Annual on Canadian aircraft? Or import?

tommywcom

tommywcom

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tommywcom
I just moved to the Los Angeles area and brought my Seneca down with me. The Seneca is Canadian registered and I have owned it for more than 5 years.

My question is are there any mechanics who perform annuals on Canadian registered planes? If so, I would assume they are accredited AMEs (what mechanics are called in Canada) who are also doing business working on Canadian planes?

I suppose the other alternative is for me to import the plane. I have read it requires a bill of sale - in this case do I just "sell" it to myself and write up a bill of sale?
 
The import will be a hassle. It's a LOT more than just "selling the airplane to yourself". You have to de-register it in Canada and have it inspected and registered with the FAA. You'll also not be able to fly it once it is N-numbered using your Canadian pilot licence (or "aviation document", or whatever they are calling it this week). You'll need an FAA endorsement first.

Might be worth it all if you plan to stay in the USA "forever", but if your stint is only for a few years you'll be way better off finding a Transport Canada approved mechanic, or fly your plane back to Canada for the annuals. I wouldn't think you'd have too much difficulty finding a TC approved mechanic in SoCal though. Check the shops that do work for brokers doing exports of aircraft to Canada. They usually have a TC approved person for the airworthiness inspections and sign offs for TC ferry permits.

Finally, welcome to PoA. Great to have another piston twin owner/pilot in the fold!

Where did you have the Seneca based when you were in B.C.? Boundary Bay? Pitt Meadows? Abbie?
 
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Thanks for the reply, @GRG55 . I am slightly worried about the importation / inspection part - in the event that I have to make modifications etc.

The upside is if imported, I will not need to comply with the 10-year prop overhaul mandated by Transport Canada which is coming up in a couple of years. That's $15K out the window give or take.

I do have an FAA certificate from way back when I lived in the US, so that's one less thing to worry about ...

Flying back for every annual is an option, but it also gets expensive. Back and forth would cost me $2K - so that's essentially $2K extra for every annual plus I will have to be up there for 2-4 weeks. Certainly an option - but I'm hoping there's an easier way.

I was based in Langley when I was in BC.
 
I’ll put it this way. Importing is not likely to be the “easier way”.

If I were in your shoes I’d do what makes the most sense. Do you plan on permanently residing here? If yes, import the plane. If no, and you’d want to have the plane return to Canada with you I’d leave it C registered.

I’ve been involved in a number of imports. Transport Canada can be a pain to deal with sometimes (we got the run around from them for 8 months when trying to deregister the last plane) plus if there are any poorly documented modifications or modifications performed that have no STC here in the US you can be in for a long ride. A friend and I just finished an import on a Stinson on floats with some unique modifications and the process took close to two years to complete for various reasons.
 
tommywcom said:
are there any mechanics who perform annuals on Canadian registered planes?
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There are various agreements between the FAA and TCCA on reciprocal aircraft maintenance authorizations. I believe the one below is applicable to your case. But I would talk to your local FAA FSDO and perhaps someone at TCCA for current details. I've never seen it work on the airplane side but know several instance of FAA A&Ps/IAs working on Charlie-Reg helicopters legally without a TCCA AME.
https://www.faa.gov/aircraft/repair/media/mip_can.pdf
 
All very good information. Thanks.

Unfortunately, going thru the https://www.faa.gov/aircraft/repair/media/mip_can.pdf doc, Section B, 1.2.b says:

"The FAA- certificated A&P mechanic is not authorized to perform Annual Inspections or Specialized Maintenance as defined in Section A of this MIP."​

So I interpret it as maintenance items outside of annuals are fine, but not the annuals themselves.

As for my long term plan, I think I will be here for the long haul. But I'm on the fence as far as how long I will hold on to the Seneca. Ideally I will upgrade to a more capable piston over the next 5 years. But of course upgrading will cost quite a bit and what I have in the Seneca is already a sunk cost.
 
tommywcom said:
So I interpret it as maintenance items outside of annuals are fine, but not the annuals themselves.
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Check with the FSDO and TCCA or contact the department listed in the MIP. I believe annuals can be performed by an FAA Repair Station.
 
I am no help, I have only exported an aircraft to canada.

Based on what a persnickety process it was for us, and assuming your Seneca is up to scratch for CAA, I'd expect it to be the easier path, going CA -> US than vice versa. I got the distinct impression that the CA authorities are pickier than US authorities on the subject of airworthiness.

