Hi,
Any idea when this will come into force? http://gazette.gc.ca/rp-pr/p1/2013/2013 ... 3-eng.html,
Regulations Amending the Canadian Aviation Regulations (Part
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Re: Regulations Amending the Canadian Aviation Regulations (
"These proposed amendments would come into force 60 days after the day on which they would be published in the Canada Gazette, Part Ⅱ."
The posting you listed is the notice for public input and consultation. Keep an eye on Part II of the Canada Gazette for the actual amendment.
The posting you listed is the notice for public input and consultation. Keep an eye on Part II of the Canada Gazette for the actual amendment.
Re: Regulations Amending the Canadian Aviation Regulations (
Well I was able to read that.
They met in 2008 and were all in agreements with the proposed changes. Who in Transport canada or in the government handle or manage these changes? I called several times and nobody seems to be in the "know". Who is controlling the ship?
They met in 2008 and were all in agreements with the proposed changes. Who in Transport canada or in the government handle or manage these changes? I called several times and nobody seems to be in the "know". Who is controlling the ship?
Re: Regulations Amending the Canadian Aviation Regulations (
Martin J. Eleyacheo wrote:Who is controlling the ship?
Director General, Civil Aviation
Transport Canada
Civil Aviation
330 Sparks Street
Ottawa, Ontario K1A 0N5
Canada
Telephone : 613-990-1322
E-mail : martin.eley@tc.gc.ca
Re: Regulations Amending the Canadian Aviation Regulations (
Its the second part that was important. Regulations do not exist until published in Part II of the Gazette. It will have an implementation statement, some regs have a longer period until they become law, some come into force when published, this one appears to have a 30 day implementation.acheo wrote:Well I was able to read that.
They met in 2008 and were all in agreements with the proposed changes. Who in Transport canada or in the government handle or manage these changes? I called several times and nobody seems to be in the "know". Who is controlling the ship?
Part I is where proposals (regs, acts,etc) are published for comment. The one you sited was published Feb 14th this year with 30 days to respond. It the responses identified a needed change, it goes through the process again (I identified a required change in a proposed labour code reg once. As written you had to have both hands on a ladder at all times. Makes going higher than one rung difficult!).
Having been involved in the process of making regulations, I can tell you that it is a bunch of middle or senior bureaucrats that write it and then it goes to legal for wording.
So it is anybodies guess when it will appear in the Part II of the Gazette, it may have already done so, you can search the archives at the Canada Gazette site. FYI industries, individuals, corporations,etc that can be affected by regulatory changes often hire searching services who stay on top of all govt publications and report items of interest to their clients. In my past job I read the Gazette every week. (boring!!)
It doesn't surprise me no one you talked to was aware of the change. Departments often do not let their staff know until it is published, in case it a) doesn't get published for a variety of reasons, or b) it will be published but with changes. Because I read the Gazette, I was often aware of changes before staff in the responsible department were aware. It used to piss them off no end!
Re: Regulations Amending the Canadian Aviation Regulations (
I called at the Ottawa office earlier this spring and they had no idea whay I was talking about. Then I called the Montreal office, same thing. Then 4days latter I got a call from Montreal and they had found it. Unfortunately, they had no date in mind.
Re: Regulations Amending the Canadian Aviation Regulations (
The Gazette link you posted provides the following contact info:
From the Government of Canada electronic directory:Chief, Regulatory Affairs (AARBH), Safety and Security, Transport Canada
Place de Ville, Tower C
Ottawa, Ontario
K1A 0N5
Telephone (general inquiries): 613-993-7284 or 1-800-305-2059
Transport Canada, Regulatory Affairs
330 Sparks Street, Ottawa, Ontario K1A 0N5
Telephone : 613-998-8358
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Re: Regulations Amending the Canadian Aviation Regulations (
A Canadian Multi-Crew Licence?
Canada's Flight Training Reputation
Trying to keep Canadian flight training competitive is a laudable goal. We have a well-deserved reputation for competence, earned the hard way by flying in our terrible weather around our huge unpopulated country with plenty of pressure to get there (sooner or later) because it's often the only way to get there.
