ATTENTION all 702 703 Operators!

[trey kule]

I wasn't too worried about this till I read a 'simple' breakdown of the proposed changes. For me, it would mean the difference between a 14 hr day making a satisfying amount (some days) and a 9 hr day making about 2/3 to 1/2of that. And no, I am not fatigued at the end of my day.

Really? I am not sure where to start.

Revenue will stay the same. Why? Did you consider that as this is hitting the industry as a whole, rates might just have to increase. And twice the pilots does not represent a huge increase. Typically 10%)
But its all about the money...yep....safety is second, and you are the typical pilot who does not get fatigued. Companies that want to cut prices to the bone and then offload this revenue loss to their staff. Work more...it is the way to earn more, rather than getting paid a fair wage for doing your job.

Air Canada. Besides the fact that the proposed regulation does not really change anything for most 705 operators, it is a bad example. How many air Canada pilots fly 42 days straight of max duty time?
Or are asked to call a weather day, a day off (because the regulations say they can), and then are expected to come in and do "other duties" which might include anything from paperwork to washing
customers' cars.

I have no dog in this fight anymore, but I am glad to see it happening. It is what a college of pilots should be promoting if they were really representing all pilots..
Next should be stat holiday pay, protection for whistle blowers, and decent living accommodation for northern pilots . the
oil companies can do it for truck drivers...but the aviation companies can't.

My feverent hope is that when it is finalized terms like duty day, work day, day off, will be worded clearly enough not to allow the snaky operators any wiggle room. Other countries have done a very good job in this regard, but I guess TC, as a leader, has nothing to learn from them

[swordfish]

"Therefore wages will drop"...???

Hello...that should read "tariffs will change to accommodate the increased costs"

[mattjvancouver]

interesting!

[fish4life]

The more I think about it the more 702/703 companies are lucky they never got harder regulation and duty days than 704/705 operators. If you think about it a guy flying an otter for 10 hours on a hot summer day will probably be more exausted than the guy flying a 320 since the guy flying the otter has a lot of non flying related duties throughout the day such a loading and unloading drums while a guy flying a 320 doesn't have to worry about tossing bags in his own plane or fuelling it or a lot of times even flight planning. Don't get me wrong flying an airbus is still working but I'd bet is much less exausted at the end of a day.

[timel]

Very interesting thread.

I will add some 703 can operate with duties up to 15 hours during summer.
People saying wages will drop, I call it BS.

[eh3fifty]

Do I have to carry a copy of these regs on board so I can figure out if I can do a trip when Joe at some mine asks me to drop him off at his buddys mine on the way home, thus adding 1 sector and reducing my allowable duty day?

If you're that incompetent to look at an extremely simple chart for 5 seconds to see how long you can work today, then I don't want you ANYWHERE near an airplane.

If you're still having trouble figuring out the takeoff distance chart I can tutor you tomorrow after 3pm... just send me a PM.

[goldeneagle]

This is going to be brutal for the small owner / operator that runs a floater over the summer, and a wheelie year round. A rather typical example. I have an 0600 launch booked in the morning, taking two folks out to a fishing camp. The only other item on the book for tomorrow, a 1900 pickup at another camp, taking two folks back into town. No problem, under these new regs, I can do that, and call it a split duty day. So tomorrow rolls around, I'm back from the first sortie, and the phone rings, Forestry wants an airplane to launch and check something out, maybe it's a reported smoke, maybe they want to do a 2 hour smoke patrol. That forestry flying, which often comes booked at the last minute, is the difference between a year of starvation, and making a decent living for that year, and the vast majority of it comes during the two summer months where the days are long, and it comes as 'last minute' calls.

So what's a guy to do ? There are no employees in our small family operation, nobody to call in for one of the flights. If I do the forestry sortie, I'm no longer legal to do that late pickup. If I dont do that forestry sortie, they are going to find somebody else, so my main bread and butter will be gone. I cant leave folks stranded in a fishing camp tonite.

These rules may make some sense for airline pilots that get caught up in time zones, exhausted after a 7 hour stint of drinking coffee that gets served on the flight deck, but they will kill the small business that's been working for years to make a reasonable living with a couple of airplanes. That floater spends the whole winter parked, and the one on wheels does a trip or two a month over the winter. Summer fishing and fire season is when one makes a living.

