:
Actually, last week I offered to give you a technical briefing, so with your agreement, I will proceed with the deck. You have in front of you a deck in both French and English, so I'll walk you through it.
I welcome the opportunity to provide you with the facts concerning the development of the regulatory proposal on flight attendant ratios.
I have with me today Mrs. Susan Greene, Transport Canada's leading safety expert on this issue. Mrs. Greene flew as a flight attendant for eight and a half years, during which time she also supervised and trained flight attendants. Mrs. Greene currently holds the position of chief, cabin safety standards; however, she also gained security experience following the events of September 11, 2001, when she was responsible for developing the revised security training requirements for crew members and guidance materials for passenger agents working at check-ins.
I don't think you need an introduction from me, since I was here on Thursday.
[Translation]
On page 2, you will find a summary of the current flight attendant requirements. Canadian Aviation Regulations require that there be one flight attendant for every 40 passengers. Regulations also include a provision under which certain eligible aircraft configured with only 50 passenger seats can operate with a limited number of flight attendants, namely on regional aircraft such as the ATR42 -300, the Dash 8-300 and the Canadair Regional Jet.
The International Civil Aviation Organization requires that all countries adopt regulations based on the number of passengers or the number of seats. ICAO does not recommend the ratio, as such, and allows member countries to make the appropriate determination. The one flight attendant for every 50 passenger seats ratio is currently used almost everywhere in the world.
[English]
As an example, you have on the slide some countries that use the one-to-fifty regime today, but just glancing at the regulations in other countries, one sees that Austria, Bermuda, Brazil, China, Chile, Estonia, Finland, France, Germany, Iceland, Jamaica, New Zealand, Norway, Poland, Singapore, Slovak Republic, South Africa, Sri Lanka, Sweden, Switzerland, United States, United Kingdom, etc., are some of the countries using the one-to-fifty regime today.
On slide 4, when an aircraft is originally designed, built, and certified to carry passengers, a maximum permissible number of seats is established for the aircraft, based on numerous safety-related criteria, among which are the number and size of exits from the aircraft, the distance between the exits, and the aisle widths. Each crew and passenger must have emergency means to allow rapid evacuation in crash landings. The manufacturer of the aircraft must prove through actual demonstrations that a full aircraft can be successfully evacuated within 90 seconds in darkened conditions with 50% of the emergency exits blocked.
The common standard used worldwide for this certification requirement is primarily based on one flight attendant for every 50 passenger seats. So even in Canada, for the aircraft that we certify, we use the one-in-fifty rule. So do the United States, France, and Brazil, countries in which a lot of aircraft are manufactured. Slide 5 is about the risk assessment. As I mentioned last week, the first industry proposal was rejected in March 2001, as the information provided failed to demonstrate a level of safety in keeping with the existing rule. As there were, and still remain, polarized views on this issue, and with the broader scope the second proposal provided, Transport Canada decided that a formal risk assessment should be conducted. Stakeholders from industry, unions, and passenger safety and consumer groups participated in the risk assessment, and in September 2003 they were provided with the risk assessment report. The ability to manage risk in a consistent and effective manner is essential to making prudent safety-related decisions. Therefore, a strong risk management process is an important part of the department's effective service delivery in safety monitoring. While we cannot remove the risk completely, we can use proven techniques to ensure that all aspects of the risk are identified and considered when making decisions.
The Canadian Standards Association's Q850 process is the basis for Transport Canada's approach. This proven process provides a guideline that assists decision-makers in identifying, analyzing, evaluating, and controlling all types of risk, including risks to safety and health. This is the formal assessment that was used. I should add that most of our staff in civil aviation have been trained to use this process.
[Translation]
On page 6, there is a brief explanation of the proposal. Based on the recommendations from the risk assessment and comments from stakeholders, Transport Canada has developed a regulatory proposal in order to provide an alternative, along with additional mitigating factors, which will offer the same level of safety to Canadians. It is important to note that the proposal is a minimal requirement and that airlines will be allowed to select a higher number of flight attendants, as is often the case currently, for client service purposes.
Under the proposed regime, airlines which choose the 1:50 passenger seat ratio would be required to meet specific conditions that do not currently exist in the regulations. These additional requirements have been included to ensure that the proposed 1:50 ratio offers the same level of security as the current 1:40 ratio.
