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Submission to the CTA Regarding Proposed Amendments to the APPR

We appreciate the opportunity to provide comments on proposed changes to the APPR’s. ATAC recognizes that some effort has been made to account for the unique operating challenges faced in Canada which is vast in size and dependent on-air accessibility especially in regional and northern communities. The unique operating challenges faced by small and medium-sized operators serving the regional and northern communities should be addressed independently by a carve out in the regulations. The current regulations, along with the proposed changes, do not reflect adequate understanding of the operating challenges faced by airlines servicing these areas of Canada. Additional on-the-ground outreach is needed with the communities themselves and the carriers serving these communities to better understand the challenges. This research and analysis is seriously lacking in the regulatory impact statement for the proposed amendments.


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