The Canadian Business Aviation Association CBAA said that its Subpart 703 on-demand air-taxi members will be “severely” affected by Transport Canada’s impending proposed flight and duty time (FDT) crew fatigue management rules. Subpart 604 private operations will not be affected. The association is “fighting for its many members who provide ad-hoc charters and medevac services, and whose business would be significantly curtailed if the regulations were enacted as proposed.”
The proposed rules, scheduled to be published in the second quarter next year, are expected to follow recommendations published in late 2014 by the Canadian Aviation Regulation Advisory Council (CARAC). In 2015, Transport Canada published its intent to issue a notice of proposed amendment, saying the current limitations, published in 1996, “are not supported by today’s fatigue science and are not meeting ICAO’s Standards and Recommended Practices.”
After an 18-month review of the current regulations, the CARAC concluded that daily pilot duty periods are too long, rest periods are too short and human physiology and cumulative fatigue are not considered. By its own admission, the advisory council said the effects of the proposed rule changes on Subpart 703 operators “will be significant.”
The current FDT requirements for these groups are significantly less restrictive than for airline operations. “Adjustments to operating schedules may be required,” the CARAC said.
