Thank you, Mr. Chair and members.
ALPA is the largest non-governmental safety and security agency in the world. This allows us a unique ability to provide professional pilot expertise.
Our brief, which we submitted earlier, highlights several important areas where aviation safety could be enhanced. For the sake of time today, I would like to highlight one issue: fatigue management.
For many years, Canada has lagged far behind the rest of the world in adopting science-based fatigue rules. While work began in the 1990s, no progress was made until a 2010 working group, composed of representatives from industry and government, developed recommendations for meeting ICAO standards.
In 2014, Transport Canada issued a notice of proposed amendment, NPA, dealing with fatigue management. This NPA very closely mirrored the working group report that, in our view, was very much a reasonable and responsible compromise in order to move the process forward. Although not all of ALPA's concerns were addressed in the report, it was as step in the right direction.
Unfortunately, the 2014 NPA has since been diluted, as witnessed in the notice of intent, NOI, that was recently issued by Transport Canada. While one can only speculate why this has happened, we are aware of many operators that have been lobbying for change to the NPA based on economic or operational concerns, not safety concerns.
In the current proposal, we have five key areas of concern.
One, these rules would not apply to all commercial pilots.
Two, the implementation period for smaller operators is way too long.
Three, if the current proposal proceeds, Canada will have one of the highest monthly flight hours and the highest monthly duty hours in the world.
Four, Transport Canada stated in the 2014 NPA that aerial work, air taxi, and commuter operations accounted for 94% of all commercial air accidents. However, the current proposal not only exempts aerial work entirely, but also gives air taxi and commuter operators four years to comply.
Five, fatigue risk management systems, FRMS, as outlined in the recent NOI, will allow operators to bypass the prescriptive rules without formal approval or oversight from the regulator. What perplexes us even more is that the draft proposal also permits aerial operators—and as I mentioned, the sector that has the highest accident record and that will be exempt from the rules—to obtain further relaxation of the current inadequate rules Canada has in place.
While the rest of the world has progressed in line with international standards, Canada's current rules continue to fall behind. In order to help advance Canadian aviation safety, ALPA recommends that Transport Canada proceed with the prescriptive rules as it proposed in the 2014 NPA, while taking into account ALPA's comments. Additionally, it is important that a one-year implementation period, applicable to all sectors of commercial aviation, be enacted.
Furthermore, we need to hit the pause button on FRMS. We believe in FRMS, but rushing this product to market without proper consultations with industry is setting up for failure. Over the course of your study, you have heard claims that the new regulations would be financially devastating to some operators. Our analysis does not support that.
Let's look at the U.S. as an example. It transitioned to new science-based rules just a few years ago. Initially, the large operators anticipated that they would require 3% more pilots and small operators 7% to 10% more pilots. However, a post-implementation study conducted by the RAND Corporation found that the impact of the new rules on pilot supply and demand was about half of what was anticipated.
To further demonstrate ALPA's concerns, we have provided you with a chart so you can see how Canada compares with several other countries. Green indicates where Canada would be ahead, yellow is for where it would be on par, white is for where data is missing or there's no comparable rule, and red is where Canada would remain behind. As you can see, there's a lot of red.
On behalf of not only our 55,000 members, but all Canadian pilots, we thank the committee for carrying out this very important study. I look forward to your questions on this and on other aviation safety issues.
Thank you, Mr. Chair.