MD – RA
Minister's Delegates - Recreational Aviation Inspection Service
Représentants du Ministre - Aviation de loisir Service d'inspection
Visit our site at: http://www.md-ra.com Visitez notre site à http://www.rm-al.com
FREQUENTLY ASKED QUESTIONS (FAQ)
- 1. RE: LETTER OF INTENT (To build an aircraft)
Note: for import of a completed and flying aircraft, see the Import Question below.
Why do I need to file a Letter of Intent?
This is a regulatory requirement, that a builder must inform the Minister when he intends to construct an amateur built aircraft. MDRA uses a fill-in form letter as the basic file data on all projects.
If I do not have all the information required, can I file anyway and finish it later?
Generally, the answer is no. We prefer to wait until you have all the info and accept the letter at that time. Please contact us at the office for further information and to discuss your particular circumstances. Note: This does not mean you should wait too long to file. Please be sure to contact us for full directions.
How do I file a Letter of Intent?
Go to www.md-ra.com go to the INSPECTION DOCUMENTS page, and select MDRA form Letter of Intent C01B. You can fill it out on the screen, print it, sign it scan it and e-mail to MD-RA office. The office also accepts facsimile and regular mail.
If a prospective builder does not have access to a computer, we will mail out a blank form on request.
What is a “Builder of Record”?
The Builder of Record is the name of the person or group of persons whose name(s) appear on the most recent Letter of Intent, C01B, accepted and entered on the project file.
Can a company or commercial operation be a Builder of Record?
No. Although a company or commercial entity may have the rights and responsibilities of a person, each registrant on our files must be a human being.
Is a Letter of Intent transferable to a new builder?
No, the new owner must file a new Letter and a new file will be created.
Can I increase the Gross Weight of my project after the Letter of Intent is filed?
Generally speaking, the answer is no. You are advised to file your project at the weight specified by the aircraft designer or the supplier of the kit or plans. Under special circumstances, and upon provision of acceptable documentation, you may be able to file for an increase, but each case must be decided on its own merits.
Can I add or delete a co-builder after the Letter of Intent is filed?
Yes, contact the MDRA office for details.
How do I file for a large group of co-builders (there is only so much room on the form for names)?
You can put the name and address of the group appointed contact person on the form and attach a list of the other names, which we will keep in your file. Contact the MDRA office for details.
I want to purchase an existing project presently in the MDRA files. How do I put it in the new name?
Please send us a new Letter of Intent and a bill of sale (Use the form on the www.md-ra.com site) and we will do the changes. The new owner must pay the fee for this new Letter of Intent. Note: the new Letter of Intent must have the aircraft data exactly as on the original file. No deviations or changes are permitted.
Do I need to file a letter of intent to import an amateur built aircraft?
No, we have a special form (C26 EA) for import of aircraft on the www.md-ra.com site, which takes the place of the Letter of Intent. Please refer to the FAQ section on Importation. Note: Refer also to the IMPORT PROCECURE page on the web site.
Does the Letter of Intent need to be renewed at any time?
No, it is valid through to the completion of the project.
- 2. PRIVACY AND CONFIDENTIALITY
Can I list a person providing professional assistance as a co-builder for convenience of communication with your office?
No. MDRA is permitted to communicate only with the Builder(s) of Record to discuss the details of our files.
Can I appoint any other person as my contact with your office?
No. MDRA is permitted to communicate only with the Builder(s) of Record to discuss the details of our files.
I see a for sale ad for an amateur built project under construction- can I call you for information on the project?
With the permission of the Builder of Record, we will put you in touch and the deal can proceed from there.
Note: On occasion, a person will become responsible for a project as a result of an inheritance, appointment as an executor of an estate, purchase at auction, or many other reasons. If you are in such a position, please call the office and we will discuss the case with you and let you know what documentation you may need.
- 3. MAJOR PORTION REQUIREMENT (SO-CALLED “51% RULE”)
Note: All amateur built aircraft in Canada, in order to be issued a Special Certificate of Airworthiness in the Amateur Built Category, must conform to the Major Portion requirement. This can be satisfied in the following ways:
- The aircraft is constructed entirely from raw materials facilitated by the use of plans.
- The aircraft is assembled from a kit which has been evaluated by Transport Canada or the FAA and found to be compliant with the requirements, and the results have been published on an eligibility list, by the above named authorities.
- The project does not meet the above criteria and has been evaluated by an inspector assigned by MDRA and found to be compliant. This evaluation is a one time event and the results apply only to the project evaluated. In addition, if used or commercially manufactured parts are incorporated in the project the provisions of SI 540-001 (IP 549-001) apply (see sec. 4 below and our www.md-ra.com site).
If I have a Major Portion review on my kit, does that mean it applies to all other kits of the same make and model?
No, such an evaluation is valid only for the specific project examined, and none other.
How then is a kit entered on the eligibility list?
The kit manufacturer or an authorized agent must apply for a Commercial Purpose evaluation with MDRA, for publication on the Canadian List. The FAA has a similar process for inclusion on their list.
How does a “Quick Build” or “Fast Build” kit meet the Major Portion?
