Interesting widow, gets me to thinking about how TCCA works at 800 Burrard.
We have a mid level TC inspector sending this kind of letter to the operators of charter businesses.
Yet upon closer examination of said inspectors past record I found this gem.
Inspector was Raleigh Bickford and the manager he made his recommendations to that were ignored was Trevor Heryet
The above seems to contradict his real devotion to safety, seeing as he would not back up one of his own inspectors who it seems had a valid concern about aviation safety with regard to Sonic Blue.
Be very careful who you believe in the shadowed halls of TCCA people, because it is all smoke and mirrors it would appear.
Here is a suggestion, copy this and hang it on your fridge with a fridge magnet, as a reality check when dealing with TCCA.
Trevor J. Heryt
Regional Manager
Commercial and business Aviation
Pacific Region
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The hardest thing about flying is knowing when to say no
After over a half a century of flying no one ever died because of my decision not to fly.
I imagine special provisions might include being instructed by tower to keep on the deck for traffic reasons or maybe a special activity like fish spotting or something?
The 300' on the coast is to avoid hitting cruise ships, ferries, container ships, etc.
That being said, we all do what we have to do to remain VFR sometimes. And who isn't crawling along low, slow and dirty (below 300' with 2 or less miles of vis over glassy water with drizzle on the windshield) keeping a keen eye peeled for that next safe place to set down just in case the weather gets worse? If you're just bombing along obliviously at that point, and not anticipating that it could and probably will get worse any second, well, your days are definitely numbered.
Someone calls you in for being under 300', well, you were scouting a landing zone.
I'm happy to fly on the deck all day long as long as I have my 2 miles of visibility. It's being low over glassy water with less than 2 miles vis and drizzle on the windshield that I hate.
The regs are covering Transport's ass in case someone does hit a boat, but I doubt very many pilots out here have ever been violated for cruising below 300'. Anyone?
I'd be worried that they are going to START issuing violations. I think that's the point. We've seen the discussions here ourselves, about what is and what isn't marginal weather for float ops. Rather than defining the special conditions, Transport is making heavy - to avoid liability. If they give the appearance of enforcing these regs, then no one can say "Transport implicitly condones the action with its own inaction" anymore. The letter does say "in light of recent events in the Pacific Region" ... I don't think it's got anything to do with boats.
widow, it has everything to do with TC making sure they have no liability and nothing else.
As I noted in a previous post the TC official who wrote the letter seems to have selective criteria for what he deems to be serious issues in the oversight of the industry.
From what I have read this guy would not support one of his own inspectors who had concerns about safety at Sonic Blue but he is Johnny on the spot with his veiled threat to enforce this chicken shit issue about flying to low over the water.....Quote the regulations and that solves the problem as far as this gem is concerned I guess.
Makes me want to throw up.
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The hardest thing about flying is knowing when to say no
After over a half a century of flying no one ever died because of my decision not to fly.
At least the internet has given us the tool whereby information can be shared and we sometimes get the names of the TC officials involved in some of these issues.....both the good ones and those who in my opinion defile the intent of the regulator.
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The hardest thing about flying is knowing when to say no
After over a half a century of flying no one ever died because of my decision not to fly.
You know, I think Widow might have it right. This looks somewhat like the precurser to an enforcement initative.
Guess we will have to wait and see.
Interesting that much is posted about common sense, and while it seems to me that AGL could be properly understood include Above Sea level if they happen to be the same altitude, and I have to shake my head that people would try to argue that AGL does not apply to overwater. This kind of semantic loop-hole is more than a little of the reason that the CARS are cumbersome..try and put them in simple , plain language and you end up with "interpretations".
As to the difference between private and commercial operators, I think the poster that said it is all about paying the paying passangers was about right...and as we have seen on these forums, there is pilots that want to get around that.
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Accident speculation:
Those that post don’t know. Those that know don’t post
Cat Driver wrote:The real killer is low ceiling low vis and glassy water.
