A General Aviation Policy for Canada
The Canadian Owners and Pilots Association, on behalf of people who own and fly
aircraft for personal travel and recreation, is a strong advocate for a sustainable air
transportation system that includes provisions for General Aviation (GA), that large
sector of aviation that is so important for connecting our country and as a training ground
for personnel as they work their way into the airlines.
Air Policies have been developed by several transportation Ministries, including the
relatively recent Blue Sky Policy, but the direction that is provided in all of these policies
is in support of large commercial air carriers, which is a relatively small percentage of the
overall aviation activity in Canada. An example of the consequence of this narrow focus
is airport infrastructure decline1.
This presentation will provide justification for conducting a review of the GA sector and
point toward the need for a Policy to ensure that it is a sustainable component of
transportation in Canada.
Background
GA is the multi-billion dollar non-airline portion of the aviation industry. It includes:
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Pilot training for the future of the airline industry
Agricultural flying to maximize the productivity of the agricultural industry
Bush flying operations serving Canada’s remote communities and providing
transportation for the multi-billion dollar tourism industry
Medical evacuation and patient transfer
Aviation maintenance
Aviation maintenance training
Corporate and business flying
Personal travel and recreation
Aviation tourism – foreign and domestic
Aerial survey and mapping
Aerial photography
Forest fire fighting
Civil search and rescue
Regional and Small Airports Study (TP14283B)
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Heli-skiing
Mineral exploration and support
Forest management flying
Aerial avalanche control
Aerial construction
Aviation research and development
Aerospace manufacturing
Pipeline and powerline patrol
Helicopter logging
Many other activities not involving scheduled air service
Air Policy Statements and Publications
A visitor to the Air Policy section of the Transport Canada website will quickly
see that there are policy documents that address many airline issues and also rents and
leases for the major 26 airports in Canada. The National Airports Policy deals with the
question of airports, although it focuses on those 26 major airports in Canada and has
little to say about non-airline aviation.
There are no policies relating to the rest of the aviation industry.
It seems odd that Transport Canada would have no policy at all for a sector of
aviation that is solely regulated by Transport Canada, operates 95% of the aircraft
registered in Canada, includes hundreds of flying and maintenance schools, employs
hundreds of thousands of people, adds billions of dollars to the Canadian economy and
provides transportation services to Canadians that no other form of transportation does or
is capable of providing.
A Historical Perspective
Canada has not always been without a policy for GA. As StraightAhead – A
Vision for Transportation in Canada points out, it was largely transportation that built
this nation.
“These may be provocative statements, but every student of Canadian history
knows that the evolution of Confederation has rested in large part on securing the
transportation links that connect us as a nation. Throughout our history, governments
have embraced a succession of bold transportation visions - national railways spanning
the continent, an international seaway, the Trans-Canada Highway, and transcontinental
air services.” (quote from Hon. David M. Collenette, P.C., M.P. Minister of Transport
StraightAhead pg 5)
In the period between the two World Wars, Canada’s transportation vision was
solidly focussed on aviation as a builder of the nation, in the same way that the railways
had been critical in nation building before the First World War.
The government of the day formed the Air Board to oversee all aviation in
Canada, including military aviation. Under the Air Board Canada was mapped in detail
from the air, a national network of airports was built, air services were established,
personal aviation supported, remote communities linked to the rest of Canada and civil
pilots were trained with government support. The unifying work of the Air Board was
driven by a solid policy that understood that the existence, promotion and government
support of all sectors of aviation, including non-airline aviation, was in the Canadian
public interest.
This broad government support of all forms of aviation led to a nation with a great
expertise in aviation. When the Second World War started, Canada’s greatest
contribution was to be what Roosevelt termed the “Aerodrome of Democracy”, the
British Commonwealth Air Training Plan (BCATP). Aircrew from almost all allied
nations trained in Canada under instructors largely recruited from that pool of Canadians
who had learned to fly in the inter-war period. Canada had become the most “air-minded”
nation on earth and the BCATP contributed strongly to the defeat of the Axis powers as a
result.
After the war ended the government continued with a strong General Aviation
policy, providing financial support for Canadians who learned to fly. Until the end of the
1950s any Canadian who completed a Private Pilot Licence had one third of the cost
reimbursed by the federal government. The government of the day felt that this was a
good investment as it encouraged Canadians to become pilots – supplying the RCAF and
air carriers with pilots and also ensuring that in a national emergency the nation had the
pilots to provide emergency airlift anywhere in the country.
