Avionics-List Digest Archive

Tue 08/15/06


Total Messages Posted: 6



Today's Message Index:
----------------------
 
     1. 07:48 AM - encoder approval ()
     2. 08:10 AM - encoder approval ()
     3. 08:39 AM - Re: encoder approval (Mike Ferrer)
     4. 06:15 PM - encoder approval ()
     5. 06:40 PM - Re: encoder approval (John Grosse)
     6. 07:20 PM - OBAM vs. ABEA ()
 
 
 


Message 1


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    Time: 07:48:33 AM PST US
    From: <bakerocb@cox.net>
    Subject: encoder approval
    --> Avionics-List message posted by: <bakerocb@cox.net> 8/14/2006 Responding to an email and posting by Michael Hinchcliff Hello Michael, Thanks for your response and your kind words. I am not happy dabbling in the arena of semantics and legalese, but it appears that the regulations and the FAA's interpretation of the regulations force us in that direction. 1) You wrote: "Everything else aside, 91.217 (c) does not say the equipment must be TSO certified, but meet the TSO standards." Correct. 2) You wrote: "TSO certification is not in the reg, but MEETING it is." Meeting all of the TSO standards for an altitude encoder is not mandatory or required. In my opinion there are three ways to have legal automatic pressure altitude reporting equipment in an aircraft: A) Go through the process of obtaining FAA TSO compliant approval for the manufacturing process, testing, performance, and all related documentation of your equipment. You will then be authorized to mark the equipment as meeting the requirements of TSO-C88a. By virtue of this marking your equipment is presumed to meet the requirement of 91.217 9(c) for equipment that meets the minimum performance standards in TSO-C88a. B) Design, build, and test your equipment. Then request a deviation from the TSO standards from the FAA in accordance with FAR 21.609. See the TSO to read what those standards are: http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/7F3CE81AFC742A4B86256DC70067B087?OpenDocument More recent editions of TSO's include an FAA policy statement like this that head you in the deviation direction: "Deviations. We have provisions for using alternate or equivalent means of compliance to the criteria in the MPS of this TSO. If you invoke these provisions, show that your equipment maintains an equivalent level of safety. Apply for a deviation under 14 CFR 21.609." MPS means Minimum Performance Standards. Note that there is a lot more to a TSO than just the minimum performance standards. FAR 21.609 reads as follows: "Approval for deviation. (a) Each manufacturer who requests approval to deviate from any performance standard of a TSO shall show that the standards from which a deviation is requested are compensated for by factors or design features providing an equivalent level of safety. (b) The request for approval to deviate, together with all pertinent data, must be submitted to the Manager of the Aircraft Certification Office for the geographic area in which the manufacturer is located. If the article is manufactured in another country, the request for approval to deviate, together with all pertinent data, must be submitted through the civil aviation authority in that country to the FAA." C) Design, build, test, and sell equipment that you are confident meets the testing requirements of 91.217 (b) when installed in an aircraft. What are the intended testing requirements of 91.217 (b)? That is the issue at hand. I think that meeting the appropriate testing requirements of FAR Part 43 Appendicies E and F fulfills the intent of 91.217 (b). HQ FAA currently says not so. I hope to change that position. Complicating the situation is the existence of hundreds of non TSO'd encoders already in satisfactory use for years and more being manufactured, sold to, and installed by amateur builders in their aircraft. 3) You wrote: "Part (b) just references how the equipment is to be tested and does not necessarily prove compliance with the required TSO." Agreed -- see paragraph 2 C above. 4) You wrote: "My simpleton answer would be to either A.) formally prove the non TSO'd equipment meets the standard and provide the paperwork that goes with it, OR B.) save a lot of time and money by purchasing equipment that's already certified as meeting the standard and start flying. Two questions: aa) If such a policy as A.) above had been in effect for the last 10 years what would be the current status of EFIS development in our community? bb) How does B.) above deal with all the non TSO'd equipment already installed and flying, being installed, and being manufactured? 5) You wrote: "Perhaps another remedy would be to see if manufacturer of the non TSO'd equipment has the necessary paperwork/evidence that proves the equipment meets the standard without having the coveted TSO $tamp." See 2) B) above. You wrote: " Have you barked up that tree yet?" No. To date I am only pursuing a more rational interpretation of FAR 91.217 (b) by HQ FAA. OC -- The best investment we will ever make is in gathering knowledge. <<OC, thanks for your objective response to my message. I appreciate healthy debate in that it improves my understanding of the issues, in this case FAR 91.217. I now see what you are saying. Everything else aside, 91.217 (c) does not say the equipment must be TSO certified, but meet the TSO standards. My question to the non-TSO'd encoder community is this: How do you prove your equipment meets the required TSO standards? TSO certification is not in the reg, but MEETING it is. Part (b) just references how the equipment is to be tested and does not necessarily prove compliance with the required TSO. My simpleton answer would be to either A.) formally prove the non TSO'd equipment meets the standard and provide the paperwork that goes with it, OR B.) save a lot of time and money by purchasing equipment that's already certified as meeting the standard and start flying. Perhaps another remedy would be to see if manufacturer of the non TSO'd equipment has the necessary paperwork/evidence that proves the equipment meets the standard without having the coveted TSO $tamp. Have you barked up that tree yet? Michael H.>>


