The beginning of the end of small private airstrips

[PilotDAR]

This is going to happen, it can't not. Certain aerodrome owners has exercised a bit too much privilege, in my opinion, and used up more than their fair share of public good will. But, that ship has sailed....

Two elements should and probably can be corrected - the "30's":

As said, 30 mile is too large an exclusion zone. Better would be that consultation is required if the normal traffic pattern of the proposed aerodrome falls within one mile of the positive airspace of an airport or extended approach path.

And, 30 days a year is much too few flying opportunity. Pilots cannot maintain proficiency at that rate. A strong argument can be made that it is a disincentive to pilot proficiency and thus not in the public interest - pilots are public too! That number needs to either much greater, or never enforced.

GA must represent itself to CARAC on this (I sure would not leave it up to COPA!). Canadian GA will get nothing more than it asks for at CARAC...

GO ASK!

[ctmorawetz]

This is going to happen, it can't not. Certain aerodrome owners has exercised a bit too much privilege, in my opinion, and used up more than their fair share of public good will. But, that ship has sailed....

Two elements should and probably can be corrected - the "30's":

As said, 30 mile is too large an exclusion zone. Better would be that consultation is required if the normal traffic pattern of the proposed aerodrome falls within one mile of the positive airspace of an airport or extended approach path.

And, 30 days a year is much too few flying opportunity. Pilots cannot maintain proficiency at that rate. A strong argument can be made that it is a disincentive to pilot proficiency and thus not in the public interest - pilots are public too! That number needs to either much greater, or never enforced.

GA must represent itself to CARAC on this (I sure would not leave it up to COPA!). Canadian GA will get nothing more than it asks for at CARAC...

GO ASK!

Great points! If those two were modified I would be satisfied. Our runway actually is partially within the Oshawa Control Zone. Before we depart or land, we contact Oshawa Tower, state our intentions and they give us the winds and Altimeter Setting. The arrangement was never cast in stone but has just become the norm over the past 20 years. There has never been an incident as a result of our airstrip being there. That is why I feel 5 nm should be sufficient for a private airstrip. If there was continuous operations, then perhaps 10 nm would be a better buffer.

Using currency as a tool to improve the 30 day/year rule is an excellent idea. We use our runway approximately 80-90 days per year but that is between two pilots and two aircraft.

[Trematode]

Just wondering if anyone involved can shed some light on how this may affect the parkland airport west of Edmonton. anybody?

[MrWings]

I believe the overnight Parkland development played a significant role in the drafting of this legislation.

If they keep the use as is, I think Parkland has to be grandfathered.

[photofly]

I'm curious why the 30 mile limit around another aerodrome triggers a public consultation rather than a consultation with the operator of the other aerodrome.

[Tom H]

I've set up a meeting with my MP as a first step to getting my concerns on the table.

Would suggest others interested in these developments do the same.

Tom

[MrWings]

Since we are dealing with Transport Canada, shouldn't you be talking to your MP instead of your MLA?

[Tom H]

Since we are dealing with Transport Canada, shouldn't you be talking to your MP instead of your MLA?

Thanks for catching that, comment corrected.

Dealing with MLA on another matter...oops.

Tom H

[RatherBeFlying]

The Parkland Airport horse is out of the barn. A big part of that story is that a local airport authority shut down a busy airport forcing operators and businesses to build a new airport - well, lets just say that they were refugees happy to have a place that would accept their business.

I'd like to suggest some additions:

1. Any public authority closing an airport with more than xxx annual movements be obligated to find another site and carry the can for any required public consultation

2. In the spirit of nondiscrimination, public consultation requirements be limited to that locally required for rural commercial uses such as: feedlots, pig farms, gravel pits, seed cleaning, poultry operations, gas plants, well drilling and operation, equipment and vehicle repair, sales and storage, cheese factories, creameries, wind turbines, power lines ...

[SuperchargedRS]

This is the problem with Canada, folks are much too docile.

If the people involved with these PRIVATE airstrips did not comply, and just told the government to shove it, the law would change or flat out go away, government only has the power the people allow it to have.

[ctmorawetz]

Does anyone think a petition would get us anywhere on this issue? Might be worth a shot. Thoughts?

[PilotDAR]

I have sent an email to Minister Raitt, my MP, and CARAC, presenting my concerns, and proposed alternative wording, an expansion of what I posted earlier here.

Anyone else?

[fleet16b]

I have sent an email to Minister Raitt, my MP, and CARAC, presenting my concerns, and proposed alternative wording, an expansion of what I posted earlier here.

Anyone else?

Perhaps you could copy it to the forum(?) so that others could use it as a format for emails to members MP's

[PilotDAR]

Here are the relevant sections of what I wrote:

"..............

Two elements of the proposed regulation deserve consideration for change:

30 miles is a much too great "catchment" distance around other aerodromes. ..............

I suggest that the regulation invoke the "consultation" if the normal traffic pattern of the subject aerodrome would come within one mile of the controlled airspace, or 5 miles of the normal traffic pattern of the "other" (presumed larger/busier) airport. This will allow for fair sharing of airspace. Uncontrolled airspace beside a larger airport is just that - uncontrolled. We don't need this regulation to start to control it. Normal airspace and circuit procedures are already effective for this.

Secondly, the notion of use of an aerodrome 30 or fewer days per year is deeply flawed. Presuming that aerodrome is the private property of a pilot/aircraft owner, by limiting the number of days of use, that pilot's opportunity to maintain their skills currency will be badly impacted. It does not at all serve the public interest to introduce regulation which reduce the opportunities for a pilot to maintain their flying skills and recency. Please approach this from a different direction. Consider limiting the number of aircraft owners who may base aircraft at an aerodrome, and the use of those aircraft.

I propose that the threshold (below which consultation is not required) be: A privately owned aerodrome, with one or two privately registered aircraft owned by the same person.

This would achieve the presumed low utilization, as only that owner, and those one or two aircraft would regularly use that aerodrome, without limiting the free opportunity of that owner pilot to use their aircraft, and remain proficient.

................"

Hopefully the foregoing will prompt some alternate thinking as to how to regulate to achieve the desired result, with less impact upon a private, personal aerodrome owner, and their personal flying.

I expect that trying to affect no consultation for an airport intended to be "public" or "busy" would be futile, so I focus on the very smallest aerodromes to preserve that small private freedom. Others may feel differently, and that is as it should be. But, enter that CARAC/regulatory change process knowing that the rule is going to change, the best you can do is to steer things a bit to your liking - stopping the new rule is not going to happen.

[fleet16b]

Here are the relevant sections of what I wrote:

"..............

Two elements of the proposed regulation deserve consideration for change:

30 miles is a much too great "catchment" distance around other aerodromes. ..............

I suggest that the regulation invoke the "consultation" if the normal traffic pattern of the subject aerodrome would come within one mile of the controlled airspace, or 5 miles of the normal traffic pattern of the "other" (presumed larger/busier) airport. This will allow for fair sharing of airspace. Uncontrolled airspace beside a larger airport is just that - uncontrolled. We don't need this regulation to start to control it. Normal airspace and circuit procedures are already effective for this.

Secondly, the notion of use of an aerodrome 30 or fewer days per year is deeply flawed. Presuming that aerodrome is the private property of a pilot/aircraft owner, by limiting the number of days of use, that pilot's opportunity to maintain their skills currency will be badly impacted. It does not at all serve the public interest to introduce regulation which reduce the opportunities for a pilot to maintain their flying skills and recency. Please approach this from a different direction. Consider limiting the number of aircraft owners who may base aircraft at an aerodrome, and the use of those aircraft.

I propose that the threshold (below which consultation is not required) be: A privately owned aerodrome, with one or two privately registered aircraft owned by the same person.

This would achieve the presumed low utilization, as only that owner, and those one or two aircraft would regularly use that aerodrome, without limiting the free opportunity of that owner pilot to use their aircraft, and remain proficient.

................"

Hopefully the foregoing will prompt some alternate thinking as to how to regulate to achieve the desired result, with less impact upon a private, personal aerodrome owner, and their personal flying.