Yeah been there done that a few too many times, I have yet to land in that stuff except as a pretty junior guy flying norseman of all things. I was never happy in the few hrs i flew that crate on the coast. im talkin mid north coast area. If its dehav u can stooge around nice and slow and crack a bit of flap and peer through the fog looking for boat masts -im talkin < 1mile vis and indefinite cig, I really miss it
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You will never live long enough to know it all, so quit being anal about it..
I guess you could always claim you were doing multiple approaches and overshoots. Always in the process of landing or taking off. Yes sir your honour, the runway always seemed to be obstructed, besides there was lots and lots of runway left.
Maybe TC should look out their front window and see what's happening inside the YVR control zone. Everyday we're out there breaking the 300' rule between salmon, sandheads and beebee either flying on the deck to avoid other seaplanes or taking the shortcut around the tip of the jetty to get to the harbour.
If TC decides to enforce the regulations as written and as they see fit to interpret the regular sea plane sked flights in the Vancouver - Victoria - Nanaimo areas will have a lot of delays.
Especially the airplanes that are operating under 704.
If Vancouver or Victoria are giving ceilings of lets say 400 feet overcast and visibility of ten miles can they depart in say a Twin Otter?
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The hardest thing about flying is knowing when to say no
After over a half a century of flying no one ever died because of my decision not to fly.
Here's a question. MJM Air, had in their Ops manual, the following:
4.3.4 Uncontrolled Airspace Weather Minima
b) Where day operations are conducted at less than a 1000 feet above AGL;
i) flight visibility must not be less than 2 miles (unless authorized in AOC); and
ii) the aircraft is operated clear of cloud.
I can only assume this is common for float ops manuals ... Does this, perhaps, constitute the "special provision" to get around the 300'/500' AGL rule?
Go with 9 pax or less and you can flip into 703. Have yet to figure out what the diff between 9 or 10 is when it comes to operations. Did it all the time, Be 1900 with 9 pax same rules as a twin comanche. Go figure.
Widow wrote:The letter does say "in light of recent events in the Pacific Region" ... I don't think it's got anything to do with boats.
I believe it has everything to do with boats. What else are they worried about a floatplane hitting below 300' over water in the Pacific Region? Recent events are probably wide-eyed ferry captains spotting Beavers at the last minute coming at them in the opposite direction at lower car deck altitude.
fogghorn wrote: u can stooge around nice and slow and crack a bit of flap and peer through the fog looking for boat masts -im talkin < 1mile vis and indefinite cig, I really miss it
Less than a mile and indefinite ceiling isn't just illegal, it's deadly dangerous, bad decision making and an accident waiting to happen. Don't take off, turn around or set her down before you get to that situation.
It's hard enough at 2SM. Less than 1SM is trouble.
zero wrote:Maybe TC should look out their front window and see what's happening inside the YVR control zone. Everyday we're out there breaking the 300' rule between salmon, sandheads and beebee either flying on the deck to avoid other seaplanes or taking the shortcut around the tip of the jetty to get to the harbour.
I'm guessing that would be one of those special provisions, inside a CZ (therefore on radar) and directed by tower.
Widow wrote:The letter does say "in light of recent events in the Pacific Region" ... I don't think it's got anything to do with boats.
I believe it has everything to do with boats. What else are they worried about a floatplane hitting below 300' over water in the Pacific Region? Recent events are probably wide-eyed ferry captains spotting Beavers at the last minute coming at them in the opposite direction at lower car deck altitude.
I think the likelihood is that it has more to do with a certain crash on Thormanby Island ...
The tragic Thormanby accident had nothing to do with the height of the island and everything to do with lack of forward vis. How else could an experienced guy fly into it? We will never know what really happened, but I think it's safe to say that had the pilot seen the island out his windshield, he wouldn't have flown into it.
300' also happens to be the height of the tallest bridges on the supertankers cruising the straights.
