Questions and Answers

1. I hold a valid Temporary Private Operator Certificate (TPOC) – will I have to register and resubmit all my documentation to Transport Canada again?

No. Transport Canada will provide all existing private operators with replacement documents that comply with the new regulations.

2. I am a TPOC holder. Do I need to follow all of the new regulations on the day that they come into effect?

No. You must comply with some, but not all of the divisions and/or sections of the new regulations the day they come into effect. Transport Canada has issued a 24-month exemption to private operators who held a TPOC in conjunction with the Interim Order. This will give you time to comply with specific divisions and sections of the new regulations.

3. I am not a private operator now, but I plan to buy an aircraft that will require me to register. What do I need to do?

  • If you are new and don't want or require any of the Division IV of Subpart 604 special authorisations, you must provide Transport Canada with the information listed in Section 604.04.

You may submit your request to become a private operator and information electronically (email) or via hardcopy. When Transport Canada receives your information we will send you a Private Operator Registration (POR).

You may also submit a Private Operator Registration (POR) form to Transport Canada, which includes all the information that you must provide to request a POR. Note that use of the POR form is not mandatory.

  • If you are new and want one or more of the special Division IV authorizations, you must provide the information listed in Section 604.05 and identify the activity in Division IV that you wish to carry out.

Be sure to include the part of your private operator operations manual that sets out the processes, practices and procedures relating to the special authorization you request. When Transport Canada receives your section 604.04 information, we will send you a Private Operator Registration (POR). We will issue the special authorization(s) after we have reviewed the part of your private operator operations manual and confirmed that you are able to meet its Division IV requirements.

4. I am a new private operator. Do I need to follow all of the new regulations on the day that they come into effect?

Yes.

5. What is a "special authorisation" and what do I need to do to get one?

Transport Canada will issue all operators "Operations Specifications" in the new ICAO format. Your Private Operator Registration (POR) will:

  • come with an Operations Specification for each type of aircraft model that you operate; and
  • include the Division IV Subpart 604 Special Authorizations we approve you to conduct.

Note: The Special Authorizations will reflect the authorities you held, previously known as Ops Spec. You obtain a special authorization by providing Transport Canada with the information specified in section 604.05.

6. I want one or more of the special authorizations, but I don't want to operate as a private operator. Can I obtain a special authorization(s) without registering as a private operator and without following the requirements of Subpart 604?

No.

7. What is the difference between 604.02 Application and 604.03 Prohibition?

  • 604.02 "Application" identifies which Canadian aircraft are eligible to participate or operate under Subpart 604. If your aircraft is not on the list, you may not operate under this Subpart.
  • 604.03 "Prohibition" identifies which Canadian aircraft you must operate under Subpart 604.

8. I was not required to be a Private Operator under the Interim Orders, but am now captured by 604.03 "Prohibition" because I operate a pressurized turbine-powered aeroplane certified for more than six passenger seats. Do I need to comply with all of the new regulations the day they come into force?

No. Transport Canada will require you to comply with some, but not all of the divisions and/or sections of the new regulations the day they come into effect. You must register as a private operator in accordance with 604.03 and 604.04; and if you wish to obtain one of the Special Authorizations in Division IV, you must comply with 604.05 and all of Division IV. We have issued a 24-month exemption that provides private operators, who were not previously captured by the Interim Order. This will give you time to comply with the new regulations.

9. Section 604.38 calls for an "operational flight data sheet". Does this need to be a paper document, or can I record this flight data in electronic format?

The operational flight data sheet may be paper (hardcopy) or electronic, as long as you record the information specified in the regulation in some format and keep it for at least 180 days after the day you completed the flight.

10. While there is a requirement for me to have an operations manual, do I need approval before I can use or amend it?

No.

11. I have a number of manuals, each of which includes a part of what is listed in 604.197. Do I need to re-create my manual so it's all in one big book?

No.

12. Section 604.180 talks about "dispatchers" … If I operate a dispatch office to help our pilots prepare for flights, does that mean my office staff needs to complete all of the training listed in 604.180?

"Dispatcher" training applies only to situations where an operator uses co-authority dispatch procedures that share dispatch responsibilities between pilots and dispatchers. We consider that operators who use pilot self-dispatch procedures, whether or not someone else is available to help, are conducting "flight following" not "dispatch".

13. I operate one pressurized 8 passenger turbo-prop aeroplane with a gross weight of 10,000 lbs. Do I have to operate as a private operator?

Section 604.03 includes: large aeroplanes; turbo-jet powered aeroplanes; or turbine-powered pressurized aeroplanes certificated for more than six passenger seats.

Since your aircraft falls within the category of turbine-powered pressurized certificated for more than six passenger seats, you will have to operate as a private operator; unless you are operating:

  • under Part VII requirements; or
  • under a flight permit issued under section 507.04.

14. I operate one pressurized turbo-prop aeroplane certified to carry 6 passengers, with a gross weight of 10,000 lbs. Do I have to operate as a private operator?

No. However, if you want one or more Division IV special authorizations, you must register as a private operator and follow the process outlined in Section 604.05.

15. I operate one pressurized turbo-prop aeroplane certified to carry 6 passengers, with a gross weight of 10,000 lbs. I want to conduct GNSS procedures, but do not require any other of the special authorizations described in Division IV. Do I have to operate as a private operator?

No. Since Section 604.03 "Prohibition" does not make it mandatory for you register and operate as a private operator, Section 604.47(2) applies. This allows you to conduct instrument approach procedures to the following minima: LNAV, LNAV/VNAV, LP and LPV, without a Special Authorization.

Note: If you wish to conduct any of the other Division IV activities, you must register as a private operator and operate your aircraft in accordance with Subpart 604.

16. I'm a foreign private operator flying into Canada. Do I need to follow the new private operator regulations?

No, subpart 604 applies only to Canadian private operators. Foreign private operators are not required to adhere to any of these requirements and are not able take advantage of any opportunities, such as special authorizations granted by these regulations.

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