During a Transport Canada presentation today, we were told that the fees levied by TC for STC/RDA/PDA applications are under consideration for increase, TC wants more cost recovery. One of the figures presented is that for approval work supported by TC, their cost recovery as around 6% (so the taxpayer is presumed to be funding 94%, I guess). They would like to have the applicant pay more, and taxpayer less.
I presented a cautionary thought on behalf GA owners across Canada, that increasing TC fees increases the cost of perhaps necessary [aging aircraft] repair approvals (RDA), and STC's (be they serialized, of to the fleet). Increased cost will result in decreased aircraft use, which mean less flying for pilots, meaning lesser proficiency, so less safe. Or, simply the more expensive you make flying, the less safe pilots and planes will be. This approach to the argument pops up a TC red flag, as they are not supposed to do things which reduce safety.
TC mentions "European" models for cost recovery. I mentioned that the 182 amphibian which was Canadian, and cost about $350 an hour to operate here, costs more than $750 an hour to operate in Norway, where it now resides. So adopting a European cost recovery model could halve flying - and maybe halve pilot proficiency. I also pointed out that more regulation and oversight is hardly needed for modification and repair of aircraft, that' not the risk we need to reduce. pilots still make errors, and planes crash, we need more pilots flying more - not less.
I mentioned that if TC left the work more to their DAR's, costs wold be lower, as TC would not have so many of their staff hours into projects on older GA aircraft, which were not really at the center of their staff's skill sets. My quoting labour rate is about 1/2 of what they say they internal hourly cost is for a TC Engineer to do approval work (and DARs are usually faster!).
And.... If an aircraft has a defect, particularly an aging aircraft/wear and tear type item, and a mod repair is needed to return it to service, they cannot dissuade the owner with higher costs to maintain a safe aircraft.
The TC staff members to whom I presented this logic were receptive to the concept. But they hastened to point out, that they react to the quantity of comments, much more than the persuasiveness of one. I was the one. Now I'm here to tell ya, that before internet chat groups and social media, I attended a TC CARAC meeting which introduced the prospect of noise compliance requirements (new CAR 516). Future engine and prop changes would most likely require noise testing to demonstrate compliance. This was the first notion that TC Aircraft Certification branch would regulate something other than safety. I pleaded (in writing) that they exempt aircraft under 350 HP, to prevent a situation where compliance would require cost prohibitive noise testing. I contacted several alphabet groups (knowing that a rep from a well known one was sitting next to me in the meeting). I could not raise any interest. In the end, TC reported to me that mine was the only letter of dissent. The rule was enacted, and yes, I have done the testing (for the afore mentioned 182 amphib) - the testing cost more than $15,000. Compliance was shown, but what a cost! If back in the pre CAR 516 days, owners had raised opposition, TC might have listened.
So it's up to you, are you worried that TC would like to recover more than the 6% they do now? If they went from 6% to half, jaws would drop, and aircraft would park. ( I guess that parked aircraft are still safe
). You can't complain about the cost of TC services, if, when they ask, you do not comment! If you're okay with whatever they decide, do nothing. I have written one email and following today's hall chat, will be writing a follow up. I will also be speaking more with a COPA director, suggesting that COPA take this on, on behalf of its members. Bear in mind that approving a mod that I might wish or require on my airplanes is affordable for me - I see the problem, but it is not my problem much. So I, the self appointed AvCanada observer today, report this to you, what would you like to do with that?
