What we heard: Modernizing the Canadian Aviation Regulations Part IV & VII: Personnel training, qualifications, and licensing

Transport Canada is changing the way we deliver our programs and services, to better serve Canadians and to adapt to a changing world. As part of this work, we’re reviewing and modernizing the regulations we oversee. This includes the Canadian Aviation Regulations and related standards. We’re making regulations more flexible, responsive and risk-based.

We’ve focused on dealing with more than a thousand issues with the Canadian Aviation Regulations. These issues were raised through different means, including a public consultation. The goal of this consultation was to speak with stakeholders, partners and the public about Canada’s aviation safety regulations. It gave stakeholders a chance to provide input directly to the Aviation Safety Regulatory Review Team.

We held a public consultation between January and June 2020 to get input on issues with regulations for personnel training, qualifications, and licensing. We asked stakeholders to identify specific issues they had with training, qualifications, and licensing related to Part IV, and Part VII of the regulations.

More specifically, we asked stakeholders “What specific irritants do you have with personnel training, qualifications, and licensing (as related to Part IV and Part VII) in the Canadian Aviation Regulations (CARs)?”

Our consultation received 630 visits, and seven submissions. We received feedback from aviation industry representatives, including Canadian air carriers and industry associations, among other interested stakeholders.

In total, the seven submissions highlighted the following issues that we will review.

On this page

Key issues

  • Logging “pilot in command” time through the Pilot in Command Under Supervision (PICUS) program can be difficult because training captains need to log PICUS time.
    • Requiring pilots to log 200 PICUS hours in 12 months is hard for First Officers.
  • There is extensive training for pilots on CARs Part IV which focuses on flying operations, but topic is barely covered for Aircraft Maintenance Engineers.
    • The Department should:
      • consider revising a structure for technical airworthiness mechanics and/or inspectors
      • revise training for tradespersons, and Aircraft Maintenance Engineers
  • The information on GPS and flight management system receivers in parts of the Information for Commercial Air Service Standards is outdated.
  • More requirements to qualify for Part 703 single pilot GPS approaches are too demanding.
  • Crew resource management training for Part 703 operators doesn’t allow training to be adjusted for the size and needs of the organization
  • Transport Canada needs to look at the gaps between the Canadian and United States versions of the airframe and powerplant oral and practical tests.
  • The number of aircraft stalls required for CASS training 703/704/705 needs to be clarified.

The Civil Aviation Regulatory Review team has grouped the issues that were raised during the consultation into three themes:

  1. Harmonize with international standards
  2. Update supporting material, regulations and guidance
  3. Update training

The team will analyze these issues more and add them to the regulatory review multi-year work plan. The team will send other feedback to the relevant team leads and will use the results to help with future work of the Department, especially items that require new policies.

You can find more information on this project and the Civil Aviation Branch’s forward plan in the Transportation Sector Regulatory Review Roadmap and the Forward Regulatory Plan.

Next steps

TCCA will continue to ask questions on specific irritants and solicit feedback from specific stakeholders. Please visit Let’s Talk Transportation: Modernizing the Canadian Aviation Regulations for the latest updates.

Please send your questions or concerns to the Aviation Safety Regulatory Review Team: TC.CARReview-ExamenduRAC-TC@tc.gc.ca.

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