RAAP and Air Liaison: did the CAQ program have adequate controls?

Yes. The *Programme d'accès aérien aux régions* (PAAR), referred to here as the Regional Air Access Program (RAAP), was created by the Coalition Avenir Québec government. It was announced in 2022 by François Bonnardel, then transport minister in François Legault's government, and substantially expanded in 2025 under Geneviève Guilbault. Its purpose—making regional flights more affordable—addresses a genuine need, especially in isolated communities where air travel provides access to health care, education and major urban centres. However, a [Radio-Canada investigation](https://ici.radio-canada.ca/info/long-format/2286533/air-liaison-aviation-reglements-police-otc), broadcast on September 24, 2026, highlights a major weakness: the program relied heavily on a declaration made when a ticket was purchased. According to the public broadcaster, thousands of potentially false declarations may have escaped the attention of the Ministère des Transports et de la Mobilité durable (MTMD), representing more than $1 million. The best-documented case involves Air Liaison. Subsidized tickets were allegedly used to move employees for work even though the rules specifically exclude business and work-related travel. The political question is therefore not only who may have used the program improperly. It is also whether the government that created, expanded and funded it put controls in place that matched the amount of public money at risk. ## A CAQ program created in 2022 The Québec government officially launched the RAAP on June 1, 2022, following the unveiling of its regional air transportation plan. In a [May 31, 2022 news release](https://www.quebec.ca/nouvelles/actualites/details/programme-dacces-aerien-aux-regions-des-billets-davion-abordables-et-accessibles-des-demain-40862), Minister François Bonnardel announced two components: partial fare reimbursement for residents of remote regions and tickets capped at $500 round-trip on selected routes. The government budgeted $38 million for 2022–23 and $48 million for 2023–24. The program was intended to support residents, tourism and regional carriers during the post-pandemic recovery. It was not simply an old program inherited unchanged from a previous government. Some fare-reduction measures already existed, but the RAAP—with its own structure and subsidized-ticket offer—was launched under the CAQ. In December 2024, Geneviève Guilbault announced a new version that took effect on February 3, 2025. The changes expanded eligible routes, replaced the $500 cap with discounts ranging from 50% to 85%, and simplified purchases by having carriers apply the discount directly. The [announced budget](https://www.quebec.ca/nouvelles/actualites/details/voyager-en-avion-au-meilleur-prix-partout-au-quebec-60128) was $55 million in each of 2025–26 and 2026–27. That simplification made the program more accessible. It also made effective verification mechanisms more important. ## What the rules clearly prohibited The government's [RAAP terms](https://cdn-contenu.quebec.ca/cdn-contenu/adm/min/transports/transports/aide_financiere/aerien-maritime-ferroviaire/acces-aerien-regions/PAAR-modalites-2025-2027.pdf) are explicit: a ticket purchased or reimbursed by a business is ineligible, apart from limited exceptions that include non-profit organizations. Business travel and trips made in the course of employment are also excluded. When purchasing a ticket, passengers had to declare that their trip was not work-related and that an employer would not reimburse the fare. They also consented to the disclosure of their information to the ministry for verification. Carriers had to collect that declaration, submit monthly passenger and itinerary lists, retain supporting records and provide any documents requested. The ministry reserved the right to inspect carrier records, recover overpayments and terminate an agreement. Control powers therefore existed on paper. The issue raised by the investigation is how effectively they were used and how long it took to identify anomalies. ## Air Liaison: 867 declarations at the centre of the dispute The August 3, 2026 judgment in *Air Liaison inc. c. Procureur général du Québec* provides part of the timeline. According to facts set out by the [Québec Superior Court](https://coursuperieureduquebec.ca/fileadmin/cour-superieure/Jugements_diffuses_sur_X/2026-08-03_Air_Liaison_inc._c._Procureur_general_du_Quebec.pdf), Air Liaison informed the ministry on April 24, 2026 that an employee had signed RAAP declarations in pilots' names. The company later submitted a table listing 867 declarations associated with professional travel. The ministry had paid approximately $233,170 in assistance relating to those tickets. Radio-Canada reports that an internal instruction dated December 27, 2024 directed staff to apply the RAAP fare to tickets for pilots travelling for work. Air Liaison says the practice was introduced by a former director and that senior management only learned of it in the spring of 2026. The judgment states that Air Liaison's president delivered a cheque for slightly more than $216,000 to the ministry on July 4. Radio-Canada says the amounts related to the irregularities were ultimately recovered with the company's cooperation. Those facts alone do not establish criminal liability on the part of any individual or the company. They do, however, document the use of subsidized tickets for professional travel that the program rules rendered ineligible. ## A problem that may extend beyond Air Liaison Radio-Canada