Registration - Consultant
Canadian Business Aviation Association / Association canadienne d'aviation d'affaires / Merlin Preuss, Consultant
Version 21 of 23 (2019-10-01 to 2019-11-14)
Subject Matter Details
Legislative Proposal, Bill or Resolution, Policies or Program, Regulation
- Environment Canada Federal Carbon Pricing Backstop legislation under consideration. Provide input to this legislative initiative to ensure business aviation concerns are understood, that the legislation aligns as much as possible with ICAO/Transport Canada legislation, and that the requirements are appropriate for the business aviation sector.
Policies or Program
- CAR 604.46 approval requirements delegation of authority to issue approvals and registration documents as well as all approvals, including Maintenance Schedules, supporting the registration document (PORD)
- CAR 604.46 delegation of approval authority for these authorizations and the registration document
- CARs Level of Service issues and problems resolutions.
- CBSA CANPASS improvements level service issues for business aviation operations.
- CBSA Level of Service Improvements for crossborder clearances for business aviation operators
- Develop processes and procedures with Transport Canada Aviation Security to provide security program approvals for Canadian operators for international and domestic operations where applicable.
- Participate in the Communication, Navigation, Surveillance/Air Traffic Management (CNS/ATM) Strategy Working Group, co-chaired by Transport Canada and Nav Canada, by providing input, identifying issues, and working with TC and Nav Canada to address issues.
- Participate in the TCCA 2020-21 Strategic Safety Risk Assessment (SSRA) Risk identification exercise and similar requests for industry input.
- Transport Canada has no regulation that permits them to issue operations specifications to foreign private operators like the provision in Canadian Aviation Regulation 701.08(g) respecting foreign commercial operators. The CBAA will be lobbying to have Transport Canada provide this service to foreign private operators by whatever means Transport Canada determines best.
- Work with TC to identify and address issues and problems identified in the CAR 604 targeted inspection program and any future inspections involving CBAA members.
Policies or Program, Regulation
- Exempt CAR 604 operators from some of the CAR 604 Safety Management System requirements.
- Have TC make provisions to allow exemption NCR-015-2018 to apply to CAR 604 operations given that CAR 604.221(3)(d) says the same thing as CAR 704.33(1)(e to CAR permit the CAR.
- Provide relief from or an alternate means of compliance related to requirements to permit operators to do Required Navigation Performance Approaches (RNP APCH).
- Transport Canada requirements to maintain night currency (5 night take off and landings) as per CAR 401.05(2)(b) Provide relief from these requirements.
- Amendments to Flight Data Recorder aircraft requirements and related issues and requirements. Provide input to this legislative initiative to help ensure it addresses safety requirements in the most effective way from a business aviation perspective.
- Civil Aviation Regulation 604.206 provides for no scheduling flexibility for the audit. The CBAA will be proposing that TC permit via whatever means exemption, regulatory change, interpretation etc a period of time before and after the expiry or the audit validity period in which the audit may be completed without changing the validity period for the next cycle.
- Exemption for 604.139 and 604.136 validity period requirements.
- Exemption to CAR 604.138 & 136 validity period requirements.
- Flight Attendant Training Requirements. CAR 604.145, 704.33, 704.34, and 704.115 and associated standards, authorizations and exemptions. Transport Canada is in the process of reviewing the current authorizations and exemptions and the CBAA will be providing input on these changes.
- Foreign Air Operator Certification Requirement CAR 701.09 d). Provide relief for foreign air operators from strict International Civil Aviation Organization (ICAO) standards who have equivalent regulatory frameworks to Canada and work with Transport Canada to have foreign aviation safety authorities recognize the Canadian regulatory framework in the same way.
- In response to a TC request to participate in the CARs Modernization Project, suggest, justify and promote changes to the CARs that would modernize them.
- Minister of Transportation Interim Order on Prevention of Laser Strikes on Aircraft under consideration. Provide input to this initiative to ensure it is as comprehensive as possible.
- Seek interpretation of take-off data and other regulatory requirements from Transport Canada.
- The published Fatigue Management and Fatigue Risk Management Regulations for Civil Aviation Regulations 700, 702,703,704 and 705 are problematic for commercial operators. The CBAA will be proposing exemptions to and alternate means of compliance for these regulations.
- Transport Canada may be changing provisions in the MMEL/MEL Policy and Procedures Manual incorporated by reference in Canadian Aviation Regulation 605.07(3). The CBAA will be providing input to these proposed changes and will be lobbying to ensure they are as simple and practicable as possible.
- Written communication
- Oral communication
The lobbyist has arranged or expects to arrange one or more meetings on behalf of the client between a public office holder and any other person in the course of this undertaking.
- Canada Border Services Agency (CBSA)
- Environment and Climate Change Canada (ECCC)
- Transport Canada (TC)
Government fundingNo government funding was received during the last completed financial year.
Client Contact Information
1 Rideau Street
Ottawa, ON K1N 8S7
Principal representative of the client
Anthony Norejko, President and CEO
Parent Company Information
Canadian Business Aviation Association / Association canadienne d'aviation d'affaires is not a subsidiary of any other parent companies.
Coalition Members Information
Canadian Business Aviation Association / Association canadienne d'aviation d'affaires is not a coalition.
Person or Organization with a Direct Interest Beneficiary Information
The activities of Canadian Business Aviation Association / Association canadienne d'aviation d'affaires are not controlled or directed by another person or organization with a direct interest in the outcome of this undertaking.
Subsidiary Beneficiary Information
Canadian Business Aviation Association / Association canadienne d'aviation d'affaires does not have any subsidiaries that could have a direct interest in the outcome of the undertaking
Merlin Preuss | Public offices held
71 Goldora Private
Kanata, ON K2T 1K8
Consultant Firm and Address
Firm: Preuss Aviation and Mangement Consulting
71 Goldora Private
Kanata, ON K2T 1K8