Government & Regulatory Affairs

Welcome to CBAA's Government & Regulatory Affairs Update.
This new monthly update will feature our ongoing and completed advocacy initiatives in support of the Association and its members. You'll find summaries of these activities with relevant background information via links.

Members may also seek additional information on request through membersupport@cbaa.ca. This is also an opportunity for members to connect with the Association and raise points of interest or concerns in the Government & Regulatory Affairs area. 

May 2024 Issue

Welcome to the May 2024 issue of CBAA Government & Regulatory Affairs Update. In this issue you will find various regulatory and operational updates as well as a summary of advocacy activities conducted in support of our membership that occurred in April and early May 2024. As you may have noted in the April 2024 and in this update, the rate of regulatory activity at Transport Canada has increased as expected since the Department initiated post-ICAO audit follow-ups.


Aviation Day On The Hill - On Wednesday, May 8, 2024, the CBAA was proud to take part in a joint Aviation Day on The Hill. Together with a group of national associations (see below), we hosted an event that invited MPs, Senators and their staff to hear a joint message about aviation in Canada. Together, members of our board and Anthony advocated for the needs of business aviation. While this is one part of our strategy, the biggest difference you can make is getting involved with your elected officials. Want to know more about the impact you can make? Reach us at membersupport@cbaa.ca.

List of co-hosts:  ATAC, CAC, CBAA, COPA, NACC, NATA and NAV CANADA


SMS Planning for Biz Av Operators - ICYMI, the first in a series of information sessions was brought to you by the CBAA on May 2nd about SMS Planning for Biz Av Operators. The session covered Biz Av Operator Annual SMS Review responsibilities. Couldn't make it? Check out this video recap. The next session will cover self-audit – stay tuned for further information.

Transport Canada Service Change - Online Booking Tool for Aviation Exams - TC has announced the launch of its new online booking tool for aviation exams. Effective immediately, clients needing to book an aviation exam to be invigilated at a Transport Canada Centercan conveniently utilize theCivil Aviation Online Exam Booking Tool. TC states that the digital platform significantly enhances the exam scheduling process by providing: 

  • Flexible scheduling 
  • Payment integration 
  • Automated confirmations and reminders 
  • Rescheduling and cancellation options 

Please read the full email here

Transport Canada Regulatory Initiatives

To ensure that the membership is aware of key regulatory initiatives at TC, their impacts, and how the Association is advocating on your behalf, here is the CBAA’s Summary and preliminary Analysis of the Transport Canada Regulatory Initiatives for the 2024-2026 period.  This summary is maintained as initiatives proceed. As well, the CBAA’s Summary and Preliminary Analysis document also includes other TC proposals issued for consultation where member input would be welcomed.

  • Proposed Amendment to the CARs - Personnel Licensing and Training - On Saturday 30 March 2024, Transport Canada published through the Canada Gazette a proposed amendment the CARs 400 series - Personnel Licensing and Training and some associated amendments to CAR 604 training requirements for a 30-day comment period that closed on 29 April 2024. Submitted comments may be seen in the Canada Gazette link.  An initial Association summary and analysis can also be seen here. Further information on the changes and comments received will be shared as it becomes available.

  • TC Notice of Proposed Amendments (NPA) - NPA 2024-001 – Update - In January 2024, we shared TC’s Notice of Proposed Amendment (NPA 2024-001) to amend the Canadian Aviation Regulations (CARs Part II) in relation to aircraft identification, registration, and operation of a leased aircraft by a non-registered owner. The Association did not comment on the NPA as our review of proposed changes concluded that they would not impact members. TC has advised that it received 245 submissions from various stakeholders mostly from the general aviation sector. A summary of these comments is shared in the enclosed What We Heard report.

  • NPA 2024-007 - Low Impact Amendments to Address ICAO Findings - TC has published NPA 2024-007 titled Low Impact Amendments to Address ICAO Findings. The proposed amendments seek to address areas of the Canadian civil aviation regulatory framework that are misaligned with the International Civil Aviation Organization’s standards.  These changes address issues concerning foreign medical examiners, carriage of documents on board the aircraft, the aircraft flight manual, ground and flight training programs, read back of safety information, air traffic flow management and pilot-in-command authority and responsibility.


