ATTENTION all 702 703 Operators!

[trey kule]

Firstly, there was, and I believe still is, a company in Canada that sells a very inexpensive computer program that can give you the duty hours of every pilot in a company in a minute or two...and I expect they will modify the program if things change. Even red flags.

Duty time off the top of your head! Thats a joke right?

I do hope that individual pilots will indicate their support for this change , or companies will put huge pressure to not have it come into force....and without the other side support, they may get their way.

The arguments by one or two operators here, I hope are not indicative of the majority, or there is a bigger problem than I thought. Their thinking and logic is rather unique and very self serving.
So much for proactively trying to mitagate risk.

[flyinhigh]

The argument I here from operators is NOT the reduction in duty day. It's how complicated it is with the Flight duty period, which is also my bone.

You want to reduce fatigue, Fine, I'm all for that. But reduce the total duty day, hell put it to 8 hours if you worried about it that much. With the way it is written, it is way to complicated (than again we are talking about TC, which makes sense to them).

For those that think they understand this, you better read it again, than go sit with about 10 other people that have a GOOD understanding of this and have a morning sit down discussing it. Remember when RVOP/LVOP came out, EVERYONE had a different understanding of it, the same is happening here.

[duCapo]

Deadline to respond to NPA has been extended to October 15th. As an operator of 7 703 Beavers, this is going to cost us in extra pilots needed and cost the existing pilots a loss of revenue. There were no representatives from any 703/704 companies fixed wing. Major consultation and rework of NPA is needed

This is a perfect example of why we need the regulations to be changed.

Operators who when faced with increased costs, respond by slashing pilot wages. No thought to increasing prices...nope...its all about how much it will cost and how you will reduce costs, not change prices. No concern whatsoever that it might make their operation safer.

Now tell us about your management's commitment to safety, and your management of fatigue. If you are going to have to hire more pilots, sounds like your limitation is regulatory only. Zero concern for the human factor. Perhaps if you had given a bit more thought about the people who work for you, the effect of this change would be zero.

The reason for the new regulations being required, is because there are operators out there who will work their employees to the legal limit without any consideration fatigue..
And the lowest of the low, when faced with the government stepping on to do what they should have already done, threatens pilots with salary cuts.

Maybe we could start a thread on the mysteries of high pilot turnover!

Who the F@#k are you to start slinging accusations at me and my company. Maybe you should think about it before you start slagging a company you nothing about.
EOM

[timel]

Ducapo, could you explain us in which way this new regs are going to effect your business and pilot wages?

[eh3fifty]

Ducapo, could you explain us in which way this new regs are going to effect your business and pilot wages?

[805ITT]

To say just raise prices is quite unfair, there is always a tipping point to A) price yourself out of the market because your customer can no longer afford you or B) price yourself to allow for competition to enter the market.

Pilots - look on the bright side, if this NPA goes through as is it will create 400ish new cruise relief pilots in Canada as AC, Transat and WJ will now need to double augment their long haul flights. Tied in with a bunch of guys hitting 65 at AC and we are going to see a hiring boom in 2016 like we have never seen before. Keep those resumes up to date, hiring is going to get crazy!

[timel]

For pilots who wish to testify about fatigue experiences:

CARRAC@tc.gc.ca

Hi,
Absolutely, we welcome personal experiences as part of the input we are collecting and have received a few personal testimonies from pilots to date. This email is the correct address and feel free to leave out your employer if that makes you more comfortable.

Regards,

Melanie


Mélanie Drouin
A/Manager, Civil Aviation Regulations Advisory Council | Gestionnaire par intérim, Conseil consultatif sur la réglementation aérienne canadienne
Transport Canada | Transports Canada
Place de Ville, 330 Sparks Street, AARBH
Ottawa, Ontario K1A 0N5
melanie.drouin@tc.gc.ca
Telephone | Téléphone 613-990-1415
Government of Canada | Gouvernement du Canada

[duCapo]

Ducapo, could you explain us in which way this new regs are going to effect your business and pilot wages?

Too many "know it alls" on AvCanada with little or no experience in business to get into it on an open forum.

