1 Canada FTDT (Gazette 1) Understanding Canada FTDT (Gazette 1) A Generic Interpretation Understanding Canada FTDT (Gazette 1) Flight and Duty Time Limitations and Rest Requirements. Version 1.0 Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

2 Disclaimer The documentation is provided “AS IS” and is solely intended to provide a general understanding of the author’s interpretation of the Proposed Canada FTDT as amended on 30-June-2017. The author makes no representations and disclaims any and all responsibility for the completeness or accuracy of the documentation. The author reserves the right, at his discretion, to change or modify the documentation as deemed appropriate. Copyright © 2017, Understanding Canada FTDT (Gazette 1) – A Generic Interpretation. All rights reserved. Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

3 Module 1: Overview of ChangesCopyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

4 Overview 1. Maximum flight timeFlight time means the time from the moment an aircraft first moves under its own power for the purpose of taking off until the moment it comes to rest at the end of a flight. The amendment proposes to reduce annual flight time limits (paragraph (1)(a) of the current CARs) from 1200 to 1000 hours in any consecutive 365 days. This provision uses flight time as a measure of workload that leads to fatigue. Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

5 Overview 2. Maximum flight duty periodFlight duty period (FDP) means the period of time that begins at the earliest of the following events and ends when the engines are off or the rotors are stopped at the end of a flight: the flight crew member carries out any duties assigned by the operator before reporting for a flight; the flight crew member reports for a flight or, if the flight duty period consists of more than one flight, reports for the first flight; the flight crew member reports for positioning; and he flight crew member reports as a flight crew member on standby. The flight duty time limit under subsection (1) of the current CARs is 14 consecutive hours in a 24-hour period. A workday of 14 consecutive hours is considered too long a duty period to maintain performance throughout. Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

6 Overview 2. Maximum flight duty periodThe proposed regulatory amendment would introduce a range of flight duty period from 9 to 13 hours as per the table below. Limits would be set per the start time of the flight duty (i.e. the time of day) and by the number of flights. Note: Day Visual Flight Rules (VFR) operation would use column 2 (not limited by the number of flights or average flight duration). This table presents the maximum Daily FDP. Table: Maximum Daily FDP Calculation Average Flight Time Column 2 Column 3 Column 4 Number of Flights 50 minutes or more 1–4 5–6 7+ 30 minutes or more but less than 50 minutes 1–7 8–11 12+ less than 30 minutes 1–11 12–17 18+ Item Start of FDP Maximum FDP (hours) 1 24:00-03:59 9.0 2 04:00-04:59 10.0 3 05:00-05:59 11.0 4 06:00-06:59 12.0 5 07:00-12:59 13.0 6 13:00-16:59 12.5 11.5 10.5 7 17:00-21:59 8 22:00-22:59 9 23:00-23:59 Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

7 Time Free From Duty (if Pilots Are Free From Duty)Overview 3. Maximum duty time In the proposal, the maximum duty time would relate to the time free from duty options. The following demonstrates the two aspects of the proposed provision. (a) Maximum duty time Proposed section would introduce a new concept of cumulative duty hour limits to address cumulative fatigue. There is currently no daily, weekly, monthly or annual duty time limit to avoid the cumulative impact of long working hours that induce fatigue. The yearly duty time limit was calculated based on the Canada Labour Code, which establishes a maximum of 2400 working hours in any 365 consecutive days. The weekly (seven days) limit (i.e. 60 or 70 hours) and monthly (or 28-day period) limit (192 or 210 hours) would be new requirements. The “monthly” and “weekly” limits would relate to time free from duty options as outlined below. This table presents the monthly and weekly limits that would relate to time free from duty options. Options Time Free From Duty (if Pilots Are Free From Duty) Maximum Duty Time Hours per 7 Days Hours per 28 Days Hours per 365 Days Option 1 33 consecutive hours with 2 local nights rest (Single day free of duty) in any 7 days and has 4 single days free in any 28 days 60 192 2400 Option 2 5 consecutive days off per 21 days 70 Option 3 5 consecutive days off in 28 days 210 Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

