From "VFR Only" to "IFR" in amateur built Canada?

I am in the process of getting the "VFR Only" amended to IFR with TC. Trying to sort through the CAR's to find and interpret the requirements is not an easy thing.

I wonder if anyone out there in Canadian Amateur Built land has been through this process recently with success and would share your experience with me. Any help and advise would be appreciated.

invisible post?

HI Ivan,
nobody but you & me seem to ever look in the 'canada' section!

don't be shy...post in the General forum; the moderators will move it sooner or later, but at least the 1500 canucks on the forum will get a chance to see it!

If I were of a different age and funding level, I'd sure be thiniking IFR ticket.
most times when I want to fly somewhere, I don't, because I don't know if I can get home!....you may have a similar motiviation?

good luck! ...especially with finding the TC regs!

Ifr

Hi
Your neighbour in moncton
I have put my rv-7a ifr in 2008. I will send the paper to transport canada next week for my rv-10.
I will send you the document from tc and the one of my rv7 and 10 when i will be home sunday. You can type the word "b032" in the serch of the TC web site and it will give you the main document.
I will try to call you when i will be home. I am at mon-tremblant airport now with the rb-10 for a meeting.
Good luck

Lan vinh do

I could not get mine certified for IFR as they said my right Efis was to far away from pilots view. So my next project is to place a 3rd Efis screen to slave off the right Efis so it is closer to the pilot.

Our requirements seem to be much more stringent. From what I learned so far is if you have the screens in the right place and no round instruments you need dual AHRS, Dual Nav and Dual radios. A 430W and SL40 does not cut it. If you have one AHRS you will need back up round instruments. Making the Dual AHRS a no brainer. So I have everything right but a mislocated Efis. I at least have night and VFR OTT on the paper work for now.

I am curious as to what the cost is to maintain the aircraft. A certified shop does that Static, xpondr and such every two years IFR or not, but what else do we have to beyond that. Do we have to take someone up to prove everything is working as it should. Is it just up to the owner as I believe it is that way in the US?

Reg and procedure

Here is the link to the regulations for the aircraft equipment requirements

http://www.tc.gc.ca/eng/civilaviation/regserv/cars/part6-605-2438.htm#605_18

and here is the link to the notice telling you what you need to do to get the "VFR only" restiction lifted.

http://www.tc.gc.ca/eng/civilaviation/standards/maintenance-aarpc-ans-b032-547.htm

For any questions or interpretations I would recommend contacting the TC Headquaters Ottawa contact for Amateur-Built Airworthiness issues:

Maurice Simoneau, Senior Inspector, Recreational Aircraft
Ph (613) 990-9490

Hope this helps

TroyBranch said:

I could not get mine certified for IFR as they said my right Efis was to far away from pilots view. So my next project is to place a 3rd Efis screen to slave off the right Efis so it is closer to the pilot.

Click to expand...

I'm not aware of any CAR requirement that deals with EFIS location in amateur-built aircraft in Canada. The requirements only require appropriate equipment fit, with nothing about location. The defined process to have the VFR restriction removed does not require you to supply any information on the instrument panel layout or photos, nor does it involve an inspection by Transport Canada.

It might be worthwhile to ask your TC inspector for the regulatory basis of his finding that your EFIS was too far away from the pilot's field of view. If he quotes any FAR 23 (or AWM 523) regs or guidance material you can point out that these are applicable to type-certificated aircraft only. If he persists in his refusal to remove the VFR restriction, you might ask for him to discuss this with the amateur-built policy folks in Ottawa.

It seems that interpretation of the regs is a regional issue in Canada just as much as in the US.

Another issue that seems to be inconsistently enforced is the requirement for a wet compass for VFR flight. The regs require that you have one that is "independent of the aircraft electrical system". A Dynon with a backup battery *is* independent of the *aircraft* electrical system, and yet MD-RA has been told that they may not approve an aircraft without a wet compass. Many people have bought stick-on compasses from Canadian Tire, and removed them after their final inspection.

'wet' compass? whaaaaaaa?

Hey Rob, I agree the regs can be inscrutable?not to hijack this VFR issue, ....but the falcon vertical card compass I just bought to put in my panel is to replace my fluid damped compass.(otherwise known as 'the mixmaster')
Neither require power, so they should be interchangeable, right?
what about an old vacuum driven gyro?

I said "wet compass" but should have said "standalone compass". Regardless, MD-RA has decided that an EFIS does not qualify even though it can meet the regulatory requirement.

