, designed and manufactured to have a maximum take-off weight not exceeding 544 kg, and a stall speed in the landing configuration (Vso) of 39 knots (45 mph) indicated airspeed, or less, at the maximum take-off weight”.
Currently, ultralight pilots can fly aircraft registered in other categories that fall under these weight and stall speed requirements, as a “Basic Ultra-Light”. This includes “C-F” and “C-G” registered aircraft. Additionally, this would mean owners of “amateur built” ultralight aircraft, that have an ultralight licence, with an aircraft that was previously registered with a registration that is not “C-I” would not be able to fly their own aircraft.
How to access the full NPA and provide comments to Transport Canada
The NPA can be accessed here, and comments on the NPA can be made by email to TC.CARConsultations-RACConsultations.TC@tc.gc.ca, or on the online form for NPA responses here.
COPA is formulating a response to the NPA which will be shared with members. We encourage all members to send individual feedback on this NPA to Transport Canada by the deadline of February 7th, 2024. To be notified by email of CARAC changes, sign up for email updates here.
COPA advocating for industry-wide consultations
These proposed amendments directly affect members of both COPA and the Ultralight Pilots Association of Canada (UPAC). Neither associations were included in Transport Canada’s consultation process, despite requests for direct engagement with our two national organizations.
These proposed regulatory changes appear to have been introduced as “add-on” items to other consultations on different matters. COPA opposes the proposed changes and will continue pushing for meaningful consultation before publication of this NPA.
This issue affects us all
While on the surface this NPA may not appear to be relevant to the COPA members flying certified aircraft, we encourage you to at least provide comment on how Transport Canada is not following their own published CARAC procedures by skipping the consultations with the relevant industry groups and associations before the publishing of the NPA.
This is a troubling trend and an indication that they do not want the input from groups directly affected when they are planning to make changes to policies, procedures, and regulations.