External Loads

[wrenches and radios]

Do I understand it correctly that the excemption from the restriction on external loads has now expired and we now need a STC/LSTC to do what we've been doing for years?

Does anyone know where I might get a good (read inexpensive) STC/LSTC?

[Flybaby]

Why does "External Loads" sounds so dirty.

[Cat Driver]

Why does "External Loads" sounds so dirty.

Because the practice is dangerous and must be regulated......???

Why just the very thought of tying anything on the outside of an airplane has to be cause for concern.

[wrenches and radios]

Yes they are making it a major mod. Has anyone ever heard of a pilot installing a major mod? sounds like the ops guy's can't handle it so thier tring to turn it over to the maintenance guys! I'm an engineer too and any other major mod I've been involved with might have the pilot turning a knob but not boltting, or in this case, strapping,the whole thing together. Am I right then? do I now need a L,STC??

[phillyfan]

The way it was worded to me in my recent dealings with TC was that the exemption has run out and that any external load unless it's effect on AC performance is negligable needs an STC. The question now is how many STC's will an opertor need? We fly all kinds of external loads Canoes, boats, lumber, skidoos, shit tanks etc. etc.
The real laugh is that less than 10% of operators complied with the requirements laid out in the exemption with regards to Tracking forms and proving flights. Those operators were not punished in any way. So why did we bother doing things legit. I'm guessing there will also be no reprecussions for not having the STC either. Just save your time and money like everybody else will. Keep flying them until TC gets there shit together.

[CD]

It does indeed appear that the exemption to 703.25 has expired and has not (yet?) been renewed:

Advisory Circular 0232R - Carriage and Reporting of External Loads Carried - Exemption to Section 703.25 and Paragraph 605.03(1)(b) of the Canadian Aviation Regulations
Exemption from paragraph 605.03(1)(b) and Section 703.25 of the Canadian Aviation Regulation (expired)

However, it is not clear if a revision to 703.25 has yet been accepted through the CARAC process. The only time that I can locate an NPA to 703.25 (and its risk assessment) being introduced was at the October 2005 Part VII Technical Committee Meeting, when the NPA was withdrawn:

NPA 2005-043
CAR 703.25 - Carriage of External Loads - WITHDRAWN

A. LaFlamme of ALPA requested to be on record as being opposed to the process being used.

G. Morin (Transport Canada, Aircraft Certification) requested that it be in the Decision Record that the Aircraft Certification Branch wants the NPA to be accepted and the dissents to be dealt with as they are received by TCCA. He also advised that he wanted it on record that the Aircraft Certification Branch is opposed to the withdrawal of the NPA.

P. Foster of ACPA requested that the Decision Record state that the Technical Committee rejected the NPA and the Risk Assessment as they did not adequately address the issue.

F. Reinhardt undertook to report to CARC that there was a general consensus that the process was flawed (with the exception of TCCA – Aircraft Certification Branch).

On the following day of the meeting (October 19th), M. Gaudreau indicated that he wanted to re-open this issue. He suggested that there may be a future Joint Part V, VI and VII Special CARAC Technical Committee meeting on this subject only. M. Gaudreau undertook to table this issue at the January 2006 CARC meeting.

[Cat Driver]

shit tanks etc. etc.

What one needs to do with that external load is drop it on Tower C in Ottawa and it will be delivered to the right place to get it filled up real fast.

[Hornblower]

The external load can’t really be a modification, and certainly not a major mod. If that was the case, a maintenance release would be required each time it was installed and removed. It is not an alteration of an aircraft any more than an internal load. It’s just cargo on the outside.

How bizarre is it that 703.25 requires an STC’d device to carry external loads when passengers are on board, yet without passengers onboard the aircraft is good to go without an STC? Holy crap, it’s either a major mod or it’s not … it’s just as illegal to fly an aircraft that has been modified (without approved/specified/acceptable data) without passengers as with them. So what they are in effect saying in the rule is: that an external load is not a mod. I agree

Since they (the rule makers) have no clue, why rush out and get an STC. I agree with Phillyfan, in any case you could never approve all the different makes/models of canoes, boats, lumber, household appliances, etc. There’s hundreds of different types/sizes canoes alone!

Gogal Air Service case.

A mix of old and new, but an interesting read, it appears the appeal panel got it mostly right.

http://www.tc.gc.ca/civilaviation/regse ... gogalA.htm

[Bushav8er]

The key to the current regs (703.25) is with passengers onboard. If you want to carry pass and an external load, the ac has to be type certified for external loads or STC'd.

In most cases, the DHC2/DHC3 are ok, for canoes/lumber, as many were approved in their Type Certificates (A-22, now held by Viking) - but get a copy of the paper work to be sure.

With some searching you can find an STC/Holder for your aircraft here -

http://www.tc.gc.ca/aviation/applications/nico-celn/

it’s either a major mod or it’s not

It's ok to kill yourself...but not paying customers.

[Hornblower]

Not really. It's inconsistant for the regulator to authorize an aircraft for flight with an unapproved mod, and by saying that you need an STC while carrying passengers is the same as saying that the carriage of an external load is a mod, ... and flying with an unapproved mod with no passengers is OK??? A serious inconsistancy here.

