TC CAR 104 Aircraft Certification fee change proposal

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PilotDAR
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TC CAR 104 Aircraft Certification fee change proposal

Post by PilotDAR » Thu Nov 29, 2018 4:11 pm

Hello owners and maintainers,

During a meeting at TC Aircraft Certification the other day, we got discussing the proposed changes to TC fees for approval of design changes. Now I realize that this is as interesting as watching paint dry, but for those who may want a mod or repair approved on an aircraft one day, this means more $$ to TC. In some cases, TC staff get a lot into these projects, and yes, the taxpayer should not be being asked to cover that. But, in many cases, an owner or maintainer might hire a DAR to handle the approval, and indeed, it is possible that the DAR could be completely delegated (meaning there would be no request for any TC service), and then paying a fee to TC (at present $220 for an sSTC, to be $550) seems a little much, when TC is not providing any service whatever with respect to that project. There are many similar examples buried in the proposal. Now if we're re-engining a jet airliner by STC, the fees TC propose seem like a deal - but most people reading here aren't re-engining an airliner, but rather asking for an sSTC for a prop/ski/float change, or an RDA for a repair.

Now's your time to speak up! If you can afford more money, hey, I can pass your payment through to TC, but if you would like to make a fee payment which is proportioned to the value of the project, you may want TC to consider that. Though the link says that commenting is closed, it was this past Tuesday that a TC staffer asked me to solicit comments. the link can be followed (in purple) from here:

https://letstalktransportation.ca/moder ... -approvals

Your friendly DAR...
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Re: TC CAR 104 Aircraft Certification fee change proposal

Post by photofly » Thu Nov 29, 2018 4:51 pm

purple... all links you’ve already followed are purple, or at least I don’t see a purple link on that page, just an email to send comments to.

Which link do you have in mind?
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Re: TC CAR 104 Aircraft Certification fee change proposal

Post by PilotDAR » Thu Nov 29, 2018 6:35 pm

On the page which opens for me here:

https://letstalktransportation.ca/moder ... -approvals

"Aeronautical Product Approvals Fee Modernization Proposal"

appears in four places, and a click on any one of them takes the reader to this page;

http://www.tc.gc.ca/en/transport-canada ... posal.html

It asks that comments be sent to:

"CARRAC@tc.gc.ca"

I'm just the messenger here....
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Re: TC CAR 104 Aircraft Certification fee change proposal

Post by PilotDAR » Fri Nov 30, 2018 6:08 am

AvCanada owners and maintainers, I have sent my comment to TC, it reads:

"Hello Transport Canada,

A senior TC staff member asked me to comment this during a meeting we attended together last Tuesday. I had commented last spring, and here I go again....

In principle, I agree that industry consumers should carry the cost of services they request from the government - that's fair. Obviously, this fee change proposal is associated with an analysis of the cost per service provided from the government perspective. However, that must also be seen from the service consumer's perspective, so a few thoughts on that:

TC can charge for requested, value added service to industry, TC cannot charge for surveillance. We need to always understand which activity is occurring, and not blur the lines.

As a delegate, I provide certain specified services on behalf of the Minister, including the issuance of certain approvals. At present, I collect and remit the TC fee on behalf of my client, but otherwise am paid by my client. I work in my area of expertise, with decades of experience working in that realm. My clients hire me based upon my experience, to get the best value for their project cost. In some cases, within my scope, I might do the entire project (sSTC), including issuance of the approval with zero request for TC service. In such a case, how can TC apply a fee? TC was not requested to, and did not provide any service? In that case, there should be nothing more than a very modest (like $25) administrative fee, to cover the cost that TC could incur administering the documents I upload to the TC web link. Just up from that situation in theme, for a full STC, again within my scope, with the only service request to be the actual issuance of the certificate itself, for which I am not delegated. I may request an hour of TC time for the quick review, and signing of the certificate I have prepared. How can TC justify a multi thousand dollar fee for that very limited service?