    Message 2


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    Time: 08:10:42 AM PST US
    From: <bakerocb@cox.net>
    Subject: encoder approval
    --> Avionics-List message posted by: <bakerocb@cox.net> 8/15/2006 Responding to an AeroElectric-List message previously posted by: "Doug Windhorn" Hello Doug, 1) You wrote: "Although, as a "Repairman", AND if one had the proper equipment and knew how to use it, I presume one could sign off a test on their own airplane." The ONLY privileges that a Repairman's Certificate for a specific amateur built experimental aircraft grants are for the holder of that certificate to perform and sign off the condition inspection for that aircraft that is required every 12 calendar months. 2) If you really want to squeeze through a transponder testing loophole yourself take a look at FAR 91.413(c) (3). I don't recommend it. OC -- The best investment we will ever make is in gathering knowledge. <<AeroElectric-List message posted by: "Doug Windhorn" <N1DeltaWhiskey@comcast.net> Kevin, Thought of that after Brian's reply and reading the FAR 43 App F. Although, as a "Repairman", AND if one had the proper equipment and knew how to use it, I presume one could sign off a test on their own airplane. Doug>>


    Message 3


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    Time: 08:39:14 AM PST US
    From: "Mike Ferrer" <mike@ferrer-aviation.com>
    Subject: Re: encoder approval
    --> Avionics-List message posted by: "Mike Ferrer" <mike@ferrer-aviation.com> >From the EAA Website: Q. Can a builder with a repairman certificate for the aircraft he built perform his own altimeter or transponder certifications? A. No. Although the FAR's do authorize the "manufacturer" of the aircraft to conduct the tests, the builder of an amateur-built aircraft does not meet the FAA's definition of a manufacturer. The FAA, in Order 8130.2, defines a manufacturer as a Production Approval Holder (PAH). Some examples of a PAH would be the holder of a Production Certificate (PC), a Parts Manufacturing Authority (PMA), and Technical Standards Order Authorization (TSOA). According to the FAA, an amateur builder does not fit this definition and, therefore cannot perform the transponder and pitot/static tests on his/her homebuilt.


