ATAC Requests Gov't Suspend Duty Regs

[BoeingMan289764]

https://www.atac.ca/post/letter-to-mini ... egulations

The ATAC has submitted a letter to the Minister of Transport requesting that the newly implemented fatigue rules be suspended for a period of no less than 18 months on the grounds of a severe pilot shortage, and suggests that the new rules as a whole are impossible to implement for all carriers except Air Canada.

The full PDF letter can be found in the linked webpage.

[Downwash]

So, ATAC is ok with pilots working fatigued and unsafe?

[flyingcanuck]

The balls these people have.

"Safety is our priority... As long as it doesnt stop is from making money"

[Stratopaused]

Imposing a regulation requiring an overnight increase in pilots in the midst of severe pilot
shortage demonstrates a complete lack of understanding and a total disregard for sustained air
services to Canada’s remote regions.

They had four years of warning!

This government is driving up the cost of our industry, making us globally uncompetitive...

But the northern operators aren't competing globally. No one is trying to decide whether they're going to do a fishing trip in northern Ontario or Belgium, so it's not like customers are going to flee to other parts of the world if prices rise. Also, the regs work for Air Canada, which does compete globally, so what exactly is their logic here?

Since they want the new regs suspended, why not just suspend all flight and duty regs? If pilots can work 24/7, the operators will make a ton of money! They'll make even more if they don't have to pay their employees, so maybe it's time to get rid of those pesky laws against slavery too!

[Big Pistons Forever]

It is tough to make an industry wide policy work for everyone. I have some sympathy for the VFR 703 operators where a one size fits all FDT presents challenges to operators and arguably decreases operational efficiency with no obvious increase in flight safety for many companies particularly helicopter and float operators.

That being said all operators had 4 years notice of the requirement and did not appear to be especially proactive in making a case for different regulations. I would suggest it would be far more useful if ATAC presented some concrete proposals to address the friction points in the current regulations.

One obvious change is the elimination of the reduction of duty times with more flights. If the report time was for example 0600 and more than 18 flights were conducted than the pilot would duty out at 1600. For a day VFR helicopter shuffling people or stuff around a work site every day is probably going to exceed 18 flights but the flying will be over with a lot of the work day left and a pilot who is not fatigued.

I also think it is more than a little disingenuous for ATAC to blame the pilot shortage on the FDT regulations. Operators need to take more responsibility for the pilot shortage and start being part of the solution not the problem.

[digits_]

If you're flying from 0600 to 1600 vfr on hot summer days in a helicopter likely close to the ground, I'd say you're likely very fatigued after 18 flights if you do that every day, but you won't necessarily feel it because it's the afternoon.

That's a 10 hour work day. That should be enough.

[Stratopaused]

Even if specific operators receive exemptions, or there's a blanket exemption for all of 703, I don't see how that's going to help with a pilot shortage. I imagine there are a lot of people who are happy in their current positions because they have good lifestyles, but when they're forced to go from a 10-hour day to 14 hours they're going to become disgruntled. Working your employees to exhaustion is just asking for them to quit and find better WAWCON, so any modifications to the FDT regs is going to backfire. The shortage isn't because of the regs, and operators don't seem to appreciate that the pilots they currently employ haven't quit because they're still fine with the working conditions, not because they're stuck with no options. Management thinks it's still 2020, and they want indentured servitude.

[cykj]

I agree with his points regarding Transport, Nav Canada, CATSA, etc. I'm not very smart but I've been aware of this page since it was published in December 2018.

https://www.canada.ca/en/transport-cana ... ement.html

Mr. McKenna writes as if he was informed of these changes last week. Perhaps he should pay more attention to what's going on.

[Arnie Pye]

Safety third.
No wonder our pilots are fleeing for other jurisdictions.

[goingnowherefast]

Almost, but we're forgetting that flights conducted VFR don't need to care about leg count, 700.28(9). Start at 6am, that's a 12 hr day for 1 leg or 20 legs if they're all VFR. Quite reasonable I'd say.

In glad the industry lobby group struggles with reading comprehension as well as ignoring the CARAC process and Gazette publications. US and European duty regs are more restrictive than even the new Canadian regs, so that statement is a straight up lie. All this makes them look the fool.

I'm wondering if this letter is more intended for ATAC membership to make it seem like they're doing something. I bet TC will store that letter in the shredder.

[TG]

I bet TC will store that letter in the shredder.

I hope they would do just that...

[Meatservo]

I really feel sorry for the little grassroots chicken-shit northern carriers. I mean how hard is it to get these goddamn lazy pilots to do an honest 14 hours for Christ's sake? Next thing you know, they're going to want holidays and regular days off and benefits. How is an employer meant to survive? It's insane! I mean, how the hell are they going to get their flights done with these reduced times? It's already pretty difficult to get 6 hours of flight time out of a typical crew with all the time they spend loading and fuelling their own planes, filling out reams of redundant paperwork that the accounting guy would prefer not to have to do, because he's not always there to do it with his weekends off and holidays and especially any time before 9:00 AM or after 5:00 PM.

This is just like the time they invented "minimums" and suddenly the lazy bastards were doing "missed approaches" when the weather wasn't perfect. Why is it so hard to get pilots to do any work? It seems like all they want to do is fly planes. THAT'S when they are supposed to be taking their "breaks"; not on company time when they should be loading their planes.

