NAV CANADA is proposing additional fees for small aircraft using Canada’s eight largest airports — these will be per-departure/day fees (i.e. a fee for each day that an aircraft departs from the airport). Here is NAV CANADA’s proposal, and here is COPA’s view. This posting contains a copy of my own written response, sent to NAV CANADA today. If you are interested in responding — pro or con — you still have until Friday 10 February to do so (for contact information, follow the COPA link).

6 February 2006

NAV CANADA
P.O. Box 3411, Station “D”
Ottawa, ON K1P 5L6
Attn: Assistant Vice-President, Revenue and Performance Indicators

Thank you for giving us an opportunity to respond to NAV CANADA’s Notice of New and Revised Service Charges. I understand that NAV CANADA is in a difficult situation, caught between pressure from carriers frustrated at paying the majority of fees for air traffic services, and pressure from the general aviation (GA) sector anxious to avoid fees that might force them out of aviation completely. I can see that a great deal of careful thought went into your plan, and that it is an attempt to balance both of those concerns in a fair way.

As a private aircraft owner, however, I believe that there are several points that raise serious questions about both the effectiveness and the fairness of the plan:

1. The plan aims to be revenue-neutral by raising fees for GA flying from Canada’s eight major public airports while reducing fees for carriers; however, the plan also aims to discourage GA traffic from using the public airports that would generate additional fees. If the plan is successful in reducing traffic, however, you will receive less money than expected from GA daily usage fees. In this respect, the two goals conflict.
2. The plan does not take into account the different natures of the airports listed. For example, Ottawa/Macdonald-Cartier is the home base for many small aircraft that, for the most part, operate from a separate runway and a separate part of the field; it should not be treated the same way as a congested airport like Toronto/Pearson. These differences suggest that reducing traffic at airports is not a reasonable goal for NAV CANADA – that should be left for individual airports to deal with, for example, by requiring landing slot reservations or imposing landing fees. Individual airport authorities are in a much better position to know their local needs.
3. The plan is designed to encourage GA aircraft to use reliever airports in the cities listed, but at present, unlike in the United States, many of the cities listed do not have GA relievers with ILS approaches for low-weather operations. In line with NAV CANADA’s responsibility not to set fees that affect aviation safety, it is likely that the company would be obliged to commission at least one fully-operational ILS approach at an alternative airport for each of the cities listed (where one does not already exist). Ottawa and Halifax, for example, have no alternative GA airports with ILS approaches, while the ILS approach at Toronto/City Centre is extremely restricted (it requires RNAV, and does not allow jet aircraft).
4. The primary purpose of air-traffic services in terminal areas is to allow air carriers to maintain their schedules — terminal air traffic services bring only limited benefits to light aircraft, who can easily function without terminal control units, ground control, or tower control, so it is not reasonable to require light aircraft to pay more than a small fraction of the fees.

Thank you for reading my comments. If you have any questions or require further information, please feel free to write, phone, or to send me e-mail.

Sincerely,

David Megginson