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. 

AnchorApril 2025 Issue

Welcome to the April 2025 issue of the CBAA Government & Regulatory Affairs Update. In this issue, you will find a consolidation of regulatory and operational updates as well as a summary of advocacy activities conducted in support of our membership during February and March 2025.

Legislative & Regulatory Publications – The following are recent regulations that have been published:

  • CARs Low Impact Amendments and Codification of ExemptionsFurther NPA 2022-008 and 2023-004 titled Low Impact Amendments and Codification of Exemptions shared in October 2022, and April 2023, respectively, this is to advise that the Regulations Amending the Canadian Aviation Regulations (Various amendments 2023) came into effect on February 26, 2025. The final version of the regulatory changes can be accessed here. Accordingly, the following exemptions apply: 
    • NCR-002-2024: Exemption from subsection 605.27(3) of the Canadian Aviation Regulations.
    • NCR-050-2021: Exemption from subsection 705.221(1) of the Canadian Aviation Regulations.
  • In February 2025, various amendments to the CARS were published. The amendments, detailed in the link above, were to address various minor issues affecting the CARs. These were identified as part of Transport Canada’s Aviation Safety Regulatory Review initiative and in letters received from the Standing Joint Committee for the Scrutiny of Regulations (SJCSR). Further details can be viewed here.

Regulatory Planning & Initiatives – The following is an update of current regulatory initiatives being considered by Transport Canada.

On 24 February 2025, TC briefed on a planned Global Exemption and sought Association feedback to assess if the proposal would alleviate some of the concerns expressed by the business aviation community. CBAA participants included two member operators that represent the issues identified during the PICA consultations. Improvement suggestions were made by participants.  TC noted that they would consider these to ensure that the exemption meets the needs of CBAA operators. After the meeting, TC shared the following notes that reflect the Association’s advocacy. The full article can be accessed here. The Association will continue its advocacy efforts and keep members informed of all developments.

  • NPA 2025-001 was published to consult the aviation industry on proposed amendments to TP 7775 – Procedures for the Certification of Aerodromes as Airports. This NPA is shared with members for information purposes should they wish to provide feedback. Comments may be provided in writing to TC.CARConsultations-RACConsultations.TC@tc.gc.ca no later than April 20, 2025.
  • NPA 2025-002 was published to consult the aviation industry on proposed amendments to Standard 425 - Flight Training. The objective of the proposal is to establish a framework requiring flight schools that are using electrically powered aircraft to develop a Transport Canada-approved training program to identify the potential risks and describe the mitigation measures they will implement. Comments may be provided in writing to TC.CARConsultations-RACConsultations.TC@tc.gc.ca no later than April 24, 2025. 
  • Pre-NPA Engagement Strategy - Transport Canada has advised stakeholders of its intent to publish a Notice of Proposed Amendment (NPA) containing a variety of amendments to each of the Commercial Air Services Standards (CASS) subparts. The attached document provides background on the upcoming NPA, the standards subject to the proposed amendments, and the intent of the consultation. Transport Canada plans to distribute the CASS Omnibus NPA in April 2025 with an associated 60-day consultation period. As this NPA will impact both CASS 723 & 724, the Association will share it as it becomes available and will also review the documents.
  • An Aeronautical Information Services (AIS) and Instrument Flight Procedure Design (IFP) Services Modernization consultation paper was published by TC. The paper can be accessed here and outlines TC’s proposal to modernize the regulatory framework for AIS and IFP design as set out in the CARs.

Canadian Aviation Regulations (CARs) Standards – There are no new Standards to present in this issue.

Transport Canada Advisory Circulars (AC)

  • AC 507-002, dated 31 March 2025, provides guidance to persons applying for a Certificate of Airworthiness (CofA) for an imported, type-certified aircraft. This AC discusses only the Certificate of Airworthiness (CofA) issued pursuant to CAR 507.02. This AC does not cover other types of flight authorities, such as Special Certificates of Airworthiness or Flight Permits. It also does not cover the requirements related to registration of the aircraft, although an aircraft must be registered in Canada to receive a flight authority. 
  • AC 606-001, dated 19 February 2025, titled Flight Simulation Training Device (FSTD) Qualification Requirements for Required Navigation Performance (RNP) Instrument Approach Training provides the criteria used by the National Simulator Evaluation Program (NSEP) to evaluate and qualify an FSTD for RNP-based approach training. 
  • AC 201-002, dated 20 March 2025, provides guidance regarding the CARs that pertain to Aircraft Identification and Marking. -Transport Canada has also issued a companion document AC 202-002 - Aircraft Registration that guidance regarding the process of registering an aircraft and obtaining a Canadian Certificate of Registration, with related information regarding aircraft import and export.

