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What specific irritants do you have with Part II of the Canadian Aviation Regulations (CARs)?

10 months ago

When submitting your comments, please be as detailed as possible and include the specific provision(s) it refers to.The information you provide will help to inform regulatory amendments to Part II of the CARs.

Consultation has concluded

  • chrisisflying 8 months ago
    I would also say that processing time of Transport Canada in regards to aircraft registration (or pretty much everything aviation related) is ridiculous. The service standard states 60 working days. That's 12 full weeks if there is no bank holiday. Often times, aircraft are purchased and registered for commercial purposes and being grounded for three months or even longer can put companies out of business. Our taxes are high, aviation related government fees are high, look at the cost of avgas here compared to the U.S. and yet, service standards are one, if not even the worst of all civilized nations across the globe. It simply shouldn't take 60 working days for something as basic as registering an aircraft or changing the ownership of an aircraft. The FAA gets those same tasks done within less than six weeks i.e. less than 30 working days. How can they be twice as efficient as our Canadian counterparts?
  • chrisisflying 8 months ago
    Removed by moderator.
  • William Clark 9 months ago
    Bill Clark-YYZLAWI agree with the commentary already posted. Time for service is our problem in servicing acquisitions, disposals and leasing of aircraft. Especially in the business end of our practice it is difficult to explain to purchasers importing a multi-million dollar aircraft into Canada why they have to pay finance charges sometimes for months before they can use their new asset due to registration delay.And we are now encountering difficulties in exports especially to the US where the delay in deregistering is now becoming known and we are encountering demands that funds will not flow to the Canadian seller until dereg is completed-they are accustomed to these matters being finalized while the closing call is completed.This delay is eventually going to reduce the marketability of Canadian aircraft into any international markets.
  • BCCampbell 9 months ago
    My comment refers more to the process regarding aircraft registration (or a change of registration). The requirements of the CARs are quite specific and extensive. In my corporate aviation career at a large CAR 704 operation and now at a CAR 604 operation, I have registered, de-registered and re-marked over 200 aircraft. Some transactions are time-critical - mainly the purchase, importation and entry-into-service of aircraft new to Canada or the operation. Typically the process requires many documents some of which are available early in the process, others not until the very end (bill of sale, notice of foreign de-registration). Currently, the expectation is that the file will not be started until all the documents are submitted, and the level of service clock begins then. This can lead to major delays after a purchase and an aircraft is ready for import and operations. There should be a process whereby the file can be started with a forecast delivery date, documents are filed as they become available, and when the last documents are submitted, the registration process can be quickly finalized and a C of R issued.Another suggestion - eliminate the need for paper Temporary Cs of R. In this age of scans, email and immediate connectivity, a scan of a C of R or written authorization should be more than adequate to meet the documentation needs of an aircraft. The cost and energy to apply for a Temporary and then a permanent seems impractical.
  • NATAadvocacy 9 months ago
    At NATA 43, the northern and remote aviation conference that was held in Yellowknife April 29-May 1,2019, members queried TCCA on its service delivery- citing cases of 60 days or more to get an aircraft registered. Which is TC service standard- which is ridiculous! Members passed Resolution 2019-4 requesting TCCA review its service standard and separate safety issues from retail and admin issues such as registering an aircraft.