Please note that this topic is not about flight instruction, TC bashing or any other side notes.

Has anyone read all the TC material regarding external loads and received any official word on what it all means? Specifically I am referring to the following:
CBAAC 0232 dated 2004.06.14
CBAAC 0209 dated 2002.05.31
Policy Letter 165 dated 2004.06.14
AMA 500/10 including Appendix A

As I understand CBAAC 0232, TC is acknowledging that the previous exemptions re passengers (CBAAC 0209), and the current regulations do not address the fact that unless approved by the manufacturer, external loads are considered a major modification to the airframe, thus requiring an STC or LSTC to carry external loads at all - regardless of whether passengers carried.

As we all know, very few operators hold STCs or LSTCs for external loads or even for the various boat and canoe racks that many possess.

What the government is finally addressing, is in fact something that has been going on for many years in Northern Canada and has been previously overlooked. In part I believe this is because nobody has wanted to take a stand on the issue. With the new structure of CARS, everything is all about liability and who's ass is covered, and when.

With the CBAAC 0232 issue on June 06th, the government is politely informing all operators that not only are they intending to remove 703.25 from the CARS and allow the existing exemption to die, they are also pointing out that even now, external loads require an STC or LSTC. If you are hauling a boat for moose season and your operator doesn't possess an STC for either the rack or the boat, your C of A is invalid and you are baaaaad.

What you say???? TC has referred those affected parties to the Airworthiness Manual, and in particular AMA 500/10 including Appendix A.
For those of you have read this advisory, I would like to pose the following questions.

Who may apply for this approval they refer to in the advisory - the AMO? the Pilot? the Operator? a Design Approval Representative?

Is there a guideline this person can obtain so they may inform themselves of all the requirements in the approval process?

Who may conduct the flight testing required and to what standard? Are they required to explore all avenues of the flight envelope with the load in question and if so how will the data be measured? Should they be qualified as a test pilot in case things go awry?

What does the affected aircraft manufacturer have to say about a potentially unlimited supply of under-qualified industry representatives issuing flight manual supplements for their type-certificated airplanes? I am quite sure they would raise quite a few objections on this point.

Does each and every conceivable item an operator might intend to carry require this process or can subsequent approvals to a basic STC be made using less stringent requirements and if so, where might we find the standards for this process?

Every bush operator in Canada should be addressing these issues to their POI in order that we may get some answers. In my humble (or not so) opinion, TC is jumping the gun in trying to correct a mistake without having clearly thought out and addressed the implications of what they are trying to re-regulate. If they are going to change the regulations, somebody better start addressing this issue of standards, and who is responsible for creating them. Eventually it all boils back down to liability.

Your responses, on topic, are welcome.

Cheers,
Snoopy

As Snoopy just very well adressed it, it is a matter of liability. And the ticklish issue of external loads arrises just as Transport Canada promises not to give classes to the companies they audit anymore...

Another way for them to slowly but efficiently give troubles to the operators.

The flight test will have to be conducted by a trained pilot, who in turn will put his full liability upon the flight where such a load will be taken, given that there will always be a way to determine a particular load will not have been tied according to the STC, or other way to decline insurance coverage...

Soon, as they did with the Beech, they will reduce the GW on the Norseman, Otters and Beavers..

I guess ignorance is bliss.

All those years of carrying external loads and to think that I was all on my own with no protection from my folly.

I guess I was just lucky.

However boys and girls you will be safe now, soon there will be no airplanes flying and we can go back to the days of using canoes in the north to transport people and cargo.

Remember how history shows that was a real safe way to do it?

Cat

Obviously Cat has the right idea. There is no valid reason for terminating the exemptions.

Yes, it is a question of liability. Even though the current track record indicates external loads have been safely carried and can even be continued to be safely carried (with a minimum or education), this does not guarantee that they will continue to be carried safely, so TC sees the need to cya. But this is not a valid reason.

However TC does not need a reason, let alone a valid one. The problem for operators is there whether or not it makes sense.

Snoopy, while your plan of action seems very good at first, what you are really trying to do here is make TC play by its own rules and live up to its responsibilities. Which i find unlikely.

But, Canadian government being what it is, it's the other kids ball and bat and we have to play by his rules.

Certainly bringing up all the points you mentioned to the POIs cannot do any harm, and for forms sake should be done regardless. Perhaps at the same time a new exemption can be requested from the minister, this time addressing the matter of STCs and pointing out that aviation safety is not likely to be affected.