Thank you very much, Chair.
Good morning. My name is Tim Perry. I am a professional pilot and have been for over 21 years. I'm a 737 captain at WestJet Airlines. I am currently the president of ALPA Canada, which is the Canadian division of the Air Line Pilots Association, International.
I am pleased to appear before the House of Commons Standing Committee on Agriculture and Agri-Food today on behalf of our members in Canada regarding Bill C-355.
By way of a brief introduction, the Air Line Pilots Association is the world's largest airline pilot union and non-governmental safety organization. ALPA Canada represents 90% of the professional pilot workforce in Canada. They are employed by 22 airlines across the country.
ALPA provides critical services to its members, including airline safety, security, pilot assistance and labour representation.
I'd like to begin by stating that the primary responsibility of the pilot in command of an aircraft is the safe operation of that aircraft before takeoff, in flight and after landing.
ALPA Canada believes that Bill C-355 does not recognize this. As a result, it will negatively impact our members by putting an unnecessary and redundant obligation on them, which is accompanied by excessive penalties if in contravention of the proposed legislation.
Further, we maintain that it is improper to place any additional responsibilities on a pilot when the pilots' responsibilities are already clearly defined in the Canadian aviation regulations and the Aeronautics Act.
We also believe that all responsibilities relating to the required written declaration in the proposed legislation should be the sole responsibility of the chief officer of customs of the airport, as identified in the bill.
For the reasons stated above, ALPA Canada suggests that Bill C-355 be amended in the following ways.
In clause 4, under “Prohibitions” and "Copy of declaration”, we request that paragraph 4(2)(a), which states, “the pilot in command or the operator of the aircraft”, be removed in its entirety.
In subclause 4(3), “No departure without declaration”, paragraph 4(3)(b), which states, “for a person in charge of the aircraft to take the aircraft on its flight”, should also be removed.
We are happy to provide these comments to the clerk.
We maintain that paragraphs 4(2)(a) and 4(3)(b) are unnecessary and put additional responsibilities on the pilot, who should remain focused solely on the safety and the operation of the flight, and this should remain the case.
Before I conclude my remarks, I would also like to take the opportunity to state that it is always our expectation that when legislation or regulations are being considered specifically with respect to the aviation industry, our members and potentially to aviation safety, there should be outreach or consultation with our association. In this case, that did not occur.
Thank you very much. I'm happy to take your questions.