The Association’s review of the proposal shows that this amendment is not expected to have a significant impact on business aviation operators. It is of note that some operators may need to adjust documents carried on-board aircraft and their audit checklists. Business aviation operators that also operate under CAR 703 or 704 may have to adjust their documentation in several areas which would align with CAR 604 requirements if not already in-place. Should you wish to provide comments to TC, you may do so in writing via the Comment Submission Form for NPAs or directly to TC at TC.CARConsultations-RACConsultations.TC@tc.gc.ca no later than June 11, 2024.

  • Approach Ban Initiative – Special Issue Aviation Safety Letter (ASL) - Over the past months we have shared several updates of TC’s work towards revising regulations related to the Approach Ban including the Association’s detailed comments on how best to address Graphic Area Forecast (GFA).  Through various discussions with the aviation community, TC has moved to address the matter wholistically. In this special issue (linked here) of the ASL, TC has summarized the various part of what is now called the Approach Ban Initiative and is being led by the Associate Director General of Civil Aviation. We look forward to sharing further information from TC and to contributing to this initiative.

  • Flight Duty Time and Fatigue Management Assessment Paper - Consultation Period Closing Soon - Transport Canada has published here a Preliminary Issue and Consultation Assessment (PICA) paper for consultation. The PICA has been prepared in recognition that, since the flight and duty time regulations have come into force, concerns have been raised by this Association and all segments of the aviation industry. Through this PICA, Transport Canada is advising that it wishes to work with industry to address concerns. The document represents the first step in the consultation process to gather information that will inform the next steps moving forward. TC will analyze the information that is received, and key themes and focus areas will be identified to inform the next steps, which could include focus groups, working groups, issues papers and so on.


Although the consultation period is closing soon (20 May 2024), please send comments or feedback to membersupport@cbaa.ca and the Association will ensure TC considers them in their analysis.

  • Proposed Vancouver International Airport Zoning Regulations (VIAZR) – The regulations were pre-published  in the Canada Gazette, Part I on 20 April 2024 for a 60-day consultation period ending June 19th. These regulations are being proposed to ensure the future viability and safe airport operations, minimize wildlife hazards and communication interference, and correct and clarify airport terminology. Further information can be found here.

Transport Canada Advisory Circular Advisory Circulars (AC)

  • Methodology for the Identification of the Aircraft Group Number (AC 302-019) - This issue of AC 302-019 provide guidance on the identification of the Aircraft Group Number. In this specific issue, the Appendices A and B, referring to the AGN flow methodology examples, have been revised to reflect the changes brought by the 1st amendment of TP 312 5th edition made effective January 15, 2020 and the references regarding the characteristics of aircraft types have been updated in sections 2.3 and 4.1 to include the links to the latest version of the Federal Aviation Administration (FAA) database and to the Airport Planning Manuals from one more aircraft manufacturer.

  • Documentation Required for the Installation of Parts onto Canadian Registered Aircraft - This issue AC 571-024 contains information that should be made available to your maintenance organizations. TC advised that the purpose of this AC is to provide information and guidance on the certification required for the installation of parts on a Canadian registered aircraft or on a component intended for installation thereon.

Canadian Aviation Safety Alerts (CASA)

  • Bombardier model BD-700-1A10 and BD-700-1A11 - Transport Canada has issued a Canadian Aviation Safety Alert (CASA 2024-03) to owners, operators and maintainers of Bombardier Inc. aeroplanes titled Inboard Flap Spigot Tube and Mid and Outboard Flap Corrosion. This CASA recommends incorporation of the Maintenance Review Board Report (MRBR) and Aircraft Maintenance Manual (AMM) tasks addressing this corrosion into the Transport Canada (TC)-approved maintenance schedule and accomplishment of these tasks.

