Chapter 4 - Aircraft Identification
4.1 MARKS - NATIONALITY AND REGISTRATION
Aircraft marks are comprised of the nationality mark and the registration mark. The nationality of a Canadian aircraft is currently identified with the letter C. The four letters following the nationality mark are known as the registration mark. The first of those four letters is either F or G and, in the case of ultra-light or advanced ultra-light aeroplanes, the letter I. The nationality and registration mark are separated by a hyphen.
Aircraft registered prior to January 1, 1974 were identified with the Nationality mark CF, followed by three letters for the registration mark. Aircraft manufactured prior to January 1, 1957, are known as "vintage aircraft" and may always retain a CF nationality mark if the owner so desires.
NOTE: While advanced ultra-light aeroplanes are identifiable through the use of the letter I, this was not always the case. Advanced ultra-lights registered prior to October 10, 1996 were issued - and may still be displaying - a registration mark that starts with F or G.
People sometimes refer to the marks as "call letters". In referring to marks, care should be taken to be clear by using the phonetic alphabet (see Appendix A).
4.2 MARK SIZE AND LOCATION
Unless an authorization has been issued (see Chapter 4.3), the marks must be affixed to the aircraft prior to its operation. The size and location of the marks depend on the type of aircraft. The Aircraft Marking and Registration Standards 222.01(1) and 222.01(2) detail these requirements, for different categories of aircraft, and should be consulted for guidance.
Mark Size and Location Requirements
Generally, there are marks on the side of the aeroplane or helicopter, and marks on the bottom surface of the wings (aeroplane), fuselage or cabin (helicopter). In Canada, though, marks on the bottom surface are optional.
If the owner has marks both on the side AND on the bottom surface of the wings or fuselage (or cabin for helicopter), the following applies:
- the marks on the side must be at least 15 cm (5.9 inches); and
- the marks on the bottom surface must be at least 50 cm (19.68 inches).
If an owner decides not to display marks under the wings of the aeroplane or the bottom surface of the fuselage (or cabin in the case of a helicopter):
- then the marks on the side must be larger, i.e. they must be at least 30 cm (11.8 inches) except where the dimensions of the structure do not permit this. In that case the marks shall be as high as possible but never less than 15 cm (5.9 inches).
Gliders, amateur-built aircraft and ultra-light aeroplanes
NOTE: For gliders, amateur-built aircraft and ultra-light aeroplanes, not displaying marks on the bottom surface, that have a structure that will not accommodate the 30 cm size marks on the side, then the marks shall be as high as possible but never less than 7.5 cm (3 inches) (see Standard 222.01(2)(o)).
Alternate Mark Size and Location for Structural Configuration Reasons
Where the structure of an aircraft prevents the marks from being displayed in accordance with the Standards, an authorization for alternate location and size may be applied for by the owner. The owner should submit a written request clearly detailing why the alternate location/size is required, along with a clear diagram of the suggested alternate location (see Standard 222.06) This is then forwarded by the Region to Headquarters where, if approved, the authorization is issued.
NOTE: The CARs do not allow for an authorization for alternate mark size or location when the reason is for cosmetic or aesthetic purposes. See Appendix B for a list of aircraft that have been approved an alternate mark size or location.
Former Military Aircraft or Replicas of Military Aircraft
Where a former military or a replica of a military aircraft retains the paint scheme of authentic military colours and military markings, application may be made by the owner for alternate mark size and location. A written request from the owner with a diagram of the aircraft’s military paint scheme and marks is forwarded through the Region to Headquarters where the authorization is either approved and issued or not. Headquarters tracks the aircraft by both the civilian marks and military markings which are affixed to the aircraft (see CARs 202.05 and Standard 222.05).
Production Test Flights - Operation of Aircraft by Manufacturer
Aircraft that are being operated by a manufacturer for the purpose of a production test flight, a customer acceptance flight or a flight to complete the manufacturing process or to export the aircraft (see CARs 202.14) can affix the marks in accordance with CARs 202.01 or 202.07. See Chapter 11 for information on flight authorizations for Canadian-manufactured aircraft.
Marks Displayed at an Angle
Refer to Standard 222.01(2)(n) for details on affixing marks displayed at an angle.
