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MD-RA requires avionics shop to test pitot?

terry.mortimore

Well Known Member
Hi gang:

I was just reading the March issue of COPA magazine which had an article about MD-RA.

In the article there is a paragraph that states that it is necessary to have a "Certified avionics shop" test the pitot static pressure system as well as any instruments or avionics associated with that such as the Altimeter, Transponder, Encoder, etc.

To my knowledge there is no Certified Avionics shop here in the Sault and I would guess the closest one would be in Southern Ontario.

I'm wondering how I will manage this, some sort of ferry permit once the airplane is flying?

Any first hand experience out there?

Terry.
 
I believe this is just for the purpose of certifying the transponder/encoder, and validate the same against the altimeter. A transponder is not required equipment except to enter certain airspace. Therefore you are legal to fly anywhere a transponder is not required. What I did was fly to an avionics shop located at an airport whose airspace did not require a transponder. I did this after the test hours were flown off - my test area did not include any "transponder required" airspace.
 
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I just had my fuselage inspected and my MR-RA inspector said that they just had an MR-RA refresher coarse and that changes were coming to the MD-RA program. One was what was mentioned in the OP. He did not say they were in effect now as stated in COPA. HE also did not know how we could comply other than have a shop come to the build site. A lot of people do not know what rural means and think planes are only built in large cities that have avionic shops just down the block (what's a block).
 
MD-RA requires avionics shop to test pitot

Thanks for the replies.

My original plan was to test the Pitot system using the following.

http://www.iflyez.com/manometer.shtml

I'm sure this would have calibrated my airspeed indicator accurately enough to allow the initial flights. Once the 40 hours are flown off I can fly to a avionics shop to have the encoder and transponder checked.

I hope MD-RA is not going to paint us into a corner here.


Terry.
 
He also advised that Transport Canada wants very little to do with us (my interpretation of our discussion)and is tasking MD-RA with more duties. It will soon be MD-RA issuing the final C of A after the time is flown off.
In the past the builder could increase the gross weight as long as the wing loading was within Transport Canada's limits from now on we will need the blessing of the kit manufacturer. I'm sure the kit manufacturers will be happy with this.
 
This is a common service in the certified world ... ask any Cessna owner near you who the use for their "24 month avionics check" (it has to be done every 2 years BTW).

As was mentioned, only required to operate in controlled airspace. Find a shop that isn't in such an airspace, and you should be golden. Some will travel to you, the equipment fits in the trunk of a car.

Lachute, near montreal, has a shop that will do it for you while you wait ... you can get there without ever entering any controlled airspace ... Long ways to go for you though!

Peterborough also has a shop (Toronto Avionics) ... another place you can get to without controlled airspace ... more reasonable distance ...

Sault college has an aviation program, maybe they could help?

Make sure you dig deep and find the right company to do business with, you'll need them every 2 years if you want to stay certified.
 
My original plan was to test the Pitot system using the following.

http://www.iflyez.com/manometer.shtml
You should do this anyway. It will be much more economical if you can go to the avionics shop knowing you have no leaks... You won't be paying for their time to chase them down.

How these tests are performed seems to vary from shop to shop. Some want to remove your airspeed and altimeter gauges to their bench for testing, some will test in the airplane. I don't know what they do when your AHARS is mounted in the tail of the airplane and your backup instruments are teed off and mounted in the panel.
 
The ASI is not part of the process for certification for controlled airspace. That only affects transponder, encoder, altimeter and pitot-static.

It certainly can be a good idea to check and calibrate your ASI mind you, but that's a separate issue.

There are schools of thought on the best way to check your altimeter calibration. If you're going to unplug your altimeter anyways, it's just a few more screws to pull it out. Some people test your altimeter in place, but use the tubing that's there ... which would be a not as clean solution, since leaks in the system could skew the results. For best results, pull it out ... once again though, the "bench test" can be fully portable.

Even though there are several avionics shop in the neighborhood around me, I still struggled to find them. Many don't have websites, and you have to ask around.

