Transport Committee on April 29th, 2010

[The Vice-Chair (Hon. Joseph Volpe (Eglinton—Lawrence, Lib.)), Liberal, Joe Volpe]

Thank you.

Colleagues, it's my pleasure to sit in for the chairman of the committee and to welcome the witnesses.

Pursuant to Standing Order 108(2), we are studying aviation safety and security.

We are pleased to have with us this morning witnesses who have come from the Air Transport Association of Canada: Mr. John McKenna, Mr. Michael Skrobica, whom we've met before, and Mr. Bill Boucher, vice-president, operations. At the same time, members, from the Helicopter Association of Canada we have Mr. Fred Jones; from the Quebec Air Transportation Association we have Marco Prud'Homme; and from the Northern Air Transport Association we have Mr. Stephen Nourse.

Gentlemen, thank you very much, and welcome. I think you've already been given an indication of how much time you have. I'm sorry we had to delay you for as long as we did.

Who shall be first?

Monsieur McKenna.

[John McKenna, President and Chief Executive Officer, Air Transport Association of Canada]

Good morning, ladies and gentlemen, members of the committee.

My name is John McKenna, and I am the president and chief executive officer of the Air Transport Association of Canada. I am accompanied today by Michael Skrobica, vice-president, industry monetary affairs, and Bill Boucher, vice-president, operations.

The Air Transport Association of Canada has represented Canada's commercial air transport industry for over 75 years. We have approximately 185 members engaged in commercial aviation operating in every region of Canada and offering services to the vast majority of the more than 700 airports in the country.

Aviation safety and security are at the very core of ATAC's reason for being. The purpose of your study touches many critical aspects of both safety and security. ATAC is a strong supporter of safety management systems. We firmly believe that SMS represents both a financial and a safety gain for air operators. The major carriers have now all implemented SMS and are seeing the benefits of proactive safety management.

For SMS to work effectively, though, both industry and Transport Canada need to have a shared understanding and show the same devotion to safety. Unfortunately, Transport Canada now lacks some of the essential tools required to allow SMS to fully come into play. These tools were to be provided by the proposed amendments to the Aeronautics Act, tabled in 2006. The enactment of this bill would have dealt with integrated management systems and would have authorized the establishment of voluntary reporting programs under which information relating to aviation safety and security could have been reported. This covered the protection of operators' confidential safety information from easy access by the general public, by competitors, or terrorists.

The amendments also provided for a non-punitive reporting system for aviation personnel, thus allowing employees the protection needed when revealing safety-related information. The bill also provided Transport Canada with the resources needed to adjust to its new role as designed by SMS. Without these tools, proper SMS can never be implemented to its optimal level. Ideally, the Aeronautics Act should have been amended before the new safety regulations came into effect.

We are very concerned that Bill C-7 seems to have been abandoned by the Minister of Transport. The monetary and social cost of the current security measures is significant. In fact, Transport Canada conducted a study on this very subject some 18 months ago. We have not been privy to the findings of this study, but we recommend that the members of this Standing Committee ask to see its results.

The social cost is also very significant. No-fly lists, passenger name records, advanced passenger information all have access to passengers' confidential information and intrude into the private life of Canadians and foreigners. The measures add much inconvenience for passengers. They have to arrive hours ahead of their flights, submit to more searches, restrict their carry-on luggage, and they heighten stress level when travelling.

The monetary costs are in the billions of dollars. There are direct costs to both the travelling public and to airlines. Canada's air travellers security charge is a case in point. In 2008, ATAC conducted a survey to rank the 175 security fees charged by either governments or airports worldwide. At that time, Canada's security charge was the second highest in the world, second only to the Netherlands. After the February 26, 2010, announcement of increases by Minister Baird, we believe the Canadian security charge to be the highest in the world, the international fee alone having gone from $17 to $25.91, a 52% increase. Why are Canada's security charges so high as compared to other countries?

There are also many other direct costs to airlines. For example, security measures required airlines to make significant and costly changes to their reservation systems to provide added passenger information, such as where they will live when abroad.

The problem with the existing security measures is that they rely on a cross-section of technology, most of which dates back some 50 years. Passengers are required to go through very old technology metal detectors while their carry-on luggage goes through x-ray detection. They are then wanded should the metal detectors light up. Once that process is over, transborder flight passengers are either patted down or put through body scanners. All this requires time and personnel. We hoped the body scanners were going to replace the old technology, not add another stage to the process. Why can't we use a modern detection technology, which will reduce the number of stages and the time and personnel required to process passengers?