  • Potential Risk of Interference of 5G Signals on Radio Altimeter - Transport Canada has issued Canadian Aviation Safety Alert (CASA 2024-05). In their summary Transport Canada (TC) states it has studied the equivalency of the Canadian spectrum environment to the U.S. to determine whether the 5G tolerance requirements for radio altimeters (RadAlt) set by the Federal Aviation Administration (FAA), known as Radio Altimeter Tolerant, can be leveraged for the Canadian environment. TC has accepted the scientific conclusions from Innovation, Science, and Economic Development (ISED) Canada and as validated by the Communications Research Centre Canada (CRC) related to the safe operation of radio altimeters in the planned Canadian spectrum environment. The CASA also presented the potential way forward under consideration, as well as the ongoing recommended actions.

Airworthiness Directives (AD) - Transport Canada has issued here AD CF-2024-12 - ATA 32 – Landing Gear – Uncommanded Steering due to Nosewheel Steering Potentiometer Universal Coupling Setscrew Failure applicable to Bombardier Inc. model CL-600-1A11, CL-600-2A12 and CL-600-2B16 aeroplanes.

MMEL Revisions - Transport Canada has issued revision 6 for the EMB-545 and EMB-550 MMEL dated 31 May 2022 and revision 4 for TC MMEL Supplement dated 24 April 2024. To download the latest version, visit TCCA MMEL-TCS

Service Difficulty Reports - The following shares recently published information on the TCFeedback website.  These are shared with members who may operate these aircraft or engine types: 

  • PT6A-34 - Oil Filter Inner Mesh Cone 
  • PW150A - Chafed Oil Scavenge Line 
  • TSIO-520-M - Blocked Oil Vent Line 
  • PT6A-50 - Damaged Garlock Seal 
  • CL600 2D24 (RJ900) - CRJ 900 – Passenger Door Aft Fitting Cracks and Fitting Attachment Bolts Sheared
  • CL600 2C10 (RJ700) - RJ700 – Fuselage Skin Damage Due to Electrical Arcing 

Transport Canada Information Webpage on Exemptions (New) - Every year, Transport Canada Civil Aviation (TCCA) handles a variety of exemption requests from the regulatory provisions contained in theCanadian Aviation Regulations(CARs) and standards. These requests come from individuals and organizations who may not be familiar with the exemption process.  Until recently, the TCCA website did not provide information on what constitutes an exemption or how to apply for one. Recognizing the importance of transparency and accessibility, Transport Canada has developed aninformative webpage on exemptions

NAV CANADA updates

  • Please find here, on behalf of Nav Canada, a letter to stakeholders from Jeff Dawson with regard toan update onCanada’s ADS-B mandate. For additional information on ADS-B, please refer to AIP CANADA ENR section 1.6.3 available here. Any questions should be forwarded to NAV Canada. 

  • Nav CANADA Aeronautical Study - Secondary Surveillance Radar - NAV CANADA has remined operators of Aeronautical Studies undertaken to review Secondary Surveillance Radar (SSR) requirements at several locations (message linked here) as previously announced in March 2024. This is because these SSR systems, implemented by Transport Canada in the early 1980s, are ageing, and the facilities will require replacement in the near future. NAV CANADA is reviewing the SSR at the locations listed below. 


Quebec and Ontario 

Prairies and British Columbia 

Big Trout Lake 

Chibougamau 

Fort McMurray 

Grande Prairie 

Chisasibi 

Hearst 

La Ronge 

Stony Rapids 

Lac Brisay 

Kuujjuaq 

Thompson 

Port Hardy 

 

 

Prince George 

Sandspit 

 

The Terms of Reference can be accessed here. Although the input period for the SSR Aeronautical Studies identified above willcloseonMay 30th, 2024, the Association has been advised that input will be accepted beyond that date.


Ongoing activities & Future Update
Looking forward to seeing many of you at the convention in June.

Are you seeking information on a government and regulatory affairs matter? Please forward your query to membersupport@cbaa.ca.

April 2024 Issue

Welcome to the April 2024 issue of CBAA Government & Regulatory Affairs Update summarizing all regulatory and operational updates completed in March 2024 as well as a summary of advocacy activities conducted in support of our membership.

Included with this update is a Transport Canada Post ICAO Audit Update message (here) outlining their post-audit corrective action plan. The Association is closely monitoring activities to ensure that actions or proposals adequately reflect the needs of our members.  As such, we are sharing the message with members for their information and future participation in Transport Canada's review of proposals as they arise.