Another source of info would be a nearby AME that does annuals on certified aircraft (i.e. your average Cessna/Piper type AME). He likely refers his clients to *someone* for this work ...
 
MD-RA requires avionics shop to test pitot

I believe I'll need to find a shop that will do the test in the airplane. I have a dynon D-100 with 2 1/4" backup altimeter and airspeed indicator.

My concern remains, the way I read the article it sounded like MD-RA wanted the test results before they would issue the airworthiness certificate (insert proper term). If that's the case, not sure how I'll be able to get it done.

I tried to re-read the article today, but my wife did too good a job cleaning up today.

There is local talent here that could do the test, but because it's being done out the back door they will not issue me a certificate to show the inspector.

I won't need this till the fall, time for a email to ask.

Terry.
 
The avionics certification is NOT an airworthiness issue and should not be a condition for you receiving your C Of A. Fight it if they try to tell you otherwise! It is quite clear in the CARs ... This is true for certified A/C as well BTW.

Let us know if you find the article ... Maybe it's on their web site?
 
Found the article ... You're right, it says that the MD-RA will want the avionics inspection done. Either the article is wrong, or the article is right and the MD-RA guys are wrong.

For what it's worth, the list of inspection documents on the MD-RA web site make no mention of this ...
 
I'm not sure my guy said that the pitot/static test before first flight was in effect now, but it is coming down the road soon. As for not being listed as to what the inspector will look for , this is very new to them as well.
 
Pitot/static I can maybe see as this relates to basic speed and altitude .. but the encoder/transponder part, and the altimeter correlation check, you should not need.
 
Well I re-read the CARs, and I'm not seeing it. There is a requirement, but only as it applies to aircraft that enter certain airspace ... can't find it anywhere in the basic airworthiness sections:

13. Altimetry Devices
(amended 2007/12/30; previous version)

(a) Altimeters and other Altimetry devices installed in aircraft operating under Instrument Flight Rules, or under visual flight rules in Class B and C Airspace or Class C and D Airspace that is designated as "Transponder Airspace" shall be calibrated at intervals not exceeding 24 months, to the parameters and tolerances outlined in Appendix B of Standard 571, or to equivalent standards acceptable to the Minister.
(amended 2007/12/30; previous version)

(b) For the purpose of this section, the term "altimetry devices" includes any air data computer, or other barometric device, providing a flight crew station, or an auto pilot, or automatic pressure altitude reporting system, or altitude alerting system with altitude data derived from static pressure.

(amended 2007/12/30; previous version)

14. Air Traffic Control (ATC) Transponders

ATC Transponders, including any associated altitude sensing reporting mechanisms, where installed, shall be tested every 24 months, in accordance with Appendix F of Chapter 571 of the Airworthiness Manual.
(amended 2000/12/01; previous version)

All he airworthiness section says is that you must have an airspeed indicator and an altimeter, and that hey must "serviceable and functioning".

I see there's a Class D CZ around the Sault airport ... is it Transponder airspace?
 
MD-RA requires avionics shop to test pitot.

Not sure of the Sault's classification, but I know how to find out. The COPA flight meeting tomorrow night has the Tower Manager as the guest speaker. I'll find out his thoughts on the subject.


Terry.
 
If you check on the MD-RA website and click on the tab for " Complete Construction Procedure" then scroll down to the Final Inspection 6.6 (3) it says that in addition to the transponder requirements there is Altimeter testing required which shows a change as of Jan 11 2015. The link to the CAR says this:

b) For an altimeter:

(1) Test by an approved maintenance organisation in accordance with the following............

That could really be a problem for someone building in the boonies....
 
MD-RA requires avionics shop to test pitot.

During the Tower managers talk last night the subject of Transponders came up, they are not required to enter the Class D control zone at the Sault.

I'm going to send an email to MD-RA and see if I can get a firm answer.


Terry.
 
For those of us who are using experimental EFIS equipment as our primary source of altimetry, this is a large and unacceptable shift in onus. The term "Approved Maintenance Organisation" is very specific in its scope. What this means for us is that a brand new, factory-calibrated EFIS will no longer be acceptable for altimetry because none of the EFIS manufacturers possess a Canadian AMO approval.