Widow. I can say I always took exactly the same precautions whether I had 1 or 19 pax on board. That's why I wonder why the difference in op's spec for exactly the same airplane. I can't see any better because there are only 9 pax on board, neither is weight an issue and speed negligable 2 maybe 3 knots. Heck there's probably that much error in some ASI's. And the lawsuits from 9 would sink most carriers so 1 more doesn't really matter in that aspect.
One more law suit when added to the cost of upgrading a small fleet (or one aircraft) to meet the regs/standards for a/c carrying more than nine pax (cost to the operator AND cost of the regulatory oversight) ... I still say, $$$
Anyway, even ALPA sees not logical reason for the differences:
In Canada, there are three sets of rules for three levels of service. Canadian Aviation Regulation (CAR) 705, the most stringent, applies to airline operations in aircraft with 20 or more seats. CAR 704, with less stringent rules, applies to commuter operations in aircraft with 10-19 seats and CAR 703, Air Taxi operation rules, applies to commercial operations in aircraft with fewer than nine passenger seats.
ALPA maintained there was no logical reason for this distinction in safety levels for scheduled passenger service. At the time, this multi-tier approach to safety was reflected in the higher accident rates for regional airlines. In Canada, separate studies have been conducted to understand the higher accident rates in the air taxi sector.
I had a discussion a while back with a Pasco pilot who said "he was just doin what we do out here and it didn't work out for him", referring to the latest CFIT in the Goose. (as if it only didn't work out for HIM)
I had to literally bite my tongue and walk away at the risk of blowing a gasket.
Am I missing something?
Is it Russian Roulette when you get in one of these airplanes?
Is there such a thing as PDM or is it just the ol' Boys Club runs the show and if ya got the balls, you're good to go? Is there anybody in the company who's got the balls to bust someone down for blowing limits?
Seems to me like the limits are like the good old days when the boys flew from camp fire to camp fire to deliver the mail... no camp fire... turn back and look for the last camp fire.
After 100+ years of navigating at tree tops, you would think the margins would be better, and the pilots would be more afraid of dying.
Is 300' really that restrictive to you? How often is it ever of any benefit to you to be able to go below that? And I know you've got decades of experience doing this stuff, but remember these are the same rules that apply to guys on their first season, guys who haven't flown for a long time, etc. It's always a little safer to be a little further from the ground, and if you consider some of the days with sh*te vis, being a little higher up would've saved some folks the fate of meeting power lines, islands, etc. And if there's an actual law in place people might go to the trouble of figuring out what altitude they'll need BEFORE hand and hold to it. And of course, with so many 703 craft being single-engine pistons, it's going to give you a little more time to figure things on an engine failure. So .... what is it I'm missing about this law that's SO terrible you've been railing against it for what, 4 pages now?
It's always a little safer to be a little further from the ground, and if you consider some of the days with sh*te vis,
The visibility is not the issue here because we all agree that the one mile forward visibility is safe, as long as you know where you are and know the area. You are not going to fly into wires if you know the area and you are not going to hit a ship if you can see it a mile ahead of you.
The issue is how is safety compromised flying at say 100 feet over water when you have the legal safe forward visibility?
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The hardest thing about flying is knowing when to say no
After over a half a century of flying no one ever died because of my decision not to fly.
When flying VFR, good knowledge of the route, alternates and weather (current and norms) for the area are ESSENTIAL for safe flight. Flying around the wet coast, there's a good chance on any given day that you'll run into a low cloud/fog bank. You're either gonna have to turn around or go OTT (assuming you're authorized in your AOC) in order to stay within the regs. I think the issue is, 300' AGL in a wheeled plane (which needs something resembling a runway for safe landing), is quite different from 300' AGL in a floatplane (which uses water for safe landing). In a wheeled plane, 300' doesn't give much time to find a suitable place to land. In a floatplane, assuming you're flying over water, you've got your suitable place to land ...
I'd guess, in a floatplane, you would be a lot safer staying 200' above the water than 300' above the rocks.
