New Approach Ban in the Works

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centerstored
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New Approach Ban in the Works

Post by centerstored »

Apparently, TC is trying to muster up support for another completely idiotic set of regulations. Word has it that TC is trying to create a new approach ban that would devastate the way that 95% of Canadian Air Operators do business...or make their money. The new approach ban will prevent operators from descending to their MDA when the prevailing weather is below the "recommended, or advisory visibilities" listed on our approach plates!! How stupid is this. They have already established that these altitudes are safe, so why should we be unable to complete an approach to minimums because some guy/gal/awos on the ground says the vis is 1 sm??? We need to stand up to this BS bureaucracy before canadian operators take a big bath. :idea:
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Waldo Pepper's Circus
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Approach Ban

Post by Waldo Pepper's Circus »

I think that Transport's idea is excellent and a long time coming. Do the math for a minute. On approach, you're generally flying towards the runway at about 200' per second, at an MDA of around 500' on a NPA. If you consider a runway that is 4,000' in length, and a max VSI in most SOPs of 1000 fpm on final, you will cover about 4,000' from the moment you attain visual with the runway until you have descended from MDA to ground elevation. Yet most approaches place the MAP at or near the threshold, creating an environment where the pilot could chop the throttles for an unstabilized descent rate when spotting the threshold at a distance closer than the recommended vis.

The advantages of this reg would be to create a level playing field where those pilots who currently successfully land at airports having no approach chart when the weather is 300' and 1/2 mile will have to wait out the weather along with all the other operators who abide by the rules and don't even try. Companies following the regs won't continue to lose revenue against these rule-breaking carriers and if the safety records improve, insurance rates should go down.

The only people this reg would affect are those companies without established SOPs who have little understanding of Visual Reference Point concepts and depend on revenues generated from flights where the competition cancels or misses due to weather.
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Post by flyboy »

So Waldo, are you then suggesting putting an end to special vfr and raising vfr minimums in uncontrolled airspace to 3sm vis? Because if they do not make those changes at the same time, your just going to encourage those operators even more to stay vfr, instead of going ifr in their ops.

I can't wait to tell a customer, no we can't go the visibility is only 2sm, and I'm not allowed to do an approach. Maybe we should go rent a 172 and go vfr.
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Post by backon3 »

Of course, TC always uses their heads (do the math) when it comes to approaches in Canada. They make it harder for us to take off and now they're trying to make it harder to land, gone are the good old days when skill was ever a factor. I guess it takes to long to transition from the AFCS to actual flying from the MAP to threshold.
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Post by oldtimer »

I have not read the new proposal but I can imagine that it is a lot like the USA where if you go beow limits, you can be violated. Waldo Pepper's Circus' remarks makea lot of sense. The problem is that many operators are violating limits on a continual basis. Most dummys who are answering this thread are responding like TC is the big bad boy out to spoil your picnic by not letting you throw caution to the wind and land in any weather.
What TC is attempting to do is keep some if not all you assholes from killing yourself and your poor suffering passengers.
CFIT is still the leading killer and this is just one more tool in the battle to help prevent needless death.
You get out on the highways here in the lower mainland where police presence is almost nonexistant and you see people doing the dumbest stupidest things with their automobiles and these same yahoos now get in an airplane and try to do the same thing. That puts me at risk and I don't like that.
It is a well known fact that most pilots think they are much better than they actually are.
How many think they can descend down to 200 ft below limits or sneak in with less than legal vis and do a safe job. I'll bet just about everone will answer in the positive when in actual fact they are doing a poor job and putting themselves at extreme risk. I see it all the time on checkrides. Those that fly a well planned and well executed approach fly to limits and no more.
What TC does that gets me a bit upset is to do little to promote and assist some bright inventor that can come up with technology that will make approaches into airports in marginal safer. Roadblocks deter bright people.
I was on a checkpilots couse recently and someone brought up the fact that a flight safety organization did a survey to determine how many mistakes an airline pilot makes in a day and I was astounded to hear they make an average of 41 mistakes a day.
How many mistakes do you make in below limits weather? How many are yuo allowed until the law of averages catches up with you. At least that is my 2 cents worth.
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Post by wantok »

Go to TC's site and look up the proposed changes in the NPA section of the CARS. They mean fairly major changes. Some of the changes are good; for instance, if you're not equipped with an autopilot you'll have to do a pilot monitored approach. Some of the other changes are:

Anyone that wants to do an approach to minimums will need an Ops Spec. in their Ops Manual.

