Yes, please.
Madam Chair, members of the committee, I represent the Canadian Federation of Aircraft Maintenance Engineers Associations, commonly known as CFAMEA. CFAMEA consists of six regional AME associations. We're all volunteer, grassroots, and membership-based. We represent members from across Canada.
The purpose of our associations is to maintain and enhance the standards of professionalism of the AME and the aircraft maintenance industry as a whole, and to promote the rights and privileges of the AME. We hold in high regard the safety of those persons affected by the aviation maintenance occupations. It is our aim to promote safe practices in the workplace and to recognize that safety is the cornerstone of the aviation industry.
Our regional associations run numerous workshops and conferences across the country to educate and update AMEs and others working in the aircraft maintenance profession. We also provide mentoring for aviation maintenance students and participate with the various colleges as advisers on their aircraft maintenance program advisory committees.
We are on the front line to provide safe, dependable aircraft for the public. Here are some of our concerns and suggestions.
First, the level of service from Transport Canada is slow and delays decisions at the operational level. For example, there can be lengthy times to obtain a ferry permit, or prolonged times for amendment approvals of maintenance policy manuals and maintenance control manuals. These delays mainly originate from decreased staff levels at Transport Canada. Lack of timely responses may result in some operators ignoring established procedures, which, in turn, could affect safety. Transport Canada should shift some decision-making back to the industry but still maintain oversight at all times. There is a system in place for ministers' delegates. It works well. Maybe this model of delegation could be applied in other areas of concerns and bottlenecks.
Second, it's important to maintain an open door policy between Transport Canada and approved maintenance organizations and the AME associations. There are various conferences, symposia, and workshops. Interaction with maintenance communities are an important means of communication. The curtailment of funding for staff of Transport Canada regional offices to attend various aviation seminars and conferences has, and will continue to have, a detrimental effect on aviation safety implementations.
Third, updated curricula are required for approved training organizations to deal with changes in aircraft maintenance and to prepare students for obtaining their license. We recommend removing the detailed standard 566.12 Curriculum and the skills requirement from 566 Appendix B and moving them into an advisory circular or other document that would be easier to amend and update.
Fourth, consideration should be given to unshackling the standards from the regulations in order that they can be updated in a more expeditious manner. Currently, changes seem to be taking up to five years. This is unacceptable. Transport Canada has to maintain oversight and control at all times, but let the industry make minor changes to established maintenance procedures.
In order to maintain a high level of aviation safety, Canada has to be able to maintain a competitive playing field with other countries, and we have to synchronize our rules and regulations with those of the European EASA, American FAA, as well as those of other countries.
While the demand for air services in Canada has been growing at an annual rate of almost 5%, Transport Canada's aviation safety budget has been consistently cut. In the face of such cuts, Transport Canada needs to delegate administrative duties and concentrate on improving the level of service of key safety related oversight activities. We implore the House of Commons to support Transport Canada by increasing the funding for this crucial mandate.
Thank you for this opportunity to voice the opinions of the aircraft maintenance engineers. We look forward to future invitations and we request that you invite us back to make a presentation when you review recreational and personal aviation.