Canadian Aviation Safety Alerts (CASA) – There are no new CASAs to present in this issue.

Airworthiness Directives (AD)

  • AD CF-2025-08 was published and applies to ATA 72 – Engine – High-Pressure Turbine (HPT) Disk – Improper Rework to Pratt & Whitney Canada Corp. (P&WC) Models PW545A, PW545B and PW545C engines effective 24 February 2025. Compliance is required, as described in AD.

Exemptions

  • Two new exemptions were issued to enable telemedicine as an option for aviation medical certificate renewals. More specifically, subject to the conditions set out in each exemption, they enable the renewal of medical certificates by telemedicine consultation to holders of medical certificates Category 1, 2, 3, or 4 with a validity period ending on or after March 17, 2020. They both came into force on 3 March 2025.
    • CAME-001-2025 is an exemption from Paragraphs 404.17(a) and 404.18(a) of the CARs. It extends, for five (5) additional years, the regulatory relief previously granted under exemption NCR-061-2020, CAME-001-2021, CAME-001-2022, and CAME-001-2023 issued on May 21, 2020, February 25, 2021, March 2, 2022, for twelve (12) months, and March 1, 2023, for twenty-four (24) months, respectively.
    • CAME-002-2025 is an exemption from Paragraphs 404.03(2)(a), 404.03(2)(b), and 404.04(1)(b) of the CARs. It extends, for five (5) additional years, the regulatory relief previously granted under exemption NCR-062-2020, CAME-002-2021, CAME-002-2022 and CAME-002-2023 issued on June 3, 2020, March 2, 2021, and March 3, 2022, for twelve (12) months, and on March 1, 2023, for twenty-four (24) months, respectively.
  • Global Exemption: NCR-003-2025 and Authorization: NCR-002-2025 - The purpose of NCR-003-2025 is to authorize Canadian air operators to operate Bombardier BDâ700â1A10, BDâ700â1A11, or BDâ700â2A12 aeroplanes while carrying passengers in an on-demand charter operation. The purpose of NCR-002-2025 is to allow these aircraft to operate under subpart 704 despite exceeding the weight limit.
  • Global Exemption: NCR-004-2025 - The purpose of this exemption is to authorize Canadian air operators to operate CL-600-2B19 (Special Edition (SE) or Challenger 800/850) aeroplanes while carrying passengers in an on-demand charter operation.
  • Global Exemption: NCR-005-2025 - The purpose of this exemption is to authorize Canadian air operators to operate Mystère Falcon 900, Falcon 900EX, Falcon 6X, or Falcon 7X aeroplanes while carrying passengers in an on-demand charter operation.
  • Global Exemption: NCR-007-2025 and Authorization: NCR-006-2025 - The purpose of NCR-007-2025 is to authorize Canadian air operators to operate modified Douglas DC3C (DC3âTP67 or DC3TP) aeroplanes while carrying passengers in an on-demand charter operation. The purpose of NCR-006-2025 is to allow these aircraft to operate under subpart 704 despite exceeding the weight limit.
  • Global Exemption: NCR-009-2025 and Authorization: NCR-008-2025 - The purpose of NCR-009-2025 is to authorize Canadian air operators to operate Gulfstream GV, GV-SP or GVI aeroplanes while carrying passengers in an on-demand charter operation. The purpose of NCR-008-2025 is to allow these aircraft to operate under subpart 704 despite exceeding the weight limit.