I won't get into the technical details of the mitigating factors we would implement but we will answer any questions you may have. However, I would like to point out that three new items are proposed to require airlines to demonstrate that they have the same evacuation procedures in case of an emergency, in order to assess the procedures and the airline's emergency training program as well as the crew members' skills and the capability of the emergency equipment onboard.
[English]
As shown on page 8, additional amendments are proposed to four existing sections of the regulations. I would like to draw your attention in particular to numbers three and four. Flight attendants would be limited to working on three aircraft types. As there are no limitations on the one-to-forty rule, that would remain the same. For large aircraft with two aisles, we would require at least one flight attendant per floor-level exit.
There are other considerations: first, passengers with disabilities, on page 9.
[Translation]
Canadian Aviation Regulations already require airlines to implement procedures for special-needs passengers, like visually impaired, hearing impaired or mobility impaired persons or unaccompanied minors. These procedures include a preflight briefing, as well as a briefing on emergency and evacuation procedures. An able-bodied person is designated to help every special needs passenger in case of an emergency or an evacuation. Flight attendants must provide an individual briefing to special-needs passengers and any able-bodied passenger accompanying them to explain emergency or evacuation procedures.
Transport Canada is confident that with the current additional regulatory requirements, aimed at ensuring inflight safety, the proposed regulations will contribute to maintaining passenger safety, including for passengers who have special needs.
[English]
Moving on to page 10, there are security considerations.
[Translation]
Moreover, these safety requirements are designed to prevent persons or objects that could pose a threat to inflight safety from coming on board an aircraft or having access to restricted areas in an airport. The overall objective is to avoid this type of situation by improving controls and better assessing threats to safety before they reach the aircraft. No scenarios regarding security issues were developed during the risk assessment portion of the safety assessment analysis since risks involving loss of life from terrorist or hijacking activity remain high regardless of the number of flight attendants onboard. The change in the number of flight attendants has no impact on safety issues raised during the consultation process.
[English]
On page 11, in choosing an option, it's important to know that air operators would be required to determine, on a company-wide basis--and I insist on that, as I believe I mentioned last week, it would be on a company-wide basis--whether it's to their advantage to stay with the current one-to-forty passengers or whether to move to the proposed one-to-fifty passengers. For each company, this will be a matter of examining their fleet composition, with the number of seats installed on each airplane, the number of floor-level exits on each wide-bodied airplane, and the projected load factor as critical parameters.
At the back of your deck I have included a chart that shows the impact of the one-to-forty and one-to-fifty regime for each operator and each aircraft in Canada.
On average, Canadian air carriers operate at an 80% load factor. In almost all cases, at 80% or below, there is no impact. As you will see by glancing through the table, the data indicates that the majority of aircraft would operate with the same or a higher number of flight attendants. At 90% and 100%, which is quite rare, there are some reductions for some types of aircraft. In most instances, there would be no difference in the number of flight attendants.
To illustrate this, I have picked three aircraft, which were referred to before, that are commonly used in Canada. Slide 12 shows the differences between the one-to-forty and the one-to-fifty ratios, based on various load factors of an Airbus 320, a common aircraft type used by Air Canada. Using the Air Canada configuration of 159 seats, with an 80% load of passengers, there is no difference in the number of flight attendants required under both scenarios.
On page 13 we show a scenario of a Boeing 737-700, again, with various passenger load factors. Under both the one-to-forty and one-to-fifty regimes, WestJet would be required to carry the same number of flight attendants: three, when there is a load factor of 80%. However, at full capacity, the one-to-fifty rule would mean one less flight attendant than the one-to-forty regime.
[Translation]
As you can see on page 14, on wide-body aircraft like the Airbus 340-300, the 1:50 seat ratio requires that there be more flight attendants in almost all instances, except if the flight is full. In this case, and only in this case, the regulatory requirement of the 1:50 ratio would be the same as the 1:40, it would require eight flight attendants onboard. For any other passenger configuration, there would be more flight attendants under the 1:50 ratio.
In closing, I would say that the proposed change was developed through broad consultation, in-depth analysis and expert studies that demonstrated that the different options will have no impact on safety. During the development stage, we consulted industry representatives, unions, consumer groups and passenger safety groups. And these people were also part of the risk assessment. The stakeholders will also have an opportunity to express their views on the regulations when they are published in the Canada Gazette, part I.
