Policy Letter 165R2
Carriage of External Loads
The purpose of this revised Policy Letter is to inform all Commercial and Business Aviation Inspectors that all air operators under Subpart 703 of the Canadian Aviation Regulations (CARs) who carry external loads will need to obtain approval through a Type Certificate, a Supplemental Type Certificate (STC) or Limited Supplemental Type Certificate (LSTC) for each aircraft type and external load they operate/carry.
Air operators under Subpart 703 of the CARs should be aware that the exemption to Section 703.25 and paragraph 605.03(1)(b) of the CARs valid to December 31, 2005, has expired.
In order to continue to carry external loads air operators will need to obtain approval through a Supplemental Type Certificate (STC) or Limited Supplemental Type Certificate (LSTC) for each aircraft type they operate with an external load.
Recently, TCCA has decided to issue a new exemption to Section 703.25 and paragraph 605.03(1)(b) of the CARs will be issue valid to 23:59 EST on December 31, 2008, which will permit Air Operators to continue to carry external loads under the new conditions of the new exemption.
- Section 703.25 of the CARs;
- Paragraph 603.05(1)(b) of the CARs;
- Exemption from Section 703.25 and Paragraph 605.03(1)(b) of the CARs;
- Civil Aviation, Aircraft Certification Advisory Circular (AC) 500-011, dated 2004-12-01.
The ability of air operators to move objects (external loads) by aeroplanes that are not transportable within the aeroplane have always formed part of the Commercial Aviation Landscape in Canada.
Section 703.25 of the CARs prohibits air operators from carrying an external load with passengers on board, except where carriage of an external load has been authorized in an STC or a LSTC.
The CARs have traditionally viewed external loads as modifications to an aircraft requiring some type of formal design approval.
An STC/LSTC approves the carriage of an external load and sets out conditions that result in a safer operation. External load operations that take place without STC/LSTC approvals are done without the benefit of a formal approval process that mitigate the risks inherent in these types of operation.
The exemption to Section 703.25 and paragraph 605.03(1)(b) of the CARs permits the carriage of passengers while carrying an external load, subject to the conditions contained in the exemption. These conditions are intended to mitigate the risks associated with the carriage of external loads.
Parts VI and VII of the CARs do not address carriage of external loads without passengers on board. Therefore, an aeroplane operating with an external load, without passengers on board, for which an STC or LSTC has not been issued, may not have a valid flight authority.
Consequently, an exemption to Section 703.25 of the CARs alone does not provide the appropriate authority for operators under Subpart 703 of the CARs to operate with an external load. To rectify this, the exemption to Section 703.25 of the CARs must be also be complemented with an exemption from Paragraph 605.03(1)(b) of the CARs.
The addition of Paragraph 605.03(1)(b) of the CARs provision to the exemption is in the interest of operators under Subpart 703 of the CARs since it will authorize the operation of their aircraft when external loads are attached without an STC or LSTC, and operated in accordance with the conditions of the exemption.
Many aeroplanes have an STC or LSTC available, which authorizes the carriage of external loads. The STC/LSTC is, typically, specific to the aeroplane configuration and external load.
At present, there are 165 different external loads STCs or LSTCs available. The list of approved external load items covers canoes, boats, porta-boats, marine craft, square stern boats, kayaks, lumber or freight.
This newest exemption will permit Transport Canada Airworthiness and Certification the time to collect data for dissemination.
Transport Canada (TC) will be presenting a Notice of Proposed Amendment, to an upcoming Canadian Aviation Regulation Advisory Council Part VII meeting, that will propose to revoke Section 703.25 of the CARs. As a result of this action, air operators under Subpart 703 of the CARs will be required to comply with the requirements of the Airworthiness Manual (Part V of the CARs) when carrying external loads; due to the modification of the aeroplane.
Air operators who carry external loads will be required to obtain the appropriate Type Certificate, STC or LSTC.
Some confusion has occurred with respect to paragraph two of the application section of the exemption. The intent of this paragraph is to ensure that holders of a Type Certificate, STC or LSTC comply with the requirements of that document. Air Operators that have been authorized in a Type Certificate, STC or LSTC to carry a specific external load may use the exemption to carry different external loads, subject to the conditions of the exemption.
LSTCs for aircraft previously approved for the carriage of external loads may be possible without further TC flight test evaluations if the proposed external load configuration and tie-down method is shown to be structurally acceptable and the applicant submits an acceptable flight test report and flight or operating manual supplement in accordance with AC 500-011.
TC Inspectors are to ensure that Air Taxi Air Operators are aware of the requirement to obtain the appropriate authorization prior to carrying external loads.
Highlights of the new exemption are:
8. A copy of this exemption shall be carried on board the aeroplane when conducting external load operations under the authority of this exemption.
9. If external loads have been carried under the authority of this exemption, the air operator shall ensure that the Minister has received the following information for the reporting periods by the report due dates specified below:
a. air operator name and address, and
b. date of every flight that carried an external load under the authority of the exemption including;
i) aeroplane type and model
ii) aeroplane registration
iii) description of particular load;
c. a copy of the relevant pages from the Company Operations Manual containing the information required by paragraph 5 of the Conditions of the exemption, for every float equipped aeroplane used for operation under the authority of this exemption; and
d. a copy of the proving flight records required by paragraph 2(b) of Annex A of the exemption for every aeroplane type and model and associated particular load used.
Report Due Date
Date of Exemption -31 December. 2006
15 January 2007
1 January 2007- 30 June. 2007
15 July 2007
1 July 2007 - 31 December. 2007
15 January 2008
1 January 2008 - 30 June 2008
15 July 2008
31 July 2008 - 31 December 2008
15 January 2009
Note 1: The first report must be submitted for the reporting period during which this exemption has first been used. Reports must also be submitted for all subsequent reporting periods to either report flights utilizing this exemption or to report that no such flights have been accomplished.
Note 2: The complete information as requested in paragraphs 9.c and 9.d above only needs to be submitted with the first report. Only copies of Amendments to the Company Operations Manual and proving flight test records need to be submitted with subsequent reports.
Forward the requested reports to:
Director, Aircraft Certification
Place de Ville (AARDH/D)
Ottawa, Ontario K1A0N8
Attention: Manager, Domestic Regulations AARDH/D; or
Fax: (613) 996-9178, Attention : AARDH/D; or
This Policy Letter will remain in effect until the CARs have been amended by the removal of Section 703.25. The exemption to Section 703.25 and paragraph 603.05(1)(b) of the CARs will expire 23:59 EST on December 31, 2008.
This Policy Letter is designated AARX No. 165R2.
Commercial &Business Aviation
- Date modified: