Thank you, Mr. Vice-Chair and honourable committee members, for inviting me to speak today.
I am Robert Deluce, president and chief executive officer of Porter Airlines.
Porter is Canada's third-largest scheduled commercial airline. We service some 23 destinations in Canada and the United States. Our fleet is comprised of 29 made-in-Canada Bombardier Q400s, and we employ approximately 1,500 team members.
Although there are many important issues where the federal government regulates and affects our operations, today I’d like to just focus my comments on the forthcoming regulations as they relate to crew fatigue management.
We are absolutely committed to safety, but the regulations as drafted would significantly affect the operations of Porter and many other airlines. The notice of proposed amendment on crew fatigue management was issued in 2014 and was met with concern by many in the industry. However, few revisions have been made. This proposed regulation implements a one-size-fits-all solution to an issue where individual considerations must be taken into account.
Porter has had tremendous success with our self-guided and Transport Canada-overseen safety management system. This allows us to emphasize best practices for safety within our particular operations. The restrictions in this proposed regulation necessitate a substantial increase in our crew numbers. We have to decide between eliminating over 650 flights per month or hiring 68 more crew members—34 pilots and 34 flight attendants—to cover the restrictions outlined in the notice of intent. This would be a 13% increase to our pilot roster. The total cost of implementation would be over $6 million per year in 2017 dollars.
Global demand for pilots is outpacing the supply from Canadian aviation schools. The 2016-17 pilot turnover has been the highest in our 10-year history of operating. The proposed regulation will require every airline to increase their pilot roster by approximately 10%, which for Air Canada—and I’m not speaking for them—and their subsidiaries, including Rouge, would probably mean 300 additional pilots. That happens to be more than Porter's entire roster of pilots. This could be devastating to our operations, as we will either have an insufficient number of pilots or have to revisit standards for training and experience.
A negative policy consequence of this proposed regulation would be the hiring less-experienced pilots in Canada, or having fewer flight options and higher fares for passengers. As only a finite number of trained commercial pilots exist, the world has a shortage and is struggling to meet market demands. Porter and other carriers are already being affected by this, and this particular notice of intent will only exacerbate the current situation.
This proposed regulation does not promote safety, as there is no empirical evidence to support that claim. What it does is to make airlines in Canada less competitive compared to their U.S. counterparts.
In our 10 years, we have successfully addressed any concerns about fatigue with our safety management system. We believe that all carriers in Canada will have more successes with fatigue risk management and safety management systems than by putting in place a one-size-fits-all intent. This allows each airline to adopt best practices and can be monitored by Transport Canada.
Thank you very much. I look forward to any questions.