IFR requirements in Canada

I would like to have the "VFR only" restriction removed from my aircraft for IFR use. I currently have a 10' Skyview touch with a GNS-430W. I know that a second HSI, in the form of an additional 7' Skyview classic will be needed for redundency as per Transport Canada regulations and knowing that CAR 605.18 states:

(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 event that the GNS-430W fails, can I manage the above requirement with the Skyview only with all IFR fixes in the database knowing that Canadian geo-referenced approach charts are not available on Skyview. Non TSO'd equipment is acceptable but not Ipads. I will also need ton convince TC which will not be an easy task.

Thanks

I do believe you need a second nav unit, such as a VOR in an SL-30 (or the new GTR series), separate from the 430, good to have the second COM along with also. And indeed a second EFIS will cover off the rest.

You should also have a separate TSOed encoder, and not use the Dynon data for this, to get your altimeter/encoder/transponder certified, if you haven't already.

If you really want to cross your t's and dot your i's, read this from TC:

http://www.tc.gc.ca/eng/civilaviation/opssvs/managementservices-referencecentre-documents-1784.html

kamikaze said:

You should also have a separate TSOed encoder, and not use the Dynon data for this, to get your altimeter/encoder/transponder certified, if you haven't already.

Click to expand...

Why? The SkyView transponder (or any other brand that takes a serial data) fed via the SkyView is perfectly fine for IFR in the US. Why would Canada not think that? Mine has passed IFR certification with flying colors since before first flight - as well as FAA verification of ADS-B out 2020 compliance.

Carl

There is a lot of confusion about this up here. Some avionics shops won't sign off with a non-TSO's encoder. But some time back a TC inspector, and it might have been on this forum, said that a homebuilt needs to demonstrate that the transponder installation meets the same standard as TSO, but it need not be TSO'd, which makes sense. In fact I would expect a skyview or other EFIS to be better. No hysteresis, no drift over time etc. I think the avionic shops are afraid to sign off on such an installation, when in fact they don't have to - they just need to do the measurements and provide them, then the owner can sign them off as being airworthy. But not everyone is on the same page it seems. If I had decent test equipment that I could show met the specs I would do it myself.

Carl Froehlich said:

Why? The SkyView transponder (or any other brand that takes a serial data) fed via the SkyView is perfectly fine for IFR in the US. Why would Canada not think that? Mine has passed IFR certification with flying colors since before first flight - as well as FAA verification of ADS-B out 2020 compliance.

Carl

Click to expand...

See here:

http://www.tc.gc.ca/eng/civilaviation/regserv/cars/part5-standards-551s-1810.htm#551_103

For the TSO requirement.

Best I can tell, amateur-builts are not exempt from this provision.

Following on that, from the Service Instruction I linked above:

Information Note: transponder and automatic pressure-altitude reporting equipment is required by CAR 605.35 for flight in transponder airspace, not solely for flight under instrument flight rules; transponder and automatic pressure-altitude reporting equipment must be certified in accordance with the applicable TSO standards specified in Chapter 551 of the Airworthiness Manual.

Wow - a good example of regulatory compliance blindly locking in 1940 technology for 21st century applications, along with all the baggage of analog system inaccuracies.

Who is the champion to tell the Canadian bean counters to wake up and smell the coffee?

Carl

Transport has come a long way in recent years.... bringing licence requirements up to ICAO standards and such. Granted, it took them a decade longer than the rest of the planet.

Some of the ministers move about as fast as maple syrup.

It is pretty shameful, though I suspect the regulatory process itself is so bad that it dampens changes. Even if TC were to wake up and smell the coffee on one issue or another, the process by which to change the CARs can be so cumbersome as to stop one from trying it I suspect. And they are so mismanaged and broke that it makes things even worst on the best of days.

That being said, because A/C separation is based on this, in transponder airspace, where you're sharing with big fast moving iron, I can see why one would consider this particular piece of equipment (and its installation/configuration) rather critical. But this a circumstance where meeting TSO without being formally certified would also work ... I've always wondered how one establishes meeting TSO though ... just manufacturer claim?

My beef is with the requirement of a whiskey compass, that one is even worst IMO!

SmackSB4 said:

Transport has come a long way in recent years.... bringing licence requirements up to ICAO standards and such. Granted, it took them a decade longer than the rest of the planet.

Some of the ministers move about as fast as maple syrup.

Click to expand...

The ICAO is located in Montreal

I tried making a link to this post but failed, so I copied and pasted.

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.



Quote:


Originally Posted by Maurice Simoneau - Transport Canada


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;
2 - the "operational" equipment has to comply with CAR 602.59(b);



Quote:


Originally Posted by CAR 602.59(b)

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 - 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:



Quote:


Originally Posted by AN B032

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.