Good luck with whatever path you choose. Enjoy LA Airspace, such a great place to fly. :D
 
schmookeeg said:
Based on what a persnickety process it was for us, and assuming your Seneca is up to scratch for CAA, I'd expect it to be the easier path, going CA -> US than vice versa. I got the distinct impression that the CA authorities are pickier than US authorities on the subject of airworthiness.
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In theory that might be true. But having been part of the import game going the other way I've consistently found that the Canadians seem much more willing to modify things and the recordkeeping of those important things (specifically modifications) is often almost nonexistent. (At least on the light airplanes I've dealt with.) This can make it hard to get an import done sometimes. The Stinson I mentioned in an earlier post was one of these airplanes. It was a beautiful plane, very unique (highly modified), and probably one of the best of the breed. But nothing was on paper for any of the modifications despite the claim that all were done IAW STCs.

So I'd caution the OP to be aware of what they're getting into. If the OP wants to fly now I'd either look at getting the plane back to Canada to complete the inspection or look into the path Bell206 pointed out. If they're ok with the plane being down for an unknown length of time I think an import would be possibly a better option. Especially if the idea is to sell the current plane in a few years to upgrade. I suspect he'd be marketing an N registered airplane to a larger audience than he would be if it remains C registered.
 
I know nothing about the particulars, but California likes to tax stuffs. Foreign registry could be advantageous in that regard.
 
Tom-D said:
Find an A&P-IA with balls and get it done
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Please supply a reference.

As far as I know, annuals are not allowed, except at a repair station with a TC supplement.
 
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JAWS said:
Please supply a reference.

As far as I know, annuals are not allowed, except at a repair station with a TC supplement.
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continue reading.
 
Bell206 said:
Check with the FSDO and TCCA or contact the department listed in the MIP. I believe annuals can be performed by an FAA Repair Station.
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2.2 (B), Section B of the MIP agreement clearly states US repair stations cannot perform an annual inspection on TC registered aircraft.

I've read through the document and can't find an exception on that.
 
Doc Holliday said:
So help me out here Tom, using the document you supplied, where does it authorize a US A&P (assuming he has an IA) to do an annual inspection on a TC registered aircraft?
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Start on page 18 in Section B. It's all outlined there.
 
Doc Holliday said:
MIP agreement clearly states US repair stations cannot perform an annual inspection on TC registered aircraft.
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Might be as JAWS states above with an additional TCCA authority. I've never been through it but have seen some C reg helicopters signed off by A&Ps and if I recall correctly the annual also as it was part of a CoA Import process.??
 
Bell206 said:
Might be as JAWS states above with an additional TCCA authority. I've never been through it but have seen some C reg helicopters signed off by A&Ps and if I recall correctly the annual also as it was part of a CoA Import process.??
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The document is very specific in what I'm reading. I too looked for additional authorizations, but can't find it.

I could see the annual in the instance of import process, but this document specifies maintenance for commercial and non commercial aircraft on both sides of the border using TC AME's and FAA A&P's.

If it's possible, I would like to see it.
 
Did some more research on this.

TCCA has an Advisory Circular AC 571-002 dated 5/1/2019. It covers everything in the bilateral agreement with the FAA.

Go to 5.0, Section B "Special Conditions:Guidance for FAA Certificated A&P Mechanics and FAA Certificated Repair Stations"

5.1 "FAA Certificated A&P mechanics located within the US performing work on Canadian-registered aircraft that are not operated in commercial air service pursuant to Part VII of the CARs. No TCCA supplement required.

2. FAA Certificated A&P mechanics may not approve an aircraft for return to service for the following:

a) Specialized maintenance;

b) Annual Inspections; or

c) Instalation of "rebuilt parts".

Now, a certain individual will try to twist this as "A&P's can't do annuals, so it doesn't apply". Wrong again.

A FAA Airframe and Powerplant certificate is just that, a certificate. For an A&P to perform an annual he must hold an Inspection Authorization. An IA is a designee of the administrator, and a IA is not a certificate.

14 CFR Part 43.17 (c) Authorized persons. (1) A person holding a valid Transport Canada Civil Aviation Maintenance Engineer license and appropriate ratings may, with respect to US registered aircraft located in Canada, perform maintenance, preventive maintenance, and alterations in accordance with the requirements of paragraph (d) of this section and approve the return to service in accordance with the requirements of paragraph (e) of this section.

14 CFR Part 43.17 (2) (d) Performance Requirements. A person authorized in paragraph (c) of this section may perform maintenance (including any inspection required by Sec. 91.409 of this chapter, except for an annual inspection)

So after reading it's clear that a US A&P (with IA) can't sign off an annual on a TC registered aircraft, and a TC AME (with authorization) cannot sign off an annual on a US FAA registered aircraft.
 