The full-body scanners are an improvement over the 1960s metal detection technology but are not entirely efficient either. They would not have prevented Umar Abdul Mutallab, the Christmas Day underwear bomber, from getting on the plane.

People can refuse to go through the scanners for medical reasons. People under the age of 18 can't go through it either, for legal reasons. In short, we don't have a problem with full-body scanners, which in our opinion are less intrusive than a pat-down. However, they are but an improvement. They are not foolproof, any more than any other measure, and they don't speed up the screening process.

The queueing of passengers is another problem. Why can't they design lines and use equipment that would shorten the delays, use better judgment when deciding who merits closer scrutiny, and not make these clusters of assembled passengers such obvious targets for terrorists? A terrorist act at a major airport terminal would cause as much devastation and as many victims as a downed airliner.

Pre-approved levels of security clearances would expedite significantly the screening process. Why not grant heightened security clearances to officers of the law, frequent flyers, and military personnel? NEXUS or CANPASS-type pre-clearance cards would also be a way to accelerate the process.

The same can be said for non-passenger screening. The screening of aviation personnel is not a good use of CATSA resources. The U.S. and Israel don't screen aviation personnel; why do we do it here?

ATAC stands against profiling for ethical and practical reasons. Clearly, profiling would not have stopped Timothy McVeigh in Oklahoma City in 1995. Profiling would increase national racism and would heighten the stress level of passengers who would adopt the same prejudicial attitude toward people of a different race and creed.

Also, we are against main-terminal type security at FBOs and for charter flights. Sending sports teams, celebrities, and VIPs through main terminals only increases motivation for terminal terrorist attempts. We do not know of any incidents that could have been prevented had these flights gone through the main terminals.

In closing, we want to insist on the fact that the end should not justify the means. Security, yes, but not at all costs. We advocate proactive measures rather than precipitated responses to incidents.

Thank you.

[The Vice-Chair (Hon. Joseph Volpe), Liberal, Joe Volpe]

Thank you, Mr. McKenna. Bang on, in terms of time.

Perhaps we can go to Mr. Jones, from the Helicopter Association of Canada.

[Fred Jones, President and Chief Executive Officer, Helicopter Association of Canada]

Thank you.

Ladies and gentlemen of the committee, let me say first what a pleasure it is to speak with you.

The Helicopter Association of Canada has been in existence since 1995 and has grown from a handful of operators to over 150 operator members and over 100 associates who provide goods and services to our operator members. Roughly 80% of the civil helicopters in Canada today are operated by HAC members, and we're the only national association in Canada dedicated exclusively to the interests of the Canadian helicopter community.

I intend to keep my presentation to you short and under the requested seven minutes, but I would be pleased to answer any questions that you may have with respect to your investigations during or following my presentation. Please don't hesitate to interrupt me.

I come to the committee with a background at the Transportation Safety Board, Transport Canada, the Air Transport Association of Canada, the Canadian Airports Council, and 23 years as a current helicopter pilot in the Canadian industry. I've been with the Helicopter Association of Canada, or HAC, as it is commonly referred to, as its president and CEO for the last 18 months. I've appeared with pleasure before this committee on a number of occasions in previous association alliances, but this is my first appearance before the committee representing HAC.

Our operator members have fleets that range in size from one to 250 helicopters. Canada boasts the second-largest civil helicopter fleet in the world. Since 2006 our accident rate has declined steadily, from 8.8 accidents per 100,000 hours to 5.7 accidents per 100,000 hours in 2008. Now, admittedly, that's still 40 accidents too many, but we're working on that, and our Canadian accident rate is still lower than virtually any other region in the world.

A number of the security-related items that form part of this committee's mandate are largely transparent to the Canadian helicopter community since most of our members are not based at airports, and even those who are do not operate from the terminal or between designated airports. Naturally, those who are based at airports or operate from them are still subject to airport security procedures and requirements, but mostly they operate smaller aircraft in the absence of screening—quite happily, I should add.

Most of our operations are conducted in remote areas where other means of transportation are difficult or impossible. Having said that, when I was invited to speak with you I could not pass up the opportunity to comment on the future of safety in an SMS context. But first, just a little more about HAC and the involvement of its members in safety.

