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IFR in Canada with single COM

prkaye

Well Known Member
Question - do any of you in Canada have an RV certified for IFR with only a single COM radio?
I was recently told by a Transport Canada inspector that a backup COM radio is required. Based on a careful reading of the regs and of Transport Canada's "Staff Instruction 500-024" (a checklist for inspectors to sign-off on IFR equipment for amateur-built A/C), I believe he is wrong. The Canadian regulations for IFR equipment require redundant "radionavigation equipment", but say nothing about redundancy for COM equipment. I am interested to know if any of you have any experience with dealing with TC on this issue in particular.
Thanks!
 
I haven't done a deep dive into the regs, but I believe you are correct. Single com radio is legal for IFR in Canada as I understand it.

Yes, there is Canadian requirements for radio navigation redundancy that differ from the FARs.
 
Nope but....

I have always assumed you needed two, but thinking about it I've never seen it written. I don't know of any that are single COM and IFR amateur built.

The single failure and be able to continue flight (basically a variation on a theme from 23.1309, the catch all for failures), is the perspective I try to take when looking at these - and how they look at the NAVs.

If I were trying to convince them I'd suggest that the fall back is my second transmitter (the transponder) and the EFC time in every clearance.

Squawk 7600 and follow the lost COM procedure.

Good luck, I fear it may be an uphill fight.

Derek
 
Staff Instruction 500-024, obtained directly from TC, in Appendix A says:
The following table lists the essential IFR equipment and its regulatory reference required to conduct flight in accordance with instruments flight rules.
605.14 - sensitive altimeter adjustable for barometric pressure
605.14 - airspeed indicator
605.14 - magnetic (whisky) compass or a magnetic direction indicator
605.14 - radiocommunication system [minimum = one piece of equipment]
605.14 - radio navigation equipment [minimum = two pieces of equipment]
...
Also,
SIs are guidance documents that provide TCCA employees with specific information and procedures to standardize the delivery of the Civil Aviation Program. SIs are consistent with departmental principles, policies and regulatory requirements.
This seems pretty black-and-white to me.. "radiocommunication system [minimum = one piece of equipment]". I don't see how they could try to argue that two are required given this document.
 
Staff Instruction 500-024, obtained directly from TC, in Appendix A says:

Also,

This seems pretty black-and-white to me.. "radiocommunication system [minimum = one piece of equipment]". I don't see how they could try to argue that two are required given this document.

Yes - much better than my argument!

Derek
 
Phil - I would urge you to probe your thinking more deeply. What is legal is not always what is wise. Flying with the minimum is not always safe, either.

Radios can, and do fail. Having a second radio is just a darned good idea. Having a second radio attached to an antenna mounted in a different location than the COM 1 antenna is an even better idea.

As a case in point, in an RV flight to CYRO at night we were unable to activate the runway lights using the COM 1 with its antenna mounted atop the fuselage. We were able to switch to COM 2 and its belly mounted antenna - this combination got the runway lights turned on.

It is also much, much easier to coordinate communications across two radios. As an example, a departure from CYRP requires the pilot to communicate on 122.8 for Carp, to tune and listen to Ottawa ATIS on 121.15 and then be prepared to talk to Ottawa Terminal on 127.7. One might still be within the vicinity of Carp while communications with Ottawa are initiated. This is exactly the situation where having two radios, while not legally required, certainly is handy. Being able to set up four frequencies (two on each radio) before entering the runway environment is a terrific way to de-escalate pilot workload during a critical phase of flight.

Again, the legal minimum isn't necessary either wise or safe. An extra comm radio doesn't cost very much and adds incredible utility to the aircraft, not to mention redundancy in the event of equipment failure. I frequently use two comm radios in VFR flight, sometimes where NO radio is required. Being penny wise on radios often leaves one feeling operationally pound foolish.
 
I was afraid this thread might turn into a debate about how-much-is-enough for IFR flying and differing comfort levels etc, which was not my intent.
To be clear, I am very likely going to have two radios in my setup, the details of which I am still working through. Rest assured, I have been spending months very carefully thinking through all these decisions.
My reason for posting this question was merely to get some insight on what seems to be inconsistency between the regulatory interpretation between different inspectors at TC, despite what seems like very clear staff instructions. I'm also wondering if there are other things to beware of TC inspectors imposing their own judgements in-place of official TC guidelines.
 
I'm also wondering if there are other things to beware of TC inspectors imposing their own judgements in-place of official TC guidelines.

Like this forum everyone has their own ideas as to what is best in each situation it is also that way with TC inspectors
 
I already had 2 COM radios before starting the VFR Only condition removal process with TC, so the subject never came up. I also don't see anywhere in the CARs or the SI that requires two COM radios.

Like others have said, two is better and this not worth an argument with the inspector. Save that for other issues that will come up because of the inspector's interpretation of the regs. There is a lot of room for interpretation, so there will be others.

As an aside, I think two COM radios are more important in busy environments than simply in IFR. Consider a landing at a controlled airport in a terminal environment. You need to tune in terminal (approach), ATIS, tower and ground frequencies. Having those preloaded across your 2 radios makes the workload so much better. This has nothing to do with IFR.
 
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