Doc Holliday said:
TCCA has an Advisory Circular AC 571-002
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Was looking too. FAA has similar AC: https://www.faa.gov/documentlibrary/media/advisory_circular/ac 43-10c.pdf
States basically same info as TCCA AC and MIP: No annual/12-Month sign offs allowed either way. There appears to be a method to get a TCCA AMO/FAA CRS approved to handle these type inspections but it is outside the scope of the BASA and MIP. I think a quick call to the FSDO will get this answered for the OP.
 
To no one in particular.
Read Para 9.2.2 and 1.2.b
Then tell me id FAR 65 doesn't give me the IA privileges
And doesn't it separate the A&P from the A&P-IA
the work that far 65 gives the A&P is the same here as it is in Canada.
The work that FAR 65 gives the -IA is good in the USA is also good in Canada too.

For many years I maintained a F-24 in "C" registry It was owned by an inspector of the Canadian CAA.
Do not concentrate on the A&P, Their privileges are different than the privileges of the A&P-IA
 
Tom-D said:
To no one in particular.
Read Para 9.2.2 and 1.2.b
Then tell me id FAR 65 doesn't give me the IA privileges
And doesn't it separate the A&P from the A&P-IA
the work that far 65 gives the A&P is the same here as it is in Canada.
The work that FAR 65 gives the -IA is good in the USA is also good in Canada too.

For many years I maintained a F-24 in "C" registry It was owned by an inspector of the Canadian CAA.
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So did you sign off annuals on the "C" registered F-24?

Tom-D said:
Do not concentrate on the A&P, Their privileges are different than the privileges of the A&P-IA
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You need to understand the difference between a A&P certificate, and a Inspection Authorization.
 
Ryanb said:
I can assure you he knows the difference between the two.
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Are you his spokesman by chance? Why do you feel the need to answer for him?

Problem is, and as witnessed by his replies so far, he doesn't understand the difference. I've posted documents by the Canadians, The FAA as well as regulations that are quite clear on the subject.
 
Tom-D said:
Do not concentrate on the A&P,
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Curious. So your interpretation is that because it does not mention "Inspection Authorization" and only "certified A&P" that you are still free to perform/sign off annual inspections on C reg aircraft regardless it stating in the MIP, FAA AC 43-10, and TCCA AC 571-002 that "The FAA-certificated A&P mechanic is not authorized to perform Annual Inspections or Specialized Maintenance"??

If so, do you also interpret a TCCA AME can perform annuals on an N reg aircraft too, due to the ambiguity of the text in the above referenced docs?
 
Is there a difference between an A&P's privileges and a A&P-IA's privileges?
Does the TCCA not say we are governed by our privileges under FAR 65?

Yes, Transport Canada see no differences under this agreement from a US A&P-IA and a Canadian AME
Can I go north and practice my trade? - NO
Can a AME come south and practice? -NO
Can a AME in Canada annual a "N" numbered aircraft in Canada - yes
Can a A&P-IA complete a 12 month inspection on a "C" registered Aircraft in the US - Yes
And why would you recommend anyone calling FSDO and ask about Canada rules?
Simply call Transport Canada offices in Vancouver
 
Tom-D said:
Can a AME in Canada annual a "N" numbered aircraft in Canada - yes
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Actually no per FAR 43.17(d):
(d) Performance requirements. A person authorized in paragraph (c) of this section may perform maintenance (including any inspection required by Sec. 91.409 of this chapter, except an annual inspection), preventive maintenance, and alterations, provided—
Tom-D said:
Can a A&P-IA complete a 12 month inspection on a "C" registered Aircraft in the US - Yes
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Actually no per TCCA Part V, Subpart 71:

Part V — Airworthiness (continued)
Subpart 71 — Aircraft Maintenance Requirements (continued)
Persons Who May Sign a Maintenance Release
  • 571.11 (1) Except as provided in subsections (2) and (7), no person other than the holder of an aircraft maintenance engineer (AME) licence issued under Part IV, specifying a rating appropriate to the aeronautical product being maintained, shall sign a maintenance release as required by section 571.10.

