By Scott McFadden, EAA 611467/Vintage 726528, Thunder Bay, Ontario, and KCFC, Grand Marais, Minneapolis
For the past few years, I did not fly my Taylorcraft in “mode C” airspace. That changed this past spring, and I had to complete the two-year mandatory altimeter/transponder performance test. I’m an AME (aircraft maintenance engineer) so I did the removal and installation (R&I) of the altimeter and the pitot/static system leak checks myself. When I received the invoice, I was stunned.
I have a mode S transponder with built-in encoder, and the broadcasting altitude is displayed on the transponder in real time. I perform the system leak test before calling the shop as a preemptive measure. I also do the altimeter R&I.
With the connections made for the leak test, I take a little time and run the system to 16,000 feet and verify the correlation between the newly tested altimeter and transponder displayed output is within the tolerance set out in the standard.
The equipment necessary to complete the above tests costs around $50 plus some tubing and fittings. Other than being confident there would be no labour charges for chasing down plumbing problems, none of this work counts because Transport Canada requires even the leak check must be certified by an AMO (approved maintenance organization).
Over the years this two-year requirement has morphed from a relatively simple and inexpensive process that was done without disturbing the system (unless an issue was identified), to the current requirement that includes mandatory removal of the altimeter(s) (with the associated risks) and the rather obscene price tag. Meanwhile the reliability of these systems and on-board redundancy in the typical GA aircraft has dramatically improved.
For example, my 172 has an altimeter, encoder, GPS navigator, Mode S transponder, and two PFDs each with a solid state altimeter built in. In addition, I can go online and verify the altitude being reported by my transponder in real time. If that’s not enough, standard procedure has me report my altitude or passing altitude on initial contact with ATC, so the performance of my system is verified, again in real time.
We appear to be headed in the wrong direction, i.e., more onerous testing of considerably more reliable systems with more and better redundancy. There may be a legitimate argument to support the notion that we’re unintentionally increasing risk (demonstrated higher probability of malfunction following any maintenance on aircraft). Certainly the $500 could be better spent on other safety initiatives.
I believe the time and cost threshold has come for GA to begin to push back on this, frankly obsolescent, requirement. I’m not suggesting the elimination of the performance verification requirements, but there are many potential sensible options on the spectrum between no testing and the mandatory $500 two-year extreme.
Some ideas come to mind… Perhaps increase the validity of the certification to four years. Maybe allow for the test to be completed with the altimeter installed. How about a two-year pitot/static leak and discrepancy check (as described above) performed by an AME, coupled with a flight test in non-mode C airspace with altitude verified through one of the internet flight trackers, could be conducted in lieu of the $500 test every two years with the “full” test performed every six years or if a discrepancy is reported to the pilot by ATC.
Aircraft with two compass systems are exempt from the annual compass calibration requirements. That same philosophy could be applied to altimeter systems, i.e., if you have LRUs (line replaceable units) installed that provide independent altitude verification, the current testing requirement is extended to x years. The point is, in 2026 there is room to move in a direction that both decreases costs to owners and, I believe, improves reliability of the airborne systems, therefore reduces risk.
Typical flat rates for the similar U.S. requirement seems to be around US$400, so this is as much of an issue for U.S. owners.
There is an opportunity for EAA to partner with AOPA, COPA, and frankly every other GA organization in and outside North America to push for much needed relief and for once, implement a no-cost (to regulators) cost of ownership reduction for GA aircraft.
One other thought: The CARs (Canadian Aviation Regulations) require every air operator, AMO, airport, etc. to have a safety management system with an “accountable executive.” One of the core responsibilities of the AE is to ensure organizational resources are allocated to areas of risk. Despite the apparent beliefs of regulators, we do live in a world of finite resources.
It is a fundamental conflict for AEs, i.e., being forced to allocate resources to regulated requirements that are NOT supported by objective risk assessment.