Much training business has come to our shores because of this reputation. The way to keep it coming is to maintain and bolster our good reputation in these trying times.
Loss of Control Accidents
In the last decade the character of airline tragedies has changed completely. Modern aircraft are so reliable that engine and system failures are rare. Aircraft and crew are designed and trained to deal with these failure if they occur. What we are seeing instead are crew failures.
These have come to be called loss of control accidents. The well-known examples are AF447, Colgan Air at Buffalo, and now Asiana 214 at San Francisco. There are many more, including, most recently, Southwest at LaGuardia. These accidents were all caused by crew action (or inaction).
(That includes, by the way, AF447 and Colgan, in which icing played a peripheral role. Flying into known icing is something for which the crew is responsible.)
These accidents all have something in common: pilot incompetence.
I know that sounds harsh, but it must be said. It is an accurate statement. The pilots in these cases may have known their airplane fairly well. They may have memorized their company's operating manual and their Standard Operating Procedures. But in all cases they did not understand some of the basics of flying an airplane. Colgan and AF447 fell into the ground or sea with the wing stalled, not flying, because the pilots pulled back on the control column and held the back pressure despite warnings and stick shakers. The Asiana crew pulled back to stretch their glide, even though they were far gone on the back side of the drag curve, within a few knots of the stall.
What is missing in these cases is basic flying training. The causes are legion and still being debated, but the fix is simple. In order to get a licence, especially a licence to fly a large airplane with many paying passengers aboard, a pilot must demonstrate an ability to take off, fly, and land an airplane while keeping it within its safe envelope. He must, in other words, demonstrate competence.
Commercial Reasoning
Canada's proposed Multi-Crew Licence has this as its rationale: Canadian flight training operators providing commercial training to foreign candidates are unable to compete with foreign operators and risk losing a segment of their industry (my emphasis).
Under various names, the Multi-Crew Licence has had a role in most loss of control accidents.
On the face of it this licence seems reasonable. There is always a Captain who has a real licence to supervise the others with lesser licences. But on closer inspection what we are really saying is that a pilot who cannot legally take a friend for a ride can occupy a cockpit seat while the captain is back in First Class (AF447, and the Korean Air flight shot down over the Kamchatka Peninsula). We speak of Crew Concept and Crew Resource Management, but if the only pilot who understands the basics is not on the flight deck, these concepts are moot.
Commercial pressures have brought us, step by innocent-seeming step, to where we are today. Each step seems reasonable, at least at the time. We now routinely fly two-engine airplanes on twelve hour overwater legs. Back in the 1970's that was unthinkable and illegal. In those days airplanes didn't land themselves. Now they can, under the right conditions, and some operations manuals even specify autolands as the normal procedure. Pilots who comply are soon incompetent, unable to land the airplane by hand. But in San Francisco last month the glidepath transmitters were shut down on both runway 28's. Indeed, they had been off since June 1. Manual landings were the only way at KSFO.
The Multi-Crew Licence seems like a logical next step in response to today's commercial pressures. In reality, it is the next step toward complete incompetence on all flight decks.
Public Assumptions
Airlines have done an excellent job marketing a service that whisks you to another continent at half the speed the sun moves. Even with today's oil prices, ticket prices are (in today's dollars) a fraction of what they were in the 1960's. This is the new normal. Flights are uneventful. Pilots are bus drivers. Airplanes land themselves, don't they?
An airplane crashes at San Francisco. There must have been something wrong with the engines. Or perhaps the autothrust? A nosegear collapses on landing at LaGuardia? Obviously a mechanical malfunction.
Marketing has succeeded in making aviation seem safe. But even though airplanes have changed since the 1930's, flying is still a dangerous adventure. The safe arrival of even today's incredible airplanes still depends on the good judgment of pilots.
We don't want to think about that, because pilots are people and can make mistakes. But we'll have to start thinking about it, and acknowledging it, or the crashes will continue.