A majority of countries require one flight attendant for every 50 passenger seats. These aircraft often take off or land in Canada and Canadians often travel onboard these foreign-owned aircraft in which the 1:50 ratio applies. The regulatory changes would harmonize our regulations with those of most other countries.
I would like to add that in this day and age, airlines have code share partnerships with other airlines. For all practical purposes, that means that if you have traveled abroad, even with a Canadian airline ticket, it's very likely that you have traveled onboard a plane where the 1:50 ratio applied. We are convinced that you did so safely. The same can be said of domestic flights. In the case of the Regional Jet or the Dash 8-300, the ratio is currently 1:50. We have never heard complaints of any kind regarding this.
[English]
Consultation is part of the development of all our Canadian aviation regulations, and our formal mechanism for initial consultation is the Canadian Aviation Regulation Advisory Council, commonly called CARAC. CARAC has participation from a large number of organizations outside Transport Canada representing the overall viewpoints of the aviation community.
I can assure you that throughout the regulatory process, whether at CARAC or during the gazetting process, all comments are carefully reviewed and play an important challenge function in ensuring that the department's decision is sound and can withstand scrutiny.
[Translation]
That means that when the time comes to decide to move forward with a regulatory proposal, the risk assessment has taken place and the department feels that this decision is in the best interest of Canadians.
Transport Canada will not introduce a change that could be detrimental to Canada's excellent reputation on safety. We take our role very seriously. The proposed regulatory changes demonstrate that we are determined to maintain a profitable civil aviation network without compromising its safety.
Thank you.
:
Thank you very, Mr. Chairman.
[English]
If I was worried before the presentation, I'm even more worried now after the presentation.
According to your own figures, Mr. Grégoire, what you're saying is that for a WestJet B737-700 with four exits, you'd be looking at three flight attendants. So for the fourth exit, for a stroke victim or a person in a wheelchair, they're basically going to have to figure their own way out. By your own figures, what you're saying is that there's an exit uncovered.
We know that flight attendants play an important role in evacuation procedures, so you're in the process of telling us, even though it's buried in the back pages of your report, that for dozens of aircraft flying in Canadian skies, if there is an evacuation, there will be exits uncovered in those cases. I find that appalling. The figures are right there. This is what you've provided to us: 44 aircraft, B737-700s, with four exits but three flight attendants.
You mentioned risk assessment. You mentioned a whole variety of groups that I know are opposed to this plan and yet you mention them. So I would like you to table that risk assessment that was done with the stakeholders, including disability groups from across the country and including flight attendants, because we need to know what they actually said. You're actually trying to use the names of those organizations to suggest that in some way they approve this change, and they don't.
My comments are more specific to what's happening internationally. We know Australia has just done a review, and Australia chose to maintain the same flight ratio. In fact, Australia sees a competitive advantage in having a safer airline industry. I think that's the public policy issue here: having a safer airline industry. That provides a competitive advantage, not a cup of coffee per passenger for a flight, which is what WestJet would save by leaving exits uncovered.
So Australia has chosen to maintain the same flight ratio. Why is that?
As to other evidence internationally, in the U.S., in the inquiry into the accident involving TWA flight 843, the National Transportation Safety Board said the evacuation of the airplane occurred within two minutes, and the speed in evacuating 292 passengers and crew from the airplane was complemented by TWA's requirement for nine flight attendants, which is actually higher than the FAA minimum.
So how many other airlines around the world with better safety records actually choose to maintain stronger standards?
Then I come back to the question I asked a few weeks ago--since you're back here. In the Air France accident, we know the flight attendants played a crucial role in ensuring that all those passengers got off safely. You mentioned that the government had no intention of waiting for the results of that TSB investigation--which is beyond me. You have an investigation that is tied clearly to flight attendant ratio. So I need to ask, is that Transport Canada's normal procedure, to ignore the results of a TSB safety audit, a safety report, in an incident that has a very clear link to where the government intends to go?
:
Thank you very much, Mr. Chair, and good morning.
[Translation]
Unfortunately, Mr. Chairman, we did not have time to translate our presentation. I apologize for that.
[English]
We appreciate the opportunity to appear before you today on behalf of the Air Transport Association of Canada to speak to the issue of modernizing Canada's flight attendant-passenger ratios. Before I do so, however, I do want to make one thing perfectly clear for the benefit of committee members, in response to some of the characterizations about our industry's position in this debate in the press over the last few weeks and months. Neither ATAC nor any of our members would ever propose a regulatory change that we believe would endanger passengers, period—not to cut costs, not for any reason whatsoever. It simply wouldn't make sense. In fact, safety and innovation have been the hallmarks of our association from the beginning.