The aircraft will need a flight director and autopilot. If no autopilot, then a pilot monitored approach must be done.

Also,to do an ILS to mins the airport will need high intensity approach and runway edge lighting.

703 ops will need two crew, even with an autopilot (ie Caravan, etc.)

It's not going to be as simple as just increasing the 1200 RVR approach ban.
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Post by FamilyGuy »

I haven't had time to read the proposed changes yet...but I will. In the meantime, Oldtimer has hit it bang on:

Old pilots, bold pilots, but no old and bold pilots.

I always thought the CDN system of suggested mins was too liberal. Only question now is how in the hell do you enforce it. Hmmm...SkyCops?? Maybe Fox will pick it up :shock:
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Post by Panama Jack »

Yours is one of the best postings I have read in a long time on this forum, Waldo Pepper's Circus. Very well said. Also some excellent observations oldtimer.

Lesson to be learned here-- where common sense goes out the window, Transport Canada is compelled to get involved in the end. As far as the observation that it will change the way 95% of Canadian air operators do business-- I see this as a BIG positive. It is no different than the way business is done in the United States and many other countries. backon3, skill will always be a factor in aviation, but perhaps you have observed, like myself, that about 90% of professional pilots would rate themselves as "above average" when it comes to skills.

This regulatory proposal will help keep everyone honest. It will also create real penalties for those who bend the limits too often (as if the threat of piling it into trees at 120 knots wasn't enough for them). Whilst Transport Canada draws a lot of flak on this forum, in the end, they become the mediator of standards separating operators from the full ire of the insurance companies. :twisted:

How do you enforce it? Well, at MF facilities that is less of an issue (someone is watching). However, do pilots observe the rules ONLY if someone is watching?
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Post by loopy »

This makes perfect sense to me. It always amazed me when you can miss a minimums, and certain companies were getting in all the time. I thought some companies were using different approach plates than me.

This should not be a bad thing.
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Post by Donald »

How will this affect the countless places with neither an approach nor "official" weather? Nevermind what Joe at the Northern/Nursing station says the ceiling and visibility are....
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Post by Panama Jack »

Donald wrote:How will this affect the countless places with neither an approach . . . .
Well, I guess it won't!!! :lol:
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Post by hz2p »

The good thing about an observation on the ground is that it is never, ever out of date, and it always correctly reflects what the pilots sees in the air .... NOT!

The distrust of Transport towards pilots, and the continuing attempts by the people who don't fly, to take authority away from those who do, is frankly quite depressing.

I guess you can just never have too many rules. Since rules create safety, the more rules the safer everyone is.
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Post by jackrabbit »

It won't really level the playing field. At the larger airports where there is an FSS or tower, I don't think I have ever flown on a day where 'some' of the guys are getting in and some aren't. It's usually pretty consistent. So either everybody is breaking the law and being unsafe or not. It's in the north where places have 800 ft mins where you see the inconsistency. Like the saying goes, if it's too bad to go IFR, go VFR, and both are legal.
Also, no one can tell me that it is unsafe to land in say a twin otter on a 6000 ft. strip if I see the runway at the last minute as opposed to one of those tube things. In fact, there is different min. vis. for the different categories of a/c, so some will be able to land and others not???? wierd.
They have all these rules to take off, alternates, take off alternates, RVR requirments, training, etc. I always look at it as once I take off everything I do is dedicated to landing again. Don't make it harder for me to do that. If it's half a mile vis in Churchill, I can still land on their 10000 foot runway if I only see it 1/2 mile away, even shooting the NDB approach. Don't prevent me from trying that if the next airport is an hour and a half away.
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Post by Doc »