Quote:


Originally Posted by AN B032

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 - Aircraft Equipment and Airworthiness Manual Chapter [STD] 551 - Aircraft Equipment and Installation.



Quote:


Originally Posted by CAR 551.01

(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.



Quote:


Originally Posted by STD 551.02(a)

... 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
[email protected] <mailto:[email protected]>.
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

__________________
Rob Prior
1996 RV-6 "Tweety" C-FRBP (formerly N196RV)

That provides so much clarification.

Sticky, maybe? In the IFR section?

IFR IN RV

Thanks Scott for the info

I plan on going thru the process next spring so the more info the better.

Once I'm done, I'll post the experience here.

Bruno Dionne
RV-4 C-GDBH

Our local TC office (Calgary) is very approachable for this type process. They would like to be involved sooner than later in planning, this way all regulation concerns are covered with the minimum of fuss (& without the head strain of poring over all the Regs one's self). I would hope other regional offices would be same.

The information from Mr. Simoneau above is very old and predates the new Staff Instruction by a good chunk of time IIRC. It's been archived here for many years, long before the SI.

The staff instruction from 2013 (relatively recent) tells TC (and minister's designates, including MD-RA) how to interpret the rules, and they should/will follow that before what Mr. Simoneau may have written in an e-mail at some point in the past.

That being said, he said the same thing: your encoder needs to be TSO'd. The rest of the equipment need not, but should *meet* TSO. For IFR navigators, I don't think anyone has created one that isn't actually certified ... so the point is moot.

Unless you have exotic equipment such as a GPWS, the only thing that *must* be TSO'd is the encoder.

You will then add an IFR navigator, and a backup device (Say, GTN 650 + GTR 255, or something like that).

Now that I think about it though, do you need a second EFIS screen? If the navigator has a screen (and they all do), and your VOR radio for example shows course deviation on its screen, you might be OK without a second EFIS (The devices themselves provide the backup screen).

Still good to have for other reasons of course, but in strict terms of IFR equipage compliance, you may be OK!

kamikaze said:

The information from Mr. Simoneau above is very old and predates the new Staff Instruction by a good chunk of time IIRC. It's been archived here for many years, long before the SI.

The staff instruction from 2013 (relatively recent) tells TC (and minister's designates, including MD-RA) how to interpret the rules, and they should/will follow that before what Mr. Simoneau may have written in an e-mail at some point in the past.

That being said, he said the same thing: your encoder needs to be TSO'd. The rest of the equipment need not, but should *meet* TSO. For IFR navigators, I don't think anyone has created one that isn't actually certified ... so the point is moot.

Unless you have exotic equipment such as a GPWS, the only thing that *must* be TSO'd is the encoder.

You will then add an IFR navigator, and a backup device (Say, GTN 650 + GTR 255, or something like that).

Now that I think about it though, do you need a second EFIS screen? If the navigator has a screen (and they all do), and your VOR radio for example shows course deviation on its screen, you might be OK without a second EFIS (The devices themselves provide the backup screen).

Still good to have for other reasons of course, but in strict terms of IFR equipage compliance, you may be OK!

Click to expand...

Could you please post a reference for the "staff instruction from 2013" stating the encoder must be TSO for IFR flights. As I have yet to read this anywhere.

Thanks
Michel

Mousse said:

Could you please post a reference for the "staff instruction from 2013" stating the encoder must be TSO for IFR flights. As I have yet to read this anywhere.

Thanks
Michel

Click to expand...

It was all posted earlier in the thread, but here you go again:

The *current* staff instruction on making an amateur-built IFR:

http://www.tc.gc.ca/eng/civilaviation/opssvs/managementservices-referencecentre-documents-1784.html

And, from that document, concerning the encoder:

"Information Note: transponder and automatic pressure-altitude reporting equipment is required by CAR 605.35 for flight in transponder airspace, not solely for flight under instrument flight rules; transponder and automatic pressure-altitude reporting equipment must be certified in accordance with the applicable TSO standards specified in Chapter 551 of the Airworthiness Manual."

In Canada, to fly into transponder airspace, you must have an encoder, and it must be TSO'ed, and the installation must be certified for flight into transponder airspace (even if VFR, or IFR, aka the "24 month avionics check" ... altimeter, encoder, transponder, correlation).

If you follow the labyrinth of the CARs you will find that statement in line with the regs as they are written.

