Another example of an email sent out today. Not as many details as above but hopefully it will help. BTW as a freshly new citizen, it's my 1st time writing to my MP and the Honorable Minister of Transport ! So if i can do it, others should be able to do it as well
It's based on the EAA Canadian council document and PilotDAR's various posts. Feel free to use it, modify it, and improve it !
Greg
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To:
Transport Canada, CARAC
The Honorable Lisa Raitt, Minister of Transport
Member of Parliament
COPA
EAA
UPAC
I am writing to you today to express my displeasure and disagreement with the following Canadian Aviation Advisory Council (CARAC) Notice of Proposed Amendment (NPA) “Responsible Aerodrome Development”.
Transport of Canada has proposed a consulting process for the establishment or expansion of all aerodromes within Canada. It is an onerous and expensive process that will not only restrict aviation, but will add substantial costs to the operating expense of each and every aerodrome or airport.
An aerodrome is any surface that an aircraft can land on and the necessary maneuvering area adjacent to it. If I land my aircraft in a field, a lake or a lane it is an aerodrome.
The proposed amendment will require the aerodrome operator to engage the public. It is estimated within the NPA that the range of cost for a small registered or unregistered aerodrome will be a one time charge of $6,000 to $15,000.
This consultation process must be implemented when a new aerodrome is to be established or changes to the existing level of service at an aerodrome are to be undertaken in a non built-up area if,
1. It is within 4 km of a built up or protected area.
2. It is within 30 nautical miles of a registered or certified aerodrome.
The consultation process need not be implemented if,
1. It is an ad hoc aerodrome (used less than 30 days a calendar year).
2. Modifications do not result in a change to existing levels of service.
3. Aerodrome used solely for agricultural operations.
The lengthy and costly consultation process, consisting of pre-consultation, consultation, signage, newspaper notification and Community information session, must take place within a limited timeframe.
No other use of any personal property comes under such ill advised scrutiny. This NPA will reduce the personal freedom by restricting the use of any property. This freedom has been in place since aviation began, but is now being threatened. Local air strips will eventually be eradicated.
The regulations that are in place for the development of private air strips have been working well for a long time now. There are the occasional abuses of the aerodrome but all should not have to pay for the abuses of a few. If Transport Canada was truly concerned about safety, the few abuses of the system would be addressed rather than generating a one size fits all approach.
If I understand the need for a consultation process when an aerodrome is close to a built-up area, some changes must occur with this NPA.
At least two elements of the proposed regulation deserve consideration for change:
1. 30 miles is a much too great "catchment" distance around other aerodromes.
I suggest that the regulation invoke the "consultation" if the normal traffic pattern of the subject aerodrome would come within one mile of the controlled airspace, or 5 miles of the normal traffic pattern of the "other" (presumed larger/busier) airport. This will allow for fair sharing of airspace. Uncontrolled airspace beside a larger airport is just that - uncontrolled. We don't need this regulation to start to control it. Normal airspace and traffic pattern procedures are already effective for this.
2. The notion of use of an aerodrome 30 or fewer days per year is deeply flawed. Presuming that aerodrome is the private property of a pilot/aircraft owner, by limiting the number of days of use, that pilot's opportunity to maintain their skills currency will be badly impacted. It does not at all serve the public interest to introduce regulation which reduce the opportunities for a pilot to maintain their flying skills and recency. Please approach this from a different direction. Consider limiting the number of aircraft owners who may base aircraft at an aerodrome, and the use of those aircraft.
I propose that the threshold (below which consultation is not required) be: A privately owned aerodrome, with one or two privately registered aircraft owned by the same person.
This would achieve the presumed low utilization, as only that owner, and those one or two aircraft would regularly use that aerodrome, without limiting the free opportunity of that owner pilot to use their aircraft, and remain proficient.
Due to the flawed NPA I would like the Minister of Transport the Honorable Lisa Raitt to withdraw this NPA or at very least send it back to the CARAC committee for a complete rewrite.
Sincerely yours,
