Importing a Canadian O-M class to US

[kcabpilot]

I’m interested in a Supercub that is in Canada and is O-M class (owner maintenance) I’m an A&P/IA but don’t know much about the rules for getting one of these registered with an N-number. I’ve been reading about it all afternoon because so much information is right at your fingertips on the internet, problem is 90% of it is wrong. Some people are saying it’s impossible. I know I can call the FSDO but this is just preliminary, I’m tossing the idea around in my head so thought I’d just throw it out here. Somebody has to have already done this right?

Thanks

[d.grimm]

I imported a Canuck from Canada. First thing my PMI asked, “Its not Owner Maintenance is it?”
I don’t think it can be done to Standard Category. Experimental Exhibition, a slim maybe.
Dave

[Skysailor]

Here in Canada we're told to think long and hard about putting our aircraft into O/M. There are a number of different reasons, but one of the opinions is the value will drop due to excluding all American buyers. If the a/c is owner maintenance, we're not permitted to fly in US airspace.
I know that doesn't answer your question, but gives you a pretty good idea how the FAA thinks of Canadian O/M.

[kcabpilot]

Yup, I guess that’s why it’s so cheap. Really nice looking plane though.

https://www.barnstormers.com/listing...php?id=1387884

[Skysailor]

Yup, I guess that’s why it’s so cheap. Really nice looking plane though.

https://www.barnstormers.com/listing...php?id=1387884

That's pretty sweet......

[S2D]

just wondering what would be the limiting factor in recertifying it in the US? If all parts meet original specs??

[mike mcs repair]

just wondering what would be the limiting factor in recertifying it in the US? If all parts meet original specs??

A different data tag and matching log books


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[n40ff]

2012 post from another forum. May or may not be the whole story?

Jack



"FAA Flight Standards aviation safety inspectors shall not issue SFAs for Canadian Owner-Maintenance category aircraft."

The bilateral agreement doesn't cover aircraft where there is no equal category. O-M aircraft have to be placarded "SPECIAL CERTIFICATE OF AIRWORTHINESS – OWNER – MAINTENANCE THIS AIRCRAFT DOES NOT COMPLY WITH INTERNATIONALLY RECOGNIZED AIRWORTHINESS STANDARDS". Experimentals need an SFA but there are similar categories on both sides of the border. Some newer categories such a LSA's and O-M have no equals.

This means not you or anyone else is flying an O-M plane in the US.


To put a plane into O-M requires "Each engine, propeller and life-limited item installed on such an aircraft shall have an “X” permanently etched, engraved or stamped at the end of the model designation and serial number on the identification plate"

This DOES change the model and the serial number. You are no longer importing a Piper PA-22, you are importing a PA-22X which is not in the FAA database. When a brand new vintage 1945 Cub can be assembled with new parts around an old data plate, a defaced data plate is worthless. But feel free to argue with Piper about wanting a new data plate with the old number when all your paperwork agrees with the defaced plate.

Assuming we got the model and serial number straightened out, next we have traceability. Or lack thereof. This is the same as buying a plane with no logs or history in the FAA database. How can you tell if the engine, which also has a defaced data plate, is assembled with the proper, approved parts? Did the altimeter come from a wreck and the owner opened it and fixed it with a little RTV? Does the prop have some gouges that were expertly finished with bondo and paint? It's one thing for an A&P to suspect the owner might have done something, it's another for him to have documented proof an owner has messed with everything.

Once in O-M, the logs are worthless as the entries show work completed by someone who is unauthorized according to the FAA. For an A&P/IA to sign off as airworthy, he has to be able to recreate the logs. This is impossible because he cannot trace the parts without complete disassembly and inspection.

[n40ff]

The post above(# was based on this. Jack



VOLUME 12 INTERNATIONAL AVIATION

CHAPTER 11 SPECIAL FLIGHT AUTHORIZATION (SFA) FOR CANADIAN “OWNER-MAINTENANCE” CATEGORY AIRCRAFT

Section 1 General

12-645 PURPOSE. This chapter contains information for Federal Aviation Administration (FAA) Flight Standards Division Managers and those offices delegated Special Flight Authorization (SFA) issuance authority. It defines FAA Flight Standards national policy regarding issuance of SFAs for Canadian‑registered “Owner‑Maintenance” category aircraft.