Now picture the fun and games we are going to have when we try to send our experimental EFIS into an AMO which, heretofore, has only seen TSO'd steam gauges. We're going to have to provide all the necessary external wiring harnesses etc so the whole EFIS system and ADAHARS can function as a system.

The net effect is that we are going to be required to pay the rather large $$$ required to bring an AMO up to speed to test our equipment on their bench, or pay the even larger $$$ required to bring an AMO's mobile testing equipment to our aircraft. For those of us in rural areas, get set for some sticker shock.

Sounds like it's time for EAA Canada to get involved in this conversation.
 
As far as getting the pitot and static system tested by an approved shop has not changed. Way back in 2006 I had my Dynon system tested in my new SuperCub and I had our RV-10 done in 2012 with a dual Skyview no problem.
The only change I see is having to pay for six hrs travel time and 600 km milage fees, rather than a fun 3/4 hr flight (times two).
 
For those of us who are using experimental EFIS equipment as our primary source of altimetry, this is a large and unacceptable shift in onus. The term "Approved Maintenance Organisation" is very specific in its scope. What this means for us is that a brand new, factory-calibrated EFIS will no longer be acceptable for altimetry because none of the EFIS manufacturers possess a Canadian AMO approval.

Now picture the fun and games we are going to have when we try to send our experimental EFIS into an AMO which, heretofore, has only seen TSO'd steam gauges. We're going to have to provide all the necessary external wiring harnesses etc so the whole EFIS system and ADAHARS can function as a system.

The net effect is that we are going to be required to pay the rather large $$$ required to bring an AMO up to speed to test our equipment on their bench, or pay the even larger $$$ required to bring an AMO's mobile testing equipment to our aircraft. For those of us in rural areas, get set for some sticker shock.

Sounds like it's time for EAA Canada to get involved in this conversation.

Look on the left side of the page at the advertisers list, tailwind aviation services has portable equipment to do all your 24 month testing including all non certified efis's. He is also a dealer for dynon and does first class panel/avionics work. we use him all the time for 24 month tests, highly recomend him. Based out of CYTB, Tillsonberg Ontario.
 
Experimental AHRS Problem

For those of us who are using experimental EFIS equipment as our primary source of altimetry, this is a large and unacceptable shift in onus. The term "Approved Maintenance Organisation" is very specific in its scope. What this means for us is that a brand new, factory-calibrated EFIS will no longer be acceptable for altimetry because none of the EFIS manufacturers possess a Canadian AMO approval. QUOTE]

Unfortunately, Canadian_JOY's concern is exactly what I am now experiencing. I'm preparing for the MD-RA final inspection of my RV-8, and spoke with our local avionics shop regarding the required transponder & altimeter check.

They were very clear that an experimental EFIS (mine is a dual GRT system) would NOT be acceptable as a source of altitude data to the transponder, UNLESS its encoder had a TSO. They pointed to CAR 551.103 as the basis for requiring TSO compliance on both the transponder and the encoder.

Needless to say, this is a needless pain. If true, I'll need to purchase and rewire for a separate TSO encoder, even though the GRT AHRS is probably a superior unit.

Anybody else have a similar experience in Canada?
 
"They pointed to CAR 551.103 as the basis for requiring TSO compliance on both the transponder and the encoder."

Darn, looks like he may be right on that part. If you track down that CAR, you'll end up discovering that the applicability (605.01) does NOT exclude home-builts.

Also worth noting that the regular 24-month checks for transponders are not contingent on using any particular airspace. If you have a transponder, it needs to be certified. And apparently, you need a TSO blind encoder to feed it.

The altimeter/pitot-static stuff is still only required if you operate in certain airspace. Also TSO does not appear to be required ... you can get your experimental EFIS "certified" to meet those requirements.