I expect that trying to affect no consultation for an airport intended to be "public" or "busy" would be futile, so I focus on the very smallest aerodromes to preserve that small private freedom. Others may feel differently, and that is as it should be. But, enter that CARAC/regulatory change process knowing that the rule is going to change, the best you can do is to steer things a bit to your liking - stopping the new rule is not going to happen.

PilotDAR
that's great thank you

[digits_]

What is considered an aerodrome ?

The CARs quote "Aerodrome. Any area of land, water (including frozen surface thereof) or other supporting surface used or designed, prepared, equipped or set apart for use either in whole or in part for arrival and departure, movement or servicing of aircraft and includes any building, installations and equipment in connection therewith."

But that definition doesn't hold much value. According to this every lake is an aerodrome to a floatplane. Every field is an aerodrome if an airplane lands there.

What about a strip in your backyard. Maximum 30 T/O per year to avoid the new regulations. Okay, how about you have 2 strips and you switch between them ? Where does the area of an aerodrome end ?

[photofly]

I'm going to suggest 90 days, rather than 30, alternatively 500 movements annually, as a lower limit.

30nm distance from another aerodrome - should perhaps trigger a consultation with the operator of the other aerodrome, but not a public exercise unless within the 4km limit.

As an aside, you have to love a government department that's entirely unable to pick one system of units and stick with it.

[CpnCrunch]

I'm going to suggest 90 days, rather than 30, alternatively 500 movements annually, as a lower limit.

30nm distance from another aerodrome - should perhaps trigger a consultation with the operator of the other aerodrome, but not a public exercise unless within the 4km limit.

As an aside, you have to love a government department that's entirely unable to pick one system of units and stick with it.

Movements makes more sense. The typical aviation nut who has their own strip will fly more than 30 times a year. However if you think about it, even a few takeoffs and landings *every day* isn't going to upset the average neighbours. I mean, each takeoff and landing is a little bit of noise for something like 1 minute. Even 1000 movements a year isn't a big deal (that's just 1.5 flights a day on average).

[fleet16b]

Just sent a copy to my MP along with my concerns
He replied that he has forwarded my concerns to the Minister of Transport for response

I would like to request that the AVCAN Forum members all submit an email based on the example that PilorDar posted requesting to put this amendment on hold pending further discussion
If everyone's MP submits / forwards the request to the Minister of Transportation , maybe it will help
It cant hurt to try.

[sportingrifle]

Duncan Flying Clubs very in depth reply:


Dear Sirs and Madame’s;
On behalf of the Duncan Flying Club, I am writing to comment on the draft NPA, “Responsible Aerodrome Development”, CARAC Reporting Notice 2013-014. By way of introduction, I hold an Airline Transport Pilots License, have worked as a professional pilot for over 30 years, own an aircraft, and am active in a local flying club. I also actively mentor young people entering the aviation industry, especially groups such as Air Cadets, Women in Aviation, and those enrolled in local aviation college programs. Additionally, and somewhat coincidentally, I serve on a land use planning committee for a local regional district.
While we recognize the very real issues that the NPA is seeking to address, the NPA as proposed could have far reaching unintended negative consequences for the aviation industry for many years to come. Before discussing the NPA in detail, it is important that all those involved in the process understand the aviation industry in Canada, and what attributes unique to Canada give us the worldwide competitive edge we currently enjoy.
Aviation is a “top down” industry in Canada. Pretty much every aircraft mechanic and pilot working in commercial aviation got there thanks to much smaller general aviation airports. Whether it was during their training or their early jobs, without the smaller general aviation airports, the glitzy high dollar end of the industry would be struggling. This can be seen in other parts of the world that don’t have strong general aviation heritage – severe pilot and mechanic shortages that are leaving brand new airplanes parked! Other countries dream of having a general aviation infrastructure and heritage as Canada does. It is very important to understand the link between small, often un-certified airports and the rest of the aviation industry. Anything such as this NPA that imperils smaller airports will eventually and inevitably hurt the entire industry, eventually depriving the government and the country of tax dollars and jobs.
The aviation infrastructure in Canada is based on a network of airports. Whether out of economic necessity or for reasons of safety, this network cannot tolerate localized “holes” in it to any degree. If you close 50% of the airports in the country over time, you do not reduce aviation activity by 50% - you reduce by much more, probably closer to 90%. An example of this is the sharing of bulk loads of fuel between smaller airports that otherwise couldn’t store an entire truck load themselves. Without the neighboring airport to partner with, this couldn’t happen, which due to the trucking costs, results in an increase in fuel cost. Aviation is an activity that requires a critical mass to function so the small scale local repression of airports and airdromes has a much more profound and long term negative effect than it would appear at first glance. Additionally and critically in this vast country of often inhospitable terrain and weather, a network of small airports across the country increases aviation safety by allowing people with mechanical or weather difficulties safe places to land. Minister Raitt’s previous comments that most airports are underutilized leads me to believe that she may not full understand these issues.
As mentioned in the NPA, larger international and other certified airports already have mechanisms built in to their operational plans that mirror the ones proposed, and therefore this NPA will have little effect on them. My concern is with the smaller community airports and aerodromes, the private aerodromes, and the currently unregistered aerodromes. This NPA will at best be an economic burden and introduce another level of uncertainty to their operations. At worst, it will in many cases over time, open a “Pandoras Box” of ill thought out additional regulations that will strangle existing airports out of existence. And like “Pandoras Box”, if this consultation and decision mechanism proves to be harmful to aviation, it will be very difficult or most likely impossible to undo the damage.
This NPA immediately raises six issues and concerns that will potentially imperil many existing and future general aviation airports.
1) The idea that this proposed consultation would be triggered if a proposed airport would lie within 30nm of another certified or registered airport defies any logical underpinnings. Most airports or aerodromes have control zones or aerodrome traffic zones of between 2nm and 3nm in radius. This area is sufficiently large to contain all the air traffic movement related to the operation of the airport. Furthermore, at this distance aircraft utilizing normal climb and descent profiles are above the minimum height for flight over built up areas. In other words, flights operating outside normal control zones or aerodrome traffic zones present no additional impact than any other overflying aircraft. Why would a consultation process be triggered by a distant geographical proximity to an existing airport when there would be no measurable or real operational impact in this area? The only possible reason I could think of for the 30nm proposal would be to protect an existing airports commercial monopoly. If this is the case, this anti-competitive motive should be fully disclosed to the public at large and be debated in a much wider forum. Otherwise, I believe the triggering consultative distance should be restricted to only an area that would incur aircraft related operational impacts.
2) The proposed mandatory compliance with local municipal building and fire codes, instead of the current practice of complying with the Federal Building Code, this NPA presents municipalities with a potential “Trojan Horse” to prevent airport development, by allowing them to create unreasonable and unworkable building codes that apply only to airports. From a public safety and construction safety standpoint a small hanger is little different than an uninhabited garage or barn. An airport fuel facility is little different than an automotive gas station. In Southern British Columbia, we have already seen two municipalities implement onerous and costly fire codes that applied to their airports only. One municipality requires a sprinkler system installed in uninhabited aircraft storage hangers that costs more than the value of the aircraft stored inside them. Another required the retroactive installation of fuel delivery system improvements to a standard not found at any other airport in Canada! Neither of these requirements provided any demonstrated safety improvements, and both have resulted in airport improvements and the resulting economic activity from them not proceeding. To enshrine the ability of local governments to place arbitrary and unreasonable standards on airport development, can, and will, result in this sort of abuse of process occurring with increasing frequency. For 50+ years the National Building Code has worked well for airport development and we see no reason why it cannot continue to do so.
3) The idea that municipal governments should have any influence in the creation or expansion of airports is in itself a concept fraught with peril. By coincidence I just happen to serve on a local government land use planning committee (Cowichan Bay Advisory Planning Commission.) and I see first hand how local government approaches land use decisions. Municipalities often do not understand the long term benefits of an airport or aerodrome in their community until after it is well established. The ability to host air ambulance service, the tourism and business benefits, the increased tax base, are often only apparent after they exist. A small vocal minority of voting NIMBY’s is very apparent before an airport even gets under construction, and many small town politicians don’t have the ability to take the broader longer term view. Conversely, some municipal governments will covet the existing aviation real estate for higher density development, thereby placing the municipalities in a position of conflict of interest with the developers of an airport. To give these voices that often lack knowledge or understanding, fail to be able to see past the next election, are NIMBYistic, or have alternate agendas, a formal say in the creation or expansion of part of our National aviation infrastructure will over the long term greatly diminish the aforementioned infrastructure.
4) The proposed exempting triggering revenue stream (less than $30 000) and triggering days of use per year (30) are so low as to be immaterial (ie useless) to small private aerodromes and airparks. Additionally, the expected cost of consultation and compliance are far out of line with any potential benefit when considering small private rural airfields and airparks. This small segment of aviation is often the seed where young less financially well off people are initially exposed to aviation. This segment is very sensitive to costs and these additional costs could be a tipping point. I propose that any development with a revenue stream of under $100 000 or with less than 1000 take offs and landings per year, be exempt from any proposed new consultation or development restrictions. To put these numbers into perspective, this is less than 3 take offs and landings per day and the typical annual operating cost of approximately 8 light aircraft.
5) The proposed NPA contains a tremendous number of undefined, vague terms that airport proponents will be expected to comply with. Terms such as “reasonable, unreasonable, acceptable, attempt, existing levels of service or operation, alternate dispute resolution process, etc.” Reading this document is at times like grabbing at smoke, and the very real fear is that without precise definition and explanation, these terms could be interpreted at a later date or by another jurisdiction to be far more broad reaching and onerous than intended.
6) Transport Canada is already understaffed to the point that staffing levels are having negative consequences to the industry in the timely and safe delivery of services. Evidence of this is the fact that aircraft ferry permits take weeks to obtain, and supplemental type approvals can take years. The industry is so concerned with this that the Director General of Civil Aviation, Martin Eley spoke to this issue at the last ATAC Conference in Vancouver. This proposed NPA will require significant involvement of Transport Canada staff. Where will these resources come from? Will the Minister commit to hiring additional personal with the relevant training and experience to administer this program, at a time when the Federal Government is hinting at budget cuts? Will resources be siphoned off from other parts of Transport Canada, thereby further eroding the quality and timeliness of service? Or will this proposed NPA cause airport developments to “die on the vine” due to service delays in implementing it running months to years? The funding and management of the proposed NPA needs very careful planning and a very long term commitment from Transport Canada if it is to be further considered.