Safety is at the top of our priority list. HAC is participating on the International Helicopter Safety Team, or IHST, an international effort aimed at reducing the accident rate for helicopters worldwide by 80% by 2016. Our association and its members have been focused in recent history on the development of industry best practices. We were developing best practices for the operation of helicopters in utility flight operations—that's hydro line maintenance, construction, and repair; in oil and gas operations; heli-ski and helicopter wildfire operations; the use of night vision glasses cooperatively with Transport Canada; class D external loads, where people are suspended below the helicopter, for mountain rescue operations, for example; the development of helicopter emergency medical services standards; and in recommended practices in a working group at the International Civil Aviation Organization.

These initiatives have been developed from inside the association's committees and most notably in the absence of any obligation to do so from Transport Canada, or anywhere else, for that matter. The best practices largely exceed the regulatory standard, or fill a void in the regulations where only the specialists in the industry are capable of developing and applying the latest and safest techniques for operating helicopters.

A number of our committees work closely with American and international groups who are focusing on similar issues in an effort to capitalize on evolving best practices being developed elsewhere. We are working closely with Transport Canada when there is an appetite from the regulator to develop standards based on what prudent and reasonable operators are doing in the field.

You should all understand that these initiatives flow very naturally from safety management system principles and are being driven by a move by Canadian certificate holders of all types—that means air navigation system providers, airports, air operators, etc.—to embrace safety management systems and the opportunities it presents.

Part of the promise of SMS has always been enhanced safety, but also the opportunity to have more influence over the evolution of our regulatory environment that historically has formed such a costly, cumbersome, and prescriptive part of our day-to-day lives in the helicopter industry. We welcome SMS if the minister is still prepared to walk the talk.

It also needs to be said that HAC and its members were floored by the minister's recent announcement to repatriate the oversight of administration of business aviation aircraft by the Canadian Business Aviation Association. The CBAA program was the only program of its kind in the world and was considered by many of us in the aviation community to represent a promising opportunity for other industry segments that are prepared to consider accepting the responsibility to assume more influence over their regulatory environment.

The minister's announcement landed like a hand grenade, and for many of us signalled a retreat by Transport Canada from the founding principles of SMS, and from the principle that industry, acting responsibly, would be given other opportunities to exercise oversight and administration.

The aviation community in Canada is filled with examples where industry is trusted to carry out part of the minister's mandate, including testing and checking pilots for commercial operations, administering exams, certifying major airframes and modifications, to name only a very few.

There is a long history of successful delegations of authority, and this is not, as some have characterized it, the fox minding the chicken coop.

These processes are all about controls, governance, and oversight for the industry body. There isn't anything we cannot accomplish with the right mix of these elements. What's more, SMS and the principles that underlie it form the most promising mechanisms to advance safety in Canada and the world.

For more detailed information relating to HAC and its members, I encourage you to contact me directly or to visit our website at www.h-a-c.ca.

Thank you for the opportunity to speak with you today. I'd be pleased to field any questions you may have.

[The Vice-Chair (Hon. Joseph Volpe), Liberal, Joe Volpe]

Thank you, Mr. Jones. You were just under seven minutes, about 29 seconds. That allows me to allow everybody to catch their breath.

We'll go to Monsieur Marco Prud'Homme.

[Marco Prud'Homme, President and General Manager, Quebec Air Transportation Association]

Good morning.

We thank the committee for giving us the opportunity today to express our concerns about aviation security. The AQTA is a non-profit organization which works to further the development of the air transport industry in Quebec. We represent the following sectors of the industry: carriers—airplanes and helicopters— airports, maintenance and certification companies, piloting schools and service enterprises.

The purpose of Security Management Systems is to increase the level of security by putting in place a corporate culture based on security within the industry, which is already a very safe industry. The concept of Security Management Systems, SMS, has never been presented to carriers as a self-regulation mechanism. It was, rather, presented in the very beginning as an alternate solution to operational verification activities. I remember well the first presentation on the topic in Montreal in the offices of Transport Canada. The carriers were surprised by the news. Later, the approach changed and currently the SMS is no longer an alternative concept but an complementary one for the operators.

The AQTA is now in favour of SMS in the industry. However, we believe there are major problems to be overcome in the implementation of this concept with small operators and piloting schools.