[DanWEC]

McKenna and ATAC are very dubious "allies" in our industry. Aside from the lobbying to promote aviation business, I'd straight out state they are our worst enemies to our pay and conditions.

[Donald]

His background has nothing to do with aviation.

Great guy to lead ATAC.

[Commonwealth]

He holds a Master's Degree in Soviet and Eastern European Ecconomic Studies. I think that qualifies him pretty well.

[EPR]

He holds a Master's Degree in Soviet and Eastern European Ecconomic Studies. I think that qualifies him pretty well.

That's it...you're going straight to Tulita to load bags for a couple of years!

[Rowdy]

The new FTDT regs are a JOKE.

Thanks for making my life considerably worse and more fatiguing. Instead of working y 14-15 days a month, I now HAVE to work 18-19.

I don't know about you.. but an extra 4-5 days a month is WAY more detrimental than an extra leg or one more hour (14 being thew max of coure).

It also drives me insane to see there was NOTHING in there in regards to circadian lows OR those godawful Standups. Seriously, I'd rather stick a hot fork in my eye than do one. It makes me completely useless as a human bean for the next three days.

[digits_]

The new FTDT regs are a JOKE.

Thanks for making my life considerably worse and more fatiguing. Instead of working y 14-15 days a month, I now HAVE to work 18-19.

I don't know about you.. but an extra 4-5 days a month is WAY more detrimental than an extra leg or one more hour (14 being thew max of coure).

It also drives me insane to see there was NOTHING in there in regards to circadian lows OR those godawful Standups. Seriously, I'd rather stick a hot fork in my eye than do one. It makes me completely useless as a human bean for the next three days.

Circadian lows are implemented in the table that limits your duty day based on amount of flights and start time of your duty day.

[Rowdy]

The new FTDT regs are a JOKE.

Thanks for making my life considerably worse and more fatiguing. Instead of working y 14-15 days a month, I now HAVE to work 18-19.

I don't know about you.. but an extra 4-5 days a month is WAY more detrimental than an extra leg or one more hour (14 being thew max of coure).

It also drives me insane to see there was NOTHING in there in regards to circadian lows OR those godawful Standups. Seriously, I'd rather stick a hot fork in my eye than do one. It makes me completely useless as a human bean for the next three days.

Circadian lows are implemented in the table that limits your duty day based on amount of flights and start time of your duty day.

So flying more legs is going to change when my low is? I don't think so. It just makes my flying schedule less productive.

Also, the science behind the duty limits is flawed. If I NORMALLY wake up at 730am every day I'm not at work, my personal low will be at 230-3. Day 1 of a 4 day that starts at 558am doesn't move that up to 130. Our bodies don't react that quickly.

Again, the new FTDT has me MORE tired, MORE fatigued, Away from home MORE, they are MORE complex than needed and...I"M MORE PISSED OFF.

I suggest a rewrite. Why can't we match the EU or FAA?

[digits_]

So flying more legs is going to change when my low is?

No, but if your low is during your duty day, you either have to fly less legs or have a shorter duty day. Look at the tables in the new regs, duty days encompassing 3 am for example, more limited in legs or duration.

[digits_]

I suggest a rewrite. Why can't we match the EU or FAA?

If you're pissed off by the 'complexity' of the new Canadian rules, you certainly don't want to be flying under the EU rules!

The EU rules wouldn't allow you to hold the same schedule that only had you fly 15 days a month either.

[Rowdy]

I suggest a rewrite. Why can't we match the EU or FAA?

If you're pissed off by the 'complexity' of the new Canadian rules, you certainly don't want to be flying under the EU rules!

The EU rules wouldn't allow you to hold the same schedule that only had you fly 15 days a month either.

The complexity doesn't piss me off. The extra days I now have to work, for the SAME PAY does. The extra days I'm away from my family does. The fatigue working 18-19 days a month does to me.

You're right, and I have zero interest in operating in the EU.

[digits_]

I suggest a rewrite. Why can't we match the EU or FAA?

If you're pissed off by the 'complexity' of the new Canadian rules, you certainly don't want to be flying under the EU rules!

The EU rules wouldn't allow you to hold the same schedule that only had you fly 15 days a month either.

The complexity doesn't piss me off. The extra days I now have to work, for the SAME PAY does. The extra days I'm away from my family does. The fatigue working 18-19 days a month does to me.

You're right, and I have zero interest in operating in the EU.

Your arguments seem to be all over the place. How is pay relevant in a fatigue discussion? Would you be less fatigued if they paid you more?
You want the new rules to match the EU ones but you don't want to operate under them?

Sounds like your anger should be directed at your employer or your union, not at TC.

[Donald]

I find I work less, shorter days.

Only major difference is that it's much more difficult to pick up OT, as you're not usually legal.

[Rowdy]

If you're pissed off by the 'complexity' of the new Canadian rules, you certainly don't want to be flying under the EU rules!

The EU rules wouldn't allow you to hold the same schedule that only had you fly 15 days a month either.

The complexity doesn't piss me off. The extra days I now have to work, for the SAME PAY does. The extra days I'm away from my family does. The fatigue working 18-19 days a month does to me.

You're right, and I have zero interest in operating in the EU.

Your arguments seem to be all over the place. How is pay relevant in a fatigue discussion? Would you be less fatigued if they paid you more?
You want the new rules to match the EU ones but you don't want to operate under them?

Sounds like your anger should be directed at your employer or your union, not at TC.

Typical Avcanada response.