Regarding the MD-RA document quoted previously, it specifically says that:

3. Perform Altimeter System Test and Inspection as per CAR 571. Appendix B Applicability: All aircraft (20150111) (Y)
4. Perform ATC Transponder Performance Tests as per CAR 571. Appendix F (20150111) (Y)

This seems incorrect. Item 3 is not, or should not, be applicable to all aircraft. ONLY to aircraft that operate in transponder airspace (See my previously quoted CAR sections). Note that the change is quite recent.

There bay be a CAR somewhere else specifying this requirement for home-builts ... but it would be odd to ask a home-built aircraft to meet a higher threshold of safety than certified aircraft ... If there is, make sure it gets quoted to you.

MD-RA is NOT a regulatory body. They do NOT get to create regulation where none exists. They are only required to apply the CARs as they exist at the time they inspect.
 
Avionics shops in Calgary don't care that we are using 'experimental' equipment, they'll take our money just as readily as from certified folk. Their way of dealing with it is doing the testing but not signing the maintenance release. They are for the most part envious of the latest Homebuilt stuff & wish they could see the same accuracy in some of the certified stuff.
 
My local shop told me the same story but they are wrong. You need to meet the SAME STANDARD as a tso'd unit but nothing on a homebuilt has to be certified. For that matter it doesn't have to be a certified shop if you can show the standard is met. There are people making up rules off the top of their head it seems.

There was a good post on another forum by a TC inspector that explained this. We sign the maintenance release, not the avionics shop. I'll try to find that.

Also, For the initial cal of an alt that is not for use with a transponder the standard of accuracy is not the same.
 
Ok it was on THIS forum:

Further update: I did get an even more authoritative answer for this. Thanks to Allan Mahon at MD-RA, who sent me this clarification from Maurice Simoneau at Transport. Note that while the question was being asked specifically in reference to IFR flight, the question was the same... What TSO requirements are there for "certification" of components. I have included Maurice's reply below. The only edits were to clarify which is a quote from the CARs and which are his words, and I also added updated links to the relevant CARs... They were moved recently and his were deprecated.

In short: TSO approvals are not required for systems on amateur-built aircraft (flying VFR *or* IFR), and the Avionics shop's responsibility ends at conducting the tests and telling the owner/builder whether the systems meet the standards. It's up to the owner/builder at that point to document it and sign it off.



IFR operations by amateur-built aircraft in Canada are subject to the following rules:

1 - the aircraft has to be equipped in accordance with CAR 605.18 (http://www.tc.gc.ca/eng/civilaviation/regserv/cars/part6-605-2438.htm#605_18);
2 - the "operational" equipment has to comply with CAR 602.59(b) (http://www.tc.gc.ca/eng/civilaviation/regserv/cars/part6-602-2436.htm#602_59);

no person shall operate an aircraft unless the operational ... carried on board the aircraft ... is functional
-- "functional" means that the equipment performs its intended function

3 - the equipment does not need be approved in accordance with TSO standards and requirements;
4 - the equipment does not need to be certified -- no requirement for authorised release documents/certificates/tags, such as TCCA FORM 24-0078/FORM ONE, EASA FORM ONE, FAA 8130-3;
5 - the installation does not need to be approved by Transport Canada;
6 - the owner can do the installation and sign the maintenance release for the maintenance activities performed.

Having stated the above, I would invite your client to consult Airworthiness Notice - B032, Edition 2 - 18 April 1996 (http://www.tc.gc.ca/eng/civilaviation/standards/maintenance-aarpc-ans-b032-547.htm) - Procedure for the Removal of 'Visual Flight Rules Only' Limitation From the Special Certificate of Airworthiness (Amateur-Built Aircraft).

