Thanks for the opportunity today.
My name is Glenn Priestley. I am the executive director of the Northern Air Transport Association, and it's a honour to work with such a fine group of professionals. For the sake of brevity, I've included an overview of NATA in a briefing note to provide you with background on the organization.
The three issues I would like to highlight today are the challenges associated with antiquated infrastructure, in the words of our Minister of Transport; the regulator's understanding and knowledge of issues; and the impact of the understanding of regulatory change without sufficient consultation.
We've broken it up into your terms of reference. Under personnel issues, I'd like to start with a quote:
...We cannot attract pilots to live in the northern communities any longer and therefore we must rotate our crews. To have a work life balance the flight crews require sufficient time off after a rotation (typically 2 weeks on and 2 weeks off). To penalize the operator because of its operating in the north is unfair. A good example would be typical [Air Canada] or WestJet pilots that do not reside in the city in which they base themselves out of. The flight crew “position” themselves at the latest possible time in order to instill the work life balance with their families. Because the airline has many flights per day throughout the southern part of Canada the pilot has many opportunities to “position” themselves. Northern communities have one and sometimes less than one flight per day and therefore the time spent by the pilot to “position” themselves is very different.
It's a different set of risks, a different set of challenges.
With regard to the enforcement and monitoring of legislation, NATA believes that's up to the organization doing the operations. Again, using the current proposed flight and duty time regulations as an example, this presentation highlights NATA's concern with a combination of factors of insufficient consultation by informed regulators to develop a set of regulations that will provide no measurable improvement in overall system safety, but will increase costs. That's an administrative example.
Let me give you another example:
...we will be looking for a vast number of exceptions to the indicated rules here with the irregular times that Medevacs are called in. Having all staff rotating into bases because we don't have the luxury of locating our bases out of large southern cities is problematic for the acclimatization side of things. This will require less time off for flight crews as we will have to rotate them up into the northern bases, put them to rest for 24 or 48 hours and then have them work a normal rotation. Their days off will be reduced dramatically and the quality of work life balance will suffer resulting in foreseeable problems....
That was from a pilot who has 25 years of experience and owns a company that's done 100,000 hours of flying accident-free. However, he was never consulted on the flight and duty time rules.
In the briefing note, I show a route map that is useful to illustrate the size of northern Canada. It's about 40% of Canada, or the size of western Europe, with the population equivalent of Moose Jaw or Kingston, and with approximately 100 airstrips, 10 of which are paved. The briefing note also lists several quotes and recommendations from the Canada Transportation Act review.
I will not read them all. The following, however, highlights the northern safety issues:
The heightened risk that attends the use of unpaved, short runways in northern and remote aviation could mean that services are lost, or that there are a higher number of accidents.
As far as the sleep issue, as a former pilot, I know it's far more fatiguing to fly into an airport ill-prepared.
Many of the Nunavut airports could benefit from the installation of GPS systems to reduce flight cancellations or missed approaches that have significant cost impacts to both passengers and airlines.
Let me continue with flight operations because it's a complex issue that northern operators have been managing very well with significant initial investment and ongoing costs. However, due to a lack of infrastructure in the north, many of the advancements in technology cannot be used. We have modern airplanes that can't go into many airports in the north, for instance.
With regard to northern accident intervention, NATA believes there's a root cause system safety issue identified that is evidenced in Transport Canada's development of prescriptive based rules for flight and duty times that do not meet the requirement of the cabinet directive on regulatory management, or the intent of the Canadian Aviation Regulation Advisory Council charter. There needs to be a better consultative process with the northern aviation stakeholders. The regulatory process is too confrontational, leading to diminished overall system safety.
We think it would be useful for Transport Canada to facilitate, in partnership with NATA, a northern aviation system safety committee comprised of stakeholders involved in ensuring safe and efficient aviation transportation. This committee would review the current proposed prescribed rules for flight and duty time, as well as a consultative approach for all future regulatory reviews.
In closing, I think this testimony clearly provides an example of how the regulator, because of lack of effective consultation, has created a problem where one did not exist. Indeed, with regard to flight and duty time:
...[it] will be extremely tough to manage and will no doubt require additional staff to maintain and track these hours in respect to each pilot and the duty day that is allowable. In the Medevac world our hours of operation are undetermined and there are many missions that would not be able to be completed by one flight crew due to stage lengths. (a typical medevac flight in the Kivalliq Region of Nunavut is 11 hours) To be required to change flight crews in the middle of a critical medevac could potentially cause serious negative effects to a patient up to and including death. The vast distances that are required to transport a patient from a northern community to a higher level of hospital care requires long duty days.
Thank you for your time.