TC may charge be the hour for staff time in some circumstances. That is appropriate, as long as the TC staff time being provided and charged is a result of a service request, is effectively spent, and the work is done by a TC staff member who applies skill, knowledge and experience commensurate to the project. It would not be fair to the client that a TC staff member unfamiliar is charging the hourly rate to "learn" as they go. I have witnessed this situation numerous times; it unfairly burdens the project cost, delays calendar progress, and can lead to things having to be explain again, and redone, once actually understood in context. Not fair to the client.

A fee of $550 for a serialized STC is far out of proportion for very simple approvals to low cost aircraft. That could be a discouragement to the owner to have the work properly approved. It detracts from aviation safety if costs are artificially increased, and flying becomes more expensive - pilots will fly less, and be less experienced and safe as a result. When accidents occur, they are most often pilot error, not airplane defect. We need to do everything possible to encourage more pilot flying, and not inflating costs needlessly.

The fee for reissuing a delegate issued certificate goes from $180 (which is already silly expensive) to $450!!? TC rarely provides ANY service at all for this effort, what is TC charging for? Sometimes the reissue is needed only to correct a typo (I've made a few), this just discourages making things right - I'll leave the typos and hope no one notices for $450!

One last theme, I know this is an "application fee", but it is invoiced at the time I apply, and then even the most simple project can languish in the TC office for months waiting for any TC action to be made - in the mean time, TC expects the fee invoice to be paid. The invoice should be payable upon the applicant receipt from TC of the acceptance of certification plan, so the project is then known to be moving ahead, again, no fair charging for a service which has not, and may not occur for months, charge for the service requested and provided!

Those are my comments, I hope they serve to alter the approach TC has presented."
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Re: TC CAR 104 Aircraft Certification fee change proposal

Post by PilotDAR » Mon Dec 03, 2018 9:11 pm

I appreciate that 166 people have read this, and one commented. I know it's boring, and who cares about the cost to modify your plane - until you need to! I hear people comment (complain) about the cost of flying. This is an uncommon cost, but one which is going to hit low cost aircraft mods and repair design approvals pretty hard as proposed, and TC wants industry comments!

I recall, sometime around 25 years ago, I was attending a TC CARAC meeting, at which proposed regulatory changes were discussed, and industry comment invited (and TC even considered those comments!). The proposed "516" for noise came up as a new initiative toward ICAO compliance - my ears perked up (pun intended). TC was now proposing to regulate noise - the first time TC would regulate something about planes which was not safety related. I grasped the possible effect this could have on the small side of GA. I asked that TC simply exempt all aircraft under 350 HP - it would be rare that such Canadian aircraft would fly to ICAO contracting states who cared about noise = what we do at home is our business. I implored the industry representative seated next to me to go out to their membership, and solicit comments back to TC. I came home and contacted AMOs I knew, and associations who represent owners who I knew could be affected. Left to pass as proposed, this would affect all propeller change approvals, requiring very expensive noise testing for some, and perhaps exemptions for others. "Write letters..." I said.

Months later the TC staff member responsible told me that my letter was the only one TC received, the regulation was going ahead. Since then, I have had to noise test a prop installation on a 182 for an sSTC, with a cost to the owner approaching $20,000. I have had to seek exemptions for two other owners, whose props we changed, but noise test was not possible. In both cases, $500 fee to TC, hours of my time preparing the exemption request, and about nine months wait (during which the aircraft sat idle waiting the approval. Other prop projects have been a regulatory challenge = $$.

No one took the time to comment, so it went ahead, so will these fees. TC staff get paid either way, I get paid either way, it is the aircraft owners and maintenance shops who should consider if the higher TC fees seem acceptable. I'll be long retired 25 year from now, but perhaps will still point back to this post, as the basis for why TC fees exceed the DAR fees for an approval, and TC did not do anything at all for some of those approval projects.

This DAR advice was free!
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