Airports of all shapes and sizes are the cornerstone of aviation in Canada. And they are disappearing at a much faster rate than they are being created. In British Columbia alone we have lost 4 airstrips and one airport in this year alone. This phenomenon is not restricted to small private airstrips either. Edmonton Municipal is gone, and Buttonville is going. The financial and logistical hurdles to creating a new airport are already almost insurmountable and for this reason they are not being replaced at anywhere near the rate that they are disappearing. This proposed NPA will do nothing to help the situation and will certainly exacerbate the problem. The proposed NPA concerns me more than any others I have seen in years for three reasons. Firstly, it formalizes a process that gives an increasing voice to those least knowledgeable and often most opposed to the development of airports. More troubling, is that once implemented, it will be very difficult if not impossible to restrict or rescind at a later date if needed. Lastly, and perhaps most troubling for other branches of the Federal Government, is that it sets a precedent. It is not hard to imagine that if adopted, other groups opposed to other types of development, will use this proposed legislation as an example in the legal arena as to why their voice should carry greater weight.
Transport Canada has the jurisdiction and responsibility to regulate and promote aviation in Canada for the benefit of all Canadians. This proposal as initially envisioned, for the six reasons I have detailed, will have the exact opposite effect. I strongly urge a very careful and sober second look at this proposed NPA, especially with respect to the issues raised in this letter.
Yours Truly,
Kevin Maher, B.A.Sc., ATPL.
Duncan Flying Club.
Cc: DFC Membership