The objective of Transport Canada's Let's Talk Transportation: Modernizing the Canadian Aviation Regulations (CARs) is to have a conversation with stakeholders, partners, and citizens about Canada's aviation safety regulations. The website, along with a generic email, gave an opportunity to provide input to support the Regulatory Review Initiative.
The consultation was held between April 6 and May 8, 2023 and sought suggestions on what areas of the CARs could be optimized to better serve Canadians. The consultation focused on gathering input related to how Transport Canada (TC) could enhance, improve, or modernize regulations related to general aviation, with a focus on balloon, hang glider, ultralight, and parachute operations.
Transport Canada received feedback from aviation industry representatives, including training pilots, commercial pilots, and industry associations, among other interested stakeholders.
The consultation webpage received 72 online submissions, and eight email submissions were sent to the generic inbox. In total, the 80 submissions highlighted over 100 suggestions. Below is a summary of what Transport Canada heard during the consultation. Feedback has been organized thematically.
What we heard
Suggestions were made in relation to the HAGAR exam. Constraints of needing to take the exam in a Transport Canada facility restrict the availability of the exam, especially for those in remote locations.
The procedure for class 4 self-declared medical should be changed to become a true self-declared medical as processing times are rising to six months or more.
Restrictive operational requirements should be revised. Common grievances are centered around:
- The use of oxygen for flights above 13000 feet for turbine skydiving operations.
- The use of aviation radio with a hang glider in class G airspace.
- Requirement of Class 4 minimum certification to provide training for a recreational permit, and others.
Unclear, contradictory, or outdated regulations
Some definitions in the CARs could be perceived as ambiguous for general aviation purposes. Transport Canada should clarify definitions in the CARs, such as "unpowered light aircrafts" and "passenger" vs "crew member".
There are overlapping requirements in CARs Part V and Part IX related to advanced autopilot and remotely piloted aircraft that should be reconciled.
The gross weight (maximum take off weight) of both Basic and Advanced Ultralights should be merged.
Skydiving operations and ultralight/gliding operations should be treated equally in the CARs.
Outdated requirements in the CARs should be eliminated. Such outdated requirements could include:
- helmets in all basic ultralight aircraft
- governing hang glider operations in class E airspace
Alignment with international partners (US, EU, UK, ICAO, etc.)
Currently, aircraft licensing standards could be perceived as providing an undue competitive advantage for American commercial aircraft operators over their Canadian counterparts within Canada due to differing aviation regulations.
Canadian standards should be aligned with ICAO standards as it pertains to unoccupied free balloons.
A driver's license should replace category 4 medical certificate as a means of validating ultralight permits.
The creation of a new class for ultralight vehicles, gliders and powered aircraft should be created similar to other jurisdictions (i.e., UK, Germany, etc.)
Gaps in current regulations
A suggestion was made to develop a new category for commercial operators who fly day Visual Flight Rules (VFR) only.
There is no wording in the CARS that clearly defines a three axis ultra-light aeroplane.
There were multiple suggestions to introduce a low-cost solution for electronic conspicuity for hang glider and ultralight pilots in air traffic.
Feedback received during this consultation is valuable for the development of a regulatory proposal to modernize regulations related to general aviation. The comments and suggestions will be assessed and validated with various subject matter experts within Transport Canada Civil Aviation.
Industry partners will get an opportunity to review the regulatory proposal when a Notice of Proposed Amendment is published through the Canadian Aviation Regulation Advisory Council. A subsequent opportunity to provide feedback will also be provided when the proposal is published in the Canada Gazette, Part I.
A broader consultation on what other areas of the CARs could be modernized to better serve Canadians is still ongoing through the Let's Talk Transportation: Modernizing the Canadian Aviation Regulations.
Questions or concerns can be sent to the Aviation Safety Regulatory Review Team.
Thank you again to all who have taken the time to provide feedback.