8 Overview 3. Maximum duty time (b) Time free from dutyCurrent regulations allow for at least 36 consecutive hours of time free from duty within each consecutive seven days (paragraph (1)(a) of the CARs). The proposed amendment changes the current requirements for time free from duty by introducing a period of time free from duty of 33 consecutive hours in seven days (i.e. 168 consecutive hours), in which the time free from duty would begin no later than 22:30 and end no earlier than 07:30 on the second subsequent morning. Although this reduces the total time free from duty by 3 hours, this amendment would require that time free from duty occur over the course of two nights (two quality sleep opportunities) and provide the flight crew with the opportunity for recovery from the effects of cumulative fatigue. In addition, there are time free from duty options for 21- and 28-day rotational operations. Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

9 Overview 4. Rest period Science shows that people need a regular rest period to avoid acute fatigue. Currently, after completing a flight duty period, the pilot will receive a rest period of eight hours plus time for travel, meals, and personal hygiene. Proposed section would require flight crew members to be provided sufficient rest time as follows: When they are at home base a period of 12 consecutive hours or 11 consecutive hours plus travel time, or if the air operator provides a suitable accommodation, a period of 10 hours in that suitable accommodation; and When they are away from home base, a period of 10 consecutive hours in a suitable accommodation would be required. Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

10 Overview 5. Rest period: Disruptive schedules, consecutive night duty periods, time zone differences, positioning The proposed amendment would provide additional rest opportunities for flight crew members when transitioning from FDP start times that are very fatiguing due to the shift in start times. It includes scenarios such as disruptive schedules, time zone differences, night duties and positioning. (a) Disruptive schedules This new concept introduced in section aims to address the shift of start duty time. It refers to changing from a late night duty to early duty or vice versa. Dramatic shifts of the start duty time will disrupt a flight crew member’s circadian cycle (i.e. disrupt sleep patterns, which results in fatigue). A local night’s rest is required to prevent or reduce fatigue associated with the circadian cycle disruption. In other words, an air operator would have to provide a flight crew member a local night’s rest between a late duty (i.e. hours of work that end between 00:00 and 01:59) or night duty (i.e hours of work that begin between 13:00 and 01:59 and that end after 01:59), and an early duty (i.e. hours of work that begin between 02:00 and 06:59); or between an early duty, and a late duty or night duty. (b) Consecutive night duty periods Proposed section addresses the additional rest and methods of counteracting fatigue resulting from multiple consecutive night duty periods. The intent is to capture any duty that is combined with a subsequent night flight duty period. It would allow three consecutive night duty periods followed by a local night’s rest; or five consecutive nights with a rest period of at least three hours in a suitable accommodation during each night duty period (split flight duty). Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

11 Overview 5. Rest period: Disruptive schedules, consecutive night duty periods, time zone differences, positioning (c) Time zone differences Crossing multiple time zones induces fatigue because the person is out of sync with local time. Therefore, the further away (time zones) a flight crew member moves from his or her acclimatized time, and the longer time he or she spends away from that acclimatized time, the more fatiguing it is in the return to the starting point. To compensate for this, proposed section imposes one, two or three additional local nights’ rest to recover, depending on the time zone differences and total time the flight crew member spends away from home base. d) Positioning Positioning occurs when a flight crew member must travel at the request of the air operator from one point to another before or after a flight. Proposed section sets out the conditions under which an air operator may require the positioning of a flight crew member and how to address the fatigue resulting from the positioning flight. Where positioning follows an FDP and the duration of the duty period exceeds the permitted maximum flight duty period by Three hours or less — the air operator must provide a rest period that is equal to the duration of the duty time; and Three hours or more — the air operator must provide a rest period that is equal to the duration of the duty time plus the time spent positioning in excess of the FDP. Examples: FDP = 13 hours + 3 hours positioning = 16 hours of rest FDP = 13 hours + 4 hours positioning = = 21 hours of rest Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

12 Overview 6. FDP due to in-flight rest and augmented flight crewProposed section would modify the current regulations to reflect the fatigue science and provide detailed criteria for permitting extensions to flight duty periods as a result of in-flight rest. This section would provide extensions to the FDP based on the quality of the rest facility and whether there is one or two additional flight crew members available to provide augmentations to the pilots flying. The maximum flight duty periods assigned by the air operator are to be as follows: With one additional flight crew member and a Class 3 rest facility: a maximum FDP of 14 hours; or Class 1 or 2 rest facility: a maximum FDP of 15 hours; or With two additional flight crew members and a Class 3 rest facility: a maximum FDP of hours; Class 2 rest facility: a maximum FDP of 16.5 hours; or Class 1 rest facility: a maximum FDP of 18 hours. 7. Long range flight As a result of proposed section , no pilot shall operate an additional flight following a planned flight greater than seven hours long if it occurs within the flight crew member’s window of circadian low (WOCL). Where there is an operational necessity to fly a continuing flight, and it infringes on the flight crew member’s WOCL, the air operator would have to submit a proposal that outlines mitigation supported by a safety case (FRMS). Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

