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Thread: Building EAB vs. Restoring Certificated?

  1. #11
    Quote Originally Posted by FlyingRon View Post
    There's no weight limit in EAB. Perhaps you mean Light SPort?
    I don't know what the reference to "weight limit in EAB" has to do with the problem of this post, but I think raytoews is describing Canadian "Owner Maintenance". Many, many years ago I went to a seminar at Airventure with the subject "Special Flight Permit, Owner Maintenance" that was available in Canada. It may have been changed since then, but at the time it was limited to certified airplanes of the size that we now call Light Sport. There was a specific list of exactly what airplanes were allowed to enter OM. It was like putting a certified airplane into the EAB category. You could do ANYTHING you wanted to do to the airplane. One of the warnings was, you can NEVER go back to certified from OM.

    I would be interested to learn how this works for Canadian airplane owners.

    At the time I was hoping that the FAA may allow something like that, but apparently not. In fact, the Airventure Notam in the last several years has this mention for Canadian Pilots:
    "Canadian pilots flying aircraft issued a Canadian 'Flight Permit-Owner Maintenance' are prohibited from flying in the U.S."
    I guess the FAA does not want anything to do with the idea.

  2. #12
    FlyingRon's Avatar
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    There's no weight limit on OM either. OM is approved on an aircraft by aircraft basis (there is a list of previously approved models in the docs but that's not a requirement to apply). I'm pretty sure ray was referring to light sport rather than EAB in his comment.

    The COPA has a pretty good document on Owner-Maintenance. You have to be a member to download it from your site, but (older) copies are kicking around on the internet. One of the biggest downsides is they aren't legal to fly into the US. It's also a long and expensive process to return back into original category. Also, by default OM aircraft are Day VFR only, but you can petition to get those restrictions lifted. Note that while the owner is allowed to perform (or certify) maintenance himself, that doesn't really change the rules for doing the maintenance (it's not the zoo EAB is in the US).

  3. #13

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    Quote Originally Posted by PJZajkowski View Post
    Canadian "Owner Maintenance". Many, many years ago I went to a seminar at Airventure with the subject "Special Flight Permit, Owner Maintenance" that was available in Canada. It may have been changed since then, but at the time it was limited to certified airplanes of the size that we now call Light Sport. There was a specific list of exactly what airplanes were allowed to enter OM. It was like putting a certified airplane into the EAB category. You could do ANYTHING you wanted to do to the airplane. One of the warnings was, you can NEVER go back to certified from OM.

    I would be interested to learn how this works for Canadian airplane owners.
    There is a path from OM back to certificated status, I doubt it's ever been used or ever will be used. And you can't do ANYTHING you want to the aircraft, there are limits. It's intended to be a method of operating airplanes that are orphaned or mostly unsupported with scarce or no spare parts.

    Otherwise, it works like this: (This is a neat article)

    Owner-Maintenance
    by Brian Clarke, Civil Aviation Safety Inspector, Operational Airworthiness, Standards, Civil Aviation, Transport Canada

    Aircraft owners can apply to have their aircraft’s ‘normal’ certificate of airworthiness replaced by a Special Certificate of Airworthiness - Owner-maintenance. When an aircraft is in the owner-maintenance classification the aircraft owner—if they are a pilot—can perform and release maintenance on their own aircraft.

    The first Special Certificate of Airworthiness - Owner-maintenance was issued in 2002 and there are now about 550 owner-maintenance aircraft registered, out of a Canadian non-commercial fleet of over 20 000 aircraft. The program is clearly not wildly popular, perhaps because owner-maintenance aircraft are not allowed by the Federal Aviation Administration (FAA) to fly in the United States. Nevertheless, questions to Transport Canada Civil Aviation (TCCA) related to owner-maintenance are frequent. The purpose of this article is to review some of the significant specifics on the subject of the owner-maintenance classification.

    Under Canadian Aviation Regulations (CAR) Standard 507.03(6), the Special Certificate of Airworthiness - Owner-maintenance was established to allow the non-commercial use and enjoyment of relatively simple, generally older aircraft for which certified parts were scarce and support from the manufacturer limited. After the classification had been in place for a few years, owners of owner-maintenance aircraft were granted a Ministerial Exemption to CAR 605.03(1)(a), (b) and (c)—the requirement to have and carry a Certificate of Airworthiness. The exemption has the effect of allowing flight of an owner-maintenance aircraft that is no longer in conformity with its type certificate, and thus allows some degree of modification of the aircraft and the installation of equipment that was not specified by the manufacturer. The letter of exemption is carried aboard the aircraft and effectively becomes the aircraft’s airworthiness certificate. We refer to aircraft with a Special Certificate of Airworthiness - Owner-maintenance and those flying under the Exemption as “owner-maintenance classification” aircraft.

    Owner-maintenance aircraft, just like other aircraft, have to be continuously maintained in accordance with a maintenance schedule conforming to CAR 605.86. Some maintenance tasks required by the schedule may require skills or equipment that the owner/pilot does not have; when the owner/pilot is not qualified or equipped to perform a required task, he or she can and should contract the work to a qualified person or organisation. In these instances, an Aircraft Maintenance Engineer (AME) or Approved Maintenance Organisation (AMO) can and should perform and release work on owner-maintenance classification aircraft.

    Maintenance on owner-maintenance aircraft has to be performed in accordance with CAR 571.02, which calls for proper practices and use of the correct tools, manuals and instruments; records have to be kept in accordance with CAR 507.03 and 605.92. All modifications and repairs to owner-maintenance aircraft must be performed in accordance with at least “acceptable data”, as defined in CAR Standard 571.06. This may seem a lower bar than the “approved data” or “specified data” required for major modifications to aircraft maintained to a “non-Special” Certificate of Airworthiness, but it does not allow the unfettered installation of inappropriate parts or radical modifications.

    CAR Standard 507.03(6)(e) lists the eligibility conditions for the owner-maintenance classification. An owner-maintenance aircraft cannot be modified beyond those limits. For instance, a constant speed propeller or amphibious floats cannot be installed on an owner-maintenance or “Exemption” aircraft, because the aforementioned standard limits eligibility to, among other things, aircraft with fixed pitch props and fixed landing gear. Significant modifications that affect the structural strength, performance, power plant operation, or flight characteristics of the aircraft have to be reported to TCCA before flight.

    A Civil Aviation Safety Inspector (CASI) who is asked to consider the issue of the letter of exemption, or indeed any flight authority, has to verify that the aircraft is safe for flight. The determination that the aircraft is safe for flight is made by examining records and documents provided by the owner, but the CARs (and normal prudence) do not require that a CASI accept the owner’s declarations without review or confirmation. As a delegate of the Minister of Transport, the CASI has the authority to personally inspect or cause to be inspected any aircraft for which an application for flight authority has been made. Any personal inspection by a CASI of an owner-maintenance aircraft will be to the extent necessary to verify that the aircraft is as described in the documentation and is free of obvious defects.

    In the simplest case of an aircraft having a valid Canadian Certificate of Airworthiness transitioning to owner-maintenance, a CASI’s inspection is very rarely required.

    CASI Inspection

    A CASI’s inspection will normally be conducted subsequent to unsatisfactory document review or if the aircraft is being imported, has not been operated in the last five years, or does not conform to its type design.

    Aircraft can be imported directly into the owner-maintenance classification and an aircraft intended for owner-maintenance that does not meet its type design on import may be issued with the Ministerial Exemption mentioned above. Well-meaning people have come to the mistaken conclusion that the classification and exemption together allow the straightforward import and registration of disassembled aircraft, damaged aircraft and aircraft with incomplete technical records as well as heavily modified aircraft. This is not the case.

    Consistent with the import requirements for other aircraft, it is reasonable for the Minister to require that an inspection up to equivalent-to-annual of the imported aircraft be carried out and if necessary that it be carried out by an AME. The CASI may require that a defect list be compiled and cleared, followed by inspecting the aircraft him or herself.

    Lastly, it is important to note that while reversal of the owner-maintenance registration is possible it will not be easy or cheap.

    Web links:

    Lists of aircraft that have been determined to be eligible for owner-maintenance classification:
    http://www.tc.gc.ca/eng/civilaviatio...507sh-1837.htm and
    http://www.tc.gc.ca/eng/civilaviatio...ation-2752.htm


    Not sure when this article was written but it's interesting to note that less than 3% of the non-commercial Canadian fleet was operating under the OM rules. At present, the FAA does not recognize canadian owner maintained aircraft and therefore operation in the US is prohibited. There is something similar being discussed in the US. Nothing published yet.

  4. #14

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    I would question that 3% must be quite old.
    For me it has been a godsend. I don't think I would have kept my Cheetah if it weren't for OM.
    The fear is it will devalue an airplane. If I was selling maybe but that isn't going to happen.
    I have done a lot of minor modifications to make it an easier airplane to maintain.
    One restriction is we cant violate the original type certificate ,,,,without the permission of the minister.
    I assume anything could be done with the appropriate paperwork (engineering).

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