AN B032 was published at a time when the Air Regulations (Air Regs) and Air Navigation Orders (ANOs) were still in effect; the draft version of the Canadian Aviation Regulations [CARs] was the Canada Gazette Part I [Pre-publication] version that was later amended and published as the "new" CARs in October 1996. I have listed below the new regulatory references:

ANO Series V, No. 5 is now CAR 602.137
ANO Series V, No. 11 is now CAR 602.96 to 602.104, CAR 602.125
ANO Series V, No. 22 is now CAR 605.18
CAR 601.03 is still CAR 601.03
CAR 605.17 is now CAR 605.18
CAR 605.29 is now CAR 605.35
CAR 605.67 is now CAR 605.35

I have quoted below those parts of AN B032 that I consider most relevant to the discussion:

A statement of compliance signed by the owner shall be attached with the application to remove "VFR ONLY" from the standardized operating conditions. The statement shall indicate that the equipment required for IFR flight as specified in ANO Series V, No. 22 [see CAR 605.18], CAR 601.03, 605.17 [see CAR 605.18], 605.29 [see CAR 605.35] and 605.67 [see CAR 605.35] has been properly installed, tested and calibrated in accordance with Chapters 571 and 575 of the Airworthiness Manual [see Standard 571] or CAR 571, 605 and related standards, and that it functions properly.

The owner must be prepared to demonstrate that the installation, test and calibration of IFR equipment has been appropriately performed". The onus to demonstrate that functionality rests with the amateur-built aircraft owner. The owner has to be able to demonstrate that he/she has the necessary testing equipment to carry out the installation of the IFR equipment, that the testing equipment has been properly tested and calibrated, and that he/she is competent to operate such testing equipment.

although the installation of IFR equipment may be performed by the owner, due to the complexity and cost of test equipment, it may be more practical for this work to be performed by an appropriately rated aircraft Approved Maintenance Organisation (AMO)

Further to the above, I would also like to direct your client's attention to CAR 551 (http://www.tc.gc.ca/eng/civilaviation/regserv/cars/part5-version-521-551-2544.htm) - Aircraft Equipment and Airworthiness Manual Chapter [STD] 551 (http://www.tc.gc.ca/eng/civilaviation/regserv/cars/part5-standards-551s-1810.htm) - Aircraft Equipment and Installation.

(1) subject to subsection (2), the standards of airworthiness for the design and installation of aircraft equipment required by Part VI or Part VII are those specified in Chapter 551 of the Airworthiness Manual.
(2) If no standards of airworthiness are specified in Chapter 551 of the Airworthiness Manual for the design and installation of an item of aircraft equipment, the applicable standards of airworthiness are those that form the basis of certification of the aircraft on which the equipment is installed.

STD 551 specifies design and installation standards for the following equipment:

Flight Data Recorders
Cockpit Voice Recorders
Ground Proximity Warning Systems
Transponder and Automatic Pressure Altitude Reporting Equipment
Emergency Locator Transmitter
Altitude Alerting Systems
Radiocommunication Equipment
Radio Navigation Equipment

It is my understanding that those design and installation standards apply to all such aircraft equipment, irrespective of the aircraft where the equipment is installed.

... equipment installed or intended for installation in aircraft shall meet the applicable standards of:

(1) Chapter 537 of the Airworthiness Manual; or
(2) this chapter [STD 551], where the equipment was already approved for use on aircraft.

Information Note:

Where a TSO is referenced as an acceptable design standard, it is intended to mean that the design standards contained with the TSO are an acceptable minimum standard and the equipment does not necessarily need to have a TSO. i.e. an applicant could obtain Transport Canada Civil Aviation approval (Supplemental Type Certificate/Limited Supplemental Type Certificate) for a design if it is demonstrated that it complies with the design standards specified in the applicable TSO.

Please let me know if I have answered your questions fully.