To me, this just looks like another attempt to regulate the small folks right out of the industry yet again.

[duCapo]

"Therefore wages will drop"...???

Hello...that should read "tariffs will change to accommodate the increased costs"

Tariffs will increase if you don't have some gypo flying next door cutting charter rates with the resultant poor maintenance.

[duCapo]

Deadline to respond to NPA has been extended to October 15th. As an operator of 7 703 Beavers, this is going to cost us in extra pilots needed and cost the existing pilots a loss of revenue. There were no representatives from any 703/704 companies fixed wing. Major consultation and rework of NPA is needed

[fish4life]

This is going to be brutal for the small owner / operator that runs a floater over the summer, and a wheelie year round. A rather typical example. I have an 0600 launch booked in the morning, taking two folks out to a fishing camp. The only other item on the book for tomorrow, a 1900 pickup at another camp, taking two folks back into town. No problem, under these new regs, I can do that, and call it a split duty day. So tomorrow rolls around, I'm back from the first sortie, and the phone rings, Forestry wants an airplane to launch and check something out, maybe it's a reported smoke, maybe they want to do a 2 hour smoke patrol. That forestry flying, which often comes booked at the last minute, is the difference between a year of starvation, and making a decent living for that year, and the vast majority of it comes during the two summer months where the days are long, and it comes as 'last minute' calls.

So what's a guy to do ? There are no employees in our small family operation, nobody to call in for one of the flights. If I do the forestry sortie, I'm no longer legal to do that late pickup. If I dont do that forestry sortie, they are going to find somebody else, so my main bread and butter will be gone. I cant leave folks stranded in a fishing camp tonite.

These rules may make some sense for airline pilots that get caught up in time zones, exhausted after a 7 hour stint of drinking coffee that gets served on the flight deck, but they will kill the small business that's been working for years to make a reasonable living with a couple of airplanes. That floater spends the whole winter parked, and the one on wheels does a trip or two a month over the winter. Summer fishing and fire season is when one makes a living.

To me, this just looks like another attempt to regulate the small folks right out of the industry yet again.

So now your fishing guests at the end of the day should be more at risk because you are tired just because you want to make some money during the day flying forestry?

[timel]

Deadline to respond to NPA has been extended to October 15th. As an operator of 7 703 Beavers, this is going to cost us in extra pilots needed and cost the existing pilots a loss of revenue. There were no representatives from any 703/704 companies fixed wing. Major consultation and rework of NPA is needed

Ok and what will be the reasons for losses in revenue? Less work available? Maybe you guys will have to re-think time management for your pilots. People don't decide on the last minute to go on a hunting or fishing trip.

[trey kule]

Deadline to respond to NPA has been extended to October 15th. As an operator of 7 703 Beavers, this is going to cost us in extra pilots needed and cost the existing pilots a loss of revenue. There were no representatives from any 703/704 companies fixed wing. Major consultation and rework of NPA is needed

This is a perfect example of why we need the regulations to be changed.

Operators who when faced with increased costs, respond by slashing pilot wages. No thought to increasing prices...nope...its all about how much it will cost and how you will reduce costs, not change prices. No concern whatsoever that it might make their operation safer.

Now tell us about your management's commitment to safety, and your management of fatigue. If you are going to have to hire more pilots, sounds like your limitation is regulatory only. Zero concern for the human factor. Perhaps if you had given a bit more thought about the people who work for you, the effect of this change would be zero.

The reason for the new regulations being required, is because there are operators out there who will work their employees to the legal limit without any consideration fatigue..
And the lowest of the low, when faced with the government stepping on to do what they should have already done, threatens pilots with salary cuts.

Maybe we could start a thread on the mysteries of high pilot turnover!

[Redneck_pilot86]

Do I have to carry a copy of these regs on board so I can figure out if I can do a trip when Joe at some mine asks me to drop him off at his buddys mine on the way home, thus adding 1 sector and reducing my allowable duty day?

If you're that incompetent to look at an extremely simple chart for 5 seconds to see how long you can work today, then I don't want you ANYWHERE near an airplane.

If you're still having trouble figuring out the takeoff distance chart I can tutor you tomorrow after 3pm... just send me a PM.

