Certainly. Thank you very much, Madam Chair.
Good afternoon, Madam Chair and honourable members of the committee. On behalf of the Air Canada Pilots Association and our 3,400 pilots who fly passengers and cargo on Air Canada and Air Canada Rouge aircraft, I thank you for the opportunity to share with the committee our expertise in aviation safety.
I'm an Air Canada captain who has flown in Canada and around the world. The primary mission of every pilot every single day is the safety of our passengers, crew members, aircraft, and the public. I can tell you that this is true whether you're flying cargo or crossing the Atlantic at night with 250 people asleep behind you. There are many important aviation safety issues that need to be addressed in Canada: runway safety, pilot training, and lighting and navigation systems. I'm going to focus, however, on one issue today. It's something that affects every pilot I know, and that's fatigue.
Canada's aviation regulations do not align with accepted fatigue science. We lag far behind jurisdictions such as the United States when it comes to this vital component of aviation safety. In Canada our outdated regulations currently allow pilots to work for up 14 hours. Under certain circumstances, such as those involving mechanical issues, de-icing, weather challenges, or passenger delays, the current rules allow Canadian pilots to work for up to 17 hours.
That makes no sense. Aviation is terribly unforgiving. Fatigue is a type of impairment. It causes reduced alertness and degraded physical and mental performance, and you cannot self-diagnose that impairment. That's why Canada needs strong fatigue rules.
We've all experienced driving on a long road trip during which your eyes start to close and you pull over, stretch your legs, or roll down the window, but those aren't effective fatigue mitigation strategies, and they are certainly not an option when you're flying over the Atlantic at 3 a.m. The only solution for fatigue is sleep.
I'm not just speaking from experience. The science is clear. After eight and a half hours of flight time at night, fatigue degrades performance. This is based on NASA research that measured brainwave activity and microsleeps in actual flight operations at night. However, these NASA findings were not reflected in the draft regulations released by Transport Canada on March 25.
The good news is that those draft regulations finally introduced time-of-day sensitivity. The bad news is that the draft rules don't go nearly far enough to address the issue of fatigue on long-haul flights at night. The draft regulations propose 10 and a half hours of flight time for departures after 5 p.m. While an improvement, that is a full two hours longer than science recommends. For us as pilots who are responsible for the safe operation of our flights, based on our extensive first-hand experience that is just not good enough.
Our American friends learned the hard way. The U.S. Federal Aviation Administration updated fatigue rules after a flight crashed in Buffalo, New York in 2009, killing 50 people. Fatigue was found to be a critical factor in that tragic accident. Today, U.S. fatigue rules limit pilots to eight hours of flight time at night, making the rules even more stringent than science recommends.
We shouldn't need an accident to improve fatigue rules. Fatigue affects all pilots. Fatigue rules should based on scientific evidence and should draw on the experience and expertise of the pilots who fly these flights at night. ACPA believes that all Canadian passengers and pilots deserve to be protected by the same level of safety.
I hope that the committee's report will recognize the need for strong, prescriptive, science-based regulations to protect against the dangers of fatigue. As a pilot, on behalf of my passengers and on behalf of my crew members I can tell you that safety is not just good business; it's the only business.
I thank you for your time and consideration and I look forward to your questions.