The delegation of responsibility regarding security to the senior manager does not confer instant competence in the area of SMS. That is why we need training tools to implant this system.

As for resources, we have some serious concerns. On the one hand, although airlines have limited resources, they have a superior capacity to that of small organizations to put in place such a system.

Since the SMS was put in place by the large carriers, we noted a substantial increase in the workload of Transport Canada inspectors. They have run out of time to carry out their inspection activities and this fact was recognized before the committee. The workload for the next phase is, we feel, even greater. The 705-type carriers are proportionally speaking not very numerous in the country as compared to other types of operators.

Recently, in March 2010, an organization known as the CAMAQ did a survey and found that there were 158 businesses specialized in air transport and the maintenance of aircraft. Of that number, 105 had fewer than 10 employees, that is to say that to date, Transport Canada has not even grappled with two-thirds of the problem represented by the implementation of this system.

With regard to training, inspectors have already received training and more is projected. As for the carriers, only the documentation is offered on the Internet. Strangely, during program validation inspections, Transport Canada does not recognize the value of self-training on important topics. Since Transport Canada feels that the SMS is crucial to our security objectives, would it not be normal to at least have some training materials in order to be able to provide training in-house?

We indicated before the committee that Transport Canada was working in cooperation with the associations. That is what we do with Transport Canada. However, we deplore the lack of financial resources. We asked for financial assistance from Transport Canada to hold workshops and our request was denied.

Is it possible to apply the SMS concept to businesses of all sizes and is it really relevant to do so? We feel that the bigger the company, the greater the need to have a system that allows for contact and feedback from the frontlines. When a business only has 15 employees or less and when the owners are a part of that, is it really useful to put in place an SMS system? How can we use statistics on security when operations are seasonal or when the volume of activity is so low that trends can only be charted over several years? For instance, where airlines are concerned, an SMS report is generally generated for every 1,000 flight hours, whereas certain Quebec operators have fewer than 700 flight hours per year.

We are facing a considerable challenge. Transport Canada does not in our opinion have the resources allowing it to supervise the implementation of SMS by all of the small carriers and those operators do not have the capacity nor the necessary competence to put in place such a system.

In conclusion, before allowing Transport Canada to prepare training tools and conduct orderly supervision over medium-sized carriers, we suggest that SMS regulations apply to businesses that have more than 15 employees. When this phase is over, it will be possible then to move on to the smaller businesses. These businesses only represent a small percentage of activity in Canada.

Transport Canada authorities told you that they would not accept any compromise insofar as security is concerned. Our proposal to restrict the application is not one that will compromise security but rather a pragmatic measure to ensure that the next implementation phase of the SMS will not once again interfere with inspection activities.

In this way, we will safeguard our reputation in the area of security.

Thank you.

[The Vice-Chair (Hon. Joseph Volpe), Liberal, Joe Volpe]

Thank you, Mr. Prud'Homme.

Now we have Mr. Stephen Nourse, who is the executive director of Northern Air Transport Association.

[Stephen Nourse, Executive Director, Northern Air Transport Association]

Good morning. I'm Stephen Nourse, executive director of the Northern Air Transport Association, or NATA. I'd like to thank all of you on behalf of our members for the opportunity to address this committee.

For those of you not familiar with NATA, the association was formed 33 years ago to represent northern air carriers in the decision-making process affecting transportation in northern Canada. We have about 88 members, including 29 commercial air carriers, all of which operate in the northern and remote areas of Canada. The carriers we represent run the gamut from large jet operators to a small mom-and-pop operation.

In the Arctic and remote regions of Canada aviation plays a very important role in the lives of everyday people. In numerous locations, it is the only year-round access possible, and in many others the only access, period. Aircraft are the local bus, ambulance, and grocery truck. Air service in these areas is not discretionary or solely the purview of the well-heeled. It is simply a necessity.

I don't think anyone seriously considers the north a significant aviation security risk. It is simply too remote, too small, and would not make the headlines. However, the north continues to incur security costs as new requirements keep coming, security requirements that are deemed necessary due to the continued threat against the state. I choose the word “state” very specifically, as the threat has always been against the state, not the actual air carriers. Yet unlike other modes of transportation, aviation is expected to pay all the cost of legislated security measures. This is especially aggravating in the north, where the threat is minimal and the expense is added to the daily cost of living.

