Review of the Civil Aviation Inspector Community at Transport Canada



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3 The Context of the Review

The context of this study includes the significant issues or developments within the civil aviation sector that effect change within the industry and, conversely, in TC.



3.1 A refocused and reorganized Transport Canada



Due, in part, to the status of public finance in Canada, the introduction and implementation of the Civil Aviation Regulations (CARS), domestic deregulation, and bilateral agreements, such as ‘Open Skies’, the role of TC in the transportation system has changed greatly. With cost recovery there is a continued focus on the delivery of services which are ‘value based’ and, hence, a demand from industry to deliver those services in the most cost effective manner possible.
TC has transformed itself from a policymaker, regulator, and purveyor of transportation services to a policymaker and regulator of the transportation system. The civil aviation safety program has been in the forefront of this transition with the transfer of the assets and the responsibility for the operation of Canada’s civil air navigation system to NAV CANADA effective November 1, 1996. Additionally, with the introduction of the CARS, effective October 10, 1996, clearer regulatory guidelines that could be effectively monitored, audited, and enforced were introduced. Finally, with bilateral agreements such as Open Skies, recent industry growth, and the emergence of new carriers, the aviation business environment has changed significantly over the past decade, prompting the Department to alter its delivery of services and administration of the national civil aviation safety program. Still, the program aims to fulfil the Department’s mission statement: “To develop and administer policies, regulations, and services for the best possible transportation system.”
In response to these challenges and opportunities, the Department has drafted an overall strategy, outlined in Challenge #98: Civil Aviation Program Overview. Briefly, the strategy aims to:


  • Improve ‘big picture’ thinking about safety;

  • Find new ways to share our safety commitment;

  • Rethink our approach to recruitment and training;

  • Improve service delivery;

  • Develop measures of organizational effectiveness; and

  • Explore new ways to fund the program.

All of these components play an important role in the transformation of TC into an organization which is better prepared to respond to the challenge of balancing regulatory intervention against a backdrop of social, economic, and fiscal realities. This must occur, while ensuring that the use of regulatory powers results in the greatest net benefit to Canadian society7. The Department’s overall strategy reflects the recognition that it must realign its service lines to reflect the changes in the industry itself. However, in order for the strategy to be successfully implemented, it is essential that TC realign its internal processes, including the recruitment, retention, and compensation policies of the CAI population.


3.2 A changing regulatory environment



The Department continues to delegate authority to trained, qualified, and monitored individuals in the industry and is moving towards the use of risk management techniques in its decision-making process regarding service delivery and safety regulation.
The emerging challenge for the Civil Aviation in the Department is to balance the demands for greater delegation by the larger airline providers with the need for traditional enforcement and frequent monitoring of very small operators who may operate on the economic margins of the industry. Delegated authority will allow those air operators with strong regulatory compliance records, advanced safety management systems, and the technical and economic resources to manage many components of air safety that were once directly regulated by the Department.
Trained professionals and effective monitoring support this delegated authority to industry employees since, ultimately, it is TC which is responsible for the civil aviation safety program. Current delegations include those to civil aviation medical examiners, company check pilots, designated flight test examiners, and approved engineering, maintenance, and training organizations.
TC is also working towards a risk management model for civil aviation safety. The Department is dedicated “to using risk management techniques in decision-making by adopting a structured process to assist decision-making for front-line and management operations, regulatory change, program priorities and policies, and by providing training in risk management.”8
Risk management introduces the idea that the likelihood of an event happening can be reduced, or its consequences minimized. Effective risk management seeks to maximize the benefits of risk taking (usually a reduction in time or cost) while minimizing the risk itself through the process of identifying risks, assessing their implications, deciding on a course of action, and evaluating the results.9
The focus on risk management is a significant “departure from a traditional, more prescriptive approach to the management of a regulatory-based safety program.”10 As such, CAIs will no longer exclusively act as ‘policemen’ enforcing the ‘letter of the law’ but as ‘safety systems managers’ involved in undertaking ongoing assessments of the risks associated with their respective operational environments and make determinations regarding the degree of regulatory intervention required at any given time.11
Additionally, an essential component of risk management is communication at all stages of the approach to risk management and decision-making. “It is important in addressing stakeholders’ perceptions of risk – perceptions which often differ and must be taken into account in determining the best course of action for minimizing risk.”12
In this context of adopting a risk management approach, the role of the CAI is not the same as it was in the past and the type of skills which will be required by CAIs in the future will need to follow this evolution. These changes in the required skill sets may include:


  • While most CAIs have excellent technical skills and are extremely familiar with CARS, there will be a greater emphasis on safety management skills, which allow the CAI to more efficiently evaluate, measure, and ensure that safety standards are met.



  • CAIs will increasingly become ‘specialists’ rather than ‘generalists’ while continuing to enhance their ability to manage an increasingly dynamic environment.



  • Finally, the communication of the reasons behind decisions will require special skill sets since decisions regarding safety often arouse strong responses, specifically economic ones raised by the operator. Ultimately, the Department’s credibility as an effective risk manager depends on its ability to be a good communicator.

TC will have to take into account and incorporate these new skill sets requirements in its future recruitment practices.


3.3 A changing labour market for licensed aviators



The career progression model in the industry has changed over the past five years due to the reduction of licensed aviation personnel (lower enrolments, higher costs of education, demographics, increased demands of the industry and technological advances in aircraft and simulators). Since TC has undertaken the practice to recruit from a pool of experienced people with an airline transportation pilot license (1,500 hours)13, an instrument and a multi-engine rating, they are greatly affected by any change in the career progression model in the industry.