I'm still trying to figure out how you'd know the wx is 300 and 1/2 at an airport without some kind of approach? And I can't see a problem with doing an approach to published limits WITHOUT a flight director! If we suddenly need ops specs(not to mention the sudden need for a flight director and a second pilot) to go to PUBLISHED limits, is TC in all their wisdom prepared to admit that the published limits are indeed too low? Methinks not. There is NOTHING wrong with shooting an approach to limits, and, if at limits the runway envirnment is sighted, and a safe landing can be made...then landing. Isn't that the whole idea of the game?
I've found that a lot less pilots are willing to bust limits than have in the past. Waldo me boy...we must shrare a beer!
IMHO, TC's mandate is not to improve safety, but to make it too expensive to even compete!! That, and to create jobs for themselves.
The problem of "pushing" the wx has never been the total fault of the pilot, but more often than not, the pressure placed on him/her by companies...want a list?
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Post by Panama Jack »

Doc,

Based on what I have read, the Transport Canada initiative is to simply create an approach ban based on visibility, not cloud height, as is common practice in many other countries, including the United States.

Since my last post I have taken a bit of time to ponder this topic, as well as it's consequences. A number of years ago I used to fly a light turbine twin into a particular airport (outside of Canada) which, due to the fact that it was on the side of a hill, had very peculiar weather. This is one of those airports that could go from CAVOK to WOXOF within minutes. "Look see" was the technique often used, and the regulations permitted us that luxury. We would be under real pressure, since our operation was very time sensitive and the duty day quite long, the nearest alternate airport (about 7 minutes away) was even less reliable and the next alternate (read last chance saloon) was over an hour away (but was good as gold). There were a number of days when I would observe the first half of Runway 27 socked in (and the tower, which because of it's location was also socked in), yet the first 2000 feet of Runway 09 were under clear blue skies. I would touch-down on Runway 09 under VMC conditions, only to roll-out into a fog bank.

If we were limited by an approach ban such as that proposed by Transport Canada, our operations into that said airport would have been severely affected.

Having said that, I'm going to do a flip. With any regulatory proposal there are those "good people" who suffer consequences, but it also causes benefits to many more. In Canada we have a real problem with air operators pushing limits, as you have identified Doc. There was a thread a few days ago begging the question whether "being a pilot is easy." The physical labor of pulling and pushing the yoke or wiggling the wings is actually quite easy. Where professional pilots earn their keep and respect is through judgment and restraint. This is what makes the difference between a professional pilot and a pilot/owner. The latter often succumbs to "get there itis." Personally, getting into an airport has never been that important to me. I will do my job and try my best, but the zeal ends there.

The problem is that many company cultures have a misplaced zeal of "getting-in" even after Jazz or the other competition goes missed approach. As Doc said, the thread of job termination or living up to the company culture creates pilots motivated to get in. Having an approach ban "helps" the pilot back his judgement and restraint. He will now simply be able to say that the visibility was below published approach minimums, and that's the end of the discussion. A step in the right direction, IMHO.
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Post by wantok »

I have to disagree on your last statement Waldo, that this will only affect operators without SOP's that don't understand visual reference. This will affect even those companies that play by the rules.

In order to fly to mins under the new ban we will have to equip our Twin Otters with flight directors. Will that happen? I doubt it since most of our flying is VFR. This means that we can't use the aircraft to it's potential; we either limit it to 703 ops (9pax) or leave it in 704 but than can never fly to mins, even though that might only be required a few times in spring and fall.

Our Caravans will now need two crew. Will the operator send the second pilot to Flight Safety or just give him a PCC, in which case how much safer is that? If Flight Safety is used that will add more training costs. So much for my raise this year.