An example of where this becomes an issue is cargo security. The concept of having any cargo on a passenger aircraft screened to the same level as the baggage is laudable; however, it brings a cost. In the case of the Arctic, it ends up adding to the already high cost of groceries and other basic supplies. The reality is that the economics of the long thin routes in the Arctic and remote regions drives you to fly combination cargo-passenger aircraft, or “combis”.

Typically, the larger the aircraft the better the operating economics are. You pick the largest aircraft that will carry the passengers and cargo for any given route typically such that you can provide daily service with minimal overcapacity. If screening the cargo to go on a combi becomes prohibitive, either on a cost or logistic basis, you end up going with dedicated passenger or cargo aircraft instead. This forces a choice: keep service levels up by using smaller aircraft for each role; or you only get freight two days a week and passenger service the other three. Either way, the community loses big time, and in all likelihood, costs still get driven up.

One of the major problems facing the northern aviation system is that there simply is not enough of a population base right now to properly support and fund the necessary airport infrastructure. Not only relative to the south is the population minuscule, but the costs of construction are at least an order of magnitude higher.

At the end of this year, many air carriers are facing what will be a no-win decision. To harmonize with the United States, a performance rule was brought in ten years ago that essentially will prohibit many commuter-class aircraft from operating in scheduled service unless longer runways can be provided. It was assumed that, by the end of 2010, either these aircraft would be phased out of service or the runways would be extended. The reality is that neither has happened.

Many of these aircraft still provide the best operating economics for these smaller markets, and the replacement options all need longer runways as well. So at the end of this year, many communities are facing having scheduled service eliminated or will end up being serviced not by twin-engine pressurized aircraft, but rather by single-engine unpressurized ones—hardly an increase in either comfort or overall safety, but we will be harmonized with the U.S.

How did we get to this state? Not through lack of discussion and awareness, but primarily a lack of funds, compounded by the fact that current runway standards impose huge costs once you go beyond 1,200 metres in length.

What's needed? More appropriate runway standards for Arctic and remote airstrips that allow for longer runways without necessarily designing them for large commercial jet transport aircraft would help. An extension to the 2010 rule until things can get sorted out is likely necessary, and most importantly, a better source of funding for these remote airports. The current airport capital assistance program, or ACAP, is both inadequate and too restrictive in scope to properly address the problem. What is needed is some sort of NCAP or northern ACAP to provide the funds necessary to properly develop and maintain these vital pieces of northern infrastructure that are so important, not only to the communities but to economic development of the area and Arctic sovereignty.

Perhaps no topic has had so much attention recently as safety management systems, or SMS. In the beginning the concept was not popular among the air carriers, being seen as an unnecessary cost to them and simply a way for Transport Canada to reduce costs. That perception has changed. The seven okayed carriers with a fully implemented SMS program are recognizing benefits to their organization. The implementation of non-punitive reporting safety cultures, risk evaluation and management processes, and risk-based decision-making are changing and improving their organizations for the better, providing incremental safety gains by addressing human factor areas.

With regard to SMS implementation to the smaller 703-704 operators, NATA feels that Transport Canada needs to be sure that the requirements imposed on them are appropriate to the size and complexity of the operator.

Carriers with fully developed SMS systems now have the internal systems in place to properly deal with performance-based regulation, the move to which NATA is in full support of. Too many times the north has been hamstrung by well-meaning prescriptive regulations that worked fine in the south, but not in the northern reality, thereby forcing us to go to Transport Canada to encourage them to modify proposed or existing regulations or to provide exemptions for northern operators.

We also believe that the systems that SMS brings will enable operators to properly evaluate and justify safe and effective means of alternate compliance applicable to the northern operating regime. The problem here, though, is that although Transport Canada has required all the systems and processes, they have been slow to actually recognize their merit when something is carrier-originated.

My time is up. I would like to thank the committee.

[The Vice-Chair (Hon. Joseph Volpe), Liberal, Joe Volpe]

Wonderful. You used up Mr. Jones' 29 seconds. It's quid pro quo, in business as in government.

I will go directly to Ms. Crombie.

[Bonnie Crombie, Liberal, Mississauga—Streetsville, ON]

Thank you, Mr. Chairman.

Mr. McKenna, let's start with you, sir.

We all agree, I think, that the tools for effective SMS implementation are the voluntary reporting and protection for confidentiality and non-punitive reporting. Is it your impression that the government has moved away from these principles? Why is the government withdrawing inspectors required for effective implementation?