  • CBAA’s RIPS Exemption Petition for Specified FAR 23 Type Certified Aeroplanes Denied - Following the issuance of the Transport Canada Regulations on Recorder Independent Power Supply (RIPS), the Association was approached by concerned members who own and operate single pilot certified aircraft but had opted for operational and safety reasons to operate dual pilot. In so doing, they became captured by the regulation’s scope and would be required to have a CVR RIPS installed. While returning to single pilot operations would have removed the need for a RIPS, the benefits of choosing dual pilot operations would have been lost, which was an important factor to consider from the Association's perspective.

The Association, therefore, petitioned Transport Canada to issue an exemption to cover this small aircraft population. The request explained that the safety benefit of dual pilot operations versus single pilot operations was greater than Transport Canada’s stated regulatory benefit statement of a CVR RIPS and in consideration of the significant cost of modifying an aircraft. Notwithstanding the Association’s advocacy, Transport Canada has denied the petition. In their concluding message, they noted:

  • Cockpit Voice Recorders (CVRs) are essential for accident investigations, accountability, pilot training, and alignment with international safety standards. While compliance may pose challenges for some operators, the requirement ensures industry-wide consistency and enhances aviation safety.
  • Private operators voluntarily adopting two-pilot operations demonstrate a strong safety commitment. While retrofitting costs may impact small operators, the limited number affected does not justify overriding the broader public interest.

 

Master Minimum Equipment Lists (MMEL) & TC Supplements (TCS)

  • Embraer EMB 545/550 - MMEL Revision 7, dated 8 November 2024, and a TC Supplement Revision 5, dated 13 February 2025.
  • Dassault Falcon 2000 - MMEL Revision 12, dated 11 July 2024, and a TC Supplement Revision 2, dated 6 February 2025.
  • Dassault Falcon 2000EX - MMEL Revision 14, dated 11 July 2024, and a TC Supplement Revision 7, dated 31 January 2025.
  •  Textron Model 525C (Citation Jet) - MMEL Revision 2 dated 23 July 2021 and a TC Supplement Revision 1 dated 21 February 2025.
  • Pilatus PC-24 - MMEL Revision 5, dated 12 February 2024, and a TC Supplement Revision 2, dated 7 March 2025.
  • Lear 60 (LR60) - MMEL Revision 6, dated 21 January 2022, and a TC Supplement Revision 4, dated 10 March 2025.
  • Bombardier Global Express (BD-700-2A12) - MMEL Revision 6, dated 14 March 2025.

To download MMELs, visit Transport Canada’s Website at TCCA MMEL-TCS.

ICYMI

  • 2025 Hazards & Trends Report - To assist members in the maintenance of their SMS, the Association creates a Hazards & Trends Report annually. Specifically, the Report contains information that operator members can refer to as they maintain their training programs, risk profile and safety plan in compliance with SMS regulations. The 2025 Report format has been expanded to add 2019 as a reference year (pre-pandemic) and to cover all AOR categories. Please note the trends as you review and assess against your own risk profiles and safety plan updates. If you are a user of the CBAA Risk Management System (RMS at https://nad.obds.com), it is available under the Documents and the Link tabs. Members who use other risk management tools and wish to obtain a copy of the Report may do so by contacting rsincennes@cbaa.ca or membersupport@cbaa.ca.
  • Unplanned RMS outage - Early on 13 February 2025, the RMS experienced an unplanned outage following an unauthorized access request by unknown actors. As a programmed security response, the RMS automatically locked itself down, preventing administrative functions from being accessed. Our RMS supplier, On-Board Data System (OBDS), took immediate action to upgrade the system based on guidance from the Canadian Centre for Cyber Security. The system became live again later in the day. ODBS has confirmed that the database was not compromised in any way, and user data remained protected. Over the next few weeks, ODBS will integrate further security updates to further protect the RMS. Should you encounter error messages, any or all of the following should be followed to fix it:
    • Clear all cookies from your Cache
    • Do an F5 refresh
    • If RMS is accessed using a preset bookmark, open it to edit the bookmark and resave it as https://nad.obds.com
    • Alternatively, run NAD in Chrome or Apple Incognito mode, which starts fresh with every session.

Please do not hesitate to contact rsincennes@cbaa.ca if problems persist.