4.3 AUTHORIZATION TO NOT DISPLAY MARKS
Aircraft being operated for the purpose of an exhibition, air show, motion picture or TV production, may require the Canadian marks to be covered or removed. Before the aircraft can be operated in Canada without displaying the marks, an authorization must be issued (see CARs 202.01(2)).
These steps should be followed when issuing the authorization:
- Receive a written request from the aircraft owner. The request must identify the aircraft, the area of operation, the name of the movie (or event) and the date(s) they will be operating.
- Confirm the make and model and serial number of the aircraft with CCARCS.
- The validity period should be the minimum time required and, in any case, is not to exceed one year.
- Prepare the authorization (see Appendix C).
The authorization must be signed by General Aviation Inspectors who are Regional Supervisors. (see Delegation of Authority document - Schedule C-8).
- Place a copy of the authorization on the aircraft file, the company’s 5258 general file and send a copy to headquarters.
CARs 202.04 also allows the removal of marks when an aircraft is being serviced, exported or withdrawn from use. No written authorization is issued when the marks are removed for these reasons.
4.4 CHANGING REGISTRATION MARKS - EXEMPTION
The CARs do not currently allow aircraft to change marks after a continuing Certificate of Registration has been issued. Owners who decide that they would prefer a different registration mark after a Certificate of Registration has been issued will require an exemption to the regulations. A new Certificate of Registration and Certificate of Airworthiness must be issued to reflect the new mark. Only Headquarters has the authority to make the change of marks in CCARCS.
The following steps should be followed when changing a mark:
- Receive a written request from the aircraft owner to change marks along with the $475 exemption fee. If there is also a change of legal custody and control, proof of legal custody and control (see Chapter 8.2) must accompany the request. If the aircraft is subject to a lease agreement, the lessor must also consent to the change.
- Allot the new marks. The owner may request special marks or obtain the next alphabetically generated mark. If the owner requests a special marks, a fee of $140 applies.
- Issue the exemption (see Appendix C).
- The validity period is one month.
- The exemption must be signed by the Regional Director, Civil Aviation. (see Delegation of Authority document - Schedule A-5).
- A copy of the exemption is forwarded to Headquarters Ottawa and is required before they can amend CCARCS to reflect the new mark. Headquarters should be advised to amend CCARCS only when the new Certificate of Registration is ready for issue.
- Before issuing the new Certificate of Registration, the applicant must submit the Certificate of Registration issued with the previous mark, an application form for registration using the new mark, and a fee of $110 for a new Certificate of Registration. The Certificate of Registration with the new marks must be issued before the exemption expires.
- Update CCARCS and print the new Certificate of Registration after headquarters has changed the marks in CCARCS. The Owner Registration Date remains the same and the Certificate Issue Date is the date that the Certificate of Registration is issued. If there is a change of legal custody and control then the Owner Registration Date and Certificate Issue Date will be the same date.
- When the Certificate of Registration is issued with the new mark, the file must be routed to the Records Management office to be changed in RMIS to the new mark. The file cover will also have to be amended to show the new mark.
- Unless the aircraft was an ultra-light, the file should also be routed to Maintenance and Manufacturing for the issuance of a new Certificate of Airworthiness.
4.5 AIRCRAFT IDENTIFICATION PLATE
An aircraft identification plate is a fireproof plate that is attached to the aircraft for identification purposes. The aircraft identification plate identifies the prime component. For aeroplanes and helicopters, it has been determined that the fuselage establishes its identity (see CARs 202.18). For balloons it is the envelope (see CARs 202.19). The aircraft identification plate must be affixed to the aircraft prior to the aircraft being operated. CARs 201.01 details where the plate should be attached to the aircraft.
All aircraft identification plates must have the manufacturer’s name, manufacturer’s model designation, aircraft serial number and where applicable, the type certificate number or equivalent designation permanently engraved on it (see CARs 202.01(4)). In the case of an amateur built aircraft or an ultra-light aeroplane built from plans, the manufacturer is the person who built the aircraft. The manufacturer in the case of an ultra-light aeroplane is the manufacturer of the kit, not the person who assembles the kit.
A copy of the identification plate is submitted to Transport Canada with the initial application form for registration. This is to ensure that the information entered into CCARCS and printed on the Certificate of Registration reflects the same information as the identification plate. Where the model designation on the identification plate is not the same as on the Type Certificate or equivalent document, the Maintenance and Manufacturing branch must determine if the aircraft is properly identified and is eligible for a flight authority. Once Maintenance and Manufacturing has approved the model on the identification plate, headquarters should be informed so that they can update the ID model field in CCARCS with the model on the ID plate. The ID model is then printed on the Certificate of Registration. Where the identity of an aircraft cannot be confirmed, a certificate must not be issued.
Care should be taken with ex-military aircraft to ensure that the information given is from the civilian aircraft identification plate and not the military plate. The model designation and serial number could be different. For deHavilland DHC-2 aircraft, there is a cross- reference index that which lists the manufacturer’s serial number with the corresponding military serial number. Occasionally, de-registration notices received from foreign aviation authorities will be sent with the military serial number rather than the civilian serial number. Maintanance and Manufacturing should be consulted to verify that the information given is correct.
4.6 TRANSFER OF AIRCRAFT IDENTIFICATION PLATE
Under subsection 201.03(1) of the CARs, the removal or replacement of an aircraft identification plate requires an authorization. The delegation for the removal or replacement of an identification plate is with the Regional Manager of Maintenance and Manufacturing. Where the replacement of a prime component occurs, the registration of the aircraft may be affected because the prime component identifies the aircraft. All subordinate components which are subordinate to the prime may be replaced without affecting aircraft registration.
Removal of ID Plate from Old Prime Component and Reinstallation on New Prime Component.
Prior to the issue of an authorization to remove an identification plate from a prime component which is being replaced and install it on the new component, the following conditions must be met:
- the replacement prime component is new and it does not have a serial number assigned to it by the manufacturer;
- acceptable evidence is provided that the old prime component has been permanently removed from service and will not be used to rebuild another aircraft; and
- where applicable, the marks of the aircraft are displayed on the new component.
4.7 MODE S TRANSPONDER ADDRESS
Some aircraft are equipped with Mode S transponders. Mode "S" transponder equipment is capable of selectively interrogating individual, suitably equipped aircraft. They are coded with a unique address that is tied to the aircraft registration mark. CCARCS is used to generate the Mode "S" transponder address code. If generated, the code is printed on the Certificate of Registration. A transponder code should never be given out over the telephone. A print-out from CCARCS should be faxed to the applicant to eliminate potential for misunderstanding.
4.8 TRANSPORT CANADA GENERATED SERIAL NUMBER FOR ULTRA-LIGHT AEROPLANES
When allotting marks, Transport Canada will assign a six digit serial number to ultra-light aeroplanes which were not assigned a serial number by the manufacturer. The serial number is preceded by the letters TC and is keyed to the last three letters of the registration mark relative to their numerical position in the alphabet. To avoid a possible repeat of a serial number each letter A through I, which would normally have a single digit numerical position, shall be preceded by the number 0. For example if the last three letters of the mark are AAA the serial number will be TC010101.
Transport Canada have a time limit applicable to reserving or issuing marks from a de-registered aircraft?
No. The marks from a de-registered aircraft can be reserved for, or issued to, another aircraft as soon as de-registration is complete. If the owner of the de-registered aircraft wants to retain those marks, it is a special mark reservation and the $140 fee applies.
What do I do when someone wants an authorization to not display marks for purposes of a movie production, but the aircraft will not be operated in Canada as stated in CARs 202.01(2)?
CARs 202.01(2) specifies that an authorization may be issued to permit the operation in Canada of an aircraft not displaying marks for purposes of a movie production. If the aircraft were to be operated in another country, Canada would still have to approve the operation of that Canadian aircraft without its marks being displayed.
In the United States, Federal Aviation Administration Regulations (FAR 91.9) makes it clear that "the certificating authority of the country of registry" (i.e. in this case Canada) would have to permit the aircraft to operate without displaying its marks.
This would not be able to be done through a 202.01(2) authorization, however, as the situation does not apply. Instead, it would be done through an exemption (with exemption fee applying) to 202.04 "Removal or Change of Marks after Issuance of Continuing Registration".
NOTE: You may also wish to advise the aircraft owner to discuss with the foreign aviation authority any other requirements which they must meet while their aircraft is operating in the movie production in that foreign country.
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