Transport Canada Regulatory Information and Updates

The following contains documents shared during March that may be important to members. Of specific importance to those members who may also have CAR 703 or CAR 704 Air Operator Certificate is a consultation request about Flight Duty Time and Fatigue Management

  • TC Consultation Request - Flight Duty Time and Fatigue Management - Preliminary Issue and Consultation Assessment (PICA) -  Here is TC’s Preliminary Issue and Consultation Assessment (PICA) paper for consultation. TC has prepared this paper in recognition of the concerns raised by this Association and all segments of the aviation industry since the flight and duty time regulations have come into force. Through this PICA, Transport Canada is advising that it wishes to work with industry to address concerns. Please read the full article here. Although the Association is actively reviewing the PICA, we encourage members that also have CAR 703 or 704 AOCs to review and provide their views.
  • Advisory Circular - Flight Crew Fatigue Management – Prescriptive Regulations - Here is Issue 4 of AC 700-047 Flight Crew Fatigue Management – Prescriptive Regulations. This issue, effective 21 March 24, reflects consultations and feedback received to date about the Flight Crew Fatigue Management – Prescriptive Regulations to explain the intent of the associated regulatory requirements. Although the AC has been published, should stakeholders have additional feedback or concerns, you may do so in writing to TC.CARConsultations-RACConsultations.TC@tc.gc.ca no later than May 20, 2024.
  • Advisory Circular - Carriage of Medical Oxygen Cylinders or Portable Oxygen Concentrators for Passenger Use on Board Aircraft - Here is issue 4 of Advisory Circular AC 700-002 titled Carriage of Medical Oxygen Cylinders or Portable Oxygen Concentrators for Passenger Use on Board Aircraft. This AC is important for CBAA members who may also have a CAR 703 or 704 commercial air operator certificate pursuant.
  • Advisory Circular - Potential for High Energy Fires due to Lithium-Ion Batteries - Here is the published version of AC 700-065 Issue 01 dated 2024-02-26. The purpose of this AC is to advise operators of the potential for high energy fires on board aircraft caused by the failure of lithium-ion batteries contained in portable electronic devices.
  • Advisory Circular - Dangerous Goods Specific Approval - Here is AC 700-001 Issue 06 - Dangerous Goods Specific Approval dated 2024-03-27. This document provides guidance to air operators on how to obtain the Dangerous Goods Specific Approval (SA) on their Air Operator Certificate (AOC).  The Dangerous Goods SA is required for members who also hold a CAR 703 or 704 Operating Certificate.
  • Revision to ACP Manual - Transport Canada has published ACP/AQPE Bulletin # 01/24 Revision 1 dated March 22, 2024. The bulletin is shared with members who are also Approved Check Pilots (ACP).  The bulletin can be viewed here. The update includes information on revisions to the Flight Test Guide documents as they are associated with the ACP Manual.
  • Global Aeronautical Distress and Safety System (GADSS) - On 16 May 2023, Transport Canada published a Preliminary Issue and Consultation Assessment (PICA) on the implementation of the Global Aeronautical Distress and Safety System (GADSS) in Canada and sought feedback from the aviation industry stakeholders. The CBAA along with other associations provided comments which have now been published in a What we Heard report which provides a thematic summary of the comments received as part of this consultation. TC has advised that it will continue to engage with industry stakeholders as the department moves towards implementing GADSS.

NAV Canada information and Updates

  • Transitioning to True North - ICAO is currently considering a work plan item that would see aviation globally transition to True North from Magnetic North. To better prepare for these discussions, the International Business Aviation Council (IBAC) is seeking information from the CBAA and international member associations to determine a common opinion on the transition from magnetic north to true north designators. Read the full article here. Please send your comments and ideas to membersupport@cbaa.ca.
  • Aeronautical Studies were initiated to assess the surveillance requirements for the identified vicinities of:
    • north-western Quebec (Lac Brisay, Chibougamau, Chisasibi and Kuujjuaq) and northern Ontario (Hearst and Big Trout Lake) (linked here).
    • Northern Prairie provinces (Thompson, La Ronge, Stony Rapids, Fort McMurray, Grande Prairie) and Northern British Columbia (Prince George, Sandspit, Port Hardy/Holberg) (linked here).