Maurice A. Simoneau

Senior Civil Aviation Safety Inspector / Inspecteur principal de la s?curit? de l'Aviation civile
Recreational Aircraft / A?ronefs de loisir
Maintenance and Manufacturing Standards / Normes de maintenance et de construction
Standards Branch / Direction des normes
telephone/t?l?phone: 613-990-9490
facsimile/t?l?copieur: 613-952-3298
[email protected] <mailto:[email protected]>.
Transport Canada Civil Aviation, Place de Ville [AARTM], Ottawa Canada, K1A 0N8
Transports Canada Aviation civile, Place de Ville [AARTM] Ottawa Canada, K1A 0N8
<http://www.tc.gc.ca/>

Government of Canada / Gouvernement du Canada
 
2 1/4 ALT calibration

Additional to the original poster re: the 2 1/4 ALT, don't bother having avionics shop try bench calibrating this unit (& charging you for doing it!) their test is to match Alt readings thru out the gauges range, be it 0 -20,000ft or whatever. Problem is the small face, cluttered print and single sweep to max alt make it impossible for the tech to confirm indicated is within 35ft of their test reading. Also consider running the 2 1/4 ALT on cabin static if MDRA gives you static.

Does your 2 1/4 ASI have colored speed range markings? Another source of MDRA static.
 
You have to understand that MDRA is trying to stem the flood of home builders that have been killed by poorly calibrated altimeters......:confused:
 
So, with all of that can I put a Dynon D-180 in my ( yet to be built) VFR only Zenith CH750 with no transponder and expect the MD-RA to sign off the final inspection?

Totally confused at this point.....
 
I have asked somebody who is an RV builder who works at TC to help unravel this rat's nest because I'm in the same boat. He is one of us and knows the regs and knows who to ask. Stand by.
 
Look on the left side of the page at the advertisers list, tailwind aviation services has portable equipment to do all your 24 month testing including all non certified efis's. He is also a dealer for dynon and does first class panel/avionics work. we use him all the time for 24 month tests, highly recommend him. Based out of CYTB, Tillsonberg Ontario.

Gary - your post actually highlights the real challenge we face if MD-RA is really going to insist on the use of an AMO to do this work. Tillsonberg is how far from Ottawa where I live? Now what if I lived in, say Kapuskasing? We're supposed to remove our EFIS, ADAHARS etc and ship them out for calibration, then get them back and install them, all while trying to coordinate a final inspection, the timing of which is at the mercy of TC's bureaucracy for a CofR and MD-RA's inspector availability? This just makes one more unnecessary complication.

There's no reason why we can't calibrate our ASI with a manometer - the laws of physics haven't changed since long before TC came into existence. Likewise there's no reason we shouldn't be able to use a vacuum source and a known-calibrated altimeter to be able to do our own altimeter calibrations on-aircraft.
 
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I note this:

"Where a TSO is referenced as an acceptable design standard, it is intended to mean that the design standards contained with the TSO are an acceptable minimum standard and the equipment does not necessarily need to have a TSO. i.e. an applicant could obtain Transport Canada Civil Aviation approval (Supplemental Type Certificate/Limited Supplemental Type Certificate) for a design if it is demonstrated that it complies with the design standards specified in the applicable TSO."

This is the same issue as what's going on with ADS-B in the states. they say you have to meet TSO requirements and specs, but you can do so without actually being TSO'ed. The alternative means of compliance seems to be an STC/LSTC ... but because home-builts have no type certificate, what does this mean to home builders?

Does the home builder self-certify that his Dynon EFIS-provided altitude reporting to the transponder meets TSO? Can a builder contact TC and ask nicely for them to agree that his GRT EFIS is "good enough"?
 
"So, with all of that can I put a Dynon D-180 in my ( yet to be built) VFR only Zenith CH750 with no transponder and expect the MD-RA to sign off the final inspection?"

Yup. The transponder is not mandatory equipment. If you have none, then obviously you don't need to calibrate or certify it.

Technically, you shouldn't need your altimeter to be checked either, since you'll obviously never enter transponder airspace.
 
Agree about the transponder requirement, no issue there if none installed.

From how I read it there are 2 separate requirements listed on that final inspection checklist.

1 is the transponder issue ( which is every 24 months anyway) but 2nd is the separate altimeter check.

What do we do if you have only a D-180 with no steam gauges at all and are in the boonies where there is no shop available to do a test? Dynon sends the unit out fully calibrated but would that count? Can I show the inspector an independent test I did with my home made manometer? I doubt it as the reg says an approved AMO.

I say again, totally confused.....
 