Under the new ban non precision approaches to mins will have to be straight in. How many non precisions approaches have circling mins only? These airports could effectively be reduced to VFR, meaning more scudrrunning underneath.

Doc, your comments are right on.
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Post by centerstored »

Many of you people are missing the point! Waldo...nice physics if it is correct...but it's all irrelevant. Pilot's have been given the authority to make the "land don't land" call. We make the call on whether to descend from MDA to the runway when we receive the required visual of the runway environment. I've missed countless times on NDB approaches to mins. We get the runway, can't get the A/c down safely in the 3/4sm remaining, we go home...big deal! That is the PIC's call...and nobody elses. Oldtimer and PJack, you've missed the whole point. This isn't about anyone busting minimums. There are no minimums on landing wrt visibility. You have to see the runway environment. If you see it and you can descend safely then you complete the approach. The operators who always "get in" by busting minimums go below MDA or create their own BS GPS approaches" you know the whole inbound track, direct enter, we're over water, down to 200 feet" thing.

This is about an irrational knee jerk reaction of our regulators. This proposed legislation will not solve anything. In fact it will create more problems and chaos. How? First of all, how many northern airports actually have accurate reported vis? How many times have you been told 1 mile and see the runway from 4 miles back? Operator's bottom line's will be governed by some subjective estimation of visibility on the ground! What about Special VFR and contact approaches?

I agree with the whole PMA scenario. That will make sense. If your pilots are trained with better standards and SOP's, you get to MDA. If not, you cannot descend. The end result in this whole process is that weak dishonest operators lose a few bucks, honest well run companies lose alot of cash, and the entire safety of the air transport industry is jeopardized because everyone is flying at the same altitude...500-1000 feet in marginal VFR weather.
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Post by Cat Driver »

Please allow the Cat to wade in on this one.

Rules in and of themselves are necessary for humans to live in harmony with each other and with nature.

Rules for the sake of rules on the other hand will always be ignored or ways found around them by those who are intent on doing so.

I have not taken the time to read up on the new proposed amendments however there has been several comments here suggesting that more manditory expensive equipment will be required and that will fix nothing.

Like all bureaucracys TC will impose any new rule they see fit to dream up with zero thought of the cost to those being impacted by said rules.

How many "rule makers " do you guys know understand accountability, especially fiscial accountability? :D

Cat
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Post by captpistola »

I guess the last 20 yrs of day to day ADF approaches with no accidents or incidents using the old criteria were unsafe and wrong.
And all those wasted hours demonstrating my ability to execute NP approaches to mins on PPC's and training flts. bang head Thx TC and all the others who will make an already challenging job that much more difficult.

Why didn't I listen to mum and get a job driving a S_hit truck? :?
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Re: New Approach Ban in the Works

Post by CD »

centerstored wrote:Apparently, TC is trying to muster up support for another completely idiotic set of regulations. Word has it that TC is trying to create a new approach ban...
Any idea where one could locate information on this proposal? There's nothing new on the TC website relating approach ban proposals - only the final report of the approach ban working group and associated NPAs from 2000:

Final Report - Regulations Respecting Take-Off Minima, Landing, Minima and Approach Ban Working Group

NPA 2000-001 (602.129 & 602.130) Approach Ban - General and Approach Ban - CAT III

"After two days of meetings, and despite some strong differences of opinion, a large degree of consensus was reached by the SG members. The consensus achieved through compromise was sufficient to formulate recommendations concerning the approach ban and dictate the intent of new regulations and standards. This NPA is one of a package of NPAs which relate to the Approach Ban and include:

Subpart 101 - Interpretation regulations,
Subpart 602 - Operating and Flight Rules regulations,
Subpart 622 - Operating and Flight Rules standards,
Subpart 604 - Private Operator Passenger Transportation regulations,
Subpart 624 - Private Operator Passenger Transportation standards,
Subpart 703 - Air Taxi Operations regulations,
Subpart 723 - Air Taxi Operations - Aeroplane standards,
Subpart 704 - Commuter Operations regulations,
Subpart 724 - Commuter Operations - Aeroplane standards,
Subpart 705 - Airline Operations regulations,
Subpart 725 - Airline Operations standards, and
Commercial & Business Aviation advisory material on pilot monitored approach (PMA)."
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Post by centerstored »

cd, sorry, I haven't been able to locate it either. Just got wind of it a couple of days ago. ATAC is organizing a meeting/petition/opposition to the proposed changes sometime in November in Vancouver for anyone interested. I have yet to see any hard proposal, only reliable word of mouth.
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Post by Cat Driver »

Hi CD.

You didn't choose CD as your name because you admire me did you??? :D :D :D

Cat Driver ( C D )
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Post by Sulako »

I drove to work the other day in pea-soup fog. I was worried I was going to miss the turnoff to the airport 'cause I couldn't see to the side of the road. When I arrived, I looked across the ramp at another medevac operator just shutting down their underpowered pressurized piston twin after landing. The vis was reported at 1/8 of a mile in fog, ceiling zero. Oh, and the ILS was out at the time, the approach in use was a VOR approach. They had to wait 2 hours until the vis. improved to 1/2 a mile so they could leave.

Sooner or later these people are gonna kill themselves and whomever else happens to be on board the airplane.

Would an approach ban help out in situations like this? I dunno. Maybe. But I do think that it removes a lot of flexibility on the approach, and I know that will result in us missing approaches that we have previously safely completed.

That being said, if that's the cost of not watching a plane crash while shooting a VOR approach to 1/8 of a mile, then I would be willing to pay it.
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Post by oldtimer »

I, like many in this post, have not read nor fully understand the implications of all the new proposed changes but this is my general overview of what the primary intent of the regulation changes are all about.
First and foremost, everyone is talking about enforcement and what will happen if the wx goes for chop and you want to go flying.
WOW, someone is about to say no!!! You are not qualified.!!!
WHAT !!! ME !!!! NOT QUALIFIED !!!! THE VERY IDEA.

First, lets look at the NPA.
Are you doing an NPA approach into a well equiped and serviced airport with good facilities?
are you doing a NPA with a modern navaid?
or are you doing an NDB "BEAUFORT 1 into Rubber Boot NWT with a "homemade approach. (BEAUFORT 1 Approach, for the uninitiated is usually a descent on a heading over the ocean to 200 ft on the radar altimeter till visual and then scudrun back to the airport because the wx is below NDB limits)
What is the difference?
Well, these regulations may or may not answer all the questions and we will have to leave that up to the lawyers of the estates of the victims of the crash, because there will continue to be a few of them.
Now, lets get look at the operators.
In one case, we have a small operator from Gopher Hole Sask or Man or Ont. with a clapped out old Navajo that he does an excellent job of keeping airworthy but all he has for navaids is what the airplane came with in 1978 with the exception of a hand held $500 GPS strapped to the steering wheel.
In the other case, we have a highly trained, experienced, simulator trained professional crew with a sophisticated turbine twin with the absolute latest in EFIS, FMS, TCAS, EGPWS, F/D Autopilot and the crews have CRM, and every other kind of training.

Under the existing legislation, both operations have the same limits as far as wx goes. A CAT 1 ILS is a CAT 1 ILS.

Once I get my rose-coloured glasses adjusted properly, I believe the legislators are attempting to answer this anomoly.
We must keep up with technology or get left by the wayside. There is such a large variation in airplanes, equipment and facilities that the current regulations are not keeping up, but keep up we must. Changes have to be made.
Maybe some of us just do not respond well to change and that is tough but changes have to be made. What we need are people like Cat Driver and others who are not afraid to speak up when the legislators overstep their bounds but by the same token, we cannot continue with the status quo.
I know many of us old farts are so proud of our ability to shoot an NDB to limits and split the centerline but lets face it, the ADF should and is going the way of the dodo bird. It is time to start holding funerals for those old pieces of shit. Ask any person responsible for the design of FMS how well the FMS/autopilot will fly an NDB approach and see what kind of reaction you get.
If you get the chance to talk to the pilot of a Gulfstream GV, ask him/her about doing an NDB approach. Alwas good for a laugh.
In the King Air's we fly, we are putting a lot of faith in modern navaids like GPS because they are so much better but how many fly around IFR with a VFR only GPS because of the cost and complexity of certifying. Well, now there is going to be a reward for going the extra distance and a penalty for not. Or at least I sure hope there is.
We did the same with engines. Years ago the TBO was cast in stone and we flew those things to time-ex regardless of condition. We kept running some clapped out pieces of shit simply because the regulations said we could and it was not time yet. By the same token we were disassembling perfectly sound engines because they reach the magic hour that said they were worn out. Now, we run engines on condition and if they are in poor condition, they are repaired but if they are in good condition, they are kept running. Operators are now being rewarded for doing the proper maintenance but penalized for ommisions.
Can any mechanics with years under their belts comment on the reliability of modern engines as opposed to say 20 years ago?

More and more we are getting away from having humans do mundane, repetative actions such as holding altitude and course, That is better left to a machine.
Robots have taken over when it comes to manufacturing our automobiles because if the program is correct, a robot will never make a mistake. Repetative actions will be far more exact than possible with a human but a human can still walk over to the wall and pull the plug. It still requires a human to monitor and intervene when something goes wrong but for the most part, machines will do a better job for us.
Just ask any Airbus driver who can fly a better ILS, the human pilot or the autopilot. How do you get CAT 111 certification?, with multiple autopilots. Just look at the new very light jets that are coming out. Do they talk about "sports car handling" "crisp controls""responsive handling" or do they talk about the sophisticated autopilots and integrated nav systems and all the fancy electronics. In some of those new airplanes, all the pilot does is select destination and say "Giddyup"
It is unfortunate but that is the way of the future.
I have to agree with many who say that some smaller operators will be impacted financially and many will go out of business and is this a bad thing?
Many will say it is and many will say it is better they go out of business before they kill someone.

I do honestly believe most, if not all the new regs are laying the groundwork for the new generation of sophisticated airplanes that are already on the drawing boards. The Aztruck, C310, Navajo have just about reached their "best before" date as far as a frontline working airplane is concerned and it is time for something new.
Is it going to cost more? You bet, lots more. Will we survive, Many will, many won't.
Remember when the price of gas went above :20.9 per litre? Who could afford to drive? But drive we did. I was happy when the price dropped to .80.9/litre here. WOW, a bargain.
People will abandon airplanes for a while but they will eventually all trickle back.

Meanwhile, for the professional pilot, it is no longer going to be good enough to just build hours to call yourself a pro, you are going to need lots of training in areas never before touched.

When I read the answers to some of the topics presented in this forum, it is quite easy to pick out the high time captains from the low time copilots just by their questions and answers. Even private pilots stand out. Good or bad.
Changes are coming, some good and some not so good. Comply or die? I don't know. It may be a wild ride but somehow, I think we will all survive.
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Post by Waldo Pepper's Circus »

Its got nothing to do with the type of engine or propulsion system that makes an aircraft or crew more likely to have an accident. I would love to run the latest Piaggios around the north but unfortunately the majority of my clients are on one form of social assistance or another and simply can't afford to both travel (out of neccessity) and feed their family. Maybe if you agreed to higher taxes so that natives could afford to fly around on the latest and greatest, then safety would improve. It all comes down to what the market can support and. In this area of Canada, customers are so price sensitive that many will place dollars ahead of technology, and this means that pistons will be around for at least another 50 years. We're talking about some people that don't even have running water in their homes yet. If you think they can shell out $6/mile for a KingAir350 then I'll take you on a little tour to show you the 3rd world economy right here in Canada.
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