CARAC Part IV deals with Personnel Licencing and
Flight Training. A Part IV Technical Committee meeting was held in Ottawa on
June 25 and 26 and was attended by COPA staff member Adam Hunt.
The package of Notices of Proposed Amendments (NPAs) was a thick one for this
meeting. It included 74 separate NPAs to be discussed.
As with most proposed changes to the CARs there was some good news and some bad
news for COPA members.
Let’s start with the good news. COPA previously asked for an amendment to CAR
421.05 to simplify the requirements for non-Transport Canada run safety seminars
to qualify as approved recurrency training.
The current rules require “participation in a recurrent training program which
is designed to update pilot knowledge of human factors, meteorology, flight
planning and navigation, and aviation regulations, rules and procedures that has
been approved by the Minister as being satisfactory for those purposes”. As many
Rust Remover organizers have found you couldn’t get a program approved unless it
included all those subject areas, exactly as the CAR says!
The new rules simply insert wording that a safety seminar could include such
subject areas as those listed above. In other words you aren’t required to cover
all those subject areas, they are just suggestions. The requirement for approval
is still there for the program to count as recurrency training, but this change
should enable COPA Flights to much more easily run their own approved safety
seminars.
COPA would like to acknowledge the work of Arlo Speer and his staff at Transport
Canada Recreational Aviation and Special Flights Ops for working with COPA on
this issue and for bringing this positive NPA to the table.
The bad news at this Part IV meeting was that TC is proposing to prevent Class
III flight instructors from conducting freelance training. This was part of a
big series of NPAs that will eliminate the Class IV Flight Instructor rating and
replace it with an “intern phase” as part of the Class III Instructor rating.
Most of the proposed changes are good news – they will simplify the process of
becoming a flight instructor and make it easier for the Flight Schools to
administer their less experienced flight instructors.
COPA is very opposed to the elimination of freelance privileges for Class III
instructors. It will eliminate the ability of current Class III instructors from
earning a living as freelancers and will greatly reduce the options for members
of the Canadian public who own and airplane an want to hire someone to teach
them how to fly.
In their support for eliminating the freelance privileges for Class III
Instructors TC completely failed to present any data to show that there is a
safety case to be made for this move or that there is a public interest case to
be made either. TC is required to show either a “data driven” safety case or a
public interest case to justify introducing changes to the CARs.
COPA is filing its dissent with TC about these changes and has asked the
executive body of TC, the Canadian Aviation Regulations Council, to allow
“graduated” (post-intern) Class III instructors to continue to have the
privileges that they have now.
There were many more NPAs discussed at this Part IV meeting. COPA is a member of
all nine CARAC Technical Committees and attends CARAC meetings to represent the
views and needs of COPA members.