Monday, October 23, 2017

Triage Statement Guide

by Pierre-Laurent Samson, Civil Aviation Safety Inspector, Regulatory Affaires, Policy and Regulatory Services, Civil Aviation, Transport Canada

Since April 1, 2006, all federal departments wishing to amend a regulation for which they are responsible have been required to submit a Triage Questionnaire. The format of this document is set by the Treasury Board of Canada Secretariat (TBS). The document allows for the evaluation of possible repercussions that a regulatory proposal may have on 13 sectors of Canadian society (health, the environment, the economy, etc.). After receiving suggestions for modifications from analysts from various departments, the TBS replaced the Triage Questionnaire with the Triage Statement. This new document, which studies 10 sectors of Canadian society, will assist with the evaluation of the overall impact a regulatory proposal may have, and formalizes the related analysis requirements. These changes allow for more efficient use of analysts who are responsible for the analysis required for drafting supporting documents (environmental studies, cost-benefit analyses, Regulatory Impact Analysis Statements [RIAS]), and thus reduces the time required to carry through the regulatory proposal.

The following are the 10 sectors evaluated in the Triage Statement along with the justifications designating their level of impact (taken form the Triage Statement Guide):

  1. Public health and safety: If a regulatory proposal is expected to have no impact on health or safety or is not applicable, it receives a No/NA rating. If a regulatory proposal is expected to have minimal impacts, it receives a low rating; if it is expected to have some impacts (e.g. reduce delays or the need for medical attention or hospitalization) it receives a medium rating; and if it is expected to have significant impacts (e.g. mortality), it receives a high rating.
  2. Environmental impacts: If a regulatory proposal is expected to have no impact on the environment or is not applicable, it receives a No/NA rating. If a regulatory proposal is expected to have minimal impacts, it receives a low rating; if it is expected to have some impacts, it receives a medium rating; and if it is expected to have significant impacts (e.g. damaging or protecting a sensitive ecosystem from irreversible harm or damage), it receives a high rating. A Strategic Environmental Assessment could provide the basis for the rating, see Cabinet Directive on Environmental Assessments: www.acee-ceaa.gc.ca/016/directive_e.htm.
  3. Social impacts: If a regulatory proposal is expected to have no social impacts or implications (e.g. changes to people’s way of life, culture, community, political systems, well-being, personal and property rights, fears and aspirations or raises ethical concerns) or is not applicable, it receives a No/NA rating. If a regulatory proposal is expected to have minimal impacts, it receives a low rating; if it is expected to have some impacts, it receives a medium rating; if it is expected to have significant impacts, it receives a high rating. Special consideration should be given to vulnerable social and economic groups (e.g. Aboriginal, official language minorities, lower income Canadians, gender, children, the elderly, cultural groups and recent immigrants).
  4. Public security impacts: If a regulatory proposal is expected to have no impacts or implications on public security (e.g. national safety and security, transportation and travel safety, criminal activity/policing, emergencies and disasters, family and home safety, financial safety, internet safety, product/consumer protection, recreational safety, school safety, bullying and workplace safety) or is not applicable, it receives a No/NA rating. If a regulatory proposal is expected to have minimal impacts, it receives a low rating; if it is expected to have some impacts, it receives a medium rating; and if it is expected to have significant impacts, it receives a high rating.
  5. Economic impacts: If a regulatory proposal is expected to have no economic impacts or implications (e.g. economy, business including administrative burden and duplication, consumers, competition and internal trade) or is not applicable, it receives a No/NA rating. If a regulatory proposal is expected to have minimal economic impacts, it receives a low rating; if it is expected to have some impacts, it receives a medium rating; and if it is expected to have significant impacts, it receives a high rating.
  6. Costs and savings of the regulatory proposal: The estimated level of gross costs or savings to government, industry, consumers, and others as a result of the regulatory proposal, in dollar terms. Estimate costs or savings in either present value (PV) terms based on at least a 10-year forecast and an 8 percent discount rate, or expressed annually, see Canadian Cost Benefit Analysis Guide: www.regulation.gc.ca/documents/gl-ld/analys/analys00-eng.asp.
  7. Public interest, stakeholder support and potential controversy: If a proposal is not controversial and is universally supported by all stakeholder groups or is not applicable, it receives a No/NA rating. If a regulatory proposal is expected to cause minimal controversy and is generally supported by all key stakeholder groups, including lobby groups, it receives a low rating; if it is expected to cause some controversy or is opposed by some key stakeholders, it receives a medium rating; and if it is expected to cause significant controversy, opposed by most stakeholders or faces large opposition, it receives a high rating.
  8. Impacts on regulatory coordination and cooperation: If a regulatory proposal is expected to have no impact on regulatory coordination or cooperation (including between federal departments, with other governments in Canada, and internationally) or is not applicable, it receives a No/NA rating. If a regulatory proposal is expected to have minimal impacts on regulatory coordination or cooperation, it receives a low rating; if it is expected to have some impacts, it receives a medium rating; and if it is expected to have significant impacts, it receives a high rating.
  9. International trade agreements or obligations: If a regulatory proposal is expected to have no impact on international trade agreements or obligations or is not applicable, it receives a No/NA rating. If a regulatory proposal is expected to have minimal impacts on international trade agreements or obligations, it receives a low rating; if it is expected to have some impacts, it receives a medium rating; and if it is expected to have significant impacts, it receives a high rating.
  10. Legal, policy/government priority, miscellaneous or other impacts: If a regulatory proposal is expected to have no legal, policy or other impacts or is not applicable, it receives a No/NA rating. If a regulatory proposal is expected to have minimal legal, policy or other impacts, it receives a low rating; if it is expected to have some impacts, it receives a medium rating; and if it is expected to have significant impacts, it receives a high rating. Miscellaneous regulations are usually rated as No/NA.