[John McKenna]

Many of these things were covered by Bill C-7. It was actually Bill C-6, tabled in 2006, and eventually became Bill C-7. We have been asking ever since for it to go through, and it hasn't. Yes, we feel that this is a required bill for SMS to go through, to fully implement.

[Bonnie Crombie, Liberal, Mississauga—Streetsville, ON]

Why do you think the government hasn't re-introduced Bill C-7? Is there a lack of commitment there?

[John McKenna]

I couldn't begin to speculate on that. I think it's perhaps a lack of priority in the minister's agenda. I don't think it's a lack of... I wouldn't care to answer that.

We've asked over and over what was happening to that, and we haven't had a clear answer.

[Bonnie Crombie, Liberal, Mississauga—Streetsville, ON]

Can you reflect on the number of inspectors you think are required for effective implementation and inspection?

[Bill Boucher, Vice-President, Operations, Air Transport Association of Canada]

My name is Bill Boucher, John's vice-president.

My view in that area is that it is not a question of numbers but a question of competences that have to be adapted to the type of work that's required in the performance-based SMS environment.

It's obvious that at Transport Canada, from a regulatory oversight and from a level of service perspective, every certificate or approval that's required requires resources behind that. In my 44 years of aviation experience, including five years at Transport Canada myself, resources have always been thin. It's a question of numbers versus competencies and training that comes into play in this area.

[Bonnie Crombie, Liberal, Mississauga—Streetsville, ON]

Have you consulted with the minister as to whether or when this will be back on the government agenda and be made a priority once again?

[John McKenna]

Yes, we have a number of times, with the minister and the department, and we have no clear answer on that.

[Bonnie Crombie, Liberal, Mississauga—Streetsville, ON]

Maybe we can ask the government members afterwards to comment on it.

To Mr. Jones now, the minister took away CBAA's authority to exercise oversight and certification under the SMS. What reasons would have caused this decision?

[Fred Jones]

It is difficult to say. In the minister's press release the minister did not articulate a rationale for it, but only that it was being repatriated to Transport Canada.

It came as a complete surprise to many of us in the aviation community. It is our view, largely without any justification that we are aware of... Insofar as their safety record is concerned and insofar as the management of the program is concerned, I think, in fairness, if anyone thought that the only program of its kind in the world was going to proceed in the absence of a learning process, they were dreaming in technicolor.

So there were bound to be some warts, and the CBAA was in the process of fixing their problems up, but it wasn't a reason to throw the baby out with the bathwater, and that is why we think it signalled a retreat from SMS principles, which are to provide a responsible industry segment with more authority to influence their regulatory environment.

[Bonnie Crombie, Liberal, Mississauga—Streetsville, ON]

But were there any specific incidents?

[Fred Jones]

There were incidents. There were accidents, but the reality of all this, with respect, is that there were accidents and incidents while Transport Canada oversighted the business aviation community prior to CBAA's private operator certificate program, and there will continue to be some accidents and incidents after April 2011, when the minister will have completely repatriated the program. So asking if there are incidents or accidents that occur is really a red herring.

If the question is how did the accidents compare and how many of them, we could live with an analysis like that. It didn't happen.

[Bonnie Crombie, Liberal, Mississauga—Streetsville, ON]

What role do you think Transport Canada should have in oversight certification and overall governance of the industry?

[Fred Jones]

Broadly written, my own view and the view of the Helicopter Association is that there have to be certain controls and processes in place, and this is related to good governance and oversight by Transport Canada, audits by Transport Canada of the program, whoever is administering it. But where industry is capable of exercising that additional responsibility in a prudent way, then I think there should be a maximum of delegation to industry. I'm not saying under any circumstances and I'm not saying in the absence of oversight. I'm just saying that there are already dozens of examples in the aviation community where industry is responsibly exercising authority that has historically been provided by Transport Canada.

[Bonnie Crombie, Liberal, Mississauga—Streetsville, ON]

Perhaps I can ask Mr. McKenna the same question. What do you think Transport Canada's role is in governance, oversight, and certification, from ATAC's perspective?

[John McKenna]

I share exactly what Fred said as far as that whole question is concerned. We feel that Transport Canada's role is one of oversight, and I think they were in the process of adapting to that role quite well. That is why we were all surprised by that decision, also.