By the 1960s that long-held vision of aviation in Canada shifted. No longer was
the federal government of the day willing to support all sectors of aviation. Instead the
airlines received strong and direct financial support, while the rest of aviation bore an
increasing burden of regulations and control, without any policy to illustrate that the
government had a vision for non-airline aviation in Canada.
By the 1990s, the government decided to divest of all but the largest airports in
Canada and they introduced the National Airports Policy for offloading hundreds of
airports across Canada.
Challenges
All sectors of aviation are facing serious challenges to their sustainability. Some
of the issues that most affect GA currently include:
1.
A crumbling national airport infrastructure system that has proven not to be
sustainable by user fees and other meagre sources of funding.
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An excessively high government regulatory burden that is seriously hurting
the competitiveness and viability of the entire Canadian aviation industry
(including the aerospace manufacturing industry, airport operators sector,
aviation maintenance industry and commercial, business and private aircraft
operators) in comparison to Canada’s foreign competitors, particularly the US.
Crumbling Airports Infrastructure
In 1994, the National Airports Policy (NAP) changed the direction for many
airports in Canada. Prior to that Policy, many key airports were run by Transport Canada
as part of a national network and revenue generated by the larger airports was in part
funnelled to smaller airports to support their operation and development.
The NAP set as a goal the divestiture of all airports in Canada except a few of the
larger airports, signalling that Transport Canada was getting out of the business of
owning and operating airports. Larger airports were leased to local authorities while
smaller airports were sold outright for nominal amounts and the fate of these airports left
entirely to the whims of local interests. Thus, the stage was set for at least a loss of focus
and at most a dismantling of the national infrastructure that not so may years ago was so
important to connecting and keeping the country together.
Sixteen years after its introduction, it is apparent that many airports are in dire
trouble and cannot sustain themselves without revenue from other than its operations.
Another indication of its failure is a recent statement from Doug Young, who was the
Minister of Transport at the time of the introduction of the NAP. He referred to the NAP
as a huge failure and his greatest mistake while Minister of Transport.
Many regional airports are trying to survive on user fees and competing against
other modes of transportation, such as road, rail that have generous government subsides.
And although some funding has become available from initiatives such as Building
Canada and Canada’s Economic Action Plan, awards of funding are more from political
decisions than with an airport system in mind.
In the Government’s Own Words
The Transport Canada Regional and Small Airports Study was not mandated to
make any recommendations, but it is clear that a significant number of smaller key
divested airports are in financial trouble. The report drew two important conclusions:
1.
The net effect of the NAP with regard to smaller airports has been municipal
downloading. The federal government walked away from the national network
of airports in Canada and left municipalities to pick up the bill for keeping the
national network functioning.
2.
Canada is non-competitive with the USA when it comes to its approach to
smaller airports. US smaller airports are seen as a major economic contributor
to the community. These airports are largely funded by various levels of
government as transportation infrastructure on the same basis as other
transportation infrastructure – highways, roads, sidewalks and sewers. This is
not the case for most Canadian airports.
Transport Canada does have a modest program to support airports in Canada,
called the Airport Capital Assistance Program (ACAP). While this program was created
with good intentions, it suffers from two distinct drawbacks:
1.
ACAP only provides support for airports that have scheduled airline service.
This restriction leaves the vast majority of airports and aerodromes without
access to funding for operations or capital improvements. ACAP is clearly
another program that supports the airlines while ignoring GA even though
these airports are just as important as the airline airports. They provide flight
training facilities for the aircrew who will eventually fly the airliners, small
aircraft located at these airports provide work for maintainers to build
experience in order to eventually work on airliners, and most importantly,
they provide convenient links to business travellers where no airline
connections are provided. Small airports are a significant economic generator
for the community and the nation as a whole and yet this fact is not
appreciated by a significant number of communities who have inherited these
assets.
2.
ACAP is vastly under funded for the number of infrastructure projects that are
required to repair and then sustain the crumbling infrastructure.