12-646 BACKGROUND.

A. A March 1, 2002 change to Canadian Aviation Regulation Part V, Airworthiness, Standard 507—Flight Authority and Certificate of Noise Compliance (507.03), authorized the issuance of a Special Certificate of Airworthiness for certain type‑certificated (TC’d ) aircraft recognized by Transport Canada as Owner‑Maintenance.

B. In accordance with Transport Canada Aircraft Maintenance and Staff Instruction 15, the Owner‑Maintenance classification allows the owner‑pilot, with regard to their TC’d aircraft and without maintenance training, to:

· Rebuild an airplane that is out of service
· Overhaul the airplane
· Install used unapproved parts
· Be exempt from Airworthiness Directives (AD)
· Modify the airplane
· Install or replace any instruments or avionics
· Sign the maintenance release for all maintenance performed
· Maintain the airplane
12-647 DISCUSSION.

A. TC’d aircraft operated under the Transport Canada Owner-Maintenance category have:

· No requirement for the use of approved parts
· No requirement to comply with ADs
· No requirement for any maintenance to be accomplished or inspected by anyone other than the pilot/owner
· No requirement that return to service sign‑off be performed by certificated persons other than the pilot/owner
· No requirement for owners to obtain any maintenance training prior to performing maintenance or signing a maintenance release
B. The FAA does not authorize the maintenance of TC’d aircraft to such extent by persons holding only a pilot certificate.

12-648 ACTION. FAA Flight Standards aviation safety inspectors shall not issue SFAs for Canadian Owner‑Maintenance category aircraft. FAA Flight Standards offices that have issued, or authorized the issuance of, SFAs to Canadian‑registered Owner‑Maintenance aircraft are to review their SFA files for authorizations that are still effective. Those authorizations issued to Canadian Owner‑Maintenance category aircraft are to be rescinded as soon as practical.

[kcabpilot]

Wow, that’s pretty definitive. Kind of a shame the seller of this plane says even though O-M everything was done by an AME and no modifications were made.

[skywagon8a]

Kind of a shame the seller of this plane says even though O-M everything was done by an AME and no modifications were made.

If that is the case, why was it placed into the O-M category in the first place? Perhaps the person who owned it prior to the current seller is the culprit?

[n40ff]

Yea, the fact that previous issued certificates are to be rescinded is pretty definitive.

It's interesting how much bad advice is available on the internet.(Not) I found so many threads on several forums on this subject with many, MANY folks suggesting that a O-M aircraft should be able to be issued a AWC in the US. It seems no one but this single person found the actual FAA opinion which is does indeed seem set in stone. Not only can't it be issued an AWC it can't even be flown in US airspace. Oh well.

Maybe it can be taken out of O-M category in Canada first in some way?

Jack

PS Of coarse the person who started this thread found the same thing as regards internet advice...mostly WRONG.

I recently purchased a 86 Z28 Camaro and need to service the AC, either find some R12 or convert to R134a? Ask 100 "experts" what to do and get at least 50 different opinions.

[skywagon8a]

Maybe it can be taken out of O-M category in Canada first in some way?

Jack

I seem to recall when the Canadian O-M category was first announced that it was stated one should be very thoughtful about going that route since it was irreversible.

[Canadian Farmer]

As stated before... Any aircraft in Canada that is placed in Owner Maintanance is NEVER allowed to fly in US airspace or ever be exported to the US. In my opinion Owner Maintanance category was designed for an aircraft with little value (less than 25k) that the owner has no intention of selling in the foreseeable future and would like to enjoy the same freedom of maintanance as the home built category.

[kcabpilot]

I found some other stuff about this when I was researching wheater or not you could fly in Canada on Basic Med (you can't) Apparently there is a lot of tit for tat going on, we have Basic Med now but won't let Canadians with class 4 med fly here. We won't let O-M in here and they won't let LSA in there. It seems there are discussions going on so maybe someday it will get resolved. Who knows...