ATAC was founded in 1934 as the national service organization for Canada's commercial air service providers, and it currently represents over 200 members, comprising 95% of Canada's commercial aviation revenues. Our membership is diverse, ranging from Canada's largest airlines to flight schools throughout the country. ATAC works on behalf of the industry to promote a world-leading commercial aviation sector based on safety, efficiency, and innovation.
On this issue in particular, ATAC, and more specifically my colleague Andy Vasarins, has been working through the Canadian Aviation Regulation Advisory Council, or CARAC, process to advance this change—Andy, specifically, for over two years now, ATAC for much longer. Indeed, this issue has been studied thoroughly at CARAC, which is an open, inclusive body, where organized labour has been a robust participant in the process. It has also been debated before this committee in each of the last two Parliaments.
While we have no interest in revisiting old ground on this debate, we would like to take the opportunity you have graciously given us here today to provide some context on the issue, to speak to the integrity of the process of amending aviation regulations in Canada, and to set the record straight on some misperceptions that have been perpetuated by those who have waged a very public campaign against modernization.
As you all know, Mr. Chairman, the issue we're referring to is a request by our industry to bring Canadian flight attendant ratio regulations in line with those of the U.S. and most EU countries. The current regulation requires one flight attendant for every forty passengers, whereas most regulatory regimes throughout the world require one flight attendant for every fifty seats. Opponents of this proposal have suggested, unfortunately—and we would suggest irresponsibly—that this would compromise safety. In fact, a detailed review of this proposal, conducted by an independent consultant for CARAC, concluded that no such case could be made. The data wasn't there.
Moreover, it should be noted that during the three years this proposal has taken to work its way through the CARAC and CARC processes, significant amendments and caveats have been added to ensure that this proposal does not in fact compromise safety.
First, air carriers will not be allowed to rotate back and forth between one to forty and one to fifty. We are now going to be required to declare which one we're operating under, and stick with it, to avoid potential confusion amongst staff. For similar reasons, flight attendants will only be allowed to be certified on up to three aircraft types.
Also, notwithstanding the ratio, all wide-bodied jets will have to have as many flight attendants on board as there are emergency exit doors on each passenger level. Moreover, carriers that choose to operate under the new standard will be required to demonstrate equal capability to evacuate their aircraft in case of emergency to the same standard that applies under the existing ratio, commonly known as the 90-second standard.
The result, Mr. Chairman, is that even after this change is implemented, it is highly likely that many flights will still carry more than the minimum crew complement assumed by those doing the simple one-to-fifty math calculation.
In short, the process has worked. Detailed data-driven studies concluded that there would be no reduction in safety by adopting this proposal, and consultative dialogue with all stakeholders resulted in a further set of restrictions to ensure that all possible concerns were addressed.
We respectfully suggest, Mr. Chairman, that this committee should and would want to support the work of a CARAC process. It is one that ensures that civil aviation regulations are debated in a non-politicized, data-driven environment to seek to achieve the best result for Canadians.
Unfortunately, opponents of this proposal have chosen to use fear in their attempt to achieve politically what they have failed to achieve at CARAC. Again, the facts are our best ally in rebuffing these claims. The one-to-fifty ratio has been in use for a little over 30 years in the United States and for slightly less time in the EU. In that period of time, not one aviation incident report has cited this ratio as the contributing factor in cases of serious harm to passengers from aviation incidents. In fact, since air carriers are regulated according to the regime of their home countries, there are literally dozens of large commercial flights from U.S. and European airlines that operate into Canada every day, carrying thousands of passengers quite safely under the one-to-fifty ratio. This standard is so common and universally accepted as a safe one that the modern aircraft are actually designed and built assuming the one-to-fifty ratio. It's working today in Canada and throughout the world.
Similarly, it's been working for some Canadian certified aircraft as well, which are operating under special provisions, allowing them to staff according to one to fifty. Specifically, each of the Bombardier CRJ200 aircraft, the Dash 8-300, and the ATR 42-300 aircraft have been operating safely using the standard for some time now.