  • (2) A person other than a person described in subsection (1) may sign a maintenance release if

    • (a) in the case of maintenance performed outside Canada,
      • (i) the person is authorized to sign under the laws of a state that is party to an agreement or a technical arrangement with Canada and the agreement or technical arrangement provides for such certification, or

      • (ii) if no agreement or technical arrangement provides for such certification, the person holds qualifications that the Minister determines to be equivalent to those of a person described in subsection (1);
The certification above being your A&P, which correct me if I'm wrong, your Inspection Authorization requires a valid A&P certification per Part 65, which as you stated above "Does the TCCA not say we are governed by our privileges under FAR 65" confirms this? So if the certified A&P is not authorized to perform an annual how can he legally use his IA per the MIP, the AC, or the CARs?

And the reason I recommend the OP to call his local FSDO is because the FAA has direct oversight of any C reg aircraft in the US, per the MIP referenced above. If we were discussing an N reg in Canada then the appropriate call would be to a TCCA office.

But you are correct an A&P and an AME cannot travel to each others countries to perform an annual or mx.:)
 
Back to the OP.

Have you tried to locate a Canadian AME that may be living in California?
 
If you are thinking of selling, it’s still probably worth reregistering or at least clearing all the roadblocks so you could.

Approaching from the position of a potential buyer, I would avoid a Canadian registered aircraft. Selling in LA and having a Canadian registration would be a strong disincentive to buying. So it might be some pain to get it registered, but your potential pool of local buyers will go way up - and according to the laws of supply and demand, so will your price.
 
Things have changed.
https://www.faa.gov/aircraft/repair/media/mip_can.pdf
Revision 1 June 14, 2019
I still believe an A&P-IA operating under FAR part 65 can.
  1. TheFAA-certificated A&P mechanic must perform the work within their privileges and limitations in accordance with 14 CFR part 65. The FAA- certificated A&P mechanic is not authorized to perform Annual Inspections or Specialized Maintenance as defined in Section A of this MIP.
    And the A&P can't, never could here or there.

 
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Tom-D said:
Things have changed.
https://www.faa.gov/aircraft/repair/media/mip_can.pdf
Revision 1 June 14, 2019
I still believe an A&P-IA operating under FAR part 65 can.
  1. TheFAA-certificated A&P mechanic must perform the work within their privileges and limitations in accordance with 14 CFR part 65. The FAA- certificated A&P mechanic is not authorized to perform Annual Inspections or Specialized Maintenance as defined in Section A of this MIP.
    And the A&P can't, never could here or there.
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You would be the only one with that belief. BTW, since you feel you could sign off a Canadian Registered aircraft for it's 12 month (annual) inspection, how would you go about complying with the provisions of the TC CAR's in regards to such an inspection, and how would you word the sign off in the logs, as well as the reporting requirements? There are differences in the FAA annual requirements and the TC 12 month inspection.
 
Tom-D said:
Revision 1 June 14, 2019..... I still believe an A&P-IA operating under FAR part 65 can.
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FYI: that was the same rev date of one I posted. But I think if the FAA Inspection Authorization was a stand alone certification you would have something. However, it is the A&P certification that legally gives you the ability to work on an aircraft and sign off that work, not the IA. The IA solely provides additional administrative privileges. Should they have included the term "Inspection Authorization" in the MIP? Maybe. However, considering the MIP is a legal agreement between governments, the agreement terms would follow that legal protocol and only use proper terms, i.e., certified A&P and licensed AME. But if you want to sign off a 12 month on a C- reg under your A&P/IA have at it. Unfortunately, the owner would also be on the hook if that sign off was not proper and flew the aircraft.
 
tommywcom said:
trying to see if there are Canadian AMEs in California.
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FYI: bflynn makes a valid point above. If you do plan to sell the aircraft before moving to back north, you may look into doing an import when your next annual/12-month is due. Part of the import process is a airworthiness verification by the FSDO or a DAR-T which most comply with an annual to satisfy. You could kill 2 birds with one stone. You could complete the dereg/rereg process, AWC app approval and have your new N number applied while the aircraft is down for its annual by an APIA. I haven't done an airplane this way but have been involve on a number of helicopters that follow the same process.
 
Bell206 said:
FYI: that was the same rev date of one I posted. But I think if the FAA Inspection Authorization was a stand alone certification you would have something. However, it is the A&P certification that legally gives you the ability to work on an aircraft and sign off that work, not the IA. The IA solely provides additional administrative privileges. Should they have included the term "Inspection Authorization" in the MIP? Maybe. However, considering the MIP is a legal agreement between governments, the agreement terms would follow that legal protocol and only use proper terms, i.e., certified A&P and licensed AME. But if you want to sign off a 12 month on a C- reg under your A&P/IA have at it. Unfortunately, the owner would also be on the hook if that sign off was not proper and flew the aircraft.
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+1
 
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