The beginning of the end of small private airstrips

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Cod Father
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Re: The beginning of the end of small private airstrips

Post by Cod Father »

This is a property rights issue and the property rights folks are going to go bonkers over this.

This all came up because of the stink that arose in Parkland County when a new "Aerodrome" decided to set up shop. Why did they set up shop? The owners wanted to own their hangars on owned land, not lease lots at the local certified Airport.
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flyingreg38
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Re: The end of private recreational airports??

Post by flyingreg38 »

Hi Guys,

Long time reader here, almost never posted anything but I thought I'd share the email I've sent today though...
It's based on the EAA document and PilotDAR post. Feel free to use it, modify it, and improve it ! ;-)

Greg
-------------------

To:
Transport Canada, CARAC
The Honorable Lisa Raitt, Minister of Transport
Member of Parliament
COPA
EAA
UPAC

I am writing to you today to express my displeasure and disagreement with the following Canadian Aviation Advisory Council (CARAC) Notice of Proposed Amendment (NPA) “Responsible Aerodrome Development”.

Transport of Canada has proposed a consulting process for the establishment or expansion of all aerodromes within Canada. It is an onerous and expensive process that will not only restrict aviation, but will add substantial costs to the operating expense of each and every aerodrome or airport.

An aerodrome is any surface that an aircraft can land on and the necessary maneuvering area adjacent to it. If I land my aircraft in a field, a lake or a lane it is an aerodrome.

The proposed amendment will require the aerodrome operator to engage the public. It is estimated within the NPA that the range of cost for a small registered or unregistered aerodrome will be a one time charge of $6,000 to $15,000.

This consultation process must be implemented when a new aerodrome is to be established or changes to the existing level of service at an aerodrome are to be undertaken in a non built-up area if,
1. It is within 4 km of a built up or protected area.
2. It is within 30 nautical miles of a registered or certified aerodrome.

The consultation process need not be implemented if,
1. It is an ad hoc aerodrome (used less than 30 days a calendar year).
2. Modifications do not result in a change to existing levels of service.
3. Aerodrome used solely for agricultural operations.

The lengthy and costly consultation process, consisting of pre-consultation, consultation, signage, newspaper notification and Community information session, must take place within a limited timeframe.
No other use of any personal property comes under such ill advised scrutiny. This NPA will reduce the personal freedom by restricting the use of any property. This freedom has been in place since aviation began, but is now being threatened. Local air strips will eventually be eradicated.
The regulations that are in place for the development of private air strips have been working well for a long time now. There are the occasional abuses of the aerodrome but all should not have to pay for the abuses of a few. If Transport Canada was truly concerned about safety, the few abuses of the system would be addressed rather than generating a one size fits all approach.

If I understand the need for a consultation process when an aerodrome is close to a built-up area, some changes must occur with this NPA.
At least two elements of the proposed regulation deserve consideration for change:

1. 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 traffic pattern procedures are already effective for this.

2. 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.

Due to the flawed NPA I would like the Minister of Transport the Honorable Lisa Raitt to withdraw this NPA or at very least send it back to the CARAC committee for a complete rewrite.

Sincerely yours,
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flyingreg38
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Re: The beginning of the end of small private airstrips

Post by flyingreg38 »

Another example of an email sent out today. Not as many details as above but hopefully it will help. BTW as a freshly new citizen, it's my 1st time writing to my MP and the Honorable Minister of Transport ! So if i can do it, others should be able to do it as well ;-)
It's based on the EAA Canadian council document and PilotDAR's various posts. Feel free to use it, modify it, and improve it ! ;-)

Greg
-------------------

To:
Transport Canada, CARAC
The Honorable Lisa Raitt, Minister of Transport
Member of Parliament
COPA
EAA
UPAC

I am writing to you today to express my displeasure and disagreement with the following Canadian Aviation Advisory Council (CARAC) Notice of Proposed Amendment (NPA) “Responsible Aerodrome Development”.

Transport of Canada has proposed a consulting process for the establishment or expansion of all aerodromes within Canada. It is an onerous and expensive process that will not only restrict aviation, but will add substantial costs to the operating expense of each and every aerodrome or airport.

An aerodrome is any surface that an aircraft can land on and the necessary maneuvering area adjacent to it. If I land my aircraft in a field, a lake or a lane it is an aerodrome.

The proposed amendment will require the aerodrome operator to engage the public. It is estimated within the NPA that the range of cost for a small registered or unregistered aerodrome will be a one time charge of $6,000 to $15,000.

This consultation process must be implemented when a new aerodrome is to be established or changes to the existing level of service at an aerodrome are to be undertaken in a non built-up area if,
1. It is within 4 km of a built up or protected area.
2. It is within 30 nautical miles of a registered or certified aerodrome.

The consultation process need not be implemented if,
1. It is an ad hoc aerodrome (used less than 30 days a calendar year).
2. Modifications do not result in a change to existing levels of service.
3. Aerodrome used solely for agricultural operations.

