Amateur Built Maintenance Question

[Howitzer]

So i'm looking at an amateur built aircraft, and i'd like it to have more HP. An additional 70 more HP to be exact. What are the legalities in TCs eyes to swap an engine out on a homebuilt?

[Taiser]

Not sure if the rules have changed but the amateur built (and owner maintenance class) is running on a Special CofA and the engine is listed with TC. Change the motor and the Special CofA is rendered invalid. This was done on purpose so they can track what's going on.

Not a big deal, just have to notify TC and some paperwork. Probably have to get MD-RA involved to sign off on it, new W&B, etc. I just got my final inspection paperwork for my homebuilt from MD-RA and they have quite a bit of stuff they want covered off before signing off on the final...

This was from COPA...

A couple of COPA members have recently found out about an interesting limitation in the CARs. If you put a different type of engine in your owner-maintenance or amateur-built aircraft you have to get a new Special Certificate of Airworthiness!
The Special CofA in these two classes specifies the engine type on that document. This means that if you change the engine type or model, the Special CofA is rendered invalid and you need to apply to Transport Canada for a new one. This isn’t an oversight; Transport Canada purposely put this in the CARs so that they could keep track of the engines installed in Canadian aircraft.

[AirFrame]

You will need to notify TC and they will evaluate and decide whether an inspection is required. If so, they will carry one out. Then you'll get a new Special C-of-A listing the new engine. Same goes for changes to anything affecting airworthiness or aircraft performance.

MD-RA is not involved beyond the initial inspection and certification of a new Amateur-Built Aircraft.

Oh, and part of getting TC to approve it will be showing TC why you think it's acceptable to add the additional power (and possibly weight) of the larger powerplant to your airframe. Some form of analysis showing that the engine mount can take the additional load at the same G limits, that the CG won't exceed aerodynamic limits, etc. will be required. You can't just say "I want to change the engine" and go do it.

[Jungle Jim]

There will also be a flight test period specified as well.

Jim

[iflyforpie]

Can you up gross too? I know that with the initial built, you have to declare your max gross and can't revise it later.

I know that structurally (including engine mount) mine can take up to 2000 lbs and 160 hp... but its at 115 hp and 1600 lbs now. If I ever put a bigger engine in, I'd have no useful load...

[Jungle Jim]

I was able to increase the gross weight of my homebuilt but I had to back it up with calculations to show the wing would not be overstressed. It was a major exercise, but not impossible.

Jim

[AirFrame]

Can you up gross too? I know that with the initial built, you have to declare your max gross and can't revise it later.

You can, as Jim mentioned.

I know that structurally (including engine mount) mine can take up to 2000 lbs and 160 hp... but its at 115 hp and 1600 lbs now. If I ever put a bigger engine in, I'd have no useful load...

As long as you have paperwork to support the increase (preferably from the manufacturer of the kit, but an engineer's calculations are good too) I'm told the change isn't that difficult. You'll need a flight permit to perform a climb test at the new gross weight, then you file the paperwork and get mailed a new Special C-of-A with the increased GW shown.

[Jungle Jim]

I found that TC was quite reasonable to deal with once they had the hard data. Also when I got my Stinson 108-3 and I noticed the W&B was wrong, I weighted the plane redid the W&B and submitted to them. They told me I wasn't qualified to do this on a certified aircraft since I wasn't a Cdn certified Aircraft Maintenace Engineer. I pointed out that the current W&B was done by a certified person and was wrong. I am a P. Eng, and submitted them the correct W&B so they had a decision to make. Stick with the wrong one done by someone they endorsed, or the correct one from a P. Eng. They saw common sense and had me stamp the W&B and re-submit. All was good.

In short if you have the data they will accept it.

Jim

[AirFrame]

I am a P. Eng, and submitted them the correct W&B so they had a decision to make. Stick with the wrong one done by someone they endorsed, or the correct one from a P. Eng. They saw common sense and had me stamp the W&B and re-submit. All was good.