In aviation, experience is judged in two ways: ‘hours of flying and the kind of flying. The kind of flying refers to the type of aircraft (single engine vs. multi-engine) and if that flying experience relates to in-command (left seat or captain) vs. non-command (right seat or first officer). Most of the regularly scheduled airlines require at least 1,500 hours of flying time, preferably in multi-engine aircraft, to be considered for first officer positions in most of the aircraft they operate. On average, the typical new-hire at regional airlines has over 2,000 hours while the average new-hire at the major airlines has almost 4,000 hours.14 TC, itself a regulated operator, is no exception to this rule.


The traditional career progression model would be summarized as moving through four levels of pilot licenses: student, private, commercial, and airline transport. Additionally, except for the pilot holding only a student license, a license holder may have different ratings or types of certification. A pilot may have ratings for single-engine, multi-engine, land, sea, helicopter and/or instrument flying.

A type rating for the specific model is required before a pilot may fly an aircraft that attains a maximum speed of 250 knots or more, and/or that requires a two-pilot crew15. Therefore, type ratings and pilot licenses work in tandem and form the core of the career progression model.


Another aspect of the career progression model is the segment in which the pilot’s airline is operating. The type of equipment, scope of services (regional, national, international - scheduled or charter services), and the type of operator license granted by TC often determine the segment of the industry. Briefly, the industry segments typically include:


  • foreign operators such as Lufthansa and British Airways;




  • airline operators, such as Air Canada and Air BC, providing scheduled and charter services using aircraft having 20 or more passenger seats;




  • private operators using privately registered and owned aircraft that vary in size but are used for corporate or business purposes and the operators are granted a private operator certificate;




  • commuter operators, such as Bearskin Airlines or Ontario Express, providing scheduled and chartered services using aircraft having 10 to 19 passenger seats;




  • air taxi operators providing scheduled and charter services using aircraft with 9 or less passenger seats;




  • aerial work operators specializing in aerial spray, forest fighting, mapping, etc.; and




  • flying schools providing training on a variety of aeroplanes and helicopters.

It should be noted that many operators might provide multiple services that may cross a number of segments in the industry. For instance, many flying schools also provide air taxi operations. Additionally, there are many interpretations of the variable used to divide the industry into various segments and any segmentation should be used with caution.


Traditionally, most pilot’s careers begin at a flight instruction school and, after an accumulation of hours, commercial and airline transport licensing occurs and once an opportunity opens up with a private, commuter or air taxi operator, he will ‘graduate’ to the next segment in the industry. Again, by accumulating flying hours and endorsements on different types of aircraft, the pilot is able to eventually move to a regional airline as a first officer that is typically affiliated with one of Canada’s two flag carriers: Air Canada or Canadian Airlines International.
Once the pilot obtains pilot-in-command experience as a captain with a regional operator, he may move to the affiliated carrier, to the charter industry, or even abroad to a foreign operator into the ‘right seat’ or first officer position in an aircraft. Typically, for an ambitious and well-placed individual, the career progression model could take a decade or more with no guarantee of reaching the ultimate goal of flying as a captain with a national flag carrier. Often, a pilot’s career ends in the ‘left seat’ or captain position of a regional airline.
Recently, a new career progression model is emerging due to the tremendous growth of the industry. Now it is taking less time than ever for pilots to fly increasingly larger aircraft for the flag carriers or charter operators. However, advancement increasingly occurs from positions in the ‘right seat’ not allowing the pilot to accumulate command time, and management experience, as quickly. This command time is essential for the airline transport pilot’s license.
While the majority of new pilots still find flight instructor positions as their first job, they do not stay there long. Flight schools are complaining of a shortage of flight instructors because the regional airlines and/or large commuter operators pick them up very quickly. It now takes three to four years after graduation to find employment with the regional operators and the prospects have never looked better for those with 1,000 to 1,500 hours of flight time. This is especially the case with formal flying with charter or business time, which allows them to quickly move to the flag carriers. In fact, previous graduating classes from Seneca or Sault Colleges averaged 30 to 35 percent of graduating students finding flying positions within a year. Now the placement rate is approaching 80 percent of graduates.16
Fred Jones of the Air Transport Association of Canada (ATAC) states in a recent Wings magazine article on the flight training industry: “A renewed interest in general and commercial aviation and a return to profitability by many of Canada’s air carriers bodes well for aspiring new pilots. We are starting to see very promising telltale signs that the hiring in our industry, as far as pilots are concerned, is about to explode.” 17
As always, rapid growth of the flag carriers affects all employers of licensed aviation personnel in the aviation sector, including TC. In the end, it is the major air carriers that drive the demand for commercial pilots all the way through the ‘supply chain’.
In the same article, Roger Burgess-Webb of the Canadian Airline Pilots Association agrees and says there will be continued demand for entry-level pilots well into the next century. He noted that the demand for pilots is fueled by the pilot age distribution – where a growing portion of pilots are now in their fifties approaching retirement age. According to Mr. Webb, “The major airlines alone will have a requirement for at least 800 new pilots just to meet current demands - if you add the factor of early retirement, expansion and increases in airline traffic, that figure increases exponentially.”18
The net result of rapid industry growth has been a rapid alteration of the career progression model for pilots. The overall pool of pilots is not growing at the same pace as demand. Thus, there is a tightening of the labour supply at the entry point to the industry and a more competitive market at the senior levels of the industry, which has driven compensation levels higher. And, according to industry observers, this will prove to be the case in the future. “The recent resurgence in general and commercial aviation doesn’t include certain sectors of aviation, but all facets of it, and is here to stay well beyond the year 2000.”19
The increasing competition at the senior levels of the industry directly effects TC, as it is this segment of the pilot population from which it recruits. This is primarily the result of the requirements for an airline transport license, command experience, and a multi-engine and instrument rating. This exposes TC directly to the competitive nature of the labour market.




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