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HAC met with the CTA prior to publication of the regulations, in June of 2018, to emphasize to the Agency that the draft regulations should not apply to helicopter operations. Their application to helicopter operations would only serve to burden small business, without any attendant benefit to Canadian travelers who often “sit beside the pilot”, and who are well aware of the reason for delays, for example. While CTA staff were largely unfamiliar with the type of work that we do, they seemed to understand how the proposed regulations were ill-suited to operations our industry – not only in terms of the type of charter operations that we carry out, but in terms of the smaller number passengers that we carry annually. In the draft regulations, the CTA seems to acknowledge that most small operations should be excluded from the application of the draft regulations however, please take some time to review the regulations and provide HAC with your comments. Set out below are some excerpts from the preamble to the draft regulations, and a link to the full text of Canada Gazette I publication.

“The Air Passenger Protection Regulations (APPR) would apply to all flights to, from and within Canada, including connecting flights. This includes certain charter flights on which one or more seats are for resale to the public, namely charter flights within Canada and flights to and from Canada that are a part of a charter originating in Canada.” 

“In certain elements of the proposal, there is a distinction made between large and small carriers. For these purposes, large carriers are considered to be carriers that have transported at least one million passengers in each of the two preceding years, as well as those operating a flight or carrying passengers on their behalf through a commercial agreement.” 

Read the Draft Regulations in French or English, at page 4879 

HAC Operator-Members with comments on the draft regulations are encouraged submit their comments to the HAC at fred.jones@h-a-c.ca no later than February 13 2019, when HAC will be consolidating comments-received in a written submission to the CTA.