The low impact RIAS template can be found at: www.regulation.gc.ca/documents/lit-reir/lit-reir-eng.asp. The medium/high impact RIAS template can be found at: www.regulation.gc.ca/documents/rias-gime/rias-gime-eng.asp.

TC AIM Fast Facts: Fuel Requirements

The fuel requirements contained in this Section do not apply to gliders, balloons or ultra-light aeroplanes.
 (CAR 602.88)

In addition to VFR and IFR fuel requirements, every aircraft shall carry an amount of fuel that is sufficient to provide for

  1. taxiing and foreseeable delays prior to takeoff;
  2. meteorological conditions;
  3. foreseeable air traffic routings and traffic delays;
  4. landing at a suitable aerodrome in the event of loss of cabin pressurization or, in the case of a multi-engined aircraft, failure of any engine, at the most critical point during the flight; and
  5. any other foreseeable conditions that could delay the landing of the aircraft.

VFR  Flight
An aircraft operated in VFR flight shall carry an amount of fuel that is sufficient to allow the aircraft

  1. in the case of an aircraft other than a helicopter,
    1. when operated during the day, to fly to the destination aerodrome and then to fly for 30 minutes at normal cruising speed, or
    2. when operated at night, to fly to the destination aerodrome and then to fly for 45 minutes at normal cruising speed, or
  2. in the case of a helicopter, to fly to the destination aerodrome and then to fly for 20 minutes at normal cruising speed.

IFR Flight
An aircraft operated in IFR flight shall carry an amount of fuel that is sufficient to allow the aircraft

  1. in the case of a propeller-driven aeroplane,
    1. where an alternate aerodrome is specified in the flight plan or flight itinerary, to fly to and execute an approach and a missed approach at the destination aerodrome, to fly to and land at the alternate aerodrome, and then to fly for a period of 45 minutes, or
    2. where an alternate aerodrome is not specified in the flight plan or flight itinerary, to fly to and execute an approach and a missed approach at the destination aerodrome and then to fly for a period of 45 minutes; or
  2. in the case of a turbojet powered aeroplane or a helicopter,
    1. where an alternate aerodrome is specified in the flight plan or flight itinerary, to fly to and execute an approach and a missed approach at the destination aerodrome, to fly to and land at the alternate aerodrome, and then to fly for a period of 30 minutes, or
    2. where an alternate aerodrome is not specified in the flight plan or flight itinerary, to fly to and execute an approach and a missed approach at the destination aerodrome and then to fly for a period of 30 minutes.

Source: Transport Canada Aeronautical Information 
Manual (TC AIM) RAC 3.13
www.tc.gc.ca/CivilAviation/publications/tp14371/RAC/3-0.htm#3-13

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