  • TC Launches New Digital Initiatives - On 4 March 2025, TC launched several new digital initiatives, reflecting progress in modernizing services to Canadians.⯠See the full TC notification here. Of particular interest to members:

TC has launched the TC AIR, its first mobile app, designed to simplify and modernize the application process for Aviation Document Booklets (ADBs).  With TC AIR, student pilots, pilots, flight engineers, and air traffic controllers can now apply for a new (initial) ADB or renew an existing one in just minutes—all from their mobile device, anytime, anywhere, and free of charge.  This eliminates the need for passport-style photos, verifiers (for renewals), and mailing costs, making the process faster, easier, and more convenient.â¯â¯

Through this new TC digital form, registering an aircraft, reserving a mark or renewing a reservation, or submitting a notification of change of ownership should now be easier. The new digital forms simplify the application process with built-in validations to ensure all required information is captured accurately. Plus, integrated fee payment allows for a seamless, all-in-one experience.⯠To further support users, TC has updated its website with more comprehensive guidance and clearer service expectations. These enhancements are designed to ensure applicants have all the necessary details upfront, reducing uncertainty and making the process even more efficient. For more information and to access the new digital forms, visit TC’s Registering and leasing aircraft webpage.⯠

Nav Canada Information to Stakeholders

 

  • NAV CANADA Strategic and National Updates - On 13 February 2025, The Association participated in NAV CANADA’s Collaboration (AOCM) webinar, sharing Strategic and National updates of their programs and initiatives.  The following presentations were shared: ATS Learning Update, Network Management, Digital Aerodrome Air Traffic Services (DAATS), Level of Service Updates, NOTAM, AIP SUP & AIRAC, and Trajectory-Based Operations (TBO).
  • AIC 1/25 - 14-Day Trigger NOTAM - Last year, NAV CANADA announced an upcoming move towards implementing 14-Day Trigger NOTAMs. These NOTAMS would align with ICAO standards and NAVCANADA’s ongoing shift towards providing key information through AIP SUPs. NAV CANADA states that this will eventually reduce reliance on NOTAMs for conveying critical information that has a long duration. NAV CANADA announced that this change would be implemented as of February 20, 2025. See AIC here. Further information is available at NAV CANADA AIP Canada
  • NAV CANADA CNS-ATM Operations Plan - In late 2024, NAV CANADA shared the latest edition of the Plan, which was drafted in collaboration with customers and stakeholders, of which the CBAA is an active participant. This edition reflects NAV CANADA’s ongoing efforts to enhance the performance of Canada's air navigation system, integrating new CNS/ATM technologies and evolving best practices to meet the dynamic needs of the aviation industry. In this update, you will find goals, operational enhancements, and key initiatives designed to support the growing demands of air traffic and improve the overall flying experience.
  • Review of the Time in Position Fatigue Limit on Aerodrome Advisory Service Aeronautical Study - On 20 January 2025, we advised that NAV CANADA had initiated an Aeronautical Study to assess the potential impact of service interruptions resulting from the Time in Position Fatigue Limit, specifically the required Time in Position breaks and mitigations associated with these breaks, at FSS during the overnight shift on users and stakeholders. The Terms of Reference document, representing the official Notice of Consultation and detailing the scope and services under review, is available here. On 4 February 2025, NAV CANADA confirmed to stakeholders to ensure clarity that the outcome of the Study was not to affect or change underlying services but to ensure clear documented processes are published.

International Operations

  • Amendment to the TA-M between the United Kingdom Civil Aviation Authority and TCCA - The latest revision of this Technical Agreement (TA-M) was announced on 12 March 2025 and is available here.

Ongoing Regulatory Activities & CBAA Monitoring – On an annual basis, Transport Canada publishes a Regulatory Plan. The latest plan (Regulatory Initiatives 2024-2026) was reviewed, and a CBAA Summary & Initial Assessment was developed for member awareness. The CBAA assessment document, linked above, also includes other regulatory documents being considered, such as Standards and Advisory Circulars.

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




February 2025 Issue

Welcome to the February 2025 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 January 2025.

Government Legislative & Regulatory Initiatives

  • On 20 January 2025, we shared Transport Canada’s update to the proposed requirements regarding Assistance to Aircraft Victims & Families. This proposal was first shared with members in September 2024 as part of Transport Canada’s discussion paper and questionnaire in which they sought feedback on the Department’s proposed approach for air carriers and airports in planning to assist aircraft accident victims and their families. 

Transport Canada received 16 responses to the online questionnaire including comments from the CBAA. The consultation report is available in the What We Heard report. Transport Canada has now advised that the comments will contribute towards informing the work aiming to meet the needs of victims and their families and consult again when they publish a Notice of Proposed Amendment. The Association will advise members when published and will provide feedback as required. 

  • On 8 January we shared the Canadian Transportation Agency’s update for the designation of large and small airlines for 2025. Although the APPR do not apply to members unless they were involved in the public sale of airline seats, the following is shared with members for information. Read the full article here.

 

Regulatory Planning & Initiatives – The following is an update of current regulatory initiatives being considered by Transport Canada.

  • In the January 2025 issue of the Update, we shared Transport Canada’s Preliminary Issue & Consultation Assessment (PICA-2024-002) titled Aircraft Rescue and Firefighting (ARFF) Amendments for Alignment with the ICAO. The PICA was drafted following a recommendation by a Private Member’s Motion (M-96) to enhance the alignment of the Canadian Aviation Regulations (CARs) with the International Civil Aviation Organisation’s (ICAO) Standards and Recommended Practices (SARPs) on aircraft rescue and firefighting (ARFF) at designated Canadian airports and participating airports or aerodromes by adding “rescue” to aircraft firefighters’ mandate and reducing the ARFF response time on airport runways.

Although M-96 will have died as part of the recent Prorogation of Parliament, Transport Canada is expected to pursue the matter given the reference to ICAO alignment. As such, the Association has completed its review and is sharing it with members here for information and to provide you with an opportunity to share any additional information that may be relevant to our advocacy with Transport Canada.

Canadian Aviation Regulations (CARs) Standards – There are no new Standards to present in this issue.

Transport Canada Advisory Circulars (AC) – There are no new ACs to present in this issue.

Canadian Aviation Safety Alerts (CASA) – There are no new CASAs to present in this issue.

Airworthiness Directives (AD) – The following ADs were issued in January 2025.

  • CF-2025-01 – Maintenance – Transport Canada has issued Airworthiness Directive CF-2025-01 on ATA 05 – Flight Controls – Uncommanded and Unarrested Flap Movement ATA 05 – Time Limits/Maintenance Checks (TLMC) – Mid-Life - Airworthiness Limitations (AWL) to Bombardier Inc. (BA) model BD-700-1A10 and BD-700-1A11 aeroplanes effective 15 February 2025. Compliance is required as described in AD.
  • CF-2025-05 – Landing Gear – Transport Canada has issued Airworthiness Directive CF-2025-05 on ATA 32 – Landing Gear – Uncommanded Steering to Bombardier Inc. model CL-600-1A11, CL-600-2A12 and CL-600-2B16 aeroplanes effective 31 January 2025. Compliance is required as described in AD.
  • CF-2025-06 – AUXILIARY POWER UNIT (APU) – Transport Canada has issued Airworthiness Directive CF-2025-06 on ATA 49 – Auxiliary Power Unit (APU) – APU Muffler Drainage Blockage Causing Fuel Leakage Accumulation to Bombardier Inc. model CL-600-2A12 and CL-600-2B16 aeroplanes effective 3 February 2025. Compliance is required as described in AD.

Exemptions

  • Aviation Medical Certificate Exemption Set to Expire – Transport Canada has advised that Exemption CAME-002-2023, which allows eligible Aviation Medical Certificate holders to renew their Medical Certificate via telemedicine appointments, is set to expire on March 3, 2025. Transport Canada advises that if you have a telemedicine appointment scheduled for after this date, they recommend converting it to an in-person appointment to avoid any issues with your license renewal. Transport Canada is currently assessing whether this measure should be extended. We will advise you as Transport Canada updates stakeholders.

Approved Check Pilot (ACP) / Advanced Qualification Program (AQP) Evaluator Bulletin No. 02/24

  • Transport Canada has issued an update that alleviates its ACP/AQP policy on establishing candidate(s) eligibility regarding medical certificate requirements where a PPC, MV or LOE is delivered in a Flight Simulator Training Device (FSTD). The full bulletin is available here.

The Association has written to Transport Canada to seek clarification regarding the bulletin as it has omitted CAR 604. In short, the bulletin permits pilots flying under Part VII to do a PPC without current medical which would validate their CAR 604 PCC. However, pilots flying only under CAR604 regulations must hold valid medical to undergo the same PCC check. A response will be shared with members as soon as it is received.


Master Minimum Equipment Lists (MMEL) & TC Supplements (TCS)

  • MMEL – Bombardier BD-100-1A10 – Transport Canada has issued an MMEL, Revision 7 dated 16 January 2025 for the BD-100-1A10.
  • Cirrus Vision SF50 – Transport Canada has issued an MMEL, Revision 3 dated 15 September 2023 and a Supplement, Original dated 20 December 2024 for the Cirrus Vision SF50.

To download MMELs, visit Transport Canada’s Website at TCCA MMEL-TCS.

Aviation Safety Letter (ASL) ICYMI – Transport Canada has issued ASL 4/24.

CORSIA - Reminder & Guidance Information

  • CORSIA Reminder

The Transport Canada CORSIA team has submitted (see here) a reminder that the 2024 Verified Emissions Reports and Verification Reports for CORSIA are due to Transport Canada by April 30, 2025. The Verified Emissions Report and the Verification Report must be submitted both by the aeroplane operator and by the verification body. If your 2024 operations were below the CORSIA threshold and you have not already notified TC, please advise them that you will not be submitting a report.

  • Guidance Information

 Transport Canada has advised that regulations (see here) are currently in the process of being updated. Once they are updated, the expectation will be that a member(s) of the verification team conducts an on-site visit if the risk assessment and evidence-gathering plan require a site visit to reduce verification risk to an acceptable level, and at minimum every few years. The updated regulations may specify a minimum number of years. A waiver will not be granted next year (for the reporting year 2025) to any operator who has not yet had an onsite visit since joining CORSIA. If there are outstanding requests for remote visits for 2024, please have your verification body send them in for consideration. Please advise Transport Canada, as applicable, if your operations are below the CORSIA threshold.

Nav Canada Letter to Stakeholders

  • Review of the Time in Position Fatigue Limit on Aerodrome Advisory Service Aeronautical Study

NAV CANADA has initiated an Aeronautical Study to assess the potential impact of service interruptions resulting from the Time in Position Fatigue Limit, specifically the required Time in Position breaks and mitigations associated with these breaks, at FSS during the overnight shift on users and stakeholders. The Terms of Reference document, representing the official Notice of Consultation and detailing the scope and services under review, is available through the Aeronautical Study website.

The views of CBAA members and all stakeholders are central to this aeronautical study given its scope. Active participation will maximize a thorough assessment of service requirements by NAV CANADA and is crucial in shaping the final proposal.  You are encouraged to make representations on the service under review before March 24, 2025, to studies.etudes@navcanada.ca.


International Operations - There are no new International Operations updates to present in this issue.

Ongoing Regulatory Activities & CBAA Monitoring – On an annual basis, Transport Canada publishes a Regulatory Plan. The latest plan (Regulatory Initiatives 2024-2026) was reviewed, and a CBAA Summary & Initial Assessment was developed for member awareness. The CBAA assessment document, linked above, also includes other regulatory documents being considered such as Standards and Advisory Circulars.

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


January 2025 Issue

Welcome to the January 2025 issue of CBAA Government & Regulatory Affairs Update.

We would like to wish all members and readers a Happy and Safe New Year. As Anthony Norejko reflected in the 2024 Annual Report, we have worked to improve communications and information sharing through this monthly column, an effort that we will continue in 2025. Having said this, there is always room to improve. As such, please feel free to share any ideas at membersupport@cbaa.ca.

This issue includes various regulatory and operational updates as well as a summary of advocacy activities conducted in support of our membership in December 2024.