    Message 4


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    Time: 06:15:46 PM PST US
    From: <bakerocb@cox.net>
    Subject: encoder approval
    --> Avionics-List message posted by: <bakerocb@cox.net> 8/15/2006 Responding to an AeroElectric-List message previously posted by Brian Lloyd Hello Brian, 1) You wrote: "ARRGGGH! You are making me want to tear my hair out." Please do not tear your hair out or rend your garments on my behalf. Life is too short for that. 2) At 10:36 AM EST on 8/10/2006 I wrote: "I wanted to avoid much controversial and distracting communications pending the, hopefully favorable, eventual ruling by FAA on this subject." At 01:23:44 PM PST on 8/14/2006 You wrote: "Now, if you don't cease and desist trying to confuse this issue, I am going to come over there and beat your hands into a bloody pulp with a hard-bound copy of the FARs so you can't type any more. :-)" Sigh 3) You wrote: "YOU MAY USE ANY ENCODER YOU WANT TO USE. WIRE IT UP TO YOUR TRANSPONDER. DRAG YOUR AIRPLANE OVER TO GET A TRANSPONDER CERTIFICATION AND THEN GO FLY. Why do I say this? Because of FAR 91.217(b) which reads:.....skip..... Hello! This is the transponder certification test! This is the test performed by the radio shop on your airplane! They feed absolute pressure into your static system and check the transponder altitude (mode-C) output at several pressure altitudes. The mode-C output of your transponder must track your altimeter to within 125' of what is indicated on your altimeter. The key point is that you have TESTED your installation to ensure it is working." It is more than a bit ironic that you and I are complete agreement on this point. The problem lies in the fact that HQ FAA (and the EAA) currently do not agree with you and me. Also neither did the avionics shop and FSDO that Brian Meyette was dealing with (see his posting). Is there trouble brewing in River City? 4) You wrote: "OK, I am going to say this just one more time as you are insisting on muddying the waters, pissing on the wedding cake, as it were." You will recall that this thread was started by Skip Simpson who posted: "Is the Rocky Mountain encoder approved for certificated aircraft, the factory says that "it conforms to c88a", is that enough, or is there more needed. Any opinions on the unit. Thanks, Skip Simpson" I think that it would have been rude of me, and counter to the precepts of this list, to ignore his request for information / help. I think that it would have been unfair of me to give him just my opinion alone when I knew the issue was unresolved. So I responded with the facts as they existed at that time. Subsequently I have responded to all questions that were posed directly to me as factually as possible. It would have been rude of me if I had ignored those postings. If I have left anyone's water muddied or anyone's cake pissed upon I apologize. 5) You wrote: "This is what happens when people ask questions of the FAA. You get some boob who hasn't got a clue to interpret things for you." I asked FAA HQ for clarification of 91.217 (b) because of a doubtful encoder situation that arose between a local builder who installed an EFIS, his FAA inspector, another individual at the local FSDO, and the manufacturer of the EFIS. I would have preferred to have not gotten a response from "some boob who hasn't got a clue" on my first try, but I wasn't offered that option. So I am trying again. 6) You wrote: "The key point is that FAR 91.217(b) is very clear and needs no interpretation." Again, I agree, and if this is indeed the case then sooner or later we will find some rational person at FAA HQ who agrees with your statement and the issue will be resolved properly. In the meantime I hope that we can deal with facts and not emotion, adamant statements of our opinions, or name calling that might turn out to be counter productive. OC -- The best investment we will ever make is in gathering knowledge <<AeroElectric-List message posted by: Brian Lloyd <brian-yak@lloyd.com> On Aug 14, 2006, at 3:19 PM, <bakerocb@cox.net> wrote: > --> AeroElectric-List message posted by: <bakerocb@cox.net> > > 8/14/2006 > > Responding to an AeroElectric-List message previously posted by > Brian Lloyd > > Hello Brian, Thanks for your input. > > You wrote in part: "But you can use any encoder you want to. It > doesn't have to be TSO'd. > You are responsible for the airworthiness of your aircraft. Satisfy > yourself." > > I am in concurrence with the thrust of your statements, but FAR > 91.217 is relevant. If your encoder / transponder is not TSO'd as > called for in 91.217 (c) then the installation must pass the tests > required by FAR 91.217 (b). ARRGGGH! You are making me want to tear my hair out. OK, I am going to say this just one more time as you are insisting on muddying the waters, pissing on the wedding cake, as it were. YOU MAY USE ANY ENCODER YOU WANT TO USE. WIRE IT UP TO YOUR TRANSPONDER. DRAG YOUR AIRPLANE OVER TO GET A TRANSPONDER CERTIFICATION AND THEN GO FLY. Why do I say this? Because of FAR 91.217(b) which reads: (b) Unless, as installed, that equipment was tested and calibrated to transmit altitude data corresponding within 125 feet (on a 95 percent probability basis) of the indicated or calibrated datum of the altimeter normally used to maintain flight altitude, with that altimeter referenced to 29.92 inches of mercury for altitudes from sea level to the maximum operating altitude of the aircraft; Hello! This is the transponder certification test! This is the test performed by the radio shop on your airplane! They feed absolute pressure into your static system and check the transponder altitude (mode-C) output at several pressure altitudes. The mode-C output of your transponder must track your altimeter to within 125' of what is indicated on your altimeter. The key point is that you have TESTED your installation to ensure it is working. > Unfortunately at the present time (until corrected) FAA HQ has > described a testing process for compliance with FAR 91.217 (b) that > is unreasonable. See their response to my letter in a previous > posting. This is what happens when people ask questions of the FAA. You get some boob who hasn't got a clue to interpret things for you. The key point is that FAR 91.217(b) is very clear and needs no interpretation. The transponder certification test is where you test and calibrate your encoder to transmit altitude data corresponding within 125' of the indicated or calibrated data of the altimeter normally used to maintain flight attitude, with that altimeter referenced to 29.92"Hg for altitudes from sea level to the maximum operating altitude of the aircraft. Notice just how similar my words are to 91.217(b)? Now, if you don't cease and desist trying to confuse this issue, I am going to come over there and beat your hands into a bloody pulp with a hard-bound copy of the FARs so you can't type any more. :-) (BTW, if you use the same pressure sensor to generate your altitude readout AND drive your transponder, the altitude sent by the transponder absolutely MUST be the same indicated since they are both the same data.) Brian Lloyd>>


    Message 5


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    Time: 06:40:03 PM PST US
    From: John Grosse <grosseair@comcast.net>
    Subject: Re: encoder approval
    --> Avionics-List message posted by: John Grosse <grosseair@comcast.net> Wow! You guys are getting way too intense about this whole thing! Lighten up and fly. By now we should all realize that you can do any thing you want until it causes a problem. Then you'll find out that if you did the wrong thing you're violated, and your insurance may no longer cover you. But, hey, I've known of guys who flew for more than 20 years without a license or insurance. So just shut up and fly. John Grosse


    Message 6


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    Time: 07:20:39 PM PST US
    From: <bakerocb@cox.net>
    Subject: OBAM vs. ABEA
    --> Avionics-List message posted by: <bakerocb@cox.net> 8/15/2006 Responding to an AeroElectric-List message previously posted by: "Robert L. Nuckolls, III" Hello Bob, I appear to aroused and aggravated two of our most senior gurus on this list (you and Brian) at the same time -- I feel like I have hit the quinella. You wrote: "Bureaucratic nomenclature not withstanding, the idea behind "OBAM" was to eliminate the terms "experimental" and "amateur" while substituting equally accurate words for public consumption. I fully appreciate, understand, and accept your motivation for eschewing the two dread words, "experimental" and "amateur", under certain circumstances. