Pursuant to subsection 5.9(2) of the Aeronautics Act, and after taking into account that the exemption is in the public interest and is not likely to affect aviation safety, I hereby exempt Canadian air operators that do not have an authorization to carry an external load and that operate a float equipped aeroplane pursuant to Subpart 703 of the Canadian Aviation Regulations (CARs), from the requirements of paragraph 605.03(1)(b) and when operating with passengers on board, from both the requirements of paragraph 605.03(1)(b) and section 703.25 of the CARs, subject to the following conditions.

Paragraph 605.03(1)(b) of the CARs stipulates that no person shall operate an aircraft in flight unless the aircraft is operated in accordance with the conditions set out in the flight authority.

Section 703.25 of the CARs stipulates that no air operator shall operate an aircraft to carry an external load with passengers on board except where carriage of an external load has been authorized in a type certificate or supplemental type certificate


The purpose of this exemption is to allow Canadian air operators to carry external loads on their float equipped aeroplanes without an authorization in the type certificate or in a supplemental type certificate and without complying with the conditions of the aeroplane flight authority with respect to the approval of the carriage of external loads.


This exemption applies to Canadian air operators when operating float equipped aeroplanes pursuant to Subpart 703 of the CARs and who are not authorized in a type certificate or supplemental type certificate to carry an external load.

This exemption does not apply to Canadian air operators who have been authorized in a type certificate or supplemental type certificate to carry an external load. These air operators shall comply with the conditions of the type certificate or supplemental type certificate.


This exemption is subject to the following conditions:

  1. The air operator shall, at all times, comply with all conditions set out in the aeroplane flight authority that are not related to the approval of the carriage of external loads.
  2. The air operator shall conduct the operation in accordance with the procedures set out in Annex A as attached;
  3. The air operator shall conduct the operation in DAY/VFR conditions only;
  4. The air operator shall include and emphasize any special egress procedures in the passenger pre-flight briefing and the alternate escape routes shall be clearly marked;
  5. The Company Operations Manual shall contain directions to flight crews concerning operations with external loads, including:
    1. a detailed description of the proposed means, which is readily repeatable, of locating and securing each load to the aeroplane;
    2. the limitations and procedures associated with the carriage of external loads; and
    3. the requirements as set out in Annex A of this exemption.
  6. The air operator shall retain the results of the proving flight set out in Annex A for a period of not less than three years;
  7. The Chief Pilot shall certify that every pilot authorized to carry external loads has been briefed and trained in accordance with section 723.88 of the Commercial Air Services Standard (CASS), and a record of this training shall be retained in the pilot’s training file, in accordance with subsections 703.99(1) and (2) of the CARs.


This exemption is in effect until the earliest of the following:

  1. 23:59 EST on December 31, 2005;
  2. the date on which an amendment to the appropriate provision of the CARs or related standards comes into effect;
  3. the date on which any of the conditions set out in this exemption is breached;
  4. the date on which this exemption is cancelled in writing by the Minister where he is of the opinion that it is no longer in the public interest or that it is likely to affect aviation safety.

Dated at Ottawa, Canada this 24th day December 2004, on behalf of the Minister of Transport.

Original signed by Merlin Preuss

Merlin Preuss
Director General
Civil Aviation

Attach. Annex A


  1. Load Location and Securing
    1. Loads shall be located so as not to impede emergency egress from the aeroplane, and the airflow in the vicinity of pitot and static sources and other air scoops or exhaust ports shall not be adversely affected.
    2. Loads shall be located and attached to the aeroplane in a manner that is both secure and repeatable, using a minimum of three separate ropes, straps or other means such that failure of any single connection does not create a hazard.
    3. Boats shall be mounted with the bow facing aft to minimize the effect of the turbulent wake on the tail surfaces, far enough aft of the propeller to prevent interference with the airflow and possible cavitation, and in a manner that prevents amounts of water from being caught and retained during take-off and landing that would create a safety hazard.
    4. Where a number of separate pieces are carried together (i.e., lumber, pipes), these pieces shall be fastened together to prevent a single piece from coming loose.
    5. The aeroplane structure shall be protected from chafing, dents or damage caused by vibration or shifting of the external load.
    6. The pilot shall check the aeroplane at the attachment points and general area of the external load for damage after each landing.

    Note: Water collection and retention shall be assessed following a high-speed water taxi.

  2. Proving Flight

  3. For each particular type of load not previously carried by the air operator on a particular make and model of aeroplane operated by the air operator, the air operator shall conduct a proving flight that meets the following requirements:
    1. The air operator shall show that the flight characteristics are safe with the load attached and that the aeroplane is safely controllable and manoeuvrable within the reduced operating envelope described under Operating Limitations below, with no exceptional pilot alertness, skill, or strength required. All changes to the aeroplane weight and centre of gravity when passengers and internal cargo are carried shall be considered.
    2. The air operator shall maintain a record of the proving flight that includes at least the following information:
      1. the date, time and location of the proving flight;
      2. the aeroplane registration, type and model; and
      3. a description of the external load being tested.

      Note: Proving flights are not necessary on subsequent flights carrying similar loads, provided that the loads are located and secured in an identical manner and the aeroplane weight and centre of gravity are not significantly altered.

  4. Operating Limitations
    1. The maximum gross take-off weight of the aeroplane shall be reduced by twice the weight of any external load attached.
    2. The maximum bank angle during external load carriage shall not exceed 30 degrees.
    3. The maximum operating speed shall be no more than 90% of the maximum speed demonstrated to be safe during the proving flight and no less than 1.5 times the stalling speed.


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