Maintenance requirements for privately operated small aircraft used for training

[mirobot200]

Good day,

Sorry if I posted this in the wrong forum... I'm having a hard time pinning down the exact CAR that specifies what kind of operation I'm running and the associated maintenance requirements.

I own a Cessna 150 I purchased for the purpose of facilitating flight training for myself toward a PPL. It is registered as a Private Aircraft. I'm also an AME-E licence holder. I hired a flight instructor through a local Flight Training Unit to provide me the Flight Training Service. The billing is done through the FTU as "Instructor Time". I would like to clarify whether the operation of my aircraft is now considered to be under Part IV of the CARs and commercial, in regards to the applicable maintenance requirements of CAR 571.05 and Standard 625 Appendix C.

My current interpretation:
Per CAR 101.01 (1) definition of "Operator", I am considered as the operator of the aircraft.
Per CAR 101.01 (1) definition of "Flight Training Service", the operation of my aircraft is considered commercial.
Per CAR 406.03 (2), the instructor I hired through the FTU is providing me a flight training service on my aircraft.
Per CAR 406.02, the Part 406 applies to the operation of my aeroplane.
Per CAR 571.05, while I operate my aeroplane for my flight training, only an AMO may perform maintenance on my aeroplane, therefore I may not perform non-specialized Avionics maintenance on my aeroplane.
Per CAR Std 625 App C Engines, As I'm operating pursuant to Part 406, which makes it a commercial operation, I must follow manufacturer hard-time between overhaul on my engine.


Referenced CARs:
CAR 101.01 (1) which states "In these Regulations, ... operator, in respect of aircraft, means the person that has possession of the aircraft as owner, lessee or otherwise;"

CAR 101.01 (1) which states "In these Regulations, ... Flight Training Service, means a commercial air service that is operated for the purpose of conducting flight training;"

CAR 406.03 (2) which states "A person who does not hold a flight training unit operator certificate may operate a flight training service if (b) the trainee is (i) the owner ... of the aircraft used for training."

CAR 406.02 which states "This Subpart applies in respect of the operation of an aeroplane, ... in a flight training service toward obtaining any of the following: (a) for aeroplanes, (i) a private pilot licence."

CAR 571.05 which states "... no person shall perform maintenance on an aircraft operated under Part IV, ... unless the maintenance on that aircraft ... has been performed in accordance with (a) a ... MPM established by the holder of an ... AMO certificate..."

CAR Std 625 App C - Out of Phase Task Listings - 7. Engines - which states "All piston ... engines installed in aeroplanes ... operated pursuant to CAR 406, ... shall be overhauled at the intervals recommended by the engine manufacturer ..."

CAR Std 625 App C - Out of Phase Task Listings - 7. Engines - which also states "Information note: No hard time, including calendar time, between overhauls need be observed in the case of small aircraft reciprocating engines in non-commercial private operation."


Any input would be greatly appreciated!
Thank you.

[photofly]

I own a Cessna 150 I purchased for the purpose of facilitating flight training for myself toward a PPL. It is registered as a Private Aircraft.

Go no further. If it’s registered as private, then it’s not “commercial”. The maintenance requirements are the same as that of any other privately operated aircraft.

As long as you own it in your own name, and not through a company, you may hire an instructor and train in it, and so many members of your family. And since you’re an AME, you can carry out (non-specialized) maintenance.

It’s nice to be able to give someone good news, for a change.


More stringent maintenance requirements arise when someone other than the owner or a member of their family wants to train in an airplane. Then the aircraft must be operated by an FTU and that requires a commercial registration. In point of fact you are not entitled to register an aircraft for commercial operation; only the holder of an Operating Certificate may do that.

[mirobot200]

Thank you for the quick reply! That is a big relief indeed.

A coworker of mine has also just pointed out Standard 571.05 of CARs which states:
"Aeroplanes or helicopters used by approved flight training units (FTUs) are operated pursuant to Part IV of the CARs, while aircraft used commercially are operated pursuant to Part VII of the CARs. Section 571.05 of the CARs is applicable to the performance of maintenance on such aircraft, or on parts installed on such aircraft."

Therefore, as my aircrafts is not operated by the FTU, maintenance requirements of 571.05 do not apply.

Thanks again!

[PilotDAR]

As Photofly has explained simply, your privately owned airplane is not being operated by an FTU, it's being operated by a private individual for their private purposes. It's not being operated commercially, as there is no commercial transaction for the operation of the plane. So TC has no interest in "regulating the operation of your plane beyond the minimum expectations for a private airplane.

On the more practical side, your 150 is not being operated with the frequency of a commercial or flight training airplane (it's not flying thousands of hours a year), so maintenance at a commercial intensity is not justified.

[mirobot200]

Thanks PilotDAR, that makes perfect sense. I think I was initially misled by the CAR 101 definition of a Flight Training Service being a commercial service, and then I read too much into the other regs.

[Heliian]

Yes, a flight training service is a commercial service, the planes they operate are registered "commercial".

Your plane is private and stays that way even when the instructor is in there.

They could not use your plane in their operation, you are just hiring the instructor.

Part 4 is mostly flight training. Part 7 is other commercial operations. 702, 703, 704, 705 are all different types of operations. They are all commercial services.