external load stc

[Redneck_pilot86]

Wolverine Air had an LSTC for canoes on the 185 with Aerocet floats, they might point you in the right direction.

[lost in the north]

Thanks for the info

[PilotDAR]

Is the STC's only for commercial operators though ? A private guy can still do as he pleases correct ?

This is one of those things where I though I knew the answer, but I was not sure how. I did my homework...

Following the logic path:

Your floatplane is Type Certificate (or STC) approved on floats. Presumably, that approval makes no mention whatever of things attached externally to the floats. So operating the plane with no external load keeps the aircraft in within the description of;

airworthy means "safe for flight AND in conformity with the type design."

Now you tie on a canoe, does the plane still conform to its type design? No. So it's a modification.

When you modify your aircraft, you must determine if the mod is major or minor. Using Appendix A of Std 571, you will ask yourself in part;

(d) Performance and Flight Characteristics

"Does the modification or repair involve alterations that:

(1) significantly increase drag or exceed aerodynamic smoothness limits?

(2) significantly alter thrust or power output?

(3) affect stability or controllability?

(4) induce flutter or vibration?

(5) affect the stall characteristics? "

'Could be yes to all five of those - so it's a major mod for sure.

So, in accordance with Std 571.06;

"(2) The criteria to be used to determine which data applies to modifications and repairs is as follows:

(a) All major modifications and major repairs shall be performed in accordance with either “approved” data or “specified” data......"

So you need approved data, which is an STC (I have never seen "specified" data which would cover this type of mod).

CAR 703 adds an unfortunate layer of confusion to this with;

"Carriage of External Loads

703.25 Except where carriage of an external load has been authorized in a type certificate or supplemental type certificate, no air operator shall operate an aircraft to carry an external load with passengers on board."

But as explained to me by a very helpful (seriously, not sarcastic) TC inspector, That regulation is an added requirement for the air operator, not a let. It essentially says that if you're going to carry an external load, and passengers, the approval for the external load must be an STC, and presumably would state that passengers were permitted (or at least not prohibit pax).

This should be viewed similarly to flying with a door removed. That requires either an OEM Flight Manual reference, an STC, or for some aircraft, be on a government list (the specified data thing).

So, as I understand it, if you want to carry an external load on a fixed wing, it will require an STC, or similar authority, regardless of how the plane is operated, and further to that, air operators may require additional authority.

My understanding (from attending the TC meeting where this was all presented), the straw that broke the camel's back for TC was a fellow who attempted to fly huge moose antlers out as an external load on a PA-18 sized plane. He was fatally unsuccessful. TC decided that turning the blind regulatory eye, to what has always been a requirement for an approval, had to end.

[retired_flyer747]

So the way I have tied my canoe on my 185, almost every weekend since the early '70's, now requires me to pay an engineering company thousands of dollars to design, and thousands more for transport Canada to approve?

[Cat Driver]

.

[retired_flyer747]

Indeed.
So I guess I now need an stc that certifies the ropes I tie my canoe on with?
I suppose I need one to be able to leave my dock lines tied to my float struts too?

[Cat Driver]

.

[CID]

edited....you know what? I just don't care.....

[lost in the north]

Cat driver, why don't you you go play with your sailboat...you are a negative old man that I am tired off.Please go hijack someone else's post.We all understand that you are the best and TC did you wrong!Let it go..

[PilotDAR]

So the way I have tied my canoe on my 185, almost every weekend since the early '70's, now requires me to....

Or viewed another way, unless there was an STC approval, the carriage of the canoe was never approved, and still is not. TC never took much interest, 'cause everyone was doing it. A few people did stupid things, and crashed, and TC took more interest.

Now, the TC regulations do not tell you that you can carry an external load without an approval. What has changed since the '70's? (other than we're talking about it).

I've carried canoes - because everyone else did, not because I knew that I had the approval, which I should have had all the way along....

[bronson]

You know in the early 80s, I a friend told me about a conversation between two TC types that he had overheard in the s. terminal (YVR) coffee shop. " you could INTERPRET this to mean" . Sure enough within a couple of months we had an inspector wandering around the dock in YPR telling people to untie the boats, you need an STC. I told him to f**k off.
That is to my knowledge how we got where we are with all this.



Also: "Cat driver, why don't you you go play with your sailboat...you are a negative old man that I am tired off.Please go hijack someone else's post.We all understand that you are the best and TC did you wrong!Let it go.." don't doubt that you are frequently "lost in the north"

[retired_flyer747]

So the way I have tied my canoe on my 185, almost every weekend since the early '70's, now requires me to....

Or viewed another way, unless there was an STC approval, the carriage of the canoe was never approved, and still is not. TC never took much interest, 'cause everyone was doing it. A few people did stupid things, and crashed, and TC took more interest.

Now, the TC regulations do not tell you that you can carry an external load without an approval. What has changed since the '70's? (other than we're talking about it).

I've carried canoes - because everyone else did, not because I knew that I had the approval, which I should have had all the way along....

So the exemption from the requirement to obtain an stc, issued in 2009, is no longer legal?
When was that repealed? At that time, transports official statement was that there was no risk to public safety by the exemption, so what could have possibly changed in the past 4 years?

[PilotDAR]

It is my opinion, and subject to a more qualified response, that the TC exemption in the case of external loads was associated with evidence of operator experience, a procedure being followed, and a safe record. My understanding is that such exemptions are not open ended, but rather intended to give a grace period, to make arrangements to comply with the "new" regulation. My understanding is that the exemption period has expired.

I have had a number of inquiries about doing such external load approvals in the last year. Regardless of the experience and success of the prior operation, an STC is still an approval, and TC requires it to follow the process. It is unfortunate that there is no TC "mechanism" for a more simple approval, this would be the perfect candidate.