I received my updated Special Certificate of Airworthiness and Operating Conditions today authorizing IFR flight. I thought I'd give a run through the process as it worked for me. Ultimately Transport Canada turned my request over in a little more than 3 business days.
As many people are aware, the process of equipping for IFR in Canada differs widely from the US - particularly in the equipment requirements. The requirements are detailed in CAR 605.18 (Power-driven Aircraft - IFR) which references equipment listed in 605.14 (Power-driven Aircraft - Day VFR) and 605.16 (Power-driven Aircraft - Night VFR). Most of these requirements are easy enough to meet and are similar to the US requirements. The item in 605.18(j) is the important one.
CAR 605.18 No person shall conduct a take-off in a power-driven aircraft for the purpose of IFR flight unless it is equipped with
(j) sufficient radio navigation equipment to permit the pilot, in the event of the failure at any stage of the flight of any item of that equipment, including any associated flight instrument display,
(i) to proceed to the destination aerodrome or proceed to another aerodrome that is suitable for landing, and
(ii) where the aircraft is operated in IMC, to complete an instrument approach and, if necessary, conduct a missed approach procedure.
In the days of GPSS approaches, this basically means you need a GPS Navigator and either a second GPS Navigator or a VHF Nav Transceiver for LOC/GS. The key point is that these need to be separate devices, so a GTN 650 or a GNS 430W with integrated VHF Nav, for example, would only count as one of these, not both. If these units have their own HSI/VSI or LOC/GS displays then that is good enough. However, if - as is the case with the GPS 175 that I installed - your unit relies on another display to show HSI/VSI, that display will need a backup. A backup battery is not sufficient. You'll see from my equipment list that I had to add a Garmin G5 and set it up as a backup HSI for the GPS 175.
Here is my IFR Navigation equipment.
- Garmin GPS 175 GPS Navigator
- MGL Avionics N16 VHF Nav Transceiver, with MGL Razor control head
- Dynon Skyview HDX Display, connected to GPS 175 via Dynon ARINC-429 unit, connected to MGL Razor via RS232
- Garmin G5 Display, connected to GPS 175 via Garmin ARINC-429 unit, connected to MGL Razor via RS232
In addition to the navigation equipment I've got dual VHF COM transceivers, a Garmin GTR 200 and an MGL V16 (also connected to the MGL Razor control head).
As far as the request to Remove VFR Only from my Operating Conditions, there were 2 key aspects. First, I obtained a copy of Transport Canada's Staff Instruction SI 500-024 and secondly, I contacted the TC CASA inspector that had done the change to my Operating Conditions at the end of my test phase in 2018. The inspector worked very closely with me in making sure that when I submitted the request that it would be assured to be approved. There is not a chance that I could have accomplished this as quickly as I did without his guidance.
My actual request was framed around the contents of the SI 500-024. I'll break that down here.
5.0 (1) (a) A letter requesting the removal of the “VFR Only” operating condition;
5.0 (1) (b) Copy of the front page of the applicable logbook that identifies the aircraft by its registration marks and make, model and serial number;
5.0 (1)(c) The list of the IFR equipment installed;
I provided a table of the requirements for CAR 605.14, 605.16 and 605.18 including the reference, requirement and the equipment that I had installed that met that requirement.
5.0 (1)(d) Documentation demonstrating that the data that was used to perform the installation of the required IFR equipment, including such data as installation and wiring diagrams, power distribution and equipment interface, as required, conforms to the relevant data acceptable to the Minister;
Here I provided a statement that all installations were done in accordance with manufacturers' installation manuals (and provided a link to these manuals). I also included an avionics interconnectivity diagram which I've attached to this post.
5.0 (1)(e) Documentation demonstrating that the source of electrical energy for all electrical and radio equipment is adequate;
For this I stated my alternator/battery configuration and provided a list of installed electrical items with their continuous draw, showing that the total was less than the capacity of my charging system. I also included a basic electrical diagram, also attached.
5.0 (1)(f) Copy of the up-to-date weight and balance report and equipment list;
This one is what I really needed guidance on, it is a list of installed equipment with their weight and moment arm along with a fresh aircraft weight. The format eventually resembled that commonly found in your typical certified aircraft's POH.
5.0 (1)(g) A copy of the pertinent pages of the maintenance records and associated maintenance release(s) related to the IFR equipment that has been installed, tested and calibrated but not yet evaluated; and
This one caught up with me. I was missing the maintenance release statements for a lot of the small jobs that I'd done (changing flat). Each of these need to be followed by a statement that reads "the described maintenance has been performed in accordance with the applicable airworthiness requirements" and a signature. The inspector helped me enter correcting entries and directed me to add one further entry reading "I have inspected the aircraft and have found it to meet the equipment requirements for IFR flight in accordance with CAR 605.18".
5.0 (1)(h) The applicable fee.
This is the best bargain I've ever had in aviation, I got a lot out of the $35 fee.
Soon after contacting the TC inspector, we determined that my AVMAP EFIS Ultra was not going to fit the bill as a backup to my Skyview HDX as 1) the manual states it's for reference only and not for VFR or IFR flight, and 2) has no way to provide backup HSI/VSI/LOC/GS. I replaced this unit with a Garmin G5 as described above. The changed also addressed the concerns that the inspector had about my panel layout. This was mostly around the required field of view should the use of the backup displays become necessary. The G5 allows me to solely reference that instrument during an approach thus eliminating possible vertigo inducing head movements. I've attached a picture of my panel in its final configuration.
All told this process took 5 months to complete. I ordered equipment in November, installed it starting in mid December and contacted the TC inspector in early March, he asked for a picture of my panel and a basic list of equipment. My request was sent in last Friday, after business hours and I received the new Special C of A and Operating Conditions this morning, 4 days later.
I hope that those of you considering a similar upgrade find this long post helpful and I'm happy to get into more detail with individuals if that would be of assistance. For now I move ahead to getting my instrument rating.