Looking for some ideas....
I imported an RV-4 to Canada last spring and by rule, had to register it at the manufacturers recommended max gross.... 1500#s. To improve versatility and allow for some upgrades, I would like to raise it to 1650. Transport Canada requires that I substantiate my request. I have NO doubt what so ever that my a/c will handle the increase... any ideas that might help me make my case? As a bonus, my a/c has an 0-360 and performance is great. Weight and balance is not a problem for me either... I have run "extreme case" examples and still stay inside the envelope. My empty weight is 985#s.
Dave,
Has TC provided any clues as to what exactly they are looking for? I am only aware of the following weight-related regulatory requirements for amateur-built aircraft in Canada:
- max weight of 5,000 lb (was 1,800 kg, but changed to 5,000 lb via Exemption 549.01).
- max wing loading requirements to avoid a need for an individual type rating (which were substantially relaxed by Exemption 549.01).
- a minimum engine power requirement which varies with weight.
- a climb performance requirement (note that you can't show compliance to this requirement until after receiving approval to fly at the higher weight).
Note that there are absolutely zero structural design requirements, so TC has no business asking for a structural justification. But a pissing contest won't get you too far, as they hold all the cards. They don't have to actually come up with a valid reason to deny your request - they can just sit on it for a few years while they cogitate. If they decide to send it up to Legal for an opinion, that will take at least six months to get an answer.
Regulatory requirement or not, the laws of physics apply equally to amateur-built and type-certificated aircraft, so you would be wise to apply appropriate limitations to your operation when above Van's recommended gross weight. For example, I plan to eventually request a higher gross weight for my RV-8. I will restrict the load factor when above 1800 lb such that the product of load factor times weight is less than the max recommended aerobatic weight times 6g. I will also only operate from smooth, hard surface runways when above 1800 lb, and I will apply lower cross wind limits.
If I were you, I would provide clear justification for all the weight requirements in AWM 549 (as amended by Exemption 549.01). Then, I would note that while there are no structural design requirements for amateur-built aircraft, you recognize that the laws of physics still apply, and for the information of TC, explain how you will limit your operation to ensure that the structure is adequate.
Disclaimer - I work for TC, but not in the part that deals with amateur-built aircraft.