Only those kits published as eligible can be accepted by MDRA. The “Quick Build” or “Fast Build” version will be shown as a separate entry on the published list(s).
I have a Quick Build version which is not on the published list, what do I do?
On occasion, the standard build version is published, but not the quick or fast build versions. In this event, we will require a separate evaluation for the non published version. Note: This evaluation, performed for an individual builder, is valid only for the project examined, and none other.
My Quick Build kit has some parts closed at the factory. Is this acceptable?
Yes, parts closed at the factory by the kit supplier and indicated as such on the kit parts list are not subject to pre-cover inspection.
Note: We recommend you have a pre-cover inspection done as soon as possible, as the degree of completion of some quick build kits is very high, so you want to ensure that you don’t get into difficulties further along in the project.
I am in contact with a company which will assist me in my build, and they say they can close the aircraft to “Quick Build status” and then send it to me for further work and inspection. Is this acceptable?
No. Only parts closed at the factory by the kit supplier and indicated as such on the kit parts list are acceptable under the legislation.
If I have a very old kit that is no longer listed, what can I do?
We have authority from the minister to accept a kit that was listed, no matter how long ago. If a copy of the publication can be found, we will accept it.
What if the kit supplier is sold, merged with another company or otherwise changes name and continues to sell kits with the original make and model? Or, if the kit is the same, but the name is changed? Are these kits still compliant?
This is an unusual circumstance and will require research and consultation with the supplier and possibly Transport Canada. Please call us for information.
- 4. REBUILDING OF A CERTIFIED AIRCRAFT AND/OR USE OF USED PARTS.
This subject is covered by a Staff Instruction (SI 549-001) issued by the Minister. This document sets out the rules for use of previously certified or commercially manufactured parts. As a “Rule of Thumb”- start by realizing that the Major Portion rule applies, and the SI does not permit a builder to receive fabrication or assembly credit for such parts, even if work (painting, cleaning, etc.) was required to make them suitable.
So- consider that you must first build the Major Portion of the aircraft without use of any of the used parts. Once this is accomplished, then and only then can you make use of previously certified and/or commercially produced parts.
You can find SI 549-001on www.md-ra.com site.
A Major Portion Evaluation will be required for such a project.
- 5. IMPORTING AN AMATEUR BUILT AIRCRAFT FROM A FOREIGN COUNTRY
The aircraft must have been built and registered as an Amateur Built aircraft to the standards for such aircraft in its state of origin, and the Minister must find those standards equivalent to ours. The aircraft must have accumulated a minimum of 100 hours flight time and it must pass an import inspection to ensure its suitability for issue of a Canadian Special Certificate of Airworthiness in the Amateur Built category.
How do we establish eligibility for inspection?
The importer/owner submits MDRA form C26EA along with some supporting documents for review. Provided the documents meet the criteria, the MDRA reviewer will issue a Report on Eligibility to the importer, who will then proceed to the import and then to the inspection stage.
Can I import the aircraft first and do the paperwork later?
Yes, but we do not recommend you do so.
How do I prepare for the Import Inspection?
The above is only a partial list- be sure to follow our published procedures on the www.md-ra.com site.
Do I need to change the Aircraft Identification Plate (“Data Plate”)
The Aircraft Identification Plate cannot be removed nor modified
If Aircraft Identification Plate does not meet the requirements of CAR 201.01. a new plate must be fabricated and mounted on the aircraft beside the old one. Transport Canada must be contacted to get approval to make this change.
Note: it is very rare for this to happen.
Which countries standards are equivalent to ours?
The Minister has deemed that all aircraft built to the standards of the Amateur Building rules in the USA meet Canadian Standards.
Can I import an aircraft from a country other than the USA?
Yes, but we will first have to submit your request to TC for review of the standards of the jurisdiction concerned, and a decision on the case in question. This could take some time.
What restrictions will I have upon issue of my Special C of A?
The standard operating conditions for an imported Amateur Built aircraft are: 1. VFR only and 2. Aerobatics Prohibited.
If the aircraft was rated for either of the above on its foreign C of A, we may be able to continue the permission on the Canadian C of A. Make sure you bring this question up during the application process.
Can I take passengers in my imported aircraft?
Yes, the only conditions are those stated above.
Can the aircraft be flown into Canada to get it into the country?
Yes, but it must be flown by a person with an American Pilot license during the time it is flown in Canada.
Can I conclude the sale in the USA and still fly the aircraft into Canada?
Yes, In this case the aircraft will be de-registered in the USA.
Transport Canada can issue a Provisional Registration and a Ferry Permit for this purpose, so it can be flown by the holder of a Canadian license. Please contact your local TC office for details.
What taxes to I pay and what paperwork do I need at the border?
Please contact Canadian Border Services for this information.
Can I keep the “Experimental” decals and markings?
No, these markings must be removed or covered on all surfaces except the Aircraft Identification Plate.
Do I have the same privileges to maintain the aircraft as if I were the builder under Canadian rules?
Yes- please see our www.md-ra.com site for information concerning maintenance requirements and the issue of maintenance releases.
Please refer to our www.md-ra.com site for detailed information on process and procedures.
Can I request a specific inspector?