13 Overview 8. Ultra long-range flightBased on international practices, flights with an FDP of over 18 hours or a flight time of over 16 hours would have to operate under an exemption from the prescriptive requirements (FRMS). 9. Unforeseen operational circumstances The requirements respecting unforeseen operational circumstances are set out in section of the CARs. This section permits overly long flight duty time (periods) that causes acute fatigue. Proposed section reflects modern fatigue science. It emphasizes the authority of the pilot-in-command to reduce or extend the flight crew member’s flight duty period and requires consultation with all flight crew members. The pilot-in-command may increase the flight duty period by one hour for single-pilot operation; two hours for not augmented flight (two-pilot operation); three hours for augmented flight crew if operating a single flight; and two hours for augmented flight crew if operating two or three flights. 10. Fitness for duty Several factors may affect fitness for duty. They include consumption of alcohol or drugs, mental and physical conditions, and fatigue. Proposed amendments to section of the CARs would prohibit an operator of an aircraft to require any person to act as a flight crew member or to carry out any pre-flight duties, or a person to act as a flight crew member or carry out such a duty, if the operator or the person is not, or is not likely to be, fit for duty. The proposed amendments to paragraph (a) of the CARs would prohibit a crew member from working within 12 hours after consuming an alcoholic beverage (an increase from the current limit of 8 hours). Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

14 Overview 11. Fatigue Risk Management SystemThe proposed Regulations would provide to Subparts 702, 703, 704 and 705 air operators the option to deviate from the prescriptive requirements (except for maximum annual flight time and maximum annual duty time) provided they can demonstrate, by way of a safety case, that they can provide at least the same level of safety as the prescriptive requirements introduced as part of this proposal. An FRMS is a management system air operators use to identify and minimize the acute and chronic sources of fatigue and manage the potential risks associated with fatigue. An FRMS is a holistic risk management approach, in which air operators identify hazards; assess risk; develop mitigation strategies; offer training and education programs; introduce fatigue monitoring systems; and adopt continual improvement processes to reflect changing circumstances; and feedback. From an operational perspective, an FRMS serves as a prevention, prediction, detection, and intervention regime. An FRMS allows an air operator to tailor its fatigue management policies, procedures, and practices to its specific conditions and unique operational demands that induce fatigue. In general terms, an FRMS allows the air operators to base their operations on scientific fatigue knowledge; test its effectiveness through bio-mathematical software, pilot surveys, monitoring and other alertness testing; and demonstrate if pilot fatigue is increased and alertness levels are maintained. Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

15 Overview 12. Summation of differences Areas for AdjustmentCurrent Limits Proposed Limits 1. Maximum flight time — 40–60 hours / 7 days — 120 hours / 30 days — 300 hours / 90 days — 1200 hours / 365 days — 112 hours / 28 days — 1000 hours / 365 days 2. Maximum flight duty period 13 hours 45 minutes or 14 hours Maximum 9–13 hours — based on start time of day and sectors flown 3. Maximum duty time 3(a) Maximum duty time Nil Hours Per 7 Days 28 Days 365 Days Option 1 60 192 2400 Option 2 70 Option 3 210 3(b) Time free from duty — 36 hours / 7 days — 3 days / 17 days — 3 periods x 24 hours / 30 days — 13 x 24 hours / 90 days 33 hours with 2 LNR in any 168:00 (7 days) and 4 single days off in any 672 hours (28 days) 5 days off in any 504:00 (21 days) Option 3  5 days off in any 672:00 (28 days)  4. Rest periods 8 hours, plus time for travel, meals and hygiene At home — 12 hours or 11 hours plus travel time, or 10 hours in a suitable accommodation provided by the air operator Away from home — 10 hours in a suitable accommodations 5. Rest periods Additional Rest Period Due to Local Nights Rest Required 5(a) Disruptive schedules Disruptive schedules 1 5(b) Time zone differences Time zone difference 1, 2 or 3 5(c) Consecutive night duties 3 consecutive night duty periods Allow 5 consecutive nights with a duty break >= 3 hours 5(d) Positioning Half the time in excess of maximum flight duty time is calculated into the following rest period If positioning 3 hours or less in excess of max flight duty period, the rest period must equal the duty period; More than 7 hours of positioning — FRMS required. Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