Feeders, Discount Airlines, and the Elimination of Apprenticeship
Flying is an apprenticeship trade. Like any job worth doing, it takes dedication and a lifetime of learning. I have 45 years and 19,000 hours of experience and I am just beginning to understand how little I know. But I have survived so far and I am very serious about continuing to survive. Dying by your own hand at the controls of an airplane is an absolute no-no for a pilot.
I was lucky. I have had (and still have) many fine teachers. When I was a young airline pilot most captains still took their teaching responsibilities seriously. Today's young pilot is not assured of the same. Pressure on unions and pilot salaries is being applied by business methods: spawning and dividing feeders and discount airlines foremost among them. The goal is to lower costs, but the (perhaps unintentional) byproduct is the interruption of the contact between old and young pilots and the teaching and learning that allows. (I believe that lowering wages also directly reduces respect for the job and the job satisfaction of the worker, but that is an argument for another time.) The FAA's response to the Colgan Air crash was to raise the experience requirement for First Officers to 1500 hours, even though it was the captain who was flying and who stalled the airplane and even though the airline had given insufficient training to both pilots on icing and how their aircraft handled ice. I have always understood that pilots are paid to be responsible. I am bemused by today's response to accidents, where band-aids are liberally applied to wounds which obviously require surgery.
Conclusion
Introducing a Multi-Crew Licence in Canada would be just another band-aid papering over the serious issues facing aviation today. Don't do it!
chris@formercaptain.ca
Canada's Flight Training Reputation
Trying to keep Canadian flight training competitive is a laudable goal. We have a well-deserved reputation for competence, earned the hard way by flying in our terrible weather around our huge unpopulated country with plenty of pressure to get there (sooner or later) because it's often the only way to get there.
Much training business has come to our shores because of this reputation. The way to keep it coming is to maintain and bolster our good reputation in these trying times.
Loss of Control Accidents
In the last decade the character of airline tragedies has changed completely. Modern aircraft are so reliable that engine and system failures are rare. Aircraft and crew are designed and trained to deal with these failure if they occur. What we are seeing instead are crew failures.
These have come to be called loss of control accidents. The well-known examples are AF447, Colgan Air at Buffalo, and now Asiana 214 at San Francisco. There are many more, including, most recently, Southwest at LaGuardia. These accidents were all caused by crew action (or inaction).
(That includes, by the way, AF447 and Colgan, in which icing played a peripheral role. Flying into known icing is something for which the crew is responsible.)
These accidents all have something in common: pilot incompetence.
I know that sounds harsh, but it must be said. It is an accurate statement. The pilots in these cases may have known their airplane fairly well. They may have memorized their company's operating manual and their Standard Operating Procedures. But in all cases they did not understand some of the basics of flying an airplane. Colgan and AF447 fell into the ground or sea with the wing stalled, not flying, because the pilots pulled back on the control column and held the back pressure despite warnings and stick shakers. The Asiana crew pulled back to stretch their glide, even though they were far gone on the back side of the drag curve, within a few knots of the stall.
What is missing in these cases is basic flying training. The causes are legion and still being debated, but the fix is simple. In order to get a licence, especially a licence to fly a large airplane with many paying passengers aboard, a pilot must demonstrate an ability to take off, fly, and land an airplane while keeping it within its safe envelope. He must, in other words, demonstrate competence.
Commercial Reasoning
Canada's proposed Multi-Crew Licence has this as its rationale: Canadian flight training operators providing commercial training to foreign candidates are unable to compete with foreign operators and risk losing a segment of their industry (my emphasis).
Under various names, the Multi-Crew Licence has had a role in most loss of control accidents.
On the face of it this licence seems reasonable. There is always a Captain who has a real licence to supervise the others with lesser licences. But on closer inspection what we are really saying is that a pilot who cannot legally take a friend for a ride can occupy a cockpit seat while the captain is back in First Class (AF447, and the Korean Air flight shot down over the Kamchatka Peninsula). We speak of Crew Concept and Crew Resource Management, but if the only pilot who understands the basics is not on the flight deck, these concepts are moot.