Increasing Regulatory Burden
Since the Canadian Aviation Regulations (CARs) were introduced in 1996 they
have grown in size and volume considerably. New regulations are added every year,
while old ones are not removed. Without a government policy to guide the regulation
writers, the number of regulations will continue to increase every year, regardless of the
consequences. This effect has been termed “Regulatory Creep” by the industry and it has
become crippling to aviation in Canada.
Here are some examples of recent “Regulatory Creep”:
1.
Many airports are now required to have detailed and TC-approved Winter
Maintenance Plans, Wildlife Control Plans and Safety Management Systems
in place – even if they cannot afford to hire sufficient staff to manage the
programs.
2.
Even single-person Approved Maintenance Organizations will soon have to
have approved Safety Management Systems. There is a proposal for these
same organizations to have a Transport Canada approved Fatigue
Management System in place, even for one person. These concepts for small
businesses are not sustainable; the consequence will be many closures.
3.
Recent surveys have shown that the sheer volume of regulations that govern
personal aviation is now so high that most pilots and aircraft owners have
given up even trying to learn them or understand them. The amount of
regulation has become unreasonable.
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Very few Transport Canada Inspectors are familiar with the enormous volume
of regulations that they are expected to police. The result of this is that many
errors are made in regulatory enforcement every day.
The regulatory burden in other countries, such as the USA, with which Canada
competes, is often considerably lower, thus rendering Canada non-competitive.
In most cases foreign aircraft operators and maintenance organizations operate
aircraft in Canada and work on Canadian aircraft while complying with their own lessburdensome regulations, which they can legally do. They transport people and repair
aircraft at lower cost and the same level of safety, by operating to their own national
regulations.
The Way Forward
GA needs to know where the government stands regarding its very existence.
After decades of solid policy support in the 1920s through the 1960s it has languished in
a policy vacuum since that time.
The non-airline GA sector is a vital part of the Canadian economy and way of life.
General Aviation means many things to Canadians. To name but a few:
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Thousands of jobs in communities like London, Ontario, where aircraft are
built for General Aviation
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A valued lifeline in the form of medevac service to hospitals in many places
with limited local medical services in Canada.
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An important means for business people to connect with their customers in the
thousands of Canadian communities where there is no airline service.
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Rescue for lost hikers when a civilian volunteer CASARA member locates
them in the Rocky Mountain wildness.
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The smile on an inner city child’s face after being taken for a Young Eagle’s
flight by a local volunteer private pilot.
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A summer cottage community saved from incineration by the timely arrival of
forest fire fighting crews by floatplane, air tankers and helicopter fire fighters.
Canadians need to know whether the government values the contributions that
this sector make to Canada or whether it will continue to be ignored by government
support and over-regulated at the same time.
The government should be interested in acknowledging the contributions of GA
to Canada in the form of a Transport Canada policy to support it, thereby setting the stage
for investment in this sector of aviation.
Recommendations - A General Aviation Policy for Canada
After more than 40 years without a coherent policy on GA in Canada it is time for
the Minister of Transport to stop the decay of GA by expanding its Air Policy to include
non-airline operations, airports and related support industries. The policy must be one
that defines the future, in terms of facilities and funding mechanisms, to ensure that there
is sufficient infrastructure and systems in place as well as reducing the regulatory burden.
COPA recommends that the Transport Minister adopt a policy for General
Aviation that has the following key features:
1.
A statement that describes the value of non-airline aviation to Canada in terms
of the service that it provides to Canadians and the value it serves in defining
and helping to build the nation. This statement should define levels of service
for General Aviation – how many airports, flying schools and aircraft does
Canada need to be competitive and the importance of the support industries to
this end. The policy should specify that regulations need to support these
policy objectives and not conflict with them. An example is a statement
regarding the airports that should be in place to make GA a viable
transportation mode. Several US States have commitments that no citizen will
be further than 50 miles from an airport.
2.
A commitment to provide adequate federal funding under ACAP to airports
that do not have scheduled airline service in Canada.
3.
A commitment to significantly reduce the current regulatory burden
represented by the CARs with the aim of making the rules more
comprehensible, more concise and restoring Canada’s place as a competitive
nation in providing aviation services.
Conclusion
A General Aviation Policy is long overdue for Canada. This multi-billion
dollar industry is a national asset that should be provided with an integrated strategic plan
to ensure its survival. This can best be accomplished by recognizing GA’s role as an
economic generator for the country and providing sufficient support and direction to
achieve the strategic plan’s goals.