PACP Committee Report

Mr. David Christopherson
Chair
Standing Committee on Public Accounts
House of Commons
Ottawa, Ontario
K1A 0A6

Dear Mr. Christopherson,

Pursuant to House of Commons Standing Order 109, on behalf of the Government of Canada I am pleased to address the recommendations made by the Standing Committee on Public Accounts in its final report entitled “2012 Spring Report of the Auditor General of Canada, Chapter 5 – Oversight of Civil Aviation – Transport Canada”.

The Government of Canada has carefully considered the report and taken note of the recommendations within it. Transport Canada has completed substantial work to address the recommendations highlighted within the report.

Recommendation #1:

That by March 31, 2013, Transport Canada provide to the Standing Committee on Public Accounts an update on its action plan, demonstrating that it has addressed the Auditor General’s recommendations.

Response:

Since the release of the 2012 Spring Report, Transport Canada has concluded all of the actions related to the implementation of the Auditor General’s recommendations. In that time, the department has achieved the following:

• Launched a standard risk assessment tool, which is designed to collect information necessary to assess aviation companies and ensure consistency across all aviation enterprises with regularly updated risk profiles to support surveillance plans and activities.
• Updated and communicated to all inspectors and managers minimum surveillance levels for civil aviation companies through a staff instruction, which provides guidance on the level of surveillance required based on the risk profile produced for the company.
• Developed a national surveillance plan to ensure that we are able to allocate resources where they are most needed, while maintaining capacity to undertake unplanned inspection activities (e.g. in response to changes in risk). Performance against the annual surveillance plan is reviewed by senior management on a regular basis, including a discussion of deviations and corrective measures. This past fiscal year, the department completed 95% of its planned surveillance activities while the 5% that were not completed have been documented (e.g. companies voluntarily closing their operations).
• Provided managers and staff clear direction on requirements with respect to surveillance documentation and expectations for management involvement, with documentation requirements relating to surveillance decisions being integrated into an updated staff instruction.
• Launched the Civil Aviation Surveillance Information Management System (CASIMS), an online database that provides a central repository for all surveillance related information, including records of key decisions related to the surveillance activity. 
• Developed a five-year internal quality assurance plan for the Civil Aviation Program to ensure the department continually evaluates the effectiveness of its program elements. The results of already completed quality assurance work will be used to enhance oversight activities.

Recommendation #2:

That by March 31, 2013, as part of the update on its action plan, Transport Canada provide to the Standing Committee on Public Accounts details on the specific measures being taken to accelerate its ability to address safety issues in a timely manner.

Response:

Transport Canada reviewed its civil aviation rule-making process, also known as the Canadian Aviation Regulation Advisory Council (CARAC) process, with a view to improving the overall timelines and efficiencies of regulatory proposals. The review identified new ways of addressing safety issues in a more timely fashion, and of streamlined consultation and communication of regulatory initiatives with stakeholders. The modernized model was presented to stakeholders on December 4, 2012 and was well received. The department is committed to complete the transition to the renewed rulemaking process by Fall 2013.

Recommendation #3:

That by June 30, 2013, Transport Canada provide to the Standing Committee on Public Accounts its updated human resources plan for the Civil Aviation Directorate, including an assessment of the number of inspectors and engineers required to carry out its civil aviation activities.

Response:

Getting to the right workforce – both in numbers and competencies – is a critical part of our work.  Transport Canada’s Civil Aviation Program went through a period of significant organizational change between 2008 and 2012, with a major restructuring of the organization and redefining the way in which work was carried out.

We are now working with the rest of the Department to strengthen resource planning.  A comprehensive human resources strategy was developed and implementation has started.    The strategy includes a description of the operating context for the Civil Aviation Program, including changes to the regulatory framework and to surveillance, the Civil Aviation workforce that will be needed, and our priorities for action.

As part of the strategy, there is a Civil Aviation action plan for 2013/14 – 2015/16 focused on:

• Developing the current workforce (training to build competencies that will be required in the future)
• Strengthening management capacity (by establishing a technical leadership advisory team and increasing succession planning)
• Recruiting experienced personnel to address attrition

In the meantime, our analysis is that Transport Canada has the resource levels it needs to deliver the civil aviation oversight program, including surveillance; our Civil Aviation workforce of 1285 FTEs as at April 2013,  is sufficient.   The Civil Aviation Directorate has identified the number of employees it needs in its core occupational groups (i.e. AO, TI, and AI inspector positions) to deliver the surveillance plan.  It also identified the number of engineering employees it needs for aircraft certification activities.  Should levels fall below these numbers, it will trigger strategic action by the Directorate to make sure effective oversight is sustainable.

It is important to note that focusing only on positions traditionally defined as “inspectors” does not present a complete picture of the resources involved in delivering the Civil Aviation Program. For example, positions designated as inspector are found both in direct delivery of service and surveillance activities and also in the development of standards.  There are many positions that are integral to the oversight program.  For example, engineers, information management system specialists, and Civil Aviation Program managers also play critical roles in front-line inspections for aircraft safety although they are not classified as “inspectors” and have not therefore been included in the numbers. 

The number and classifications of positions that we now have in Civil Aviation are the product of many years experience, however the oversight program and surveillance plan are not static.  Over time, industry’s risk profile will change, the Program will evolve and the mix will have to evolve.  The Civil Aviation Program will review its surveillance plans and resource requirements annually in this context and adjust resource requirements as necessary. 

The Government of Canada would like to thank the members of the Standing Committee, and the many witnesses who appeared before it, for their insight and commitment to understanding and strengthening aviation safety in Canada, and for their work in preparing this report.

Sincerely,

The Honourable Lisa Raitt, P.C., M.P.

Minister of Transport