From a broad point of view, the group discussed the possibility of delegating to the HAC the responsibility and accountability for setting commercial helicopter operational standards, as well as issuance and maintenance of helicopter air operator certificates. At the end of the day, all parties agreed to continue discussing the issue and exploring its potential, without committing to anything.
At the meeting, Gage explained how the CBAA’s private air operator certificate program works and what results have been achieved. The CBAA has been responsible for the issuance of private air operator certificates in Canada for about two years now. The program has proven very cost-effective for the taxpayer without causing any job losses or layoffs in the public service. Transport Canada has simply redirected freed-up resources to more productive safety oversight activities.
Prior to the meeting, Jenner consulted a half-dozen CBAA members, some of whom are also members of the HAC. Jenner says that all six confirmed what Rich Gage had identified as the three principle advantages: 1. The level of service from CBAA is superior to the level of service offered by Transport Canada when it comes to things such as issuances, amendments, etc., 2. Although they have to pay for the CBAA services, they come at a price that is cost-effective to the operators, because of rapidity and quality of the service, and 3. CBAA members find the private sector audits to be more in-depth and complete than Transport Canada’s, even though they take less time and tend to be less intrusive.
The question is, can this model be used in the context of a commercial helicopter services? The CBAA members’ comments suggest that, liberated from public sector constraints, the HAC might well deliver better oversight for less money from the taxpayer and better service for a little more money from the operators. However, Transport Canada has expressed concerns about the apparent contradiction between the profit motive and the delegation of responsibility for safety oversight. While that may be an issue in regard to delegation to individuals, HAC counters that the discussion is now about the delegation of oversight to the industry as a whole. There’s a big difference between individual commercial interests and the economic interest of the entire industry.
Jenner believes that operators know safety is good business and that a safe operation is also a reliable operation. A properly maintained aircraft is available for service when the customer needs it. A poorly maintained aircraft stays on the ground while its customers fly on a competitors’ aircraft. Safety is a recipe for financial success. Nonetheless, in cases where an individual operator is in a bad financial shape or lacks business acumen, Transport Canada is right, safety might be compromised in favour of short-term profit.
But Jenner is also quick to point out that at any given time the vast majority of Canadian operators are not in financial trouble, nor do they lack good business sense. Since the association is under the control of the entire industry and not of an individual or group of individuals, HAC will always be guided by the good of the industry. That good is synonymous with safety. Since strong safety oversight ensures a level-playing field, the vast majority of operators will demand that their association ensures short-term individual gains do not take precedence over safety imperatives.
Like CBAA, Jenner thinks HAC oversight would probably be more rigorous than Transport Canada’s. For example, Transport Canada has now essentially abolished PPCs for single-engine VFR helicopters. The HAC board of directors is convinced if HAC had been responsible for the oversight and management of the system, it would not have abolished PPCs. Instead, it would have made the PPC program more accessible and more efficient.
As a result of the meeting, HAC and Transport Canada will now analyze the possibility of creating a “new collective accountability framework” based on delegating responsibilities to industry collectively through its association. Since the basics are the same, whether it’s business aviation or commercial helicopters, they will proceed by way of a differential/gap analysis of the feasibility studies that were done for CBAA.
The HAC must still confirm that delegation would be of net advantage to its members. Jenner believes there’s enough potential to make continued discussions worthwhile, while expanding consultation on the issue to the entire membership.
As for Transport Canada, up till now it has been looking primarily at the principle of delegation to individuals, this shift of perspective now has them looking at the principle of delegation to the collective. The idea has merit. It will be interesting to see how all of this unfolds.