No, we will assign the inspector. If you do make such a request, we will have to refuse, and send another.
Can I call an inspector for advice during my construction?
No, our inspectors are not permitted to consult or coach, or to inspect any project they have worked on. Please call the office with your questions, and you will get an answer, or be referred to a knowledgeable person for assistance.
Can I get builder assistance on my project?
Yes, you can have professional help.
Is the amount of help I receive limited by the Major Portion Rule?
No, there is no limit.
Do I have to supervise the assistance 100% of the time?
No- but you must be in control of all aspects of the project at all times.
Can my assisting person represent me during the inspection?
No, the builder of record must be present during the inspection and be able to answer all questions about the project which may be asked by the inspector.
Note: The inspector may, at his sole discretion, exclude any person from participation in the inspection in progress.
When will the inspector arrive?
When you have all required paperwork complete and the project ready, then you call the inspector listed on the MDRA C07 form which we send to you, and make the appointment.
What is a pre-cover inspection and why do I need one?
A pre-cover inspection is mandated to provide for inspection of any areas which will not be accessible once the aircraft is completed and ready for final inspection. The purpose is to ensure that the builder used acceptable materials and methods of construction, and to provide for correction of any observed deficiencies prior to any further progress on the project.
If I have deficiencies, what is the procedure to correct them?
The inspector will complete an inspection report (MDRA form C21) on which he will list the components inspected, the deficiencies found, and he will also indicate any other inspections which are required.
The report (also called a “snag sheet”) is in 3 copies, you as the builder will be given the white, original copy. On the back, you will list the corrective measures taken and keep the form in your project records for the next inspection.
Note: The C21 is a serial numbered form, and it is extremely important that you fill it out as required and keep your copy in your project file. It will be required for inclusion in the documentation at your final inspection.
Does the inspector have to return to see the corrections?
No, not normally. In special cases, a Supplementary Inspection may be required, which will necessitate a return visit.
What does a Supplementary Inspection mean?
If deficiencies are particularly serious on a pre-cover, the inspector, at his option, may require a second visit to ensure that the remedial measures are acceptable. This requires payment of an inspection fee and associated travel fees. Upon completion, you will receive another written report for your files. Note: The C21 is a serial numbered form, and it is extremely important that you fill it out as required and keep your copy in your project file. It will be required for inclusion in the documentation at your final inspection.
Can I have more than one visit on a pre-cover?
No, each visit requires an application and payment of the inspection fee and associated travel for the inspector.
If you can, you are best to assemble the components, closed with temporary fasteners, and store them away until you have all parts available for inspection.
In this way, you can reduce fees paid.
- 8. MAJOR PORTION EVALUATION
See section 3, above.
This applies to aircraft of wooden and composite construction, for inspection of a spar which, when complete, is an enclosed box. It must be inspected before closure.
- 10. FINAL AND IMPORT INSPECTIONS
These inspections take place when the aircraft is in all respects ready for flight, but with inspection covers, cowlings, and spinners, etc. removed.
You must have your certificate of registration for the aircraft, and provide numerous documents and reports for the inspector upon his arrival.
How do I apply for the inspection?
Go to the www.md-ra.com site or call the office (877-419-2111) and get the C02 Inspection Request form, complete it, and send it in with payment.
The staff will process the application, and send you the required forms and information to assist in the process.
Note: There is quite a lot of documentation. Read it all carefully and call the office if you have any questions.
What documentation do I require?
You need the application for registration, application for Special C of A, weight and balance report, maintenance schedule, log book with some initial entries, project history, Certificate of Registration, your white copies of the inspection reports from all previous inspections, among others. All this information will be found in the reply to your inspection request. Read it all carefully and call the office if you have any questions.
- 11. REGISRATION AND MARKINGS
When do I have to register my aircraft?
You must register your aircraft prior to the Final or Import inspection and you must have the Certificate of Registration to show the inspector at the time of the Final or Import Inspection.
How do I get marks assigned?
At the time of your pre-cover, you will be given MDRA form C15, to apply for marks. The inspector will sign the document and leave it with you after the inspection. There is a fee for this (payable to the Receiver General), and you must renew your reservation annually.
Can I request special marks?
Yes, on the C15 form there is a section to request special marks. There is an extra fee for this, and the reservation is renewable annually.
How do I register my aircraft?
You start by submitting the MDRA C02 Inspection Request (Final or Import) to the MDRA office. We will then send you the information and forms you need to apply to Transport Canada for your registration. If you have built the aircraft yourself, you should have marks reserved after the pre-cover inspection.
For an import, you will have the opportunity to get the marks at the time of application.
Note: Do not send your application for registration to TC before you apply for the inspection. The fee for registration is $110.00 payable to the Receiver General.
Do not send your application for registration to MDRA.
What size do I make the letters on my aircraft and where can I put them?
Please refer to our www.md-ra.com site for information on markings. Here is another “Rule of Thumb”- If you have a space on the fuselage which will permit letters of the maximum required size, you must use it. Aesthetic considerations are not operative here.
Do I have to put letters under the wings?
No, but you must have letters on the sides of the fuselage 12in. in height, please see the www.md-ra.com site