Mr. Chairman, it's time to allow Canadians and Canadian carriers to compete fairly with their U.S. and European counterparts. Yes, this is largely a cost issue for our members, but as I stated at the outset, we would never allow cost concerns to supersede safety concerns. The simple reality is, however, that there is no data to suggest there are any outstanding safety issues associated with this proposal. Let's recall that there was a time when every aircraft had a flight engineer on the flight deck. There was a time when every flight attendant had to be a registered nurse. Clearly, those regulations have all been in response to the times. So, too, the flight attendant-passenger ratios in Canada must evolve to meet safe and proven international standards, which allow Canadian operators to compete and thrive with their international counterparts on a level playing field.
Thank you for your time, Mr. Chairman. With that, we look forward to your and the committee members' questions.
Thank you for coming before us today.
I've got a series of questions. I'll get them all out and then ask for responses.
First, what's the estimate on the actual cost saving of having one less flight attendant? I'm thinking particularly of the B737-700s. How much would the airline save by having one less flight attendant?
Secondly, why are you not calling for stronger regulations? It is a major competitive advantage in an industry where, as you know, safety is a primary concern. Why not call for the strongest possible safety regulations and have a worldwide reputation that Canadian airlines are under more rigorous safety regulations than any other airline in other countries?
Third, on the issue of the internal process, it's my understanding that you mentioned organized labour. I assume you were referring to flight attendants. They've been part of the process, and they've been vehemently opposed. Within the internal process that you have, why aren't those views reflected in what you're bringing forward today?
Fourth, you mentioned an independent consultant who had done a study. Would you release that to the committee?
Fifth, on wide-body jets, you mentioned that you're looking at regulations to ensure every exit is covered by a flight attendant. But as you know from previous testimony, again for the B737-700s, there's an exit that's not covered. The fact is, with these new flight regulations, we're looking at dozens of aircraft with an uncovered exit. Is that not of concern to you? It certainly is to me.
The next question is on the United States. If I didn't misinterpret what you said, you mentioned that not one single report has indicated flight ratios were a factor. But I cited TWA Flight 843 and the U.S. National Transportation Safety Board, which clearly indicated that flight attendants and the fact that TWA went beyond FAA requirements were factors in ensuring that all of the 292 passengers were evacuated.
You also mentioned that it was universally accepted, but we know that Australia has reviewed flight attendant ratios and has rejected any diminishment of the safety standards they have. Why can't we emulate best practices in the industry?
My final comment is on an issue that Mr. Grégoire raised as well. We've been working on this for a number of years, but the public obviously has serious concerns. Flight attendants who are the first-line responders have serious concerns. Why don't you drop it?
:
Mr. Chairman, I'll respond in order, and I apologize in advance if I have missed some of the questions. I trust you'll remind me. I think I have them all.
As to your first one—how much an airline would save in going to a 1:50 ratio—I have to admit we really don't know. Each individual carrier is going to have to determine for itself what the potentials are.
Some of the factors and the reasons we don't know are that so many different factors play in deciding how many flight attendants to deploy and essentially what the costs of deploying a flight attendant are under given situations.
As to your second question—why not call for the strongest possible safety standards as a competitive advantage—this is a very important point, and I'm glad you brought it up. It allows me to once again reinforce this message to the committee. I don't even know if it's unspoken, but it's a pretty blatant tradition in the industry that you do not use safety as a competitive element. Safety is something that should be and is taken as a given. The regulator exists to ensure that we operate in a safe environment. Airlines exist to ensure they provide safe service. We do not compete with each other on safety. Safety is a given, and if there is anybody out there competing on safety, they're really doing a disservice to the entire industry.
And to that point, just before I leave the question, we don't accept the premise that staying at the 1:40 ratio would ensure the strongest possible safety standards, because the data-driven assessment of the CARAC process has shown, as Mr. Grégoire rightfully pointed out, that there would be no appreciable decline in the safety levels. We don't accept the premise of the question.
As to your third question asking why, if the CARAC process is open and inclusive and CUPE's views, as the union that participated, were opposed and their views aren't reflected in this process, the committee will be interested to know that their views were in fact included.
The way the CARAC process works, objections are noted in detail, and members around the table are required to respond to them. When they can't respond quantitatively to those objections, the CARAC committee then decides whether further study is needed.
In fact their views were very much noted, and each and every one of their concerns was addressed at a substantive level. Were we able to make them happy at a political level? No, and I cede the point that I don't think we'll ever be able to.
