ATAC and HAC Meet with Treasury Board Senior Staff

ATAC and HAC met with a senior staff member at Treasury Board to voice our concerns over the inadequacy of the Regulatory Impact Analysis Statement (RIAS) conducted as part of the Canada Gazette I process. In its response to the publication of the draft regulations in Canada Gazette I, HAC wrote, in part “The written survey of operators was conducted in the midst of the summer operating season – when small seasonal operators are working at peak and less able to focus on the completion of surveys. What’s more, the survey was ambiguously worded and confusing. It required that operators completing it base their comments on an older version of the proposed regulations, that needed to be updated by the survey respondents through the use of a matrix that respondents were expected to apply to the outdated regulatory text.” … “The effective response rate for the RIAS survey was … 6.2% … for [CAR] 703 operators.”  The associations have repeatedly made the point that there has been a lack of transparency in the consultation process and that fatigue is a safety issue that is being managed by the commercial air carrier community. Fatigue has never been on the TSB’s WatchList for aviation. “The RIAS survey should be a source of embarrassment to the Minister and his staff, and falls woefully short of the standard that Canadians expect from their regulators when significant new regulations are promulgated.”