Transport Canada Responds to Feedback on Proposed Flight and Duty Time Regulations for Subparts 703 & 704 Transport Canada is actively addressing feedback from Subpart 703 (air taxi) and Subpart 704 (commuter) operators regarding proposed Flight and Duty Time Regulations and Fatigue Risk Management Systems (FRMS). Here's what we know from the recently released Preliminary Issue and Consultation Assessment (PICA) report: Feedback Highlights: • High implementation costs (over $40,000) are a significant barrier for operators. • Concerns about the complexity and compatibility of FRMS with unscheduled operations. • Requests for simpler, more practical regulations that align with ICAO standards. Key Issues Identified: • Inconsistencies in definitions (e.g., local night’s rest, home base, duty time). • Inefficiencies in the approval process and concerns about safety data validation. • Limited flexibility in emergency operation definitions, creating operational and financial challenges. Transport Canada’s Response: • Acknowledges that current FRMS proposals may not fit the realities of unscheduled operations. • Plans to refine prescriptive regulations and streamline the FRMS framework to better align with ICAO standards. • Focus groups, consultations, and pilot projects will take place through winter 2025 to address industry concerns. • Improvements to regulatory definitions, statistical methods for fatigue data, and administrative processes are on the table. This is a promising step forward in creating regulations that are both effective and practical for operators. For updates, stay tuned to the Canadian Aviation Regulation Advisory Council (CARAC). What do you think about these developments?