16 Overview 12. Summation of differences Areas for AdjustmentCurrent Limits Proposed Limits 6. FDP due to in-flight rest and augmented flight crew Pilots Seat Bunk 1 more 2 more 17 hours 20 hours Class 3 rest facility 14 hours 15.25 hours Class 2 rest facility 15 hours 16.5 hours Class 1 rest facility 18 hours >18 hours extension requires an FRMS. 7. Long range flights Nil No additional FDP following a greater than 7-hour flight if it occurs within the WOCL. 8. Ultra long-range flight Permitted (standard 720.16(3)) Permitted only under an FRMS. 9. Unforeseen operational circumstances Add 3 hours to flight duty period Number of flight crew members Permitted additional flight duty period One pilot One additional hour Not augmented (two pilots) Two additional hours Augmented If one flight, three additional hours If two or three flights, two additional hours Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

17 Definitions: CAR 101.01 Term Definition fit for dutyin respect of a person, means that their ability to act as a flight crew member of an aircraft is not impaired by fatigue, the consumption of alcohol or drugs or any mental or physical condition; (apte au travail) flight duty period means the period that begins at the earliest of the following events and ends at engines off or rotors stopped at the end of a flight: the flight crew member carries out any duties assigned by the private operator or the air operator or delegated by the Minister before reporting for a flight, the member reports for a flight or, if the flight duty period consists of more than one flight, reports for the first flight, the member reports for positioning, and the member reports as a flight crew member on standby; (période de service de vol) home base means the location where a flight crew member normally begins and ends a flight duty period; (base d’affectation) positioning means the transfer of a flight crew member from one location to another, at the request of the air operator, but does not include travel to or from suitable accommodation or the member’s lodging; (mise en place) rest period means the continuous period during which a flight crew member is off duty, excluding the travel time to or from suitable accommodation provided by a private operator or an air operator; (période de repos) Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

18 employed on a full-time basis flight crew member on deployed standbyDefinitions: CAR Term Definition acclimatized in respect of a flight crew member, means a person whose biorhythm is considered aligned with local time; (acclimaté) all-cargo aeroplane means an aeroplane that is equipped and used mainly for the carriage of goods; areas of operation means areas in which operations are conducted between points in Canada, between points in Canada and points abroad, and between points abroad; class 1 rest facility means a bunk or other horizontal surface located in an area that (a) is separated from the flight deck and passenger cabin; (b) has facilities to control the temperature and light; and (c) is subject to a minimal level of noise and other disturbances; (poste de repos de classe 1) class 2 rest facility means a seat that allows for a horizontal sleeping position in an area that (a) is separated from passengers by a curtain or other means of separation that reduces light and sound; (b) is equipped with portable oxygen equipment; and (c) minimizes disturbances by passengers and crew members; (poste de repos de classe 2) class 3 rest facility means a seat that reclines at least 40 degrees from vertical and that has leg and foot support; (poste de repos de classe 3) early duty means hours of work that begin between 02:00 and 06:59 at the location where a flight crew member is acclimatized; (service de début de journée) employed on a full-time basis means working for an air operator on a continuous basis for at least the number of hours required to carry out the duties of the position for the safe operation of the commercial air service; extended charter means the charter of a Canadian commercial aircraft to a Canadian or foreign air operator for a period of 21 days or more in order to supplement the fleet of the charterer; farmer means a person whose primary source of income is derived from the tillage of the soil, the raising of livestock or poultry, dairy farming, the growing of grain, fruit, vegetables or tobacco, or any other operation of a similar nature flight crew member on deployed standby means a flight crew member on standby who is located at or near an aerodrome and who has been provided with suitable accommodation by an air operator for the period during which they are available to report for flight duty; (membre d’équipage de conduite en attente de déploiement) Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

