External loads

gr8gazu · Post by **gr8gazu** » Sat Feb 25, 2006 11:11 pm

Cat Driver wrote:Also as to racks the only rack I remember ever using was on a Beech 18 and I honestly do not know if it was STC ed or not..

It was an STC, but i can't remember who held it.

185_guy · Post by **185_guy** » Sun Feb 26, 2006 8:57 am

An operator I worked for a while back had racks on the 185. They were home-made, and TC did not want them on there! They were bolted on with 4 bolts, with castle nuts with a saftey pin. They were very easy to remove and install. He argued with TC that the rack was itself, an external load, and was just an 'external load bumper'. He said removing/installing it was elementary maintance. So for every canoe we hauled, we in fact had 2 externals on....the rack, and the canoe. I thought this idea was brilliant. And the fact the rack was homemade dident bother anyone a bit....it wasent a farmer-cobelled-togeather piece of shit!! After all, he was using it too, and had been for years and years.

Edo · Post by **Edo** » Sun Feb 26, 2006 9:38 am

Hornblower:

Well said, I dont think TC even needs to address this issue, but now that they have I dont see them taking the requirement away.

These rules just make the operator go out and get data to prove its safe.

I agree they should provide data saying its unsafe. More than some dumbass flying a load exeryone will tell him is bad. Or a guy flying in +28 C with 2 canoes on a Beaver, then have a mechanical failure and conlcude "without the canoes the pilot would have been higher than 700' and may have made it to a lake"

What do you think the chances are that we as an industry can force TC to prove to us further data is needed to justify further regulation??

not good - so if doing 1 proving flight to fly every kind of canoe out there makes the STC crap go away, well Im all for it.

CD · Post by CD » Sun Feb 26, 2006 12:03 pm

Here are some more links with information and discussion on the issue:

General Operating and Flight Rules Technical Committee - External Loads Working Group Terms of Reference
General Operating and Flight Rules Technical Committee - External Loads Working Group Final Report
TSB Report Number A03W0210

04/03/25-10.2 Risk Assessment on the Carriage of External Loads

Decision: The CARC members approved the recommendation of the risk assessment to amend the CARs to revoke section 703.25 and to require compliance with Part V of the CARs.
Civil Aviation Regulatory Committee (CARC) March 25, 2004 - Decision Record
Risk Assessment on the Carriage of External Loads

Technical Committee Meeting - October 18, 2005 - NPA 2005-043 - 703.25 Carriage of External Loads

Cat Driver · Post by **Cat Driver** » Sun Feb 26, 2006 1:10 pm

AAAhhh CD..

Thank you for linking that stuff from TC.

Reading that stuff brought back vivid memories when I read such names as Merlin Preuss, Don Sherritt and especially this guy.....

From the TC stuff..Quote...

" . ....D. Nowzek provided some feedback on the Forum that he organized for the industry in Vancouver on March 11, 2004. N. Girard’s presentation on the CARAC process and the exemption process prompted a lot of questions and positive feedback from industry. D. Nowzek confirmed that he would recommend at a future National Civil Aviation Management Executive Committee (NCAMX) meeting that a CARAC presentation be made to other regional associations. "

If ever I had the missfortune of being involved with moral deficit cretins it has to be that bunch. Especially the above, anyone thinking about how tricky CAR's can be enforced, interpreted or totally ignored need to deal with this individual, trust me I personally admire Al Capone far more than this group.

Now that I have got that vented I feel better.

Note:

The above is my opinion and I am willing to back it up if required. . ..

Cat

Edo · Post by **Edo** » Sun Feb 26, 2006 2:26 pm

Ok so in reading the info from CD

it seems NPA 2005-043 (notice of proposed amendment) has been issued

Does anyone know if a NPA always results in chages to the CARS or is there still time to avoid this?

CD · Post by CD » Sun Feb 26, 2006 3:32 pm

Edo wrote:Ok so in reading the info from CD

it seems NPA 2005-043 (notice of proposed amendment) has been issued

Does anyone know if a NPA always results in chages to the CARS or is there still time to avoid this?

As this is a change to a Regulation, if it was accepted at the October Commercial Air Service Operations meeting, then the next opportunity to make comments will be when it is published in the Canada Gazette, Part I. But it may be quite a while before that happens.