As to your fourth question, whether we would be able to release to the committee a substantive study that we cited as having been made, I referred to the same study Mr. Grégoire referred to, which he indicated is either already on the record or he is about to submit it to the committee. I will defer to this. If in fact he does not submit it, I invite the chairman to get in touch with me, and we'll do our best to make it available.
Concerning your fifth question, about the Transport proposal showing there are in fact emergency exits not covered, despite my comments that suggest one of the mitigating factors would be that all emergency exits would be covered, unfortunately I didn't get a copy and haven't seen the Transport Canada proposal. But we noted with interest the reference to the Boeing 737-700 having four exits. It's our understanding it actually has more than that, but that's not even the issue here.
The specific mitigating measure that's put in place is that on all wide-body jets—that's jets with two aisles or more—irrespective of the 1:50 ratio, if you choose to adopt it, you have to have one flight attendant for every exit door on that aircraft.
As to your sixth question, about the TWA report showing that the flight attendant ratios were a factor despite my statements that they are not, what I actually said was—I can give my exact words—there is no report that shows the lack of flight attendants was a reason why people were harmed.
Perhaps we're playing with words a little here, but going to that same point, I can refer to the quote you read. It's important to note that what they actually qualified it as was I think “a contributing factor”. Maybe I'm mischaracterizing the word, but—
Mr. Peter Julian: "Complemented".
Mr. Fred Gaspar: It complemented. I'm sure it did complement, but as Mr. Grégoire rightfully pointed out, we have to exist in a data-driven environment, and in fact there was no evidence to suggest that more flight attendants would have made the process any quicker or any better.
As to your seventh question—why not emulate best practices such as Australia's—Australia has looked at this, and they've decided not to go the other way. I would suggest to committee members that it would be an error in judgment to conclude that Australia is not going to the 1:50 ratio model because they have looked at this thing inside and out and have concluded it is unsafe. They are dealing with the same political pushback we are dealing with here. Unfortunately, they do not have the courage of their convictions to proceed. It's up to them to decide in their own best interests, but I would suggest to you, respectfully, that it was not because of a lack of merit of the position.
Unfortunately, I believe you had another question, but I didn't have time to write it down.
Mr. Peter Julian: Why don't you drop it?
:
Each member of the committee has been given a PowerPoint presentation in English and French, some poll results in English and French, and a blue book that I'll be referring to, which is completely bilingual under the tabs. I'd like to walk you through the PowerPoint presentation, because I think we'll be able to answer many of the issues raised by Transport Canada, and by ATAC, and hopefully answer some of the questions you have.
One of the things is on page 11 of the slide show. We met with the minister on June 6 with Mr. Grégoire. It was the first time we heard that there is now a company-wide election for this rule, so something has changed that we weren't even aware of. But let's be clear on what the proposal is. I would draw your attention to slide 3. Mr. Grégoire described it on his slide, but it will be unique in the world. You will have a choice between three rules: the current one-to-forty passengers, with some long overdue improvements; a one-to-fifty seats rule for wide-body aircraft, above the U.S. rule; and a one-to-fifty seats rule for narrow-body aircraft, which we believe will be effectively the same as the U.S. rule. Airlines will be able to pick and choose as they see fit. The last time we saw this rule go forward, it was by aircraft type, so we're surprised that there has been a change.
If you go to slide 4, you will see what is referred to as Frances Wokes' comment. Mr. Grégoire told you today that Transport Canada rejected the one-to-fifty seats rule in 2000 because of safety concerns, but to date we've not been able to get the document because it has been withheld at the direction of the deputy minister. As you can see on slide 5, it was rejected in 2001 because it did not maintain an equivalent level of safety, which Mr. Grégoire says it does today. We would like to discuss that very seriously. He also insists that the 2001 proposal is different. Today we have a different proposal.
I would like to draw your attention to slide 6. Some of you may have been able to see these documents that Frances Wokes prepared. What we have in the yellow tab in the blue book is a summary of what MPs from this committee have told us were in those documents. Those documents contained a three-column matrix. The third one is blanked because of access to information, even though the same analysis in 2005 was released in its entirety. They never showed us the document, but members of the old SCOT described it to us and said that the documents were a smoking gun, and they saw no reason why those documents could not be released.
We believe we cannot have a regulatory process that is fair when all the available facts are not on the table. As you can see on slide 7, we met with the minister on June 6, and we asked him to release the documents. We may need your help to get those documents released.