Commercial pressures have brought us, step by innocent-seeming step, to where we are today. Each step seems reasonable, at least at the time. We now routinely fly two-engine airplanes on twelve hour overwater legs. Back in the 1970's that was unthinkable and illegal. In those days airplanes didn't land themselves. Now they can, under the right conditions, and some operations manuals even specify autolands as the normal procedure. Pilots who comply are soon incompetent, unable to land the airplane by hand. But in San Francisco last month the glidepath transmitters were shut down on both runway 28's. Indeed, they had been off since June 1. Manual landings were the only way at KSFO.
The Multi-Crew Licence seems like a logical next step in response to today's commercial pressures. In reality, it is the next step toward complete incompetence on all flight decks.
Public Assumptions
Airlines have done an excellent job marketing a service that whisks you to another continent at half the speed the sun moves. Even with today's oil prices, ticket prices are (in today's dollars) a fraction of what they were in the 1960's. This is the new normal. Flights are uneventful. Pilots are bus drivers. Airplanes land themselves, don't they?
An airplane crashes at San Francisco. There must have been something wrong with the engines. Or perhaps the autothrust? A nosegear collapses on landing at LaGuardia? Obviously a mechanical malfunction.
Marketing has succeeded in making aviation seem safe. But even though airplanes have changed since the 1930's, flying is still a dangerous adventure. The safe arrival of even today's incredible airplanes still depends on the good judgment of pilots.
We don't want to think about that, because pilots are people and can make mistakes. But we'll have to start thinking about it, and acknowledging it, or the crashes will continue.
Feeders, Discount Airlines, and the Elimination of Apprenticeship
Flying is an apprenticeship trade. Like any job worth doing, it takes dedication and a lifetime of learning. I have 45 years and 19,000 hours of experience and I am just beginning to understand how little I know. But I have survived so far and I am very serious about continuing to survive. Dying by your own hand at the controls of an airplane is an absolute no-no for a pilot.
I was lucky. I have had (and still have) many fine teachers. When I was a young airline pilot most captains still took their teaching responsibilities seriously. Today's young pilot is not assured of the same. Pressure on unions and pilot salaries is being applied by business methods: spawning and dividing feeders and discount airlines foremost among them. The goal is to lower costs, but the (perhaps unintentional) byproduct is the interruption of the contact between old and young pilots and the teaching and learning that allows. (I believe that lowering wages also directly reduces respect for the job and the job satisfaction of the worker, but that is an argument for another time.) The FAA's response to the Colgan Air crash was to raise the experience requirement for First Officers to 1500 hours, even though it was the captain who was flying and who stalled the airplane and even though the airline had given insufficient training to both pilots on icing and how their aircraft handled ice. I have always understood that pilots are paid to be responsible. I am bemused by today's response to accidents, where band-aids are liberally applied to wounds which obviously require surgery.
Conclusion
Introducing a Multi-Crew Licence in Canada would be just another band-aid papering over the serious issues facing aviation today. Don't do it!
chris@formercaptain.ca
Re: Regulations Amending the Canadian Aviation Regulations (
Very nice, sure, I agree with everything that you just wrote. So what?
You have ALL the knowledge, but NONE of the control, so the point is moot, isn't it.
Go to a karate nationals, who's running the tournament? A 5th dan master.
Entry into the finals is a 3 brick break minimum; demonstrated first, by the guy running the tournament.
Who's the skipper on a aircraft carrier? At some point in the past, that guy was a Lt.
The difference is MONEY.
Not so very long ago, ALL endevors of man were driven by experience. The experience to do a thing, was nessesary to both regulation, and profit. The profit not always being money.
It could have been a longer life, more experience, the respect of peers, or any number of driving factors of life, at the time.
Today, it's money, and experience is no longer nessacery to hold control or be respected by one's peers, only money. Legislation costs money, lobiests cost money, NONE require experience and, in todays scociety, the man with more money garners more respect.