says the problem was not limited to one carrier. The outlet's public materials do not all provide the same total: its press centre refers to potentially 2,700 false declarations, while the description of its YouTube report says 2,800. The cautious formulation is therefore approximately 2,700 to 2,800 potentially false declarations, representing more than $1 million. That discrepancy should be disclosed, but it does not alter the central issue. If confirmed, the number of anomalies was large enough to raise questions about the ministry's capacity to identify patterns that were inconsistent with program rules. The ministry says it began conducting checks in late summer 2025 after noticing irregularities in the number of tickets purchased by certain individuals. It also says it strengthened its controls and took action regarding the people concerned. An important question remains: why did a program that received passengers' names, itineraries and ticket counts every month not flag repeated or apparently work-related purchases sooner? The public documents reviewed do not reveal which automated tests were in place, how many cases were manually audited or how frequently carriers underwent on-site inspection. ## A "closed" budget envelope that was exceeded The RAAP terms describe its funding as a closed envelope and state that assistance cannot exceed the program's allocation. Radio-Canada nevertheless reports that 2025–26 program spending exceeded the announced $55-million amount by 33%. That does not mean one third of the spending was improper. Higher demand, the expansion of eligible travel or budget adjustments could also explain the increase. Two issues must be kept separate: potentially false declarations valued at more than $1 million, and the program's overall cost increase. Their coexistence nevertheless strengthens the case for transparency. The government should disclose the amount actually paid, the authorization used to exceed the announced envelope, the number of subsidized tickets and the portion recovered after verification. ## Why was Air Liaison allowed back into the program? On July 2, 2026, Minister Benoit Charette [terminated Air Liaison's agreement](https://www.quebec.ca/nouvelles/actualites/details/programme-dacces-aerien-aux-regions-air-liaison-exclue-a-la-suite-de-fausses-declarations-71548). The ministry said program conditions had been breached, sought repayment of excess assistance and provided its information to Québec's anti-corruption unit. One month later, the Superior Court suspended the exclusion pending a final judgment. That decision was not a finding that Air Liaison was blameless on the merits. Rather, the judge found that immediate exclusion would cause serious harm to the company and to communities that depend on its flights. At that preliminary stage, the measure also appeared disproportionate, particularly because Air Liaison had reported the declarations, cooperated with the review and reimbursed the requested amounts. The Court temporarily reinstated the company while requiring strict compliance with the agreement. The principal dispute therefore remained unresolved. This distinction matters. The interim court order did not erase the 867 documented declarations, but it recognized that air access on the Lower North Shore is an essential service and that sanctions must account for their effect on residents. ## Where does political responsibility lie? Conduct attributed to a carrier's employees or managers cannot automatically be attributed to the CAQ. None of the sources reviewed shows that the government requested, authorized or knowingly tolerated false declarations. Political responsibility lies elsewhere. The CAQ created the RAAP, made it more generous, simplified access and increased its budget. The ministry had verification powers, received monthly data and knew that a false declaration could unlock a subsidy covering up to 85% of a ticket. It therefore had a duty to design a system capable of promptly detecting foreseeable abuse. At this stage, the facts support a more precise conclusion than an allegation of complicity: oversight did not match the risk. That administrative failure belongs to the government even if the declarations themselves were produced elsewhere. ## What Québec should disclose Before renewing or extending the RAAP beyond March 31, 2027, the government must provide the Treasury Board Secretariat with a program review. For voters to assess the program's management, that review should be published in full and answer at least the following questions: - How many ineligible declarations were confirmed, broken down by carrier? - What total amount was paid, claimed back and recovered? - When were the first warning signs detected? - What controls existed before summer 2025, and what has been added since? - Why was the $55-million envelope reportedly exceeded by 33%? - How many travellers and communities depend on the program, and what alternatives would prevent a sanction from cutting off an essential service? The RAAP addresses a real problem. For many residents of remote regions, flying is not a luxury. That necessity does not lessen the obligation to protect public funds; it makes that obligation even more important. The program is indeed a CAQ initiative. The alleged irregularities do not prove government complicity. They do, however, show that the oversight model chosen by its ministry allowed too many declarations to pass before action was taken. Political accountability should be assessed on that design, that oversight and the transparency of the response.