I would draw your attention to slide 8. We have had mention repeatedly of this risk assessment that Transport Canada conducted in 2003. There is the scoring of the five rules they looked at. The current rules scored 404; the U.S. rules scored 256. To answer, I think, Mr. Laframboise's question, the risk assessment did not score the new proposal.
Moving to slide 9, there's a lot of talk of one-to-fifty being the gold standard. The U.S. National Transportation Safety Board has always been critical of that move, and in fact Transport Canada's own risk assessment concluded that the one-to-fifty rule had to be improved for wide bodies by putting in the floor-level coverage, which is unique in the world.
Going to slide 10, we have already had reference to the TWA crash. The evidence shows flight attendants save lives. Mr. Gaspar and Mr. Grégoire talk about the lack of flight attendants being the cause of deaths of people. Here we have a crew in excess of legal minimums, that saved lives. We believe that properly conducted accident investigations demonstrate the weakness of bad rules.
Slide 11 shows us the commitment of the Conservative Party during the election. Many of you are recipients of e-mails from our members. These are the responses back from the Conservative Party. They don't believe there would be a bad impact. We heard from Mr. Grégoire today that there would not be a bad impact. We have all the numbers of different ratios.
We would now draw your attention to slide 12. We want to have you look at full loads. Monsieur Grégoire said the one-to-fifty was deficient, particularly as it relates to wide-body aircraft, and that Canada has done better. Transport Canada is going to require one flight attendant per floor-level exit.
The diagram in slide 12 represents the typical configuration of an Air Canada A340-300. It is the same type of aircraft that crashed at Pearson last summer, just a few seats smaller. There are eight floor-level exits on this aircraft. They are circled in the diagram there. Under the U.S. and European rules, only six flight attendants would be required, leaving two of the exits uncovered, which are marked in red. That is the rule that ATAC sought in October 2002 when they filed their petition. This is the debate. They wanted a crew of six, leaving two floor-level exits uncovered.
I would like to move to slide 13, to the same plane, the A340. As a result of the Transport Canada risk assessment, when this plane is full, eight flight attendants will be required under the current Canadian one-to-forty rule, covering all floor-level exits. Transport Canada has agreed that under their version of the one-to-forty rule, they would ensure full coverage for these wide-body aircraft. This is more than the so-called international standard because the risk assessment found that the international standard was deficient. It ensures that one-to-forty and one-to-fifty Canadian...are the same. This is a good thing, a safe thing.
Now let's look at the impact on narrow-bodied aircraft like the A320, which is shown in slide 14. I would like to clear up the confusion. There are two floor-level exits at the rear of the aircraft, two floor-level exits at the front, and the two little dots there are overwing type III exits not to be run by a flight attendant. They are passenger self-help exits. So when somebody says there are six or eight exits on an aircraft, we're talking about floor-level exits. There are four floor-level exits on an A320.
Mr. Grégoire said that TC would never reduce safety. Well, under the current one-to-forty rule, this plane requires a crew of four flight attendants at full passenger loads, at 121 and 140 seats. There you can see there are four flight attendants. There will be complete floor-level coverage. Carriers will have the option to flip to the one-to-fifty rule, the same standard Transport Canada rejected in 2001, and you will be able to operate this same aircraft with only three flight attendants. This is a 120-foot cabin; there is no margin for error at these crew levels. If a flight attendant is injured or unable to help, there will only be two flight attendants to evacuate that full aircraft.
I will move to the next slide. This is not just affecting Air Canada; it also affects WestJet and other aircraft.
We've heard a lot about these mitigation factors. There are 14 such mitigating or compensating factors; 12 of the 14 will apply to both the one-to-forty and the one-to-fifty rules. So what mitigation is there to move from the lower one-to-fifty to the higher one-to-forty when they both have the same enhancements? The limitation of aircraft types.... In our view, WestJet, for example, will not be subject to the limitations because they only have three aircraft types. Air Canada has many more aircraft types, but Transport Canada has watered down the definition so much that we think Air Canada will be able to get under the rule of five. It's not three; it's also five.
The only mitigating factor we see is new in-charge training. The cabin personnel who are in charge of the aircraft will have new training. They should have had new training required by law. It may be as little as one-half a day. Such extra training for one person on a reduced crew will not compensate for one less body on these aircraft. We would suggest that moving to a one-to-fifty rule will cut the crews on narrow-bodied aircraft overnight, without any mitigating factors whatsoever.