Government Legislative & Regulatory Update – In late December, the Government announced two Regulatory proposals to amend the Accessible Canada Regulations (ACRs) and Air Passenger Protection Regulations (APPRs).

  • The ACR would only apply to private sector organizations with more than 100 employees over the previous three calendar years, referred to as “small businesses” in the proposal as they would be exempted from the proposed requirements.
  • Given the Applicability section of these regulations has not changed, the AAPR would not apply to Association members who have CAR 703/704 certificates offering charters if they are not offered for resale to the public. It remains, however, important to stay vigilant, aware, and understand the proposal.

Please read the full article here if you are interested in knowing more about these two proposals or to provide comments.

Regulatory Planning & Initiatives – The following is an update on current regulatory initiatives being considered by Transport Canada.

  •  TP 308 / GPH 209 Criteria for the Development of Instrument Procedures - NPA 2024-013

Transport Canada has published proposed amendments NPA 2024-013 to TP 308 / GPH 209, Change 9.1 Criteria for the Development of Instrument Procedures. TP 308 / GPH 209 comprises the standards and criteria necessary for formulating, reviewing, approving, and publishing instrument procedures in Canada. The proposed amendments to TP 308 / GPH 209 described in this NPA are part of Transport Canada’s regular review of the manual to keep the standards and criteria aligned with those from the FAA’s TERPS. The NPA has been shared for member information and reference. Members wishing to make comments may do so in writing to TC.CARConsultations-RACConsultations.TC@tc.gc.ca no later than February 2nd, 2025.


  • Aircraft Rescue and Firefighting (ARFF) Amendments for Alignment with the ICAO - Preliminary Issue & Consultation Assessment (PICA) 2024-002

Transport Canada has published PICA-2024-002 titled Aircraft Rescue and Firefighting (ARFF) Amendments for Alignment with the International Civil Aviation Organization (ICAO) for consultation. The PICA is being shared with members as it is the result of a recommendation from a Private Member’s Motion (M-96) to enhance the alignment of the Canadian Aviation Regulations (CARs) with the International Civil Aviation Organisation’s (ICAO) Standards and Recommended Practices (SARPs) on aircraft rescue and firefighting (ARFF) at designated Canadian airports and participating airports or aerodromes by adding “rescue” to aircraft firefighters’ mandate and reducing the ARFF response time on airport runways. While the Association will review the PICA to assess any possible impacts to members, comments may be submitted directly to TC in writing to TC.CARConsultations-RACConsultations.TC@tc.gc.ca no later than 11 February 2025.

  • Night Vision Imaging Systems (NVIS) – Exemption Renewal

In late December 2024, Transport Canada issued five (5) new Global Exemptions on Night Vision Imaging Systems (NVIS) applicable to CAR 604 and to Subparts 2, 3, 4 and 5 of Part VII. These exemptions are a re-issuance NCR-008-2019, which expired November 30, 2024, and are provided below:

NCR-034-2024 (NVIS) – CAR 604

NCR-035-2024 (NVIS) – CAR 702

NCR-036-2024 (NVIS) – CAR 703

NCR-037-2024 (NVIS) – CAR 704

NCR-038-2024 (NVIS) – CAR 705

The purpose of these exemptions is to allow flight crew members conducting operations under private operators, as outlined in Subpart 4 of Part VI of the CARs, and flight crew members conducting operations under Canadian air operators, operating under Subparts 2, 3, 4 and 5 of Part VII of the CARs, to permit persons from entering or leaving an aircraft in flight and to conduct a landing or take-off at night while using Night Vision Imaging Systems (NVIS).


  • Enhanced Flight Vision System (EFVS) – Briefing to Industry

Transport Canada recently hosted Q&A sessions that were attended by the Association and a wide cross-section of industry leaders on Enhanced Flight Vision System (EFVS) operations and the associated proposed global exemption from subsection 602.128 (1), and paragraphs 602.128(2)(a) and (3)(a) of the Canadian Aviation Regulations. It should be clarified that this should not be confused with the Night Vision Imaging Systems (NVIS) noted above.

