The CARAC Part V Maintenance and Manufacturing
Technical Committee meeting on Jan. 14, saw many issues raised regarding the
Owner Maintenance category.
Five Notices of Proposed Amendment (NPAs) to the CARs sought to bring changes to
the O-M category. The first was clarification that O-M aircraft do not have to
meet standard airworthiness requirements to enter the O-M category.
The amendment to CAR 507.03 specifies that to enter the O-M category aircraft
will only have to conform to the O-M category criteria and be “safe for flight.”
This will clarify the O-M category is open to aircraft that do not meet the
original requirements of their standard Certificate of Airworthiness, such as
not being airworthy at the time of application.
Another NPA will add some new aircraft to the list of those eligible to become
O-M aircraft in the near future. Added to the list now are; Stinson 108, 108-1,
108-2, 108-3, Bellanca 14-19, Cessna 150, 150F, 150G, 170, 170A, 170B, 172, 175A
and the 177.
It should be noted that these are specific models – the reference to Cessna 150,
means just the 1959-60 model Cessna “150” and not the Cessna 150A, B or other
models (other than the F and G which were specifically added).
The same applies to the Cessna 172 and 177 on this list – these are the 1956-59
model 172 (and not the Cessna 172A, B and so on) and the 1968 model Cessna 177
(and not the 1969 Cessna 177A and so on).
It should be noted that Transport Canada does not seek out aircraft to add to
the list – it is up to individuals who want to put an aircraft into the category
to do the research and apply for each type to be added. At that time TC will
assess the model to see if it complies with the criteria.
The Piper PA-28-140 Cherokee was requested to be added to the O-M list, but was
rejected for the O-M category at this time since 10.8% of that model are
currently in commercial use. To be eligible, “less than 10% of the type may be
in commercial service.”
At the same time that new aircraft were added to the CAR Standard that contains
the O-M list, TC introduced an NPA to move the list out of the CARs. The main
difficulty with having it in the CAR Standards is that it can take a year or
more to amend the list due to the delays in the CARAC process.
The NPA moves the list from the CAR Standards to an Airworthiness Notice. COPA
has asked for this for some time and strongly supported this concept, since it
will greatly speed up the process of getting new aircraft onto the O-M list.
The most controversial NPA was one imposing restrictions on modifications to O-M
aircraft. When the O-M category was introduced there were strict criteria
restricting which aircraft could enter the category.
The criteria, developed from negotiations involving TC and several Associations
state; eligible aircraft had to have four or fewer seats and be powered by a
single normally aspirated piston engine. They also must have fixed landing gear
and a fixed pitch propeller unless they are gliders, powered gliders or aircraft
with wooden structures.
Through an oversight, the O-M rules as they now exist in the CARs allow
unlimited modifications once an aircraft is in the category. TC officials have
had questions from O-M owners who would like to put turbo-prop engines on the
aircraft or fit seven seats to aircraft that were designed for four people.
TC’s NPA proposed restricting O-M aircraft to only those modifications that
would not have disqualified them from being put into the category in the first
place.
The O-M category was conceived as a means to keep old airplanes flying safely,
not as a category for experimental aircraft.
COPA in general supports the concept, as it is important to preserve the O-M
category and not have radically modified aircraft that will force TC to take
steps to curtail the category.
COPA, however, did object to the restriction that this would impose regarding
variable pitch and constant speed propellers and turbo-charged engines. COPA’s
position was that variable and constant speed props reduce the noise of these
aircraft and increase efficiency.
TC was prepared to accept an exclusion to allow constant speed props on aircraft
in the category, however, the representative of the Canadian Federation of AME
Associations, Ben McCarty, objected strenuously to the exclusion, citing the
original deal struck at CARAC excluded these kinds of radical changes to O-M
aircraft.
TC agreed with the AME Association and accepted the NPA as originally presented
over COPA’s objection.
TC did add that the intention is aircraft in the O-M category should continue to
meet the entry requirements for the category. The best way to address the
problem of constant speed propellers is in changes to the entry criteria for the
O-M category.
TC did indicate that they would accept proposals that look at modifying the
entry criteria for the O-M category, but the category is too new to do that at
the present time.
This means for now, those aircraft with wooden airframes or were on the original
list as special cases, such as the Republic RC-3 Seabee, can have constant speed
props. Aircraft that do not enter the list with constant speed props, like the
Aeronca Champ, cannot be modified to have a constant speed propeller.
It also means that certified aircraft that have constant speed props installed
under an STC and do not have wooden airframes will not be allowed in the O-M
category without being de-modified back to fixed pitch propellers.
COPA will pursue changing the entry criteria to the O-M category in a future
request made to CARAC on this issue, but it’s going be some time before this
will to occur.
The COPA Guide to the Owner Maintenance Category will be amended to reflect
these changes to the O-M category. The Guide is available free to COPA members
on the COPA website “members only section”.
In other news from the CARAC Part V meeting, CAR 625 Appendix K has been amended
to indicate that the person who is able to sign a maintenance release for an
aircraft can sign for the aircraft after an abnormal occurrence, such as a
gear-up landing.
This amendment to the CARs comes as a result of a CAT case where the owner of a
homebuilt was violated under this CAR by TC Enforcement for signing out his
aircraft after repairs following a gear-up landing. The CAR required the
signature of an AME for all aircraft, even homebuilts under these circumstances.
Also amended was CAR 625 Appendix C. This section of the CARs details
“out-of-phase” maintenance items such as ELTs and propellers. The amendment will
exclude aircraft operating under a Special Certificates of Airworthiness in the
amateur-built and O-M categories from complying with the ten-year variable pitch
propeller overhaul requirements.
Owners of those aircraft will now be able to decide when their variable pitch
and constant speed props need overhauling.
The changes to the CARs mentioned in this article will come into effect in the
near future. Because most of them affect CAR Standards they are relatively quick
to implement.
COPA will carry the effective dates on the COPA website when these provisions
become effective. Until then, the current CARs remain in effect, so don’t take
any action on the changes until they are in effect! All together the Technical
Committee considered 39 NPAs during the meeting.
For more information contact the COPA CARAC Part V representative, Adam Hunt.
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