We are the members of the Ontario Regional Employees Association (OREA). We are comprised of approximately 130 pilots that fly for Air Georgian. Air Georgian is “an integral part of Air Canada's North American market presence, we operate over 30,000 flights annually carrying more than 320,000 passengers to locations all across North America. We provide hub connections via Toronto, Montreal, Halifax and Calgary to Air Canada's and Star Alliance's global networks, while providing service to and from many smaller communities as a complement to Air Canada's schedule.” (http://www.airgeorgian.ca/)

Through conversation with industry colleagues OREA became aware of the CARAC Flight Crew Fatigue Management Working Group and were very pleased to read of the long overdo changes proposed in the Working Draft Report.  More recently, it has come to our attention that those representing 703 and 704 operators may attempt to have their segments of the industry omitted from any proposed changes.   This document serves as plea, to ask that you do not exclude any segment of our industry from the improvements to flight safety contained within the working draft report.

An Air Georgian pilot carries the same passengers that an Air Canada pilot does, in smaller and older equipment and with more frequent take offs and landings every day. At the very least an Air Georgian pilot and their passengers require the same level of safety with regards to flight crew fatigue limits as an Air Canada pilot and their passengers.

Currently there is a contract in place between OREA and Air Georgian that in many cases restricts the duty for flight crew to less than that in the Canadian Aviation Regulations. However, there are a few cases where an Air Georgian Pilot will find themselves working to CARs limits. The financial realities of today’s aviation industry have seen that crews are frequently working to absolute CARs limits.  Moreover, sophisticated computerized scheduling systems and concessionary negotiating environments will see pilots flying closer to the limits every day.   The 703/704 environment typically sees younger, less experienced pilots operating lesser-equipped aircraft in challenging conditions with little support, and usually without the protection of a union or an association.   The Canadian Aviation Regulations are the only protections these pilots, and their passenger have.

Please include 704/703 operations when making adjustments to flight crew fatigue management rules.