Now that's interesting... And that's on a certified aircraft as well. Need to make sure I still have my stamp somewhere...

[Heliian]

I found that TC was quite reasonable to deal with once they had the hard data. Also when I got my Stinson 108-3 and I noticed the W&B was wrong, I weighted the plane redid the W&B and submitted to them. They told me I wasn't qualified to do this on a certified aircraft since I wasn't a Cdn certified Aircraft Maintenace Engineer. I pointed out that the current W&B was done by a certified person and was wrong. I am a P. Eng, and submitted them the correct W&B so they had a decision to make. Stick with the wrong one done by someone they endorsed, or the correct one from a P. Eng. They saw common sense and had me stamp the W&B and re-submit. All was good.

What kind of certification and registration and how big was the change and what decade was this?

[Jungle Jim]

With respect to the Stinson, it was about 2005. The changes to the amateur built aircraft were in the mid to late 90's. I don't imagine much has changed at TC since the same people are still working at 2100 Yonge St.

Jim

[Heliian]

With respect to the Stinson, it was about 2005.

So you reweighed the a/c? That's odd that they would let you do that as there would be no calibration on the scales and it's not elementary work or serviceing. Unless...you were not under a normal c of a. It's a very curious case.

[GyvAir]

So you reweighed the a/c? That's odd that they would let you do that as there would be no calibration on the scales and it's not elementary work or serviceing. Unless...you were not under a normal c of a. It's a very curious case.

This is interesting. As far as the scales are concerned, having access to three suitable scales with current calibration status shouldn't be too difficult. Any physical work or servicing required to weigh a Stinson would be doable under elementary maintenance rules, wouldn't it? Things just get fuzzy when it comes to who can do the calculations, amendments, log entry, etc.

[iflyforpie]

The physical work is fine no matter who does it.. unless it is a Commercially Registered aircraft or Specialized Maintenance (NDT, assembling a geared crank case, welding, etc)... its the authority to sign it off at the end that is the problem.

[Jungle Jim]

Actually, I did have the scales calibrated. I forgot to mention this. We have the calibration guys here at work fairly regularly.

Jim

[plhought]

....

My brother has a P. Eng with his field geomatics/surveying...that doesn't make him qualified to certify work on an aircraft....

He thinks the above story is absurd and not in keeping with the ethical onus that all Engineers would abide to. He's a pilot as well and isn't oblivious to weight and balance stuff either.

...but I suppose if TC only needs a couple angry pinky-fist bangs on the table to sign a maintenance release then all the power to ya.

Sorry Jim, it's kind of disappointing. Even if ya did most of the weigh yourself I think it would have been prudent to at least have an AME take a peek at your paperwork. Or just swallow the couple bucks to have an AME swing by when you were weighing it to make things legit.

[Cat Driver]

Or just swallow the couple bucks to have an AME swing by when you were weighing it to make things legit.

The way I read what he said TC was O.K. with what he did and accepted it.

So why is it not legit?

[AirFrame]

He thinks the above story is absurd and not in keeping with the ethical onus that all Engineers would abide to. He's a pilot as well and isn't oblivious to weight and balance stuff either....
...Sorry Jim, it's kind of disappointing. Even if ya did most of the weigh yourself I think it would have been prudent to at least have an AME take a peek at your paperwork. Or just swallow the couple bucks to have an AME swing by when you were weighing it to make things legit.

Engineers are required to evolve and adapt their skills as time goes on, sometimes completely changing their field of expertise. Learning how to do a Weight and Balance should be well within the skillset of anyone holding a Canadian P.Eng. If there's a P.Eng. out there who can't handle the math necessary to document a Weight and Balance, they probably shouldn't be practising engineering either.

The difficulty in performing a W&B isn't in the math. It's in having the facilities, equipment, and knowing the tricks to get the airplane into flying attitude with a minimum of effort while balancing it on scales.

[Heliian]

Engineers are required to evolve and adapt their skills as time goes on, sometimes completely changing their field of expertise. Learning how to do a Weight and Balance should be well within the skillset of anyone holding a Canadian P.Eng. If there's a P.Eng. out there who can't handle the math necessary to document a Weight and Balance, they probably shouldn't be practising engineering either.

The difficulty in performing a W&B isn't in the math. It's in having the facilities, equipment, and knowing the tricks to get the airplane into flying attitude with a minimum of effort while balancing it on scales.

It doesn't matter who does the work, ever, it's the signout that counts. The aircraft in question is obviously not in the normal category or it's c of a would be invalid.

[Howitzer]

So if you were to import a popular kit from the US and it has a Gross weight that is specified my the kit manufacturer, you can crunch the numbers as per CARS V and come up with a new GTOW?

[robertw]

Hmmm... I guess regulations and standards don't matter anymore? CAR 571 App. C (1)(b) requires that all weight and balance reports for type certificated aircraft be certified with a maintenance release. Last time I checked, only an appropriately rated AME could provide one of those.

http://www.tc.gc.ca/eng/civilaviation/r ... sc-253.htm

[plhought]

Or just swallow the couple bucks to have an AME swing by when you were weighing it to make things legit.

The way I read what he said TC was O.K. with what he did and accepted it.

Like I said - A couple of pinky-ring-fist bangs were good enough for TC. All the power to him I suppose.

Learning how to do a Weight and Balance should be well within the skillset of anyone holding a Canadian P.Eng. If there's a P.Eng. out there who can't handle the math necessary to document a Weight and Balance, they probably shouldn't be practising engineering either.

I would expect the same. I don't think the math & principles would be challenging for many fields. I've got a pretty good handle on survey tech as well, but I wouldn't allow myself nor expect others to allow me to sign off wellsite plans. There's P. Engs and LSs for that.

So if you were to import a popular kit from the US and it has a Gross weight that is specified my the kit manufacturer, you can crunch the numbers as per CARS V and come up with a new GTOW?

Absolutely - you could perform a typical weight and balance amendment. Just do the math and changes within your existing weight and balance and you'd be good to go (IE: remove 50lbs and arm/station xxx.x and add 32 lbs to arm/station xx ). As things get major though it's probably more prudent to reweigh.
I'm not a pro with Amateur-Built aircraft nor regs, but if the kit itself specified what the weight and balance change is (in my world a STC would typically include this information) then it's even easier.
If you were installing something not type specific like a avionics package or something, then you are more than welcome to weigh what ya take out and where...and do the opposite on install. Same applies on certified aircraft...provided it's certified by an appropriately rated & trained AME.

...I am a P. Eng...

This may not apply to you Jim in respect to your specific field but I place it here simply as an example.

The Engineering and Geoscience Professions Act

Printed April 2012
CODE OF ETHICS



Schedule

CODE OF ETHICS

(established pursuant to section 20(1)(k) of the Engineering and Geoscience Act)

Preamble

Professional engineers and geoscientists shall recognize that professional ethics is founded upon integrity, competence, dignity and devotion to service. This concept shall guide their conduct at all times.

Rules of Conduct

1 Professional engineers and geoscientists shall, in their areas of practice, hold paramount the health, safety and welfare of the public and have regard for the environment.

2 Professional engineers and geoscientists shall undertake only work that they are competent to perform by virtue of their training and experience.

3 Professional engineers and geoscientists shall conduct themselves with integrity, honesty, fairness and objectivity in their professional activities.

4 Professional engineers and geoscientists shall comply with applicable statutes, regulations and bylaws in their professional practices.

5 Professional engineers and geoscientists shall uphold and enhance the honour, dignity and reputation of their professions and thus the ability of the professions to serve the public interest.

AR 150/99 Sched.;37/2003;8/2005

[AirFrame]

So if you were to import a popular kit from the US and it has a Gross weight that is specified my the kit manufacturer, you can crunch the numbers as per CARS V and come up with a new GTOW?