An Enhanced Flight Vision System (EFVS) uses a sensor, typically infrared, to capture an enhanced image of the external scene ahead of an aircraft, which is then displayed to the pilot via a head-up display or equivalent device. EFVS enhances the visual cues available during the visual segment of an instrument approach. The exemption would enable the use of EFVS in lieu of natural vision, to acquire the required visual references to descend below published DA/DH.

The Association will review the information provided and will continue to participate in consultations.  Members are invited to review the enclosures. Members may wish to familiarize themselves with this subject by referring to the full article here and provide any comments in writing to TC.CARConsultations-RACConsultations.TC@tc.gc.ca no later than January 31, 2025.

Canadian Aviation Regulations (CARs) Standards – In late December, we were advised of the publication amendments to various Civil Aviation Standards that will come into effect on January 31, 2025. Transport Canada has stated that the changes aim to clarify certain requirements, correct outdated references, and codify a few longstanding exemptions. Of note to members is the amendment/introduction of 624.56 - RVSM Eligibility requirements. Full information about the amended standards is available here.

Transport Canada Advisory Circulars (AC) – There are no new ACs to present in this issue.

Canadian Aviation Safety Alerts (CASA) – Transport Canada has issued CASA-2024-13 titled Maintaining Accessibility to Portable Oxygen Bottles to operators and maintainers of all transport category aeroplanes. The purpose of this Civil Aviation Safety Alert (CASA) is to raise awareness regarding the accessibility of portable oxygen bottles, particularly in transport category aeroplanes where Transport Canada (TC) has received multiple in-service reports of portable oxygen bottles not being immediately available to the cabin crew when needed.

Airworthiness Directives (AD)

  • CF-2024-39 Flight Controls – Transport Canada has issued Airworthiness Directive CF-2024-39 on ATA 27 – Flight Controls – Uncommanded and Unarrested Flap Movement to Bombardier Inc. model CL-600-1A11, CL-600-2A12 and CL-600-2B16 aeroplanes effective 13 December 2024. Compliance is required within 60 days from the effective date of this AD unless already accomplished.
  • CF-2024-41 Time Limits/Maintenance Checks – Transport Canada has issued Airworthiness Directive CF-2024-41 on ATA 05 – Time Limits/Maintenance Checks – Airworthiness Limitations (ALI) to MHI RJ Aviation ULC. (MHIRJ) (formerly Bombardier Inc.) model CL-600-2C10, CL-600-2C11, CL-600-2D15, CL-600-2D24, CL-600-2E25 aeroplanes effective 13 December 2024. Compliance time is as indicated in the AD unless already accomplished.

Exemptions – Refer to the text above for NVIS exemption renewal and the proposed EFVS exemption.

Master Minimum Equipment Lists (MMEL) & TC Supplements (TCS)

  • Dassault Falcon 6X - Transport Canada has issued a MMEL, Revision 1 dated 29 November 2023 and Transport Canada Supplement (TCS), Original dated 10 December 2024 for the Dassault Falcon DA-6X. To download MMELs, visit Transport Canada’s Website at TCCA MMEL-TCS.

Aviation Safety Letter (ASL) - Transport Canada has issued ASL 4/24.

Nav Canada Letter to Stakeholders – The following Aeronautical Study updates describing their completion and next steps were shared with stakeholders in December 2024:

International Operations

  • European Union (EU) Entry/Exit System Update – Implementation Update Further to our earlier update notifying that the EU’s ESS was being postponed given not all States are ready (full article here). The EU has now proposed a Progressive Start of Operation of the EES. A Q&A on the proposal is available on the European Commission website. While the CBAA continues to participate in these discussions along with other Canadian and international carriers, it is important for members or their agents who plan their European travel to review and provide any feedback to the Association on the potential impacts of the proposal on their operations.  Your feedback may be provided directly to rsincennes@cbaa.ca.

Ongoing Regulatory Activities & CBAA Monitoring

Transport Canada Regulatory Initiatives – On an annual basis, Transport Canada publishes a Regulatory Plan. The latest plan (Regulatory Initiatives 2024-2026) was reviewed, and a CBAA Summary & Initial Assessment was developed for member awareness. The CBAA assessment document, linked above, also includes other regulatory documents being considered such as Standards and Advisory Circulars.

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