Emerging / Evolving Issue - GPS Spoofing: Should Operators Be Concerned?

In the March issue of Government & Regulatory Affairs, we published an article titled Emerging / Evolving Issue - Beware of Spoofing which shared the events of an Israeli flight from Thailand (here). In its March/April 2024 issue of Insider, the National Business Aviation Association (NBAA) presented an article titled GPS Spoofing: Should Operators Be Concerned (linked here).

Given that the spate of reported incidents of GPS spoofing in certain airspace regions last year unnerved many international business aircraft operators, we believe it is important to share all relevant information in this matter. The article provides information on how concerned industry should be about this issue and how operators can tell when they’re being spoofed (e.g. recognizing the signs).

Airworthiness Directives (AD)

Here are Airworthiness Directives (AD) for the BD 500 and CL 600 series aircraft that members operating those types may need to know

Transport Canada Exemptions

Here is Transport Canada global exemption NCR-013-2024. The purpose of the exemption is to allow licensing applicants who have applied for a two-crew type rating after January 1st, 2023, but no later than July 31, 2024, and who have successfully completed the knowledge requirement in or after October 2021, to extend their exam validity.

 ICYMI - MMEL amendments

  • Here is MMEL revision 11 dated 25 May 2023 and TC MMEL Supplement revision 3 dated 7 March 2024 for the GV, GV-SP and GIV-X.
  • The TC MMEL Addendum Amendment for the CL-600-RJ dated 23 February 2024 (STC SA23-99) is available here.

Bilateral / Technical Agreement Update - Civil Aviation Safety Alert (CASA) 2024-02

Transport Canada has published CASA 2024-02 issue # 01 titled Approvals under the FAA-TCCA IPA that can be viewed here. The purpose of this CASA is to inform aircraft owners, operators, maintainers, and distributors of the documentation requirements for parts intended to be installed in accordance with a Federal Aviation Administration (FAA) Supplemental Type Certificate (STC) design approval grandfathered under the Implementation Procedures for Airworthiness (IPA) between the FAA and Transport Canada Civil Aviation (TCCA).

Ongoing activities & Future Update

Transport Canada Regulatory Initiatives – To ensure that the membership is aware of key regulatory initiatives at TC, their impacts, and how the Association is advocating on their behalf, is the CBAA has developed a Summary and Preliminary Analysis of these initiatives (2023 edition here).

TC has recently released its Forward Regulatory Plan containing revised priorities for 2024 and the next several years. The Association is now reviewing these and is amending its Summary and Preliminary Analysis document which will be shared with the May Government & Regulatory Affairs Update. 

Are you seeking information on a government and regulatory affairs matter? Please forward your query to membersupport@cbaa.ca.

March 2024 Issue

Welcome to the March 2024 issue of CBAA Government & Regulatory Affairs Update. In this issue you will find various regulatory and operational updates as well as a summary of advocacy activities conducted in support of our membership that occurred in February 2024. In this issue we also introduce the sharing of Airworthiness Directives (AD) information that are seen of importance to members.

Transport Canada Safety Collaboration Forum

Earlier this year, Transport Canada announced that they would host four virtual Safety Collaboration Forum briefings. The first two briefings were held this February with the next sessions planned for March.  Information on the first two briefings is shared below:

  • The first session was a briefing on Transport Canada’s SMS modernization initiative. The briefing was a summary of the Notice of Proposed Amendment information received earlier and shared in the February update here. For your reference, we have enclosed the meeting notes here.
  • The second session was a briefing on Transport Canada’s Aircraft Ground Icing-related Activities. Meeting notes and associated presentations are shared here.

Emerging / Evolving Issue - Beware of Spoofing 

In recent months, the aviation industry has learned that bad actors have attempted to create hazards or dangerous situations by spoofing Air Traffic Control.  Although these issues are in areas of conflict zones, here is an article on the subject for your information.