That is why Frances Wokes' report is so important. She found out the problems with that rule in 2001. In our view, it is indeed a smoking gun.
There were some questions.
In the blue book is the staff report that Monsieur Grégoire carefully avoided answering on. I listened very carefully to his answer, but he never answered it.
You will see the staff recommendation where they expressed concern. This is not scaremongering. These are not the foes of modernization that ATAC would lead you to believe. This is from a Transport Canada staffer, Christopher Dann, who was sitting here during the presentation but unfortunately had to leave.
They talked about the sensitivity of this issue and the risk of lowering public confidence in aviation safety. They went on to say that we needed to do eight more things, seven of which, to our knowledge, have not been done.
We have finally seen the aircraft analysis tied to this slide show, an analysis we have been asking for since April 2004. It has appeared today, and only because this standing committee made Transport Canada come.
In addition, you will see the Australian quote “after a security incident”. After a passenger attacked flight attendants with pointed sticks, Australia realized they should not lower their ratio of 1:36, and we believe for good reason.
Will passengers benefit? Will there be lower fares, better service, and free blankets and pillows? We don't think so.
You have the complete poll results as well, and 69% of Canadians want to maintain the current 1:40 ratio. More importantly, 50% strongly oppose the change, even if it is to maintain corporate international competitiveness.
In summary, Transport Canada's culture of secrecy is inconsistent with the government's commitment to open and transparent government. Transport Canada officials are asking you to deliberately increase risks to passengers for no tangible public return, and even their own staff believe more homework must be done.
I'll say a word on consultation. We had two one-half days in 2003 to discuss risk assessment in separate rooms. The unions were in one room, the employers met separately, and there were public interest groups. We had two one-half days of that. In April 2004 we had two days when we were all brought together. There have been three days of consultation on this regulation. The rest of the time, any delay has been due to the department.
Finally, we ask you as parliamentarians to take action to put this initiative on hold. We need all the work done that was identified in the November 2004 staff report. We need the full Wokes' analysis. We need to return to the department, because, quite frankly, it's now on a fleet-wide basis, and that's news to us. We need to know what is being planned.
In conclusion, we need to ensure that you have done your job. In 1981 the U.S. House of Representatives had public hearings when the U.S. government considered moving to a 1:50 passenger ratio. After considering it, they rejected it.
Finally, with the greatest of respect to Mr. Grégoire, if you want to be data-driven, you learn from accidents. Wait for the investigation report of Air France Flight 358.
Thank you for the opportunity to appear.
We know that we ran too long, but I think we've anticipated a lot of the questions and we've tried to put the full debate before the committee on all these issues.
We're open to your questions, Mr. Chair.
The recommendation that is coming from Transport Canada is based on that risk assessment. It's presumably based, at least in part, on the CARAC study. It's based on the fact that virtually all of the other major airlines in the world use the 1:50 rule.
Going back to the poll itself and the methodology used, I'll refer you to page 3, first of all. The question, presumably, that was addressed to the survey participants was whether they were in favour of maintaining Canada's current regulation for flight attendant requirements or matching regulations with the U.S.
Why just the U.S.? If 99% of the world's major airlines are using the 1:50 rule, why do we focus on the U.S.? Given the fact that Canadians have a much more cautious approach than our American neighbours--for a number of different reasons--than we did 30 years ago, it seems to me that referring to the U.S. in this question would tend to skew the results in favour of the answer you wanted to receive.
Before you answer the question, just to buttress that point, I'll go to page 6, which does the same thing. Again, I believe it's incorrect methodology at play here. The question is, “Should Canadian airlines lower their safety standards to stay internationally competitive?” In fact, the evidence from TC is that safety standards aren't being lowered. So if you use the words “lowering safety standards”, obviously you're going to get a response that's negative from Canadians. In fact, I'm surprised it's not 100%.
It's how you ask the questions. Clearly, I would feel uncomfortable using this as the basis for my decision, and for the decision that the minister is going to make on this issue.
I'll leave it up to a response from you, but I'm really concerned when we use a poll like this, which isn't a study. None of these survey participants, presumably, were asked questions such as, “Are you aware that the large majority of airlines in the world are using 1:50?” They probably weren't provided with copies of the risk assessments. They probably weren't provided with the TC briefing.
So that's my struggle in trying to put any weight on this document.