Check 6

Like Kevin says in post #6. Posts 5 and 6 cover the topic quite well.

IFR Gauge locations & compass

Troy's comments on gauge/efis positioning came from his discussions with a Transport Canada inspector in Calgary, as mentioned by others, maybe a regional or interpretational issue. Maybe us folks out west should be more bold & challenge the local knowledge & get a ruling from Ottawa.

Conversely, a builder friend in Edmonton did challenge the compass requirement and received a reply from Ottawa that wording of the rules required the compass... in this case MD-RA's advice is per TC...read for yourself, (builder name has been removed)...
--------------------------------------------------------------------------------
From: [email protected]
To:------------------
CC: [email protected]; [email protected]
Date: Tue, 22 Mar 2011 13:58:31 -0400
Subject: CAIRS# GV-3554


Dear Mr. ------------------

As you are aware, the recent concerns you expressed in your submission of February 9, 2011 in connection with the requirement for a stand-alone liquid-filled compass, were entered into the Civil Aviation Issues Reporting System (CAIRS) and were assigned file number GV-3554. As a result of my review of the above referenced file I would like to take this opportunity to provide you with the following information.

Paragraph 605.14 (d) of the Canadian Aviation Regulations (CARs) states that ?no person shall conduct a take-off in a power-driven aircraft for the purpose of day Visual Flight Rules (VFR) flight unless it is equipped with a magnetic compass or a magnetic direction indicator that operates independently of the aircraft electrical generating system?.

2. It is our understanding that the Electronic Flight Information System (EFIS) installed in your aircraft is connected to the aircraft electrical generating system, and that it comprises a back-up battery that will supply electrical power to the EFIS in case of a failure of the aircraft electrical generating system.

3. It is our understanding that the EFIS installed in your aircraft has to be turned ON for the remote compass module to become ?alive? and indicate magnetic direction.

4. Therefore, we can state that the remote compass module installed in your aircraft is not independent of the aircraft electrical generating system. If it was indeed independent of the aircraft electrical generating system, there would be no need to turn the EFIS ?ON? in order to get a compass reading.

5. Hence, the reason why, during the course of the final inspection of an amateur-built aircraft construction project, Minister?s Delegates ? Recreational Aviation (MD-RAs) have been instructed to verify that a stand-alone liquid-filled magnetic compass is installed in the aircraft. If none is installed, the MD-RAs have to enter a discrepancy (snag) on the inspection report.

6. A stand-alone liquid-filled magnetic compass is still the easiest way to comply with the requirements of CAR 605.14(d).

I would like to take this opportunity to thank you for sharing your views, as all comments we receive are appreciated.

Should you have any further questions, please feel free to contact Maurice A. Simoneau at 613-990-9490 or via e-mail at [email protected].

Sincerely,

Jacqueline Booth
A/Director Standards

Ralph, thanks for that letter.

Unfortunately, point (4) in the letter is a complete twisting of the facts. The system *is* independent of the aircraft electrical generating system, in that it can operate just as easily when completely removed from the aircraft, with no external power source. Yes, it does need to be turned "on," but that can and does happen independently of the aircraft. I suspect that Ms. Booth doesn't fully understand how independently the Dynon operates when running on the backup battery.

The further side effect of this outdated regulation is that some builders are completing their aircraft with stick-on liquid-filled compasses from Canadian Tire, just to ensure they pass the MD-RA checklist. Once MD-RA signs off, the stick-on gets removed.

F1R said:

Like Kevin says in post #6. Posts 5 and 6 cover the topic quite well.

Click to expand...

I seem to recall an issue with annunicator panels/display heads.... I think it may be in the GNS430 Install guide. If the 430 is installed a certain distance away from line of sight, then the annunciator panel and or display head must be installed tp correct this. Could this be the issue if you are using an EFIS as an HSI/annunciator?

V

compass

I agree the ruling doesn't meet changing technology. Hope not too many builders expose themselves to potential future ramp check violations.

TroyBranch said:

I could not get mine certified for IFR as they said my right Efis was to far away from pilots view. So my next project is to place a 3rd Efis screen to slave off the right Efis so it is closer to the pilot.

Our requirements seem to be much more stringent. From what I learned so far is if you have the screens in the right place and no round instruments you need dual AHRS, Dual Nav and Dual radios. A 430W and SL40 does not cut it. If you have one AHRS you will need back up round instruments. Making the Dual AHRS a no brainer. So I have everything right but a mislocated Efis. I at least have night and VFR OTT on the paper work for now.