The lengthy and costly consultation process, consisting of pre-consultation, consultation, signage, newspaper notification and Community information session, must take place within a limited timeframe.
No other use of any personal property comes under such ill advised scrutiny. This NPA will reduce the personal freedom by restricting the use of any property. This freedom has been in place since aviation began, but is now being threatened. Local air strips will eventually be eradicated.
The regulations that are in place for the development of private air strips have been working well for a long time now. There are the occasional abuses of the aerodrome but all should not have to pay for the abuses of a few. If Transport Canada was truly concerned about safety, the few abuses of the system would be addressed rather than generating a one size fits all approach.

If I understand the need for a consultation process when an aerodrome is close to a built-up area, some changes must occur with this NPA.
At least two elements of the proposed regulation deserve consideration for change:

1. 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 traffic pattern procedures are already effective for this.

2. 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.

Due to the flawed NPA I would like the Minister of Transport the Honorable Lisa Raitt to withdraw this NPA or at very least send it back to the CARAC committee for a complete rewrite.

Sincerely yours,
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comanchepilot
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Re: The end of private recreational airports??

Post by comanchepilot »

I sent an email to the appropriate parties, however I modified it in the following way:
I propose that the threshold (below which consultation is not required) be: A privately owned aerodrome, with a few privately registered aircraft owned by the same person, and an additional small number of partners sharing the space if they are local to that location. This would achieve the presumed low utilization, as only that owner and associated partners, and that small number of aircraft would regularly use that aerodrome, without limiting the free opportunity of those owner/pilots to use their aircraft, and remain proficient.
I amended the statement for the following reason:

A place that I fly out of recreationally has a few owners with a few aircraft based out of it. It is just a a few certified aircraft and one ultralight. The amount of flying taking place there is minimal and I find the proposed regulations are completely ridiculous and unnecessary.

I have also sent a link to this forum to other affected parties with the expectation that they will send similar correspondence to those responsible...
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lownslow
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Re: The end of private recreational airports??

Post by lownslow »

Thanks for the sample letters, guys. Would an organization take repeated copy/paste letters from many people seriously or is it better to paraphrase it into my own words?
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CpnCrunch
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Re: The end of private recreational airports??

Post by CpnCrunch »

lownslow wrote:Thanks for the sample letters, guys. Would an organization take repeated copy/paste letters from many people seriously or is it better to paraphrase it into my own words?
I think it's much better to use your own words. Definitely don't use that EAA "get off my lawn" form letter posted above.
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Re: The end of private recreational airports??

Post by Taiser »

I got a blast out from EAA showing concern. COPA seems to have something on their site about this but what exactly are they doing to lobby against this? :(
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Re: The end of private recreational airports??

Post by Prairie Chicken »

I agree using your own words is better, but volume of correspondence counts too. The ideas here give you a pretty good place to start. My letter is in draft now.

Edited to add: Letters have now been mailed.
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Last edited by Prairie Chicken on Tue Mar 31, 2015 4:07 am, edited 1 time in total.
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Re: The end of private recreational airports??

Post by Tanker299 »

What if your aerodrome has a gross revenue of less then $30,000? Would it still meet the criteria of a small aerodrome?
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fleet16b
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Re: The beginning of the end of small private airstrips

Post by fleet16b »

Email address for the Minister of Transport

lisa.raitt@parl.gc.ca
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Re: The end of private recreational airports??

Post by fleet16b »

Minister of Transport email address
Please send a letter of protest

lisa.raitt@parl.gc.ca
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Re: The beginning of the end of small private airstrips

Post by PilotDAR »

I have just received the following email:
Dear Mr. -----,

Thank you for your email dated March 6, 2015 regarding the Notice of Proposed Amendments for Responsible Aerodrome Development (#2013-014). Your comments have been forwarded to our technical experts for consideration.

Thank you for your interest in this file and taking the time to submit your comments.


Sincerely,

------
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Re: The beginning of the end of small private airstrips

Post by Thunderbyrd »

This seems reasonable to me, can someone explain why it is not?
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Re: The beginning of the end of small private airstrips

Post by PilotDAR »

This seems reasonable to me, can someone explain why it is not?
Perhaps elaborating of the intended meaning of "This", in the context of the comment would be helpful in preventing misunderstanding....
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Re: The beginning of the end of small private airstrips

Post by ctmorawetz »

Today was supposed to be the beginning of the CARAC hearings on this issue. Has anyone heard any updates about today's proceedings? Any media coverage of it?
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Re: The beginning of the end of small private airstrips

Post by fleet16b »

ctmorawetz wrote:Today was supposed to be the beginning of the CARAC hearings on this issue. Has anyone heard any updates about today's proceedings? Any media coverage of it?
The hearings are taking place
I just spoke with Doug Ronan , who is representing the Canadian Seaplane Assoc.
Doug is in Ottawa working along side COPA , UPAC, APBQ and most of the other major stake holders, all of who are representing us from the Aviation Community.
He reports this a.m. that yesterdays talks went quite well and that some really good progress was made.
This sounds encouraging, I for one am very happy that these organizations are being given a chance to voice their concerns , consult etc
Thank you to everyone there for being our voice
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Re: The beginning of the end of small private airstrips

