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.