19 Definitions: CAR 700.01 Term Definition flight crew member on reservemeans a flight crew member who has been designated by an air operator to be available to report for flight duty on notice of more than 1:00 late duty means hours of work that end between midnight and 01:59 at the location where a flight crew member is acclimatized; (service de fin de journée) local night’s rest means a rest period that begins at 22:30 and ends at 07:30 at the location where a flight crew member is acclimatized; (nuit de repos locale) net take-off flight path means the one-engine-inoperative flight path that starts at a height of 35 feet at the end of the take-off distance required and extends to a height of at least 1,500 feet AGL, reduced at each point by a gradient of climb equal to 0.8 per cent for two-engined aeroplanes, 0.9 per cent for three-engined aeroplanes and 1.0 per cent for four-engined aeroplanes night duty means hours of work that begin between 13:00 and at 01:59 and that end after 01:59 at a location where a flight crew member is acclimatized; (service de nuit) operations between points abroad means air service operations that are conducted wholly outside Canada for any length of time reserve availability period means the period in any period of 24 consecutive hours during which a flight crew member on reserve is available to report for flight duty; (période de disponibilité en réserve) reserve duty period means the period that begins at the time that a flight crew member on reserve is available to report for flight duty and ends at the time that the flight duty period ends; (période de service en réserve) single day free from duty means a period free from duty that begins at the end of the first local night’s rest and ends at the beginning of the following local night’s rest; (journée isolée sans service) sub-base means a location at which an air operator positions aircraft and personnel and from which operational control is exercised in accordance with the air operator’s operational control system types of operation means VFR, VFR at night and IFR operations Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

20 window of circadian low (daylight saving time)Definitions: CAR Term Definition types of service means a domestic service, a scheduled international service, a non-scheduled international service and a sightseeing operation window of circadian low means the period that begins at 02:00 and ends at 05:59 at the location where a flight crew member is acclimatized; (phase de dépression circadienne) Additional Definitions: The above additional terms and definitions are used to aid in clarification and understanding of the regulations. Authors note: Airlines should be aware when CM’s will be impacted by a transition between STD and DST. The impact is that the WOCL will not be in synch with definitions of WOCL. The STD/DST transition reduces the window for a LNR, while a DST/STD transition will increase the window for a LNR. Term Definition calendar day means a 24-hour period from 0000 through 2359 using base time flightcrew member (FCM) means a crew member assigned to a Standby, Reserve or FDP for duties on the Flight Deck., as a Captain, First Officer, Relief Pilot, Flight Engineer, or Flight Navigator. standard time (STD) the official local time of a region or country determined by the distance from Greenwich of a line of longitude passing through the area daylight time (daylight saving time) (Summer Time) (DST) Daylight saving time (DST) or summer time is the practice of advancing clocks during the lighter months so that evenings have more apparent daylight and mornings have less. Typically clocks are adjusted forward one hour near the start of spring and are adjusted backward in the autumn. Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

21 Intent of this presentationTo summarize the following sections of CAR (Gazette 1). Flight Duty Period (FDP). Extension of FDP by Split Duty Consecutive Duties Infringing on the WOCL Un-Augmented Long Range Flight Extension of FDP by in-Flight Rest Ultra Long Range Flight Rest Periods Additional Rest Due to Disruptive Schedules Rest Periods – Time Tone Differences Rest afteran Augmented FDP Rest Period – Positioning Cumulative Flight Time Limitations Cumulative Duty Time Limitations / Time Free of Duty Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

22 Intent of this presentationTo summarize the following sections of CAR (Gazette 1). Unforeseen Operational Circumstances — PIC’s Discretion Unforeseen Operational Circumstances — Split Duty Delayed Reporting Time Deployed Standby (DSB) Standby (SBY) Reserve (RAP) Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

23 Not included in this presentationThe following sections of CAR (Gazette 1). Non-application and Interpretation Monitoring System and Records Air Operator Obligations — Scheduling Fitness for Duty Home Base Nutrition Break Division IV - Fatigue Risk Management System through Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.

24 Canada FTDT (Gazette 1) Understanding Canada FTDT (Gazette 1) A Generic Interpretation Understanding Canada FTDT (Gazette 1) Flight and Duty Time Limitations and Rest Requirements. Version 1.0 Copyright © 2017 Understanding Canada FTDT (Gazette 1) – A Generic Interpretation All rights reserved.