For an Amateur-Built Aircraft, anyone can. You just need to end up with a document that explains why your aircraft is airworthy at the new (presumably increased) gross weight, and someone in Transport has to accept its validity. Then you'll have to do a climb test at that gross weight.

2 Professional engineers and geoscientists shall undertake only work that they are competent to perform by virtue of their training and experience.

Training comes through many avenues, including classroom, self-study, and practical application. Taking the case above at face value, the owner had a W&B completed by a certified, document carrying AME that was incorrect. He also had a W&B completed by a competent P.Eng that was correct. For all we know, the P.Eng just saw a math error in the original W&B, corrected it, and re-submitted it.

4 Professional engineers and geoscientists shall comply with applicable statutes, regulations and bylaws in their professional practices.

Sometimes you need to ask for a variance or exemption from the same statutes, regulations, and bylaws... Going to Transport and asking for the variance would seem to be prudent.

Keep in mind that we're not talking about sizing a structural repair on a wing spar. We're looking at a weight and balance report, which could be compared to other weight and balance reports from similar aircraft. As long as the request wasn't for something that's completely out-to-lunch (same gross weight, same CG limits, minor change to empty CG) then i'm almost thinking that this is something that should be covered under elementary maintenance that any owner could do.

Only almost, because i've seen the W&B math confuse more than a few pilots...

[plhought]

Whatever.

I give up. I tried to cover both sides in my argument but whatever.

It's obviously one special unwritten rule apparently for these P. Eng's and one for everyone else when it comes to you guys and TC. I don't understand how any of you guys (or TC) think this is kosher.

God forbid an insurer gets involved. What if something happened? It's with this kind of stuff that an insurer would leave you high-and-dry should an accident happen, even with some special "variance" from TC (of which there is no legal basis or statutes for). I'm sorry you had a bad W&B and that's unacceptable - as it would be if it came from a P. Eng. You could always go back to said AME and get them to correct it...

Once again... (I should mention this is from Alberta's Professional Engineers Act)

(3)
Notwithstanding subsection (2), a professional engineer,
licensee or permit holder may affix a stamp, seal or permit number,
as the case may be, to a plan, drawing, detail drawing,
specification, other document or reproduction prepared by other
persons if the professional engineer, licensee or permit holder
completes a thorough review of and accepts professional
responsibility for that plan, drawing, detail drawing, specification,
other document or reproduction.
RSA 2000 cE-11 s3;2007 c13 s5;2011 c3 s5

Replace the above "professional engineer", with "AME" and you basically have the essence of 571.10. So apparently your rules are good enough for you. But the Aeronautics Act (and by virtue, CARs) isn't. What horse****.

Just to be clear, I'm disappointed with the above specific case but more-so with TC. I'm all for sensibility and rational ideas when it comes to non-AME's performing work on aircraft. I've also seen f***ing outstanding work on amateur-built and owner maintained aircraft. I know there's more then competent individuals who have great skills and training by virtue of whatever profession. But there has to be a line. Regs regarding Elementary Maintenance and Scope of Work is there to protect everyone - not to encourage some bizarre sort of AME labour protection...as some think.

You can always power through that ICS course whilst working on and flying your aircraft. Get an AME to watch/certify your work and sign your required tasks and in a couple years you'll have your own AME license. 4 years goes by quick nowadays. Then this is all moot.

Or just go amateur-built and make all us Certified A/C owners jealous with all that fancy and fun kit .

[Bede]

Part of being a professional is having the judgement to decide what you are qualified to do and what you aren't . I know an engineer and all he does is design industrial greenhouses. Is there a "greenhouse engineering" discipline? No there isn't. A client came to him one day and asked him to design a greenhouse. He read some books, designed the guy a greenhouse, and stamped it. Referral led to referral and now that's all he does.

How is this different than an P. Eng. studying up on how to do a W&B and correcting it? Or for that matter, designing their own airplane?

Keep in mind, as per the AA, TC can OK anything as long as they feel it is safe. In this case TC felt it was safe for a PEng to stamp a weight and balance.