Here is the exact trail of regulations:

- CAR 605.35 requires "Automatic Pressure-Altitude Reporting Equipment" for flight into transponder airspace
- CAR 511.03 details the technical standards the equipment must meet (TSO C88 or C88a)
- CAR Standard 625 Appendix C Chapter 13 lays out out-of-phase maintenance tasks for "altimetry devices" (This is what defines the 24 month check).
- The maintenance must be done according to CAR standard 571 Appendices B and F (This is what tells the avionics shop what to do).

Amateur-builts are NOT exempt from any of these rules.

kamikaze said:

It was all posted earlier in the thread, but here you go again:

The *current* staff instruction on making an amateur-built IFR:

http://www.tc.gc.ca/eng/civilaviation/opssvs/managementservices-referencecentre-documents-1784.html

And, from that document, concerning the encoder:

"Information Note: transponder and automatic pressure-altitude reporting equipment is required by CAR 605.35 for flight in transponder airspace, not solely for flight under instrument flight rules; transponder and automatic pressure-altitude reporting equipment must be certified in accordance with the applicable TSO standards specified in Chapter 551 of the Airworthiness Manual."

In Canada, to fly into transponder airspace, you must have an encoder, and it must be TSO'ed, and the installation must be certified for flight into transponder airspace (even if VFR, or IFR, aka the "24 month avionics check" ... altimeter, encoder, transponder, correlation).

If you follow the labyrinth of the CARs you will find that statement in line with the regs as they are written.

Here is the exact trail of regulations:

- CAR 605.35 requires "Automatic Pressure-Altitude Reporting Equipment" for flight into transponder airspace
- CAR 511.03 details the technical standards the equipment must meet (TSO C88 or C88a)
- CAR Standard 625 Appendix C Chapter 13 lays out out-of-phase maintenance tasks for "altimetry devices" (This is what defines the 24 month check).
- The maintenance must be done according to CAR standard 571 Appendices B and F (This is what tells the avionics shop what to do).

Amateur-builts are NOT exempt from any of these rules.

Click to expand...

Thanks JF for the reference.

Michel

More TC

I went through this process with my Glasair. TC was happy to guide me to compliance, and tell me what they wanted. The watch out especially for folks bringing in perfectly fine US IFR airplanes in to Canada is the redundancy question which is more rigorously tested in Canada.

After my first submission, I was asked to flush out what I'd done to cover CAR605.18. The response covers at the end of it, the redundancy requirement. Note that in speaking with them, the second navigation source also needs a display head in the primary view of the pilot. Screen failure can't take out both radios. A display on the radio does not count, nor does a big screen on the other side of the cockpit. My Glasair was steam gauges.

For my 10, I'm planning either a G5 or a D10A with nav fed from the second radio right next to the primary screen to cover this requirement, but since I'm not flying, I haven't gotten TC blessing on that. I'm not one to pick a fight with a TC guy, so I didn't chase the "show me where it's written" angle.


snip ----
For example, currently I don?t see that the following is installed:
? Alternate air source for air instruments,
? Pitot/Static heat,
? OAT gauge,
? Equipment for Night VFR/IFR flight,
Power/Vacuum system failure warning indicator, for gyro instruments,
? Sufficient navigation equipment to allow for safe IFR flight, including redundancy (for example: should any part of the installed KLN 94 GPS unit fail- CAR 605.18(j)). Note: The KLN 94 was designed under TSO-129a as: Airborne Supplemental Navigation Equipment GPS, for type certified aircraft, not as the primary navigation equipment.

Therefore, please provide documentation to demonstrate that all of the equipment required for IFR flight is installed, as required by CAR 605.18(a) through(j):

Also, in addition to the log pages supplied, please provide documentation demonstrating the aircraft is currently in full compliance with its Maintenance Schedule:
Encoding Altimeter & Transponder /Correlation test, & Pitot Static test, are coming due xxxx (Only a reminder for this bullet at this time, and just in case removal of the VFR operating limitation extends past this date. If so, I will need to see the technical record demonstrating compliance for these requirements).
snip----

"A display on the radio does not count, nor does a big screen on the other side of the cockpit."

That does not make a whole lo of sense. IFR navigators (430, 650, etc.) are *required* to have a screen per TSO. Why then say they don't count as a backup screen??

There are some "standards" related to field of vision and where things are placed ... I'm not sure those are regulatory however ...

Here's another good read on the topic of IFR instrumentation and human factors:

http://www.tc.gc.ca/eng/civilaviation/certification/guidance-523-523-008-954.htm#5_8

It's kind of old and predates the widespread adoption of glass cockpits in GA, but it's still "official" best I can tell.

As the previous poster mentionned, that can't be entirely right, G1000 aircraft have backup instrumentation, but not with nav capabilities usually. Reversionary modes are there for that purpose.

That being said if you don't want to argue, your idea of hooking up your second nav source to a G5 or similar seems sensible and not too much of a burden ... for IFR, you'd likely want those instruments anyways. If you can hook up both nav sources to both primary and backup EFIS's, that would likely be ideal.

That being said, if your "center radio stack" is in your field of vision (as required for this purpose), I certainly would consider the screens on the devices themselves as usable assuming they can display the information you need.

I mean, you have GTN 750 sitting there right next to your EFIS that went dead, and someone is saying you need to hook it up into your G5 to be in your field of vision, when you have a beautiful huge screen showing you everything you need right there? I don't buy it ... and lots of certified planes fly not configured this way AFAIK ...

kamikaze said:

http://www.tc.gc.ca/eng/civilaviation/certification/guidance-523-523-008-954.htm#5_8

It's kind of old and predates the widespread adoption of glass cockpits in GA, but it's still "official" best I can tell.

Click to expand...

Thanks for that link - an older version of the document also came up while going through the restriction lifting process.

As explained to me both the primary and backup CDI's needed to be in the positions described in (at that time a previous version) of that document.

The G1000 setups in certified airplanes meet this by putting the screens side by side, without the center stack between them, which in my mind would be a valid alternative to the G5/D10A I'm thinking of.

The center stack is sufficient for things like NAV/GPS (i.e. which one is selected) indication, but not for flying an approach.

YMMV - Lots of room for interpretation when most of the guidance hasn't been updated since the steam age.

To be clear, I think I could likely do a reasonable non-precision approach using a 650 screen, and I also think the requirement for a TSO 'ed Encoders should have been lifted a long time ago, but I'm still going to install a redundant display and the cheapest TSO'ed encoder I can find.

Helps to keep the weight of the paperwork and letters to TC under the gross weight of the aircraft.

Derek - with respect to your comment concerning a cheap TSO'd encoder, this may be false economy and a huge source of frustration. Sure, some cheap encoders work well, however the money and time spent diagnosing and repairing a faulty encoder can be significant, hence my use of the term "false economy".

If I may be so bold as to suggest it... You are building a travelling airplane, so it's reasonable to assume you may want to fly to or across the USA.

Given the ADS-B mandate with which you will likely wish to comply, perhaps the more efficient approach to installing an encoder would be to install a Trig TT22 Mode S/ES transponder (it's actually the same footprint as most discrete altitude encoders) and install the matching TC20 control head. The joy of this solution is the control head is also the altitude encoder. You get a small control head that also has a fully TSO'd encoder contained within it, you get a fully 2020-compliant transponder, and these devices consume little power and are very light in weight. When I made this same equipment selection for our aircraft I just couldn't see how this solution was anything less than a win-win.

Built in encoder

Mark - It's a good call out. ADS-B is definitely part of the plan. The integrated encoder approach is certainly a reasonable one. I was aware of the Garmin add-on, but not of the Trig solution so one more option to consider - and looks to be quite a good one.

There is part of me that wants to be optimistic and wire both the grey code from the encoder and serial from the glass to the transponder, so that if/when the TSO encoder requirement drops, I could software change, do a 24 month check and have a consistent altitude displayed on my screen and in 25' increments on the controllers screen.

That way when I'm squeezing between our noise sensitive neighbors, and 50 to 100 ft below the bottom of Toronto's airspace I don't make the controllers nervous about TCAS blips on the approach path 1000 feet above me.

That said a modern pressure transducer is going to be much less likely to drift between the 24 months checks - so the built in encoder approach does get me most of the way there - and does it now.

These choices are never easy!

Coming to this a little late I know, but Scott's earlier post quoting my quote of Maurice Simoneau's letter is rather hard to read so here's a direct link to the post which is a little easier to parse:

http://www.vansairforce.com/community/showpost.php?p=657871&postcount=10

"The G1000 setups in certified airplanes meet this by putting the screens side by side, without the center stack between them, which in my mind would be a valid alternative to the G5/D10A I'm thinking of."

Right, that kind of makes sense, so basically if you want a dual screen EFIS from Dynon or Garmin, if you go with headless avionics and put the 2 screens right next to each other, you may be able to satisfy TC that you can safely fly your approaches even in reversionary mode ... since both are enough into your field of view.

If you're not attached to having 2 full screens, you can go the G5/D10A way, which might be good anyway, to have disparate technologies. Or if you put a 7" as a second screen, there may be room for a 650 above/below it?

The dynon transponder does not appear to take grey code in (only connects to the EFIS systems?) ... the latest GTX series from Garmin has an available encoder for purchase.