So far, there is no indication on the CARAC site relating to the status of any of the NPAs discussed at the October meeting:

CARAC : NPA System Technical Committee Meeting Details - CASO 2005-10-18

Edo · Post by **Edo** » Sun Feb 26, 2006 5:18 pm

My head hurts

I read the NPA 2005-043 and see there are issues with 702 aerial work and externals. I read the NPA and it looks like we can fly externals without pax.

Then the last line says all loads need STCs after the 703.25 reg is removed.

So can I fly under 702 without pax and no STC? the explination says yes (i think) and the last statement says no.

I shudder at the thought of all the overtime the TC people are getting when this much paperwork is generated for something this unnessary

twotter · Post by **twotter** » Sun Feb 26, 2006 5:49 pm

What a crock of crap.. We've all been hauling externals for years.. Now TC has to look after us... ie big brother.. God, back in the old days, it was common to say, well, if it won't fit inside, well, we'll fly it on the outside.. I've flown more crap on the outside of a beaver/otter than I would care to remember.. Including the time I actually flew 2 airplanes at once.. Long story, crashed cub on the outside of an otter but that's another story.. I just hope the powers that be will realise that it does not need another reg. to protect us from ourselves..

Airtids · Post by **Airtids** » Sun Mar 05, 2006 6:20 pm

OK. So besides all the ranting here (which I'm happy to see, and absolutely agree with. Believe me, I'm pulling my hair out on this one), the upshot is that as of TODAY, if i want to be a good boy, and do everything legal-like, I will need an STC (along with the proving flight, pilot training, documentation, and Ops Manual ammendment) to carry a canoe, a separate STC for a kayak, and another for Mountain bikes? All this on a 182 which is a relatively unproven floatplane, and therefore has a limited number of STCs available for purchase (none that i found on a search). So, I'm probably more looking at an LSTC for each of the above. Have i dummied it down for myself correctly?

If you were me (who really does want to keep everything on the upandup, cultivate good relations with my overseers at TC), what would you do?

Cat Driver · Post by **Cat Driver** » Sun Mar 05, 2006 6:43 pm

I would just drop the idea of giving training for external loads.

Cat

Airtids · Post by **Airtids** » Mon Mar 06, 2006 11:18 am

I would agree that is the easiest solution. However, we want to be able to do some 'Fly in, Bike out' tours to some of the alpine lakes here as well, so it becomes an operational question as well as a training one. My POI is on an audit until the 17th, but then I'll ask him what he wants to see and let everybody know.

It seems that what is required for an LSTC is a proving flight, training program, and documentation for each type of load carried. This really doesn't sound like too much trouble- a needless PITA, yes, but manageable if my interpretation of the requirements is accurate.

Edo · Post by **Edo** » Mon Mar 06, 2006 12:10 pm

AirTids:

Those requirements would work under the exemption. They would also work if the NATA proposal is accepted.

For an LSTC I am pretty sure you need to do all that plus get a design approval rep (DAR) to draw up plans and oversee the testflight. Then the DAR has to take the data to TC and get an LSTC for you.

I have never worked with a DAR but this is roughly the process. TC can provide you with a list of the DARs in your area.

As for the post before your last one that's the same way I interpret the rules as well.

Airtids · Post by **Airtids** » Mon Mar 06, 2006 1:48 pm

Several years ago, i needed an LSTC to strap some telemetry antennae on. Went through the DAR, and after 3 MONTHS, this guy had me welding little pieces onto my customers gear, along with several other UNWORKABLE solutions. I approached the manufacturer of the brackets, and they sent me to OMNR as they too had mounted the brackets to a 172. Being as how Ministry information is in the public domain, I had them forward me their documentation, which I then submitted to Pacific region, and had the approval in two weeks. Left me with a VERY sour taste in my mouth abouth the whole DAR process.

Edo · Post by **Edo** » Mon Mar 06, 2006 2:12 pm

Given that TC wants external loads banned how quick do you think they will be to approve a new stc/lstc? I can see the DAR/TC process dragging out to the point where an operator runs out of time and money trying to get an approval.

ettw · Post by **ettw** » Wed Mar 08, 2006 8:47 pm

I had to deal with a DAR for a ferry system once. I was OK with most of it but a year later I wanted to move the tank laterally in the cabin. TC wanted a letter stating that moving the tank did not affect the previous DAR calculations. No problem, nothing changed but the DAR would not do the letter, I had to type it up for him and his John Hancock on the bottom cost me 600 bucks!

