The following is a letter COPA President/CEO
Kevin Psutka wrote to Canadian Transportation Commissioner regarding Air
Canada’s opposition to Nav Canada’s fee increase as well as the airline’s dismay
with paying for services it says it does not use.
Dear Commissioner,
I am writing on behalf of 18,000 members of the Canadian Owners and Pilots
Association who use aircraft for personal travel and recreation in Canada,
concerning the filing by Stikeman Elliot on behalf of their clients, Air Canada,
opposing the recent NAV CANADA fee increase.
The Air Canada proposal is contrary to the spirit and intent of the fiscal
principles in the Air Services Commercialization Act.
Air Canada contends that it should not pay for services that it does not use;
specifically those that they feel are provided exclusively for General Aviation.
I would like to emphasize that the system of navigation aids, weather reporting
stations, communications stations, towers and the like, are just that – a
system. Control towers at smaller airports that Air Canada does not serve, for
example, are available for Air Canada’s use in case of emergency.
The Flight Information Centres, providing en route weather, emergency
communications and search and rescue notification are available for all to use.
In fact, I have heard several Air Canada flights contact the Flight Information
Centres for weather information during my flights this year.
The non-commercial users are paying for the availability of NAV CANADA services
with after-tax dollars. We have no one to pass the fees on to, and NAV CANADA
has been sensitive to this in the setting of their fees.
Furthermore, the air navigation system was built for the airlines and, for the
most part, we are incidental users of the system. Consider us the bicycles of
the air. A relatively minor portion of the system is provided exclusively for
our use, similar to bike lanes.
There are many places where we are not allowed or discouraged from using,
similar to many high traffic roads, and there are other places where we use the
same airspace and facilities as the airliners, like on city streets. The bike
lanes are provided to separate bikes from the rest of the traffic, which
benefits the vehicle traffic and enhances safety.
Towers at smaller airports serve the same purpose. Smaller airports off-load the
general aviation traffic from the larger airports, providing capacity and safety
benefits for the airlines and their passengers.
There are no separate charges for the use of bike paths because it would
discourage people from using them, which would not be in the interest of safety.
The same is true for the charging principles for the air navigation system.
Everyone pays into the road structure in one capacity or another, for the
benefit of all. This fundamental and similar principle is entrenched in the Act
and it would be severely compromised if the charging principles in the Act were
changed as suggested by Air Canada’ submission.