[Cat Driver]

I can not imagine anyone even thinking of tying cargo on the outside of any airplane....they were designed to put your cargo inside them.

Does Air Canada tie cargo to the outside of their airplanes?

TC is only looking after your safety and to try and argue with anything concerning safety is unprofessional, not to mention showing disrespect for your regulator.

WTF is with you idiots anyhow?

[freakonature]

phillyfan made reference to a skidoo externally loaded on an aircraft. If someone has a picture of that being done, can you post it?

[MUSICMAAN]

Just save your time and money like everybody else will. Keep flying them until TC gets there shit together.

Amen to that!!

[wrenches and radios]

As I see it what we really need is to have a special cert of airwortiness for external loads with all the restriction that go along with it. when the role of the aircraft changes the normal c of a is back in force. This is the only air tight solution to all the hot air TC might blow our way.

[HS-748 2A]

As I see it what we really need is to have a special cert of airwortiness for external loads with all the restriction that go along with it. when the role of the aircraft changes the normal c of a is back in force. This is the only air tight solution to all the hot air TC might blow our way.

That does seem sensible W&R.. Good thinking. It could fall under 'Aerial Work' in the regs.
Guess they're not paying us to iron this out though are they...

'48

[1000 HP]

Here's a couple of nice ones. I left the really raunchy ones out..

[1000 HP]

Hey, and shouldn't this thread be under bush flying? We're getting bored over there.

[Driving Rain]

phillyfan made reference to a skidoo externally loaded on an aircraft. If someone has a picture of that being done, can you post it?

When a skidoo or any motorized toboggan is loaded in a Beaver they are placed in the doorways both main doors are removed so therefore part of the load is external. It's the same with some refrigerators.

It seems some in the regulatory area are trying to subvert the intent of the law here. They count on the fact that when they charge you they hope you are unaware of the regs and or it's intent. For what end they do this I do not know.

[Oil Burner]

Quite often, when a skidoo is needed at a trapline in the winter season, the trapper will plan ahead and have it flown out on the floatplane's float. It works well on the flat-topped floats.

[Cat Driver]

They count on the fact that when they charge you they hope you are unaware of the regs and or it's intent. For what end they do this I do not know.

Yeh, it makes no sense to me either.

Why bother even writing these regulations when they can and do ignore them if it suits their agenda of the moment.

[wrenches and radios]

The more I think about this the better my ideas get!! I'm going to put seat rail on the float because it is then elementry maintenance to attach equipment to them!

[HS-748 2A]

The more I think about this the better my ideas get!! I'm going to put seat rail on the float because it is then elementry maintenance to attach equipment to them.

That is a good thought; rule-books or not, it would be a handy way to attach the load.

You know, we'd all be prudent to take a pic of every external load we carry, and keep notes on how the airplane flew, how much trim rqd', where exactly was the load installed, etc.. That way when T.C. comes a' knocking down the road - We've got something to back up what we're saying. Don't get me wrong - it would be great if this all would just go away but its not going to so we're going to have to play their little game one way or another. They have a harder time arguing with numbers and dates.

[1000 HP]

Good Idea

[1000 HP]

The more I think about this the better my ideas get!! I'm going to put seat rail on the float because it is then elementry maintenance to attach equipment to them.

That is a good thought; rule-books or not, it would be a handy way to attach the load.

You know, we'd all be prudent to take a pic of every external load we carry, and keep notes on how the airplane flew, how much trim rqd', where exactly was the load installed, etc.. That way when T.C. comes a' knocking down the road - We've got something to back up what we're saying. Don't get me wrong - it would be great if this all would just go away but its not going to so we're going to have to play their little game one way or another. They have a harder time arguing with numbers and dates.

As a matter of fact, most of the companies I have worked for lately do just that, with a couple of old-timer run holdouts.

[Hornblower]

As I see it what we really need is to have a special cert of airwortiness for external loads with all the restriction that go along with it. when the role of the aircraft changes the normal c of a is back in force. This is the only air tight solution to all the hot air TC might blow our way.

That does seem sensible W&R.. Good thinking. It could fall under 'Aerial Work' in the regs.
Guess they're not paying us to iron this out though are they...

'48

First of all, a special certificate of airworthiness is only issued in certain categories, none of which are a normal aircraft with cargo on the outside.
Secondly, Aerial work is not applicable, since anyone (or mostly anyone) carrying an external load is carrying the cargo for H&R, thereby falling straight into the category of an “Air transport service” needing a AOC under part VII sub 3, 4, or 5.

No I’m afraid if we are to continue to carry external loads, it must be done without an STC, since that would be an admission that attaching an external load to an aircraft is a major modification requiring engineering and flight test validation of every model canoe, boat, etc., and a maintenance release each time something was attached. Ever see an STC’d rope? Ever see a rope with a certificate of compliance to some recognized military or aeronautical standard??

And as I mentioned above, even the regulator believes that the load or method of attachment is not a modification to the aircraft since they tacitly indicate such, given that it’s OK by their regs to commercially fly an external load without passengers or an STC. And in addition, no rules at all apply for private operators.