For now I'm going to have to keep looking for my Supercub. It's out there somewhere.

[dstr59]

just wondering what would be the limiting factor in recertifying it in the US? If all parts meet original specs??

I would think, (in a sensible world) that a conformity inspection, like a standard category aircraft undergoes, when it is imported here would clear up any airworthiness issues.
but remember who we're dealing with

[hotrod180]

Basic Med and canadian class 4 medical seem somewhat comparable from what I've read.
EAA & AOPA are (supposedly) working on Canada accepting basic med.

But LSA isn't the same thing as owner-maintenance category.
And I don't think Canada has anything comparable to sport pilot.

[skywagon8a]

I would think, (in a sensible world) that a conformity inspection, like a standard category aircraft undergoes, when it is imported here would clear up any airworthiness issues.
but remember who we're dealing with

I sort of agree with you as far as the airframe goes, maybe, but how do you do a conformity inspection on the engine without totally dismantling it?

[RoddyM]

Basic Med and canadian class 4 medical seem somewhat comparable from what I've read.
EAA & AOPA are (supposedly) working on Canada accepting basic med.

But LSA isn't the same thing as owner-maintenance category.
And I don't think Canada has anything comparable to sport pilot.

We have a recreational pilot licence and an ultralight pilot permit with passenger carrying ratings
which is similar to the US Light Sport License.
Roddy

[RoddyM]

I sort of agree with you as far as the airframe goes, maybe, but how do you do a conformity inspection on the engine without totally dismantling it?

Splitting hairs. Strange, no owner maintenance allowed in the US (certified aircraft), but no problem for Advanced Ultralight which is owner
maintenance.
If you come to Canada with a valid pilot licence and a passport, highly highly unlikely you’d be turned away with your LSA.
Would Canadian border officials know or care? Not likely.
Roddy

[Lasater]

Can private pilot (not sport pilot) fly a US Light Sport Aircraft in Canada?

[RoddyM]

Can private pilot (not sport pilot) fly a US Light Sport Aircraft in Canada?

Without looking at the itty bitty rules, which most pilots are unsure of, me included, the Canadian border people will be looking for valid pilot license, passport, and insurance.
They see that the thing has wings and looks like a plane, what exactly it is and how it’s registered likely means nothing to them. For example - a SuperStol can be registered Advanced UL here. In the US it’s a LSA.
Roddy

[n40ff]

I sort of agree with you as far as the airframe goes, maybe, but how do you do a conformity inspection on the engine without totally dismantling it?

Exactly! Even if possible, add $15k to the price.

[dgapilot]

As a DAR, I haven’t really researched if there is a “prohibition” on bringing an OM Aircraft from Canada to the US. That said, you have to realize how the import/export works. If it is an aircraft that ever had a US standard certificate, or a US Export certificate, there is no export required from Canada. The airplane is simply “coming home”. On the other hand if the airplane was manufactured someplace other than the US, or never had a US Standard or Export, then it would require an Export Certificate from Canada, which they won’t do.

Now, hypothetically, if an OM Aircraft were presented to me for inspection for a Standard, you would likely need to have the engine, propeller, all the instruments, all the avionics, and any component that has mandatory overhaul requirements overhauled. Any “modifications” or repairs that were done while OM would likely need to be removed. The “conformity inspection” would likely involve hands on inspection of every nut and bolt in the airplane, every system in the airplane, and may involve significant disassembly (think of things like brake cylinders). Even for something like a Cub, this could run anywhere from $20k to over $100k (think fabric done by the owner). No matter how you look at it, there is no savings for OM when you consider lost resale value.

Again disclaimer: I have not researched even if FAA would allow being an OM Aircraft “back home”.


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[hotrod180]

We have a recreational pilot licence and an ultralight pilot permit with passenger carrying ratings
which is similar to the US Light Sport License. Roddy

The big deal with our sport pilot is that no medical certificate is required.
Do your recreational & UL licenses require a medical?