What do we do if you have only a D-180 with no steam gauges at all and are in the boonies where there is no shop available to do a test? Dynon sends the unit out fully calibrated but would that count? Can I show the inspector an independent test I did with my home made manometer? I doubt it as the reg says an approved AMO.

I say again, totally confused.....

This is what I was trying to highlight in an earlier post. The use of the term AMO places severe restrictions on who can do the altimeter calibration. None of the experimental EFIS manufacturers are AMO's, and none of them will want to become an AMO unless they can recover the cost in increased sales so once again it's the Canadian builder who will foot the bill.

We have been able to, until now, get by with calibration against a known-good standard. For that purpose I kept my brand new altimeter when upgrading my panel from single EFIS+steam to dual EFIS. Now it appears I can't calibrate my own EFIS altimeters against that known-good calibrated altimeter. This really ups the PITA factor quite significantly, not to mention the cost.
 
I have been told that the Recreation Aviation has been eliminated at TC and its function has been rolled into Operational Airworthiness. So they have made this decision with no understanding of the bigger ramifications or the magnitude of the "problem" it is intended to address. Given this further reduction in services in support of GA I think we can expect a lot more of this stupidity in the future. Wait till they discover that some of us use car engines and we do our own annuals....
 
That's just great....:(

So now what, back and forth over the next 10 years to get these guys onside?

I don't suppose there is anyone on here that is from the ministers riding, The Honourable Lisa Raitt, that could bend an ear?
 
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OK, let me run this by you guys....maybe we ( I ) are getting ahead of ourselves.

CAR 549.113 states:
(a) Aeroplanes and powered gliders: Subject to 549.113 (b), all the equipment and instruments specified in section 549.13 are required as a minimum.

549.13 states:
Unless otherwise indicated in the applicable subchapter, aircraft shall have the following serviceable and functioning equipment and instruments, as a minimum:

(b) Flight & Navigation Instruments:

(1) An airspeed indicator.

(2) An altimeter.

(3) A magnetic compass.

No mention what so ever of certified/tested/etc.

Now if we look at 549.115 Instrument Flight Rules (IFR)

(a) Upon receipt of a Special Certificate of Airworthiness with modified operating conditions issued pursuant to Chapter 507 of this Manual, the owner of an amateur-built aircraft may apply for the removal of the "Visual Flight Rules only" restriction.

(c) The aeroplane and the installed equipment shall be maintained according to the applicable maintenance requirements of Chapter 571.


Now in 571 appendix B is where we see all this Altimeter testing requirements.

So, can I assume that the final inspection checklist that the MD-RA has includes the requirements for someone how wants to have the "VFR only" restriction removed? That if you are VFR only you can stop at 549.113.

Thoughts? ( my bold added to above)
 
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In terms of airworthiness, you are correct.

The catch is that the requirements for the altimeter and transponder maintenance are not always just an airworthiness matter.

To be *airworthy* as a VFR-only aircraft, you just need a serviceable and functioning altimeter, that's it.

But to be *airworthy* with the VFR restriction removed, you MUST have equipment X and maintain it to standard 571.

But, as per 605.86, you cannot execute a take off unless specific equipment (in this case the altimeter and transponder systems) has been maintained per 571. It is NOT an airworthiness restriction. Your C of A is still valid even if you missed your maintenance schedule, but it is "illegal" in that you are not meeting maintenance requirements.

So, since all home-builts start VFR-only (I think? right?) all you need to get your initial C of A is a functioning altimeter. MD-RA cannot refuse your C of A based on 605.86 issues, as they are NOT an airworthiness requirement. They are a *maintenance* requirement, and the responsibility to meet them is YOURS.

That being said, as per 605.86 and under some circumstances, you would need your altimeter/transponder setup checked by an AMO BEFORE first flight. How to meet this requirement remains a conundrum ...
 
OK, but what my initial concern was that I would not be able to pass the final inspection by the MD-RA without all the altimeter testing for a VFR non-transponder equipped a/c.

