Nov. 22, 2004 marked the start of a long CARAC Technical Committee meeting for Part V Aircraft Certification. In fact, the meeting didn’t wrap up until Jan. 12, 2005!
The meeting itself wasn’t seven weeks long, however the agenda wasn’t completed in the initial three days allocated and so the meeting was concluded with two more days in January for total of five days.
COPA is the only association representing small aircraft owners that participates in the CARAC Part V Aircraft Certification
Technical Committee. Adam Hunt is the COPA representative to this important committee that affects all certified aircraft in Canada.
There was only one topic of discussion at this five day meeting – the proposed CAR 521 Notice of Proposed Amendment (NPA).
The new CAR 521 is an attempt to bring Canada into line with the organization of the equivalent FAA FAR 21 and European EASA IR 21 rules with regard to Aircraft Certification – to make our rules easier to understand and use within Canada and internationally as well.
This ambitious project was designed to take Canadian Aviation Regulations Part V, Subpart 11, 13, 16, 22, 23, 25, 27, 29, 31, 33, 35, 37, 41, 51, 91 and 93 as well as Airworthiness Manual Chapters 505, 511, 513, 537, 591, and 593 and incorporate them all into a new Canadian Aviation Regulation Part V, Subpart 21 (CAR 521).
Needless to say the new CAR 521 will be a large document, but it will be better organized than the previous 22 CARS and Airworthiness Manual Chapters that it replaces.
Generally industry, including aircraft manufacturers, Design Approval Representatives (DARs) and associations with an interest in certified aircraft, including COPA, has been supportive of this move.
Naturally TC did not just take the text of the existing rules and re-package it in the proposed CAR – some changes were made along the way. Some of these changes were just to incorporate other Notices of Proposed Amendment (NPAs) that have not yet made it into the CARs, while others were new rule changes.
The five days spent on this new CAR were mostly to ensure the new rules incorporated do not introduce anything more onerous than the old rules required and especially that we are not putting Canadian certified aircraft at a disadvantage compared to the competition from other countries.
The proposed new CAR 521 includes a number of divisions that mirror the US FAR 21 and EASA IR 21. The new CAR will look like this:
Division A – General – This includes definitions, applicability, Service Difficulty Reporting, Airworthiness Directives and the requirement for Safety Management Systems within approved organizations and DARs.
Division B – Type Certificates – regulates anyone manufacturing an aircraft and seeking a type certificate for it. This division also establishes basis of the Standards of Airworthiness for each category of aircraft.
The actual standards themselves are located in the Airworthiness Manual, such as Chapter 523 for Normal, Utility, Aerobatic and Commuter Category Aeroplanes. These will not change under this new CAR.
This division also includes aircraft emissions, basis of certification and flight testing.
Division D – Changes to Type Designs – addresses major and minor changes to a type design and changes to emissions when
changing a type design.
Division E – Supplemental Type Certificates – deals with STCs in all their forms. One of the changes coming with this new rule is that Limited STCs (LSTCs) will disappear in Canada to be replaced with serialized STCs. This will, in general, be an advantage to industry and aircraft owners in Canada.
Division J –Organizational Delegate Authorizations – deals with those manufacturers who are authorized to approve products on behalf of TC.
Division K – Design Approval Representative Authorizations – deals with those industry individuals who are conducting design approvals on behalf of TC.
Division M – Repair Design Approvals – addresses the requirements for approved repairs to certified aircraft.
Division N – Foreign Aeronautical Products or Changes to a Type Design – regulates imported aeronautical products used on certified aircraft.
Division O – Technical Standard Order Design Approvals – establishes a Canadian TSO standard in harmony with the USA and EASA, allowing Canadian companies to produce TSO’d products in Canada that should be internationally acceptable.
Division P – Part Design Approvals – establishes a similar system for Canadian PDA parts that exists in the USA. Again this should allow Canadian manufacturers to produce parts for the international marketplace with greater acceptance.
The divisions not mentioned above are currently reserved for future use, if needed.
The presentation and acceptance of this NPA represents the culmination of good work by TC’s certification staff under Director Martin Ely and also by the industry members of the CARAC Part V Aircraft Certification Technical Committee.
During the five days of meetings on this issue the Technical Committee members contributed many recommendations for changes to the proposal – most of which were accepted by TC.
To give credit where it is due, the high standard of work that was done by the TC Aircraft Certification staff in this project was
quite noteworthy. The background information provided and the formal Risk Assessment prepared for this CAR 521 project will serve as an example of how best to conduct a Risk Assessment for other TC directorates in the future.
COPA participates in all nine CARAC Technical Committees to represent COPA members to Transport Canada in the CAR rulemaking process.
COPA is the only association that represents non-commercial aircraft owners and pilots that participates on all CARAC Technical Committees, ensuring that COPA members’ interests are heard in Ottawa.