Exhibit 31


                                 Certification
           Pursuant to Section 302 of the Sarbanes-Oxley Act of 2002

I, Robert A. Milton, certify that:

1.       I have reviewed this annual report on Form 40-F of Air Canada;

2.       Based on my knowledge, this annual report does not contain any untrue
         statement of a material fact or omit to state a material fact
         necessary to make the statements made, in light of the circumstances
         under which such statements were made, not misleading with respect to
         the period covered by this annual report;

3.       Based on my knowledge, the financial statements, and other financial
         information included in this annual report, fairly present in all
         material respects the financial condition, results of operations and
         cash flows of the registrant as of, and for, the periods presented in
         this annual report;

4.       The registrant's other certifying officer and I are responsible for
         establishing and maintaining disclosure controls and procedures (as
         defined in Exchange Act Rules 13a-15(e) and 15d-15(e) for the
         registrant and have:

         a.       Designed such disclosure controls and procedures, or caused
                  such disclosure controls and procedures to be designed under
                  our supervision, to ensure that material information
                  relating to the registrant, including its consolidated
                  subsidiaries, is made known to us by others within those
                  entities, particularly during the period in which this
                  annual report is being prepared;

         b.       Evaluated the effectiveness of the registrant's disclosure
                  controls and procedures and presented in this report our
                  conclusions about the effectiveness of the disclosure
                  controls and procedures, as of the end of the period covered
                  by this report based on such evaluation; and

         c.       Disclosed in this report any change in the Registrant's
                  internal control over financial reporting that occurred
                  during the period covered by the annual report that has
                  materially affected, or is reasonably likely to materially
                  affect, the Registrant's internal control over financial
                  reporting; and

5.       The registrant's other certifying officers and I have disclosed,
         based on our most recent evaluation of internal control over
         financial reporting, to the registrant's auditors and the audit
         committee of registrant's board of directors (or persons performing
         the equivalent function):

         a.       All significant deficiencies and material weaknesses in the
                  design or operation of internal control over financial
                  reporting which are reasonably likely to adversely affect
                  the issuer's ability to record, process, summarize and
                  report financial information; and

         b.       Any fraud, whether or not material, that involves management
                  or other employees who have a significant role in the
                  issuer's internal control over financial reporting.


Date:  May 19, 2004                            /s/ Robert A. Milton
                                               ---------------------------
                                               By:    Robert A. Milton
                                               Title: President and Chief
                                                      Executive Officer



<PAGE>



I, M. R. Peterson, certify that:

1.       I have reviewed this annual report on Form 40-F of Air Canada;

2.       Based on my knowledge, this annual report does not contain any untrue
         statement of a material fact or omit to state a material fact
         necessary to make the statements made, in light of the circumstances
         under which such statements were made, not misleading with respect to
         the period covered by this annual report;

3.       Based on my knowledge, the financial statements, and other financial
         information included in this annual report, fairly present in all
         material respects the financial condition, results of operations and
         cash flows of the registrant as of, and for, the periods presented in
         this annual report;

4.       The registrant's other certifying officer and I are responsible for
         establishing and maintaining disclosure controls and procedures (as
         defined in Exchange Act Rules 13a-15(e) and 15d-15(e) for the
         registrant and have:

         a.       Designed such disclosure controls and procedures, or caused
                  such disclosure controls and procedures to be designed under
                  our supervision, to ensure that material information
                  relating to the registrant, including its consolidated
                  subsidiaries, is made known to us by others within those
                  entities, particularly during the period in which this
                  annual report is being prepared;

         b.       Evaluated the effectiveness of the registrant's disclosure
                  controls and procedures and presented in this report our
                  conclusions about the effectiveness of the disclosure
                  controls and procedures, as of the end of the period covered
                  by this report based on such evaluation; and

         c.       Disclosed in this report any change in the Registrant's
                  internal control over financial reporting that occurred
                  during the period covered by the annual report that has
                  materially affected, or is reasonably likely to materially
                  affect, the Registrant's internal control over financial
                  reporting; and

5.       The registrant's other certifying officers and I have disclosed,
         based on our most recent evaluation of internal control over
         financial reporting, to the registrant's auditors and the audit
         committee of registrant's board of directors (or persons performing
         the equivalent function):

         a.       All significant deficiencies and material weaknesses in the
                  design or operation of internal control over financial
                  reporting which are reasonably likely to adversely affect
                  the issuer's ability to record, process, summarize and
                  report financial information; and

         b.       Any fraud, whether or not material, that involves management
                  or other employees who have a significant role in the
                  issuer's internal control over financial reporting.


Date:  May 19, 2004                       /s/ M.R. Peterson
                                          --------------------------
                                          By:    M. R. Peterson
                                          Title: Executive Vice President
                                                 and Chief Financial Officer