What does Warren Buffet do? He is very respected, and his name is well known, but what has he done? what experience does he have? Now compare him to Howard Hues.
Two very different men, from different generations.
The airline captains of today, for expample, only garner respect for the perception that thay make lot's of money. Respect from peers, comes along the same lines. Todays generation of aspiring pilots do not covet the experience of a 19,000 pilot like yourself, they covet your paycheque. They only strive to gain your paycheque, not your experience. They don't care about that, and now, you see, that they no longer need it. (crashes explained otherwise, of course)
This, is what has been lost from scociety in the 21st century, and the problems you describe accociated in this specific industry stem from this change in Global culture.
When we talk about global trade, and compeating on a global scale, weather individually or as a scociety, we speak of wealth and money, not experience, not knowledge.
I know you mentioned it above though-Canada, best pilots, hard fought experience. Only because, it's the only kind avalible in the system here. That's why we differ world wide.
Do you go to karate nationals to make money, or to be the best. The one who others come to for you experience. Experience hard faught for. Respect of peers, and, of course an open invetation to host the nationals, cu'z you're the best. This was all 20 years ago.
Now a days, it's all about the UFC fast tracked puppy mills and the 100 thousand dollar knockout bonus. No buddy cab break bricks anymore, and soon no one will be left to teach the skill. It just wount be done anymore.
This is how things ARE, but the one sure thing is that they will change, they always do, and not always for the "better".
Anyways, that's my Sunday morning rant.
Naw I'm not going to fix that sp, no money in it for me...
You have ALL the knowledge, but NONE of the control, so the point is moot, isn't it.
Go to a karate nationals, who's running the tournament? A 5th dan master.
Entry into the finals is a 3 brick break minimum; demonstrated first, by the guy running the tournament.
Who's the skipper on a aircraft carrier? At some point in the past, that guy was a Lt.
The difference is MONEY.
Not so very long ago, ALL endevors of man were driven by experience. The experience to do a thing, was nessesary to both regulation, and profit. The profit not always being money.
It could have been a longer life, more experience, the respect of peers, or any number of driving factors of life, at the time.
Today, it's money, and experience is no longer nessacery to hold control or be respected by one's peers, only money. Legislation costs money, lobiests cost money, NONE require experience and, in todays scociety, the man with more money garners more respect.
What does Warren Buffet do? He is very respected, and his name is well known, but what has he done? what experience does he have? Now compare him to Howard Hues.
Two very different men, from different generations.
The airline captains of today, for expample, only garner respect for the perception that thay make lot's of money. Respect from peers, comes along the same lines. Todays generation of aspiring pilots do not covet the experience of a 19,000 pilot like yourself, they covet your paycheque. They only strive to gain your paycheque, not your experience. They don't care about that, and now, you see, that they no longer need it. (crashes explained otherwise, of course)
This, is what has been lost from scociety in the 21st century, and the problems you describe accociated in this specific industry stem from this change in Global culture.
When we talk about global trade, and compeating on a global scale, weather individually or as a scociety, we speak of wealth and money, not experience, not knowledge.
I know you mentioned it above though-Canada, best pilots, hard fought experience. Only because, it's the only kind avalible in the system here. That's why we differ world wide.
Do you go to karate nationals to make money, or to be the best. The one who others come to for you experience. Experience hard faught for. Respect of peers, and, of course an open invetation to host the nationals, cu'z you're the best. This was all 20 years ago.
Now a days, it's all about the UFC fast tracked puppy mills and the 100 thousand dollar knockout bonus. No buddy cab break bricks anymore, and soon no one will be left to teach the skill. It just wount be done anymore.
This is how things ARE, but the one sure thing is that they will change, they always do, and not always for the "better".
Anyways, that's my Sunday morning rant.
Naw I'm not going to fix that sp, no money in it for me...
Re: Regulations Amending the Canadian Aviation Regulations (
Here's the answer to my question above for those who care.
http://www.prnewswire.com/news-releases ... 87571.html
http://www.prnewswire.com/news-releases ... 87571.html