Post by ctmorawetz »

fleet16b wrote:
ctmorawetz wrote:Today was supposed to be the beginning of the CARAC hearings on this issue. Has anyone heard any updates about today's proceedings? Any media coverage of it?
The hearings are taking place
I just spoke with Doug Ronan , who is representing the Canadian Seaplane Assoc.
Doug is in Ottawa working along side COPA , UPAC, APBQ and most of the other major stake holders, all of who are representing us from the Aviation Community.
He reports this a.m. that yesterdays talks went quite well and that some really good progress was made.
This sounds encouraging, I for one am very happy that these organizations are being given a chance to voice their concerns , consult etc
Thank you to everyone there for being our voice
Great news! Thanks for the update. Let's hope today goes well too.
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Re: The beginning of the end of small private airstrips

Post by RatherBeFlying »

Letter sent -- feel free to plagiarise:

Thank you for the opportunity to respond on this proposal, even though the notice has been short.


EXTENSIVE CONSULTATION NEEDED

First of all I find a certain irony that an onerous public consultation process is proposed to be suddenly imposed on the aviation community when next to no, if any, outreach has been made to that community on how best to accomplish this.

In addition, this proposal is contrary to this government's many initiatives to reduce intrusion on private activities.


REQUEST 1 -- that outreach be made to the aviation community on this proposal in at least as thoroughgoing a manner as that proposed to be imposed upon this community.


BACKGROUND

We are all aware that the closure of Edmonton City Centre Airport and concomitant eviction of many long established operators at great cost to many was done with no meaningful consideration of their needs.

These people were thrown out by a short notice expropriation and were forced to find and develop a greenfield airport with no time available for the niceties of the proposed public consultation procedures if they were to continue in operation.

Closure is a change of use that deserves the same level of consultation with those affected as has been proposed.

REQUEST 2 -- When a public body decides to shut down an airport or redesignate it for another use, that that body undertake the public consultation for the establishment of alternate airport(s) to accommodate the displaced airport.

REQUEST 3 -- that the airport designated for closure be maintained in operation until completion of the public consultation process and construction of alternate facilities adequate for the needs of the displaced aviation community.


NORMAL RURAL COMMERCIAL USAGES

Because of their very nature, airports are a normal rural use. Those airports today in built up areas were initially established before residential or commercial development came near.

The problem is much less that new airports are being established as that many airports are being closed in favor of redevelopment.

REQUEST 4 -- In the spirit of nondiscrimination, public consultation requirements be limited to that locally required for common rural commercial uses such as: feedlots, pig farms, gravel pits, seed cleaning, poultry operations, junkyards, building supply, gas plants, well drilling and operation, equipment and vehicle repair, sales and storage, cheese factories, creameries, wind turbines, pet kennels, gocart and atv tracks, race tracks ...


DIFFERENT LEVELS OF USE CALL FOR DIFFERENT LEVELS OF PUBLIC CONSULTATION

Today most of my flying is in my glider. It has taken decades of hard work for me to be in a position to own an aircraft -- as with most other aircraft owners. One friend has spent decades restoring a historic Tiger Moth, for which he has built a hangar and airstrip on his property.

Glider pilots generally form clubs on rural property to accommodate their aircraft and runways. Clubs have from 6 to 120 members with annual revenues ranging from $5,000 to $120,000. The cost of any public consultation process needs to be within the means of the operators.

REQUEST 5 -- Public consultation costs be limited to 5% of annual revenue or operation costs.


GRANULARITY

Airports range from strips with one based aircraft through glider clubs, small training operations, local municipalities, airports accommodating turbine traffic up to major airports -- all with quite different impacts on the neighboring community.

REQUEST 6 -- Research and consultation be performed on the different levels of impact of the many different kinds of airports and that public consultation requirements be tailored to the different levels of impact.

REQUEST 7 -- Radii requiring public consultation be tailored to the level of proposed operation.

REQUEST 8 -- The radius of 30 nautical miles from a registered or certified airport be reduced to 5 statute miles which is the current radius of the control zone of a tower controlled airport.

Kindly keep me updated on this regulatory initiative. I look forward to a constructive engagement.
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Re: The beginning of the end of small private airstrips

Post by Rookie50 »

ctmorawetz wrote:
fleet16b wrote:
ctmorawetz wrote:Today was supposed to be the beginning of the CARAC hearings on this issue. Has anyone heard any updates about today's proceedings? Any media coverage of it?
The hearings are taking place
I just spoke with Doug Ronan , who is representing the Canadian Seaplane Assoc.
Doug is in Ottawa working along side COPA , UPAC, APBQ and most of the other major stake holders, all of who are representing us from the Aviation Community.
He reports this a.m. that yesterdays talks went quite well and that some really good progress was made.
This sounds encouraging, I for one am very happy that these organizations are being given a chance to voice their concerns , consult etc
Thank you to everyone there for being our voice
Great news! Thanks for the update. Let's hope today goes well too.
I have also heard through the grapevine the talks have gone well and aviations voice has been well heard though this process. Hopefully this is encouraging and we can do all we can to promote GA in Canada.
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Re: The beginning of the end of small private airstrips

Post by rac007 »

Any updates on the results of the CARAC hearings?
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