Today's Message Index:
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1. 04:24 AM - encoder approval ()
2. 04:39 AM - encoder approval ()
Message 1
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| Subject: | encoder approval |
--> Avionics-List message posted by: <bakerocb@cox.net>
8/11/2006
Responding to an AeroElectric-List message previously posted by Kevin
Horton.
Hello Kevin, Time spent in attempting to correct an injustice or an
absurdity by governments is never wasted. It is a peculiarity of human
nature that once people are placed in a position of authority or officialdom
that a percentage of them will abuse that position either out of ignorance
or arrogance. Left unchallenged, that abuse never diminishes on its own, but
instead tends to grow.
The current situation is that every day companies are manufacturing and
selling more non TSO'd encoders that are better than the TSO calls for, some
builder are buying those encoders or have bought them in the past, avionics
shops are approving those non TSO'd encoders in accordance with the tests
called for in FAR Part 43 Appendix E and F, and many airplanes (hundreds?
thousands?) are flying around with those encoders responding with an
altitude readout that ATC is entirely satisfied with.
And FAA headquarters currently says: "No, that can't be because it is in
violation of FAR 91.217 (b) as we interpret it."
I don't know how this situation would eventually resolve itself if we just
ignored it, but I don't feel that a head-in-the-sand approach is the best
way to go.
OC -- The best investment we will ever make is in gathering knowledge.
<<AeroElectric-List message posted by: Kevin Horton <khorton01@rogers.com>
Good luck. I think you are wasting your time, albeit for a good
cause. Granted, you might manage to find some FSDO that doesn't
understand that 95% probability does in fact mean over the full range
of expected conditions (speaking from experience working with the
aircraft cert FARs for many years). But, once Washington finds out
the FSDO has approved something under 91.217(b) without requiring
testing over the full range of conditions, they will probably release
a policy letter that stops you in your tracks.
I'm not saying that things should be like this, but this is the way
they are, like it or not. The only way out, in my opinion, is a
change to 91.217, but reg changes typically take 10 years or more.
Kevin Horton>>
Message 2
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| Subject: | encoder approval |
--> Avionics-List message posted by: <bakerocb@cox.net>
8/11/2006
Responding to an AeroElectric-List message previously posted by Brett
Ferrell
Hello Brett, Thanks for your input.
In fact it was the EAA web site wording that caused me to take action on
this issue.
My reaction was: How can the EAA, which is supposed to be our amateur built
proponent, ignore the current situation which is that every day companies
are manufacturing and
selling more non TSO'd encoders that are better than the TSO calls for, some
builder are buying those encoders or have bought them in the past, avionics
shops are approving those non TSO'd encoders in accordance with the tests
called for in FAR Part 43 Appendix E and F, and many airplanes (hundreds?
thousands?) are flying around with those encoders responding with an
altitude readout that ATC is entirely satisfied with?
When I corresponded with EAA on this issue their response was: "We stand by
our position."
I could not accept this head-in-the-sand approach and wrote to the FAA.
OC -- The best investment we will ever make is in gathering knowledge.
<<AeroElectric-List message posted by: Brett Ferrell <bferrell@123mail.net>
Have you enlisted the help of EAA on this matter? I would think that thier
involvement would be helpful. They've already weighed in on this matter, in
the other direction, supposedly with FAA input!!.....skip.....>>
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