MD-RA requires avionics shop to test pitot?

[C-FAH Q]

Originally Posted by Canadian_JOY

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.

[Gunter Malich]

[quote=Canadian_JOY;966802]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?

[kamikaze]

"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.

[Ralph Inkster]

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.

[sblack]

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.

[sblack]

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/civilaviatio...8.htm#605_18);
2 - the "operational" equipment has to comply with CAR 602.59(b) (http://www.tc.gc.ca/eng/civilaviatio...6.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/civilaviatio...s-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/civilaviatio...1-551-2544.htm) - Aircraft Equipment and Airworthiness Manual Chapter [STD] 551 (http://www.tc.gc.ca/eng/civilaviatio...-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
maurice.simoneau@tc.gc.ca <mailto:maurice.simoneau@tc.gc.ca>.
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

[Ralph Inkster]

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.

[sblack]

You have to understand that MDRA is trying to stem the flood of home builders that have been killed by poorly calibrated altimeters......

[CDNRV7]

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.....

[sblack]

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.