Thank you, and good afternoon.
You have a copy of my written introduction notes in front of you. I am going to skip over the mandate of the Helicopter Association of Canada and the part about myself, but I would like to take a moment to introduce Sylvain Séguin, who is attending with me here today. He is vice-president and COO of Canadian Helicopters Limited, the largest Canadian domestic helicopter operator. He is also the immediate past chair of the Helicopter Association of Canada board of directors. He served on our board for the last seven years.
We have structured our presentation to tailor it to the items identified in your aviation safety outline.
Thank you for the opportunity to appear before the committee on the subject of aviation safety, an issue very important to the Helicopter Association of Canada.
We are the national voice for the helicopter industry in Canada. There are currently more than 2,800 helicopters registered in Canada, of which more than 1,800 are commercially registered. In the commercial sector, our industry employs 6,200 full-time equivalents, with employees earning over $500 million annually. With indirect employment, this increases to 8,900 full-time equivalents and a $640-million annual payroll. The average full-time wage is $80,000.
The sector generates GDP of almost $1 billion, and $2.1 billion in economic impact annually. The annual tax contribution is approximately $285 million at all levels of government. We are pleased to provide the committee with a copy of a recent independent economic impact study that will provide more specific details on these economic factors and what it is that the members of the association do.
The Canadian helicopter community is actively involved in the development of industry best practices. I sit on the executive committee of the International Helicopter Safety Team. In the last 10 years, and in the face of rising utilization, we have seen our accident rate decline significantly. I direct you to the HAC website and the International Helicopter Safety Team website for further details.
Helicopters are a unique, vital, and often irreplaceable form of transportation in Canada. We are often the only option to reach many remote locations. We lead and support life-saving missions, including search and rescue, emergency medical transport, and evacuation from disaster-stricken communities. The recent Fort McMurray wildfire and major accidents on the Sea-to-Sky Highway are common scenarios.
Mining and resource sectors are heavily dependent on helicopter services for surveying, development, and ongoing support of major mining and oil and gas developments. Offshore oil, the oil sands, and most mining developments, due to their remote nature, depend heavily on helicopter support, making the helicopter industry a crucial component of the primary economic drivers of the Canadian economy. Without helicopters, these activities could not happen, or they would cost considerably more to carry out.
On the subject of personnel issues, this past week Transport Canada issued a notice of intent to proceed with new fatigue management regulations for pilots, with the draft regulations to be gazetted later this spring. In a letter two months ago, and when we met with Minister Garneau two weeks ago, we specifically asked the minister to pause this process to allow parliamentarians on this committee the full opportunity to do their work with this study. We also asked him to pause while the Transportation Safety Board concluded its investigation into air taxi accidents. Unfortunately, this pause did not occur.
First, let me be abundantly clear. The Helicopter Association supports reasoned efforts to improve aviation safety that are proportional to the risk. These new regulations, however, are not proportional to the risk and will serve only to put our services beyond the reach of Canadians in many areas. Fatigue-related risks are largely being managed in the helicopter industry, which is not to say that some changes should not occur. But the proposed changes will erode safety, not improve it. What's more, when changes do not improve safety, they will make it more difficult and costly for our members to provide essential and life-saving services.
You may have heard, “A pilot is a pilot, and fatigue is fatigue”, but one set of rules cannot apply to everyone. Helicopter operators cannot be regulated on this subject like the airlines. Unfortunately, this view has pervaded the Department of Transport right up to the minister's office, and the result is a flawed, one-size-fits-all set of proposed regulations. They will not improve safety but will erode it, in our view.
Our pilots are subject to fatigue, but it must be addressed differently in our industry than in the airline industry, for the following reasons.
Because of the seasonal nature of the work that we do, particularly our service to remote and northern communities, HAC would argue that the proposed new regulations are more suited to the airlines than they are to helicopter operations. They do not adequately contemplate deployed camp operations, where our pilots live on the job site while conducting remote operations. Helicopter pilots are not airline pilots.
Another reason is the unscheduled work that we do in deployed operations, which is often at a camp setting where replacement crews are difficult to supply, particularly on short notice. There are long daylight hours in northern Canada. As well, it is important to consider the life-saving emergency medical services, or EMS operations, in our work in support of the resource industries.
In the helicopter world, the proposed rules will do little to advance safety and in most cases are not supported by anchor points in the fatigue-related science—most notably in the removal of the zeroing provisions and the use of cumulative duty hours.
HAC would argue that these new regulations will affect safety but in a negative way, particularly for the majority of helicopter operators who provide services in Canada's most isolated regions.
Would limiting pilots to one hour of flying each day reduce the effect of fatigue on safety? I use this ridiculous example to illustrate that the key to balancing the restrictive nature of the regulations with their impact on safety is to ensure that the restrictions they impose are proportional to the risk that they are trying to remedy.
HAC—