Air Time Versus Flight Time Issue Unlikely to be Resolved – At Least Until the Fall

You may recall from a previous issue of the Newsletter, that Transport Canada is revisiting the definitions of Flight Time and Air Time that were recently imposed on the industry. The current definitions have been delivered to Justice, for their interpretation, and there has been some recent dialogue with HAC. Your association has tried to help inform the Department about some of the problems that have arisen with the current definitions. The current definitions were not really drafted with the rotary-wing community in mind. Your association is concerned that the department will torture the interpretation of the current definitions, by applying Guidance Material, rather than fix the problem by revisiting the definitions themselves. You can’t fix a bad definition by applying your own definition that defies the meaning of the words in the regulation. HAC believes that would be “regulation through Guidance Material,” which circumvents the regulatory process altogether.