I am curious as to what the cost is to maintain the aircraft. A certified shop does that Static, xpondr and such every two years IFR or not, but what else do we have to beyond that. Do we have to take someone up to prove everything is working as it should. Is it just up to the owner as I believe it is that way in the US?

Click to expand...

Hi, sorry to revive an old thread but in reviewing 605.14 to 605.18 I see no requirement for Dual comm radios and the requirement for dual Nav could be 2 gps, one gps and one VOR/ILS, etc. Is that correct?

Hi,

This is from memory but should be pretty close.

I don't have the e-mail from my IFR a few years ago, but the requirement is that you have to be able to fly an approach in the areas you normally fly after the failure of a single indicator (which has to be on the primary field of view - hence the screen issues) or radio.

I believe the "places you normally fly" was used to ensure one was an ADF up north. I didn't run into that in southwest Ontario.

I doubt you could make a convincing enough case for for transport Canada with dual gps due to the interdependence on having good satellites, but I don't speak for transport.

The rest will depend on your ability to present a story.

Derek

Look at it from a practical standpoint. As Derek pointed out, there are times when GPS goes Pffft, either by NOTAM'd outage or not. Dual GPS with no alternate means of carrying out an approach doesn't seem very wise, irrespective of whatever minimum equipment Transport Canada requires. Likewise for having only a single VOR/ILS and an ADF when you fly in an area where there aren't any ADF approaches available - you lose the NAV and you're in duck soup.

Take a look at where you intend to fly and what approaches are available, and equip your aircraft so that if one system fails you have a second means of executing an approach. This puts you in a safe position. Then look at the regs to see what else you might have to install in order to meet the letter of the law - that will put you in a position that is both safe and airworthy for IFR ops.

In converting our panel from VFR to IFR I opted to install a GNS480 to compliment the pre-existing SL30. I ditched the steam gauges that surrounded the single EFIS and installed a second EFIS with its own AHARS and its own backup power source. Redundant nav display is accomplished by having both the SL30 and GNS480 within the prescribed field of view (the 480 installation manual has an excellent graphic representation of the acceptable field of view). We have a whiskey compass, just in case. And two stand-alone battery-powered VFR GPS receivers plus a quick access port which allows us to connect a hand-held VHF comm to the aircraft antenna.

A lot of stuff has to go wrong before we can't find our way out of the clouds. This meets TC's requirements and my own requirements. My requirements for redundancy are considerably higher than those of TC. Ask yourself one question and answer it honestly. When the dirty stuff hits the fan and you're up in the clouds, do you want to be equipped to a minimum level determined by a bureaucrat?

To each man his mission.

Take a look to the alternate airport requirement

I don't have the cap gen with me but with 2 gps you can't file an alternate unless it's vfr.
You can't take into account the gps approach to file the alternate ( but if you need to go to the alternate, you can do the gps approach).
Unless it changed since a last tool a look at it.

Alternate

You would be limited


Pilots may take credit for a GNSS (GPS or WAAS) approach at an alternate aerodrome, provided that:
(a) An approach completely independent of GNSS at the planned destination is expected to be available at the ETA.
(b) The published LNAV minima are the lowest landing limits for which credit may be taken when determining alternate aerodrome weather minima requirements. No credit may be taken for LNAV/VNAV or LPV minima;
(c) The pilot-in-command verifies that LNAV approach-level RAIM or WAAS integrity is expected to be available at the planned alternate ETA, taking into account predicted satellite outages; and
(d) For GPS TSO C129/C129a avionics, periodically during the flight, and at least once before the mid-point of the flight to the destination, the pilot-in-command verifies that approach-level RAIM is expected to be available at the planned alternate ETA.
Otherwise, when determining alternate aerodrome weather minima requirements, the pilot shall only take credit for functioning traditional aids at that aerodrome. In this case, if the alternate aerodrome has GNSS approaches only, the pilot shall use the alternate weather minima requirements for "No IFR approach available". Additional guidance on flight planning of GNSS- based approaches at alternate aerodromes is contained in the TC AIM COM 3.16.12.

I was just pointing out that TC does not make this mandatory to get an a/c IFR certified, not that it is a good idea.

Fully agree that redundancy and appropriate equipment for the type of flight is the right way to go. I will have GPS of course but also a NAV receiver for both backup to the GPS and for ILS capability.