I am so in the wrong end of this busniness sometimes.

CID · Post by **CID** » Fri Mar 17, 2006 4:04 pm

Man! you guys are dangerous.

Cat Driver · Post by **Cat Driver** » Fri Mar 17, 2006 4:16 pm

" Posted: Sat Mar 18, 2006 7:04 am Post subject:

--------------------------------------------------------------------------------

Man! you guys are dangerous. "

Explain why?

gr8gazu · Post by **gr8gazu** » Fri Mar 17, 2006 7:33 pm

CID wrote:Man! you guys are dangerous.

Inquiring minds want to know....

Please explain!!

CID · Post by **CID** » Sat Mar 18, 2006 11:07 am

The general attitude here is that pilots have the knowledge and skill to determine what external loads are "safe".

It's one thing to operate on the backs of past risk takers, but its worrisome when I read things like this:

I don’t agree that proving flights or any other type of approval is appropriate. First of all, as you have already said no two externals are the same, if you fly a mad river on the test, is an old town going to be the same? Are they structurally the same? Are they shaped the same? Do they weigh the same? What about the F’ing Sports-pal? And that’s only the canoes! What about lumber, boats, fridges sticking out the side of the beaver?

There is no way that TC should be involved in approving external loads, ... no way then can approve them either. They are not a modification to the aircraft, they are junk on the side. Only the racks or devices used to hold the external could possibly be approved, and then only because they would be designed to a standard, and built under approved processes. Does Mad River need a PMA (or PDA) and a manufacturing approval to build their canoes? I think not!

They are not a modification to the aircraft, they are junk on the side? Wow. That scares the crap out of me. Hornblower, tell you what. Strap whatever "junk" to the side of your airplane you want. I'll watch from the shore with a video camera.

Doc · Post by **Doc** » Sat Mar 18, 2006 1:37 pm

Saw a DHC4 flying hydro poles sticking out the rear....is this a bad thing? Guess so, they didn't have red flags attached to them....could have rear-ended the bleeding things with the Racer!

Doc · Post by **Doc** » Sat Mar 18, 2006 1:46 pm

Just because "old bush rats" have been doing something for years dosen't make it safe! BUT.......Just because "old bush rats" have been doing something for years, dosen't make it UN-SAFE either! This is a simple point that "that moron" in Ottawa hasn't figured out yet!

. ._ · Post by **. ._** » Sun Mar 19, 2006 8:28 pm

Doc wrote:Saw a DHC4 flying hydro poles sticking out the rear....is this a bad thing? Guess so, they didn't have red flags attached to them....could have rear-ended the bleeding things with the Racer!

I think TC only requires the red flags if they're sticking out 6 or more feet. If it's at night, it's gotta be a red light.

You're welcome.

-istp

carholme · Post by **carholme** » Wed May 31, 2006 6:47 am

Gentlemen/Ladies;

As the exemption for external loads is in place, we are hearing that very few if any have applied to operate under it. Presumably operators are going to carry external loads this summer and our fear is that if there are no applications, TC will in the end have just cause to permanently cancel the exemption. We are applying and making the changes to our manuals to stay legal in case of a ramp check. We think our boat rack for the Beech 18 will be ready by the end of the year and after that we won't have a problem.
But what about all of the other operators who do need the exemption to stay alive? Is anybody thinking of applying? Once it is gone, it would be difficult to get it back and the fault would be on our own shoulders, not TC.

carholme

185_guy · Post by **185_guy** » Wed May 31, 2006 5:01 pm

Some TC guys were by our dock the other day, and told us that the exemption to the CARS regarding external loads has been put back into place. All an operator needs to haul an external load is to have it in the ops manual and do the proving flight. To get around the boat rack issue, it is an external load itself, and call it an external load bumper, not a rack. Pretend you tie the ropes and ratchet straps to the struts, not the rack.

I dont know how long the exemption is in place for, and have yet to see it on paper, but the TC inspectors were spreading this good word.