ATAC Presentation to the Standing Committee on Transport, Infrastructure and Communities
(SCOTIC)

Fred Gaspar
Vice President, Policy and Strategic Planning
Andy Vasarins
Vice President, Flight Operations

Tuesday, March 20, 2006

 
Thank you very much, Mr. Chairman and good morning.  Malheureusement, monsieur le président, nous n’avons pas eu le temps de traduire notre présentation en français.  Je m’excuse.

We appreciate the opportunity to appear before you today, on behalf of the Air Transport Association of Canada, to speak to the issue of modernizing Canada’s flight attendant / passenger ratios.

Before I do so, however, I want to make one thing perfectly clear in response to some of the characterizations of our industry’s position on this debate in the press over the last few weeks and months; neither ATAC nor our members would ever propose any regulatory change which would endanger passengers, period.  Not to cut costs, not for any reason whatsoever.

In fact, safety and innovation have been hallmarks of our association from the beginning.

ATAC was founded in 1934 as the national service organization for Canada’s commercial air service providers and currently represents over 200 members, comprising over 95 per cent of Canada’s commercial aviation revenues.  Our membership is diverse; ranging from Canada’s largest airlines to flight schools throughout the country.  ATAC works on behalf of the industry to promote a world-leading commercial aviation sector based on safety, efficiency and innovation.

On this issue, in particular, ATAC – and more specifically, my colleague Andy Vasarins – has been working through the Canadian Aviation Regulations Advisory Council – or CARAC – process to advance this change for over 2 years now.  Indeed, this issue has been studied thoroughly at CARAC, which is an open, inclusive body, where organized labour has been a robust participant in the process.  It has also been debated before this committee in each of the last two Parliaments.

While we have no interest in revisiting old ground on this debate, we would like to take the opportunity you have given us here today to provide some context to this issue, speak to the integrity of the process of amending aviation regulations in Canada and set the record straight on some misperceptions that have been perpetuated by those who have waged a very public campaign against modernization.

As you well, know, Mr. Chairman, the issue we are referring to is a request by our industry to bring Canadian flight attendant ratio regulations in-line with those of the US and most EU countries.  The current regulation requires 1 flight attendant for every 40 passengers, whereas most regulatory regimes throughout the developed world require 1 flight attendant for every 50 seats.

While opponents of this proposal have, unfortunately and irresponsibly suggested that this would compromise safety, in fact, a detailed review of the proposal conducted by an independent consultant for the CARAC process concluded that no such case could be made.  Moreover, it should be noted that during the three years that this proposal has taken to work its way through the CARAC and CARC processes, significant amendments and caveats have been added to ensure that this proposal does not, in fact, compromise safety.

Firstly, air carriers will not be allowed to rotate back and forth between 1:40 and 1:50.  They will be required to declare that they are operating under one standard or the other, be certified to that standard and stick with it to avoid potential confusion amongst staff.  For similar reasons, flight attendants will only be allowed to be certified on up to 3 aircraft types.  Also, notwithstanding the ratio, all wide-body jets will have to have as many flight attendants as there are emergency exit doors on each passenger level.  Moreover, carriers who choose to operate under the new standard will be required to demonstrate equal capability to evacuate their aircraft in case of emergency to the same standard that applies under the existing ratio; commonly known as the 90-second standard.  The result, Mr. Chairman, is that even after this change is implemented, it is highly likely that many flights will still carry more than the minimum crew complement assumed by those doing the simple 1:50 math calculation.

In short, the process has worked.  Detailed, data-driven studies concluded that there would be no reduction in safety by adopting this proposal and consultative dialogue with stakeholders resulted in a further set of restrictions to ensure that all possible concerns were addressed.  We would respectfully suggest, Mr. Chairman that this committee should support the work of the CARAC process.  It is one which ensures that civil aviation regulations are debated in a non-politicized, data-driven environment to seek to achieve the best result for Canadians.

Unfortunately, opponents of this proposal have chosen to use fear in attempt to achieve politically, what they have failed to achieve at CARAC.  Again, the facts are our best ally in rebuffing their claims.

The 1:50 ratio has been in use for a little over 30 years in the United States and slightly less time in the EU.  In that period of time not one aviation incident report has cited this ratio as a contributing factor in cases of serious harm to passengers from aviation incidents.  In fact, since air carriers are regulated according to the regime in their home countries, there are literally dozens of large commercial flights from US and European airlines which operate into Canada every day carrying thousands of passengers under the 1:50 ratio.  This standard is so common and universally accepted as a safe one that modern aircraft are actually designed and built, assuming the 1:50 ratio.  In short, it’s working today in Canada and throughout the world.

Similarly, it has been working for some Canadian-certified aircraft, as well, which are operating under special provisions allowing them to staff according to the 1:50 standard.  Specifically, each of the Bombardier CRJ-200, Dash-8 300 and the ATR 42-300 aircraft have been operating perfectly safely using this standard for some time now.

Mr. Chairman, it’s time to allow Canadian carriers to compete fairly with their US and European counterparts.  Yes, this is largely a cost issue for our members but, as I stated at the outset, we would never allow cost concerns to supersede safety concerns.  The simple reality is however, that there is no data to suggest that there are any outstanding safety issues associated with this proposal.

There was a time when every aircraft had a flight engineer on the flight deck.  There was also a time when every flight attendant had to be a registered nurse.  Clearly those regulations evolved in response to the times.  So too, must the flight attendant passenger ratios in Canada evolve to meet safe and proven international standards, which allow Canadian operators to compete and thrive with their international counterparts on a level playing field.

Thank you for your time.  With that, we look forward to your questions.