onboard the aircraft. However, Section 2 of the SATR explicitly refers to screening performed by a person or entity responsible for aviation screening, such as the Canadian Air Transport Security Authority (CATSA) in Canada, and the Transportation Security Administration (TSA) in the United States.
Regrettably, this significant distinction was not included in the PPP Carrier Eligibility Checklist Questionnaire circularized to all air carriers possessing commercial authority from Transport Canada, hence the source of the confusion. Question #5 of the Questionnaire asks:
Are all or some of your flights subject to screening (incl. screening of passengers, property, and personal belongings/baggage) that is carried out – in Canada under the Aeronautics Act or in another country – before boarding? (Y/N)?: _________
We have pointed out to Transport Canada the lack of completion in the above question, which we believe was intended to mirror the language of Section 2 of the SATR. This discrepancy is particularly consequential for business aircraft carriers who conduct screening on an internal basis, and are therefore uncertain on whether they fall under the PPP program. Based on the language of the SATR, it is our opinion that business aircraft operators who have their passengers and baggage subject to internal screening only, need not comply with the PPP.