The vast majority of 703 work in Canada is last minute phone calls. When I start my duty day, I haven't got a clue how many sectors I can expect to do that day. There is a great example above about getting a last minute call to go do a smoke patrol...which customer do you disappoint? The small guy who booked a 1900 pickup to come to town and meet his wife, or the large customer that, by the very nature of their work, can't give you any more notice? At the start of the day, with 4 legs planned, we were allowed 11.5 hours of duty. But if we accept the 2 legs for forestry, we are now only allowed 10.5 hours, and can't do the evening trip.

I'm not necessarily against reducing duty times. 15 hours a day is ridiculous. But why make this big chart with so many variables? Why not just say we are limited to 12 hours, or 10, or 5, or whatever. Why is the difference between starting at 5:29 am vs 5:30 am worth 30 minutes at the end of my day on a day of shuttles?

[AOW]

If you're that incompetent to look at an extremely simple chart for 5 seconds to see how long you can work today, then I don't want you ANYWHERE near an airplane.

If you're still having trouble figuring out the takeoff distance chart I can tutor you tomorrow after 3pm... just send me a PM.

If it is so simple, can you tell me off the top of your head how many duty hours you've worked in the past 4 weeks, because that is a limit too! Don't forget that your time free from duty depends on whether you are at your home or at a company provided hotel/house. I admit that I appreciate the extra two hours to f****my wife (where **** is most likely "ight"), but if the guy I am paired with is staying in the crew hotel, then he only needs 10 hours free from duty!

The whole purpose of the NPA is to gather input, so anybody who feels that this is more complicated than it needs to be, please make your position known.

[eh3fifty]

No, I don't have my duty times memorized. That's ridiculous. The company I work for has a computer program that does that and many other things.

Are you telling me that these regulations shouldn't go through because companies will be required to get a computer program to input duty hours? Get real!

Why is the difference between starting at 5:29 am vs 5:30 am worth 30 minutes at the end of my day on a day of shuttles?

Redneck, do you really need that explained to you? You're old enough, can't you figure it out? It's the same reason that 60 kph is not speeding in a 60 kph zone and 61 kph is speeding in a 60 kph zone. You need to put the limit somewhere. Your argument has no merit.

[trey kule]

Firstly, there was, and I believe still is, a company in Canada that sells a very inexpensive computer program that can give you the duty hours of every pilot in a company in a minute or two...and I expect they will modify the program if things change. Even red flags.

Duty time off the top of your head! Thats a joke right?

I do hope that individual pilots will indicate their support for this change , or companies will put huge pressure to not have it come into force....and without the other side support, they may get their way.

The arguments by one or two operators here, I hope are not indicative of the majority, or there is a bigger problem than I thought. Their thinking and logic is rather unique and very self serving.
So much for proactively trying to mitagate risk.

[flyinhigh]

The argument I here from operators is NOT the reduction in duty day. It's how complicated it is with the Flight duty period, which is also my bone.

You want to reduce fatigue, Fine, I'm all for that. But reduce the total duty day, hell put it to 8 hours if you worried about it that much. With the way it is written, it is way to complicated (than again we are talking about TC, which makes sense to them).

For those that think they understand this, you better read it again, than go sit with about 10 other people that have a GOOD understanding of this and have a morning sit down discussing it. Remember when RVOP/LVOP came out, EVERYONE had a different understanding of it, the same is happening here.

[duCapo]

Deadline to respond to NPA has been extended to October 15th. As an operator of 7 703 Beavers, this is going to cost us in extra pilots needed and cost the existing pilots a loss of revenue. There were no representatives from any 703/704 companies fixed wing. Major consultation and rework of NPA is needed

This is a perfect example of why we need the regulations to be changed.

Operators who when faced with increased costs, respond by slashing pilot wages. No thought to increasing prices...nope...its all about how much it will cost and how you will reduce costs, not change prices. No concern whatsoever that it might make their operation safer.

Now tell us about your management's commitment to safety, and your management of fatigue. If you are going to have to hire more pilots, sounds like your limitation is regulatory only. Zero concern for the human factor. Perhaps if you had given a bit more thought about the people who work for you, the effect of this change would be zero.