[kcabpilot]

It all seems rather bizarre. Is there anything on a Cub with a "mandatory overhaul requirement"? There is no liability for Piper, as far as I know, as the law exists today. Maybe the FAA? We aren't talking about a transport category aircraft here, just a Cub. There has to be some sort of underlying motive for such scrutiny, I have no idea what that would be other than to just flat out make it clear that hey, we don't want to have anything to do with this so don't even ask. If that is the goal it would appear they have succeeded.

[RoddyM]

The big deal with our sport pilot is that no medical certificate is required.
Do your recreational & UL licenses require a medical?

Our UL license requires a “Self Declaration” form to be filled out, signed and sent to Transport Canada.
If you you’ve checked “positive” on heart disease, previous head injuries etc, you then must take it to your
family Doc to sign off. Transport then issues a medical certificate good for 5 years. We’ve had this system for UL for years now and it is a good one. Many many of the US LSAs can be registered “Advanced UL” including most of RANS, Just Aircraft, Tecnam, and Flight Designs to name a few. Some J3 Cubs are also flown legally on a UL license. So we have a “medical certificate” - it’s a requirement, but very straight forward to obtain. You say “no medical certificate”? So you sign nothing at all making no declaration regarding your health and you’re good to go LSA? I thought our system was too good to be true. Guess not lol.
Roddy

[dgapilot]

It all seems rather bizarre. Is there anything on a Cub with a "mandatory overhaul requirement"? There is no liability for Piper, as far as I know, as the law exists today. Maybe the FAA? We aren't talking about a transport category aircraft here, just a Cub. There has to be some sort of underlying motive for such scrutiny, I have no idea what that would be other than to just flat out make it clear that hey, we don't want to have anything to do with this so don't even ask. If that is the goal it would appear they have succeeded.

The big deal is the liability for a DAR to issue a certificate. Just as when an IA signs an annual, a DAR has to attest to the fact that the Aircraft is “Airworthy”. There is a very specific definition of what that word means! Airworthy has 2 components - first is that the aircraft needs to meet its Type Design, and the second it that it needs to be in a condition for safe flight.

In the case of OM airplanes, establishing the “meets type design” is the problem. Yeah, for something like a Cub, there aren’t any life limited items, but who is to say that the cover was done to an STC with approved products if it was done after transitioning to OM. Who is to say if that engine overhaul actually used the right parts and was inspected properly. Yeah, I know these things can happen with a Standard certificates airplane, but there is supposed to be someone’s name and certificate on the line if it’s done wrong. Not so with OM airplanes.

In my case the liability is more I want to take on. While the owner may be a nice guy, you have no control over the litigation started by his estate or a passengers estate after an accident.


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[kcabpilot]

While I can understand the personal decision to mitigate liability I was referring more to the statement quoted earlier that I assumed was an official FAA policy statement...

FAA Flight Standards aviation safety inspectors shall not issue SFA's for Canadian Owner-Maintenance category aircraft

Which kind of says that even if you wanted to you couldn't.

[jnorris]

While I can understand the personal decision to mitigate liability I was referring more to the statement quoted earlier that I assumed was an official FAA policy statement...

"FAA Flight Standards aviation safety inspectors shall not issue SFA's for Canadian Owner-Maintenance category aircraft"

Which kind of says that even if you wanted to you couldn't.

That statement applies to issuing a special flight permit that would allow the Canadian-registered plane to fly in US airspace. It does not refer to issuance of a US airworthiness certificate.

I just did a couple of searches of FAA Order 8130.2J, which is the guidance used when issuing US airworthiness certificates and special flight authorizations. The above-quoted statement is the ONLY place in the entire order that specifically mentions Canadian Owner-Maintenance aircraft. There is no specific prohibition stated for importing an owner-maintenance aircraft. However, the cost of having all the required conformity inspections and other documentation building taken care of may end up being more than the plane would be worth, even WITH a US airworthiness certificate.

[kcabpilot]

Ahh okay, my misunderstanding.