[Heliian]

I would just like to point out that your FDP ends when you shut the engines off and have no more flights. All the work you do after that does not count to your duty period like the current 30 minutes or however you interpret it.

This is why they go through the whole NPA process, to serve fair warning and to allow you to prepare for changes. If you can't tailor your operation to meet the new requirements or make a good schedule for your crews then you don't belong here.

Changes to your organization may cost you revenues or it may not, we can all make scenarios up that won't work with the new hours, but why don't we focus that energy on creating solutions to these "foreseen" problems.

[NotDirty!]

I see this as a mixed blessing for flight crews. Yes, you don't have to work as long, but it probably means that your days off are going to suffer to compensate. Now instead of being able to work long blocks on and getting long blocks off, these new rules will put an end to that. If you are restricted to 60 duty hours in 7 days, you will essentially turn into a pumpkin after the 5th day, if not sooner (1/3 of the time spent on standby counts as duty, so even if you sit all day "on call" and don't get called, it still counts 4 hours towards your duty limit). Not to mention, the 1928 duty hr/365 days is going to affect almost everybody, especially anybody whose work involves single day trips with long holding. That limit seems awfully low, when you consider that in other jobs you can work 150 hrs more than that and still not be eligible for overtime! Welcome to the 37 hr work week!

Why are you restricted to 2 sectors following a split duty break? My total duty day is already limited by number of sectors flown, but the split duty day allows me to extend that slightly... but what if I have to make 2 or more stops on the way home?

The night duty restrictions are going to hurt air ambulance operators a lot! No more than 3 consecutive nights?? ok, there is an ability to extend to 5 nights, if you have a 3 hr break every night, but that only helps freight drivers--medevac guys don't get a guaranteed 3 hr break!! So those guys doing 4 days/4 off/4 Nights/4 off are going to lose out!

Did anybody else notice that there are 6 different duty day limits for starts between 4:30 and 7:00? Isn't there a simpler way?

The FAA imposed VERY similar regulations earlier this year, but with only 10 different start of FDP blocks (but 7 different number of sector columns). Here's a hint to save operators some $$ - IF this is the way it has to go, just copy FAR 117! That way, all of the apps and other software for time tracking for FAA operations can be used by Canadians, without someone having to develop unique Canadian tools.

[NotDirty!]

I would just like to point out that your FDP ends when you shut the engines off and have no more flights. All the work you do after that does not count to your duty period like the current 30 minutes or however you interpret it.

It's actually "no intention for further aircraft movement by the same flight crew member" which I see as a "dig" at those operators who have previously had their off duty (gaining their required duty rest!) flight crews taxi their aircraft from the gate to the hangar, often reducing the time free from duty well below the (correct) interpretation of the current CARs. Presently, the CARs does not add any time for post flight duties to your "duty day" for 702/203 (it's 15 minutes for 704/705), but your "time free from duty" should mean just that... free from duty!
The NPA defines "Rest period" with "... flight crew member is free of all duties", so you have to be parked with engines off within your 13 hr or less FDP, but your rest period does not start until you are free of all duties, so your next FDP is limited by when you are actually released from all duties.

[eh3fifty]

Presently, the CARs does not add any time for post flight duties to your "duty day" for 702/203 (it's 15 minutes for 704/705), but your "time free from duty" should mean just that... free from duty!
The NPA defines "Rest period" with "... flight crew member is free of all duties", so you have to be parked with engines off within your 13 hr or less FDP, but your rest period does not start until you are free of all duties, so your next FDP is limited by when you are actually released from all duties.

Bingo!

End of duty time for 703 is engines off and for 704/705 it's 15 minutes after... as a minimum, by law. If you are still performing duties then you are not done your duty day. If my company wants me to fill in the paperwork for the flight afterwards and talk to maintenance about snags I've written in the book then that'll be part of my duty day. My duty day does not end until I'm done performing the duties listed under my position in the Company Operations Manual. If the company is forcing me to have my duty day end at engines off for 703 then I'll be walking straight off the airplane and to my car.

And that's based on the current regulations. You should already be following this. These new proposed regulations should make this matter even clearer though.