Canadian Aviation Safety Advisory (CASA) 2024-01

Here isCASA 2024-01 - Incorrectly Installed Outflow Valve (OFV) Coupling. This CASA applies to owners, operators and maintainers of Airbus Canada Limited partnership aeroplanes model

BD-500-1A10 and BD-500-1A11. 

Airworthiness Directives (AD)

  • Here is AD CF-2024-05 - Emergency AD – Engine – Second-Stage Power Turbine (Pt2) Blade Failure
  • Here is AD CF-2024-06 - Flight Controls – incorrect airplane flight manual (AFM) approach speed adder and landing distance factors for slat-flap fail caution CAS message () - This AD applies to Bombardier Inc. model BD-700-1A10 and BD-700-1A11 aeroplanes.

Transport Canada Exemptions

  • Global Exemption Request – On behalf of affected members, the Association has submitted a Global Exemption Request to allow for specified aircraft to operate without CVR/RIPS under CAR 604. Several aircraft certified under FAR23 / Subpart 523 of the Airworthiness Manual are certified for single pilot operation, which does not require a CVR/RIPS. Although not required, some CAR 604 operators have opted to conduct their corporate operations with two pilots. In so doing, they become required by 605.34(1) to install CVR/RIPS, thereby introducing significant cost to these operators. The outcome is that corporate operators who opted for two pilot operations may revert to single pilot operations, thereby resulting in possible increased operational risks, to mitigate costs.
  • Here is NCR-001-2024. While this exemption is applicable to airport operators, it is being shared with members to advise that airports can initiate installation of signs consistent with internationally accepted standards and that a transition time can be expected.  Further information on schedules as applicable can be obtained from your local airport authority. 
  • Here is NCR-003-2024. While this exemption is applicable to AMOs, this exemption is shared to inform members that AMO certificate holders with rating(s) in the Avionics, Instrument and Component categories have received relief from the requirements of subsection 573.02(11) of Standard 573. They will not be required to have procedures for the evaluation of undocumented parts outlined in Appendix H of Standard 571 approved in their Maintenance Policy Manual. 

Bilateral / Technical Agreement Update

Here is Issue 1 of the Canada/Brazil Technical Arrangement on maintenance. This reciprocal agreement is important for organizations who have work completed in Brazil or for Brazilian organizations doing work in Canada.

Transport Canada Advisory Circular (AC 601-007) - Submitting an Aeronautical Assessment Form (AAF) 

Here is AC 601-007, Issue 01 titled When to Submit an Aeronautical Assessment Form (AAF) dated 2024-02-27.  The purpose of this AC is to provide guidance for when to submit an Aeronautical Assessment Form (AAF) for obstacle notification and assessment to the Minister.  While this AC is primarily applicable to any person who plans to construct or modify a building, structure or object, or launch a tethered object who would be notifying the Minister of their plan, the information presented herein is of use to anyone in the aviation industry in general should they need to advise the Minister of any such structure that may not have previously completed in accordance with the CARs. 

Victim & Family Assistance – Update

 Here is an update on Transport Canada’s consultation paper published on November 9, 2023, to inform the aviation industry of potential new victim and family assistance requirements for air operators and airport operators and to solicit their questions and comments on the new initiative which was also briefed on during the 20th Canadian Aviation Regulation Advisory Council (CARAC) Plenary.  In response to the consultation request, the Association provided a detailed letter to TC on December 5, 2023, that was a significant part of the 10 responses received by TC. The content of these responses is covered in the What We Heard Report herein.

Ongoing Activities & Future Update

 Transport Canada Regulatory Initiatives – To ensure that the membership is aware of key regulatory initiatives at TC, their impacts, and how the Association is advocating on their behalf, here is the CBAA’s Summary and preliminary Analysis of these initiatives.  This summary is maintained as initiatives proceed. TC has advised that the next update to reflect priorities over the next several years will be made available by Spring 2024. We will keep you informed as priorities evolve.

Are you seeking information on a government and regulatory affairs matter? Please forward your query to membersupport@cbaa.ca

Past Editions

Are you seeking information on a government and regulatory affairs matter? Please forward your query to membersupport@cbaa.ca