So, if that line on the MD-RA checklist about altimeters only applies if you are requesting the "VFR only" restriction be removed then that is fine with me ( in this circumstance)
 
You only need your transponder checked before first flight if you are test flying from an airport that needs a transponder. You take he transponder out for first flight and you are legal. Once you have your time flown off you can get permission to fly into a larger airport that needs a transponder to get your transponder checked. You need to confirm your system is leak free and that can be done by yourself. (before first flight) It's best that you always do that yourself before the shop anyway as that is what cost you, chasing down leaks that you could have found.

If your equipment is not new it will have to be bench tested by a shop before flight. If it is new only the leak test is required if you take the transponder out.


This is my latest understanding:rolleyes:
 
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Remember: What we believe to be the case here on the internet means zippo when the MD-RA inspector arrives and wants you to meet every line on his checklist. You don't meet the requirement of the line? You don't fly.

MD-RA inspectors are not given the leeway to interpret. They are given direction from their head office to follow certain rules certain ways, that do not always strictly agree with the CARs.
 
Unfortunately I agree with you.....just as TC inspectors from one region interpret something one way and another region 180 degrees the other way......ask me how I know this :)
 
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"You only need your transponder checked before first flight if you are test flying from an airport that needs a transponder."

Nope, the 571 maintenance requirements for the transponder is NOT conditional on airspace. If you have a transponder, it must be maintained to 571, and this must be done before a take off, including your first one. The 571 altimeter requirements are the ones that are conditional on airspace use.

As to someone else's point, you are correct that ultimately, our own interpretations may not matter much to your local MD-RA inspector.

BUT if we think (know?) MD-RA is "wrong", people should certainly complain to MD-RA and/or TC about it. Don't let abuses of power go unchecked ...

Even if MD-RA was right (which I'm 99% sure it isn't), there needs to be some talk on means of compliance, because, going back to the OP, it may be impossible, or ridiculously complicated and expensive, to be.
 
All correct Kamikaze, regardless of what airspace you are based in, if the a/c ( certified or amateur ) has a transponder then it must be maintained in accordance ( 24 month certification, etc.)

However, what was mentioned previously was that if you want to do your first flight from an airport located in G airspace and there is no transponder installed, that is perfectly legal and SHOULD be acceptable to an MD-RA.
 
"However, what was mentioned previously was that if you want to do your first flight from an airport located in G airspace and there is no transponder installed, that is perfectly legal and SHOULD be acceptable to an MD-RA."

Absolutely! Even their own published rules would kind of agree with that ... they require transponder "certification", and it says applicable to all aircraft, but presumably they at least understand that it's all aircraft THAT HAVE ONE! :)

The altimeter one is the one that definitely should NOT say "applicable to all aircraft" because that's plain not true.
 
The altimeter one is the one that definitely should NOT say "applicable to all aircraft" because that's plain not true.

Agreed, that is the line on the checklist that is the problem area.

IMHO it should say "applicable to all aircraft requesting VFR only restriction removed" or something to that effect.
 
Ok guys, now that we have beat that one to death, I have another question.

Again on the MD-RA checklist ( pre-cover and final) one of the items is:

Are all surfaces protected against environmental deterioration?

Does that mean if you decide to not prime ( primer wars here) would it be a no-go item? Or would they consider Alclad as protection for aluminum skins?
 
"IMHO it should say "applicable to all aircraft requesting VFR only restriction removed" or something to that effect."

Or VFR aircraft that intend to navigate transponder airspace.

But again, none of these things are airworthiness items ...

"Are all surfaces protected against environmental deterioration?"

All 549.7 says is : "(a) Materials shall be appropriate and should conform to aviation quality specifications."

Alclad 2024-T3 it seems would certainly meet this requirement.

BTW, this AMA details compliance requirements:

https://www.tc.gc.ca/eng/civilaviation/standards/maintenance-aarpc-ac-549-1b-2745.htm

And it clearly says that inspections are to determine airworthiness as per *CAR 549*, not whether you're maintaining your A/C as per CAR 605.
 
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