The reason for the new regulations being required, is because there are operators out there who will work their employees to the legal limit without any consideration fatigue..
And the lowest of the low, when faced with the government stepping on to do what they should have already done, threatens pilots with salary cuts.

Maybe we could start a thread on the mysteries of high pilot turnover!

Who the F@#k are you to start slinging accusations at me and my company. Maybe you should think about it before you start slagging a company you nothing about.
EOM

[timel]

Ducapo, could you explain us in which way this new regs are going to effect your business and pilot wages?

[eh3fifty]

Ducapo, could you explain us in which way this new regs are going to effect your business and pilot wages?

[805ITT]

To say just raise prices is quite unfair, there is always a tipping point to A) price yourself out of the market because your customer can no longer afford you or B) price yourself to allow for competition to enter the market.

Pilots - look on the bright side, if this NPA goes through as is it will create 400ish new cruise relief pilots in Canada as AC, Transat and WJ will now need to double augment their long haul flights. Tied in with a bunch of guys hitting 65 at AC and we are going to see a hiring boom in 2016 like we have never seen before. Keep those resumes up to date, hiring is going to get crazy!

[timel]

For pilots who wish to testify about fatigue experiences:

CARRAC@tc.gc.ca

Hi,
Absolutely, we welcome personal experiences as part of the input we are collecting and have received a few personal testimonies from pilots to date. This email is the correct address and feel free to leave out your employer if that makes you more comfortable.

Regards,

Melanie


Mélanie Drouin
A/Manager, Civil Aviation Regulations Advisory Council | Gestionnaire par intérim, Conseil consultatif sur la réglementation aérienne canadienne
Transport Canada | Transports Canada
Place de Ville, 330 Sparks Street, AARBH
Ottawa, Ontario K1A 0N5
melanie.drouin@tc.gc.ca
Telephone | Téléphone 613-990-1415
Government of Canada | Gouvernement du Canada

[duCapo]

Ducapo, could you explain us in which way this new regs are going to effect your business and pilot wages?

Too many "know it alls" on AvCanada with little or no experience in business to get into it on an open forum.

[Heliian]

I would just like to point out that your FDP ends when you shut the engines off and have no more flights. All the work you do after that does not count to your duty period like the current 30 minutes or however you interpret it.

This is why they go through the whole NPA process, to serve fair warning and to allow you to prepare for changes. If you can't tailor your operation to meet the new requirements or make a good schedule for your crews then you don't belong here.

Changes to your organization may cost you revenues or it may not, we can all make scenarios up that won't work with the new hours, but why don't we focus that energy on creating solutions to these "foreseen" problems.

[NotDirty!]

I see this as a mixed blessing for flight crews. Yes, you don't have to work as long, but it probably means that your days off are going to suffer to compensate. Now instead of being able to work long blocks on and getting long blocks off, these new rules will put an end to that. If you are restricted to 60 duty hours in 7 days, you will essentially turn into a pumpkin after the 5th day, if not sooner (1/3 of the time spent on standby counts as duty, so even if you sit all day "on call" and don't get called, it still counts 4 hours towards your duty limit). Not to mention, the 1928 duty hr/365 days is going to affect almost everybody, especially anybody whose work involves single day trips with long holding. That limit seems awfully low, when you consider that in other jobs you can work 150 hrs more than that and still not be eligible for overtime! Welcome to the 37 hr work week!

Why are you restricted to 2 sectors following a split duty break? My total duty day is already limited by number of sectors flown, but the split duty day allows me to extend that slightly... but what if I have to make 2 or more stops on the way home?

The night duty restrictions are going to hurt air ambulance operators a lot! No more than 3 consecutive nights?? ok, there is an ability to extend to 5 nights, if you have a 3 hr break every night, but that only helps freight drivers--medevac guys don't get a guaranteed 3 hr break!! So those guys doing 4 days/4 off/4 Nights/4 off are going to lose out!

Did anybody else notice that there are 6 different duty day limits for starts between 4:30 and 7:00? Isn't there a simpler way?

The FAA imposed VERY similar regulations earlier this year, but with only 10 different start of FDP blocks (but 7 different number of sector columns). Here's a hint to save operators some $$ - IF this is the way it has to go, just copy FAR 117! That way, all of the apps and other software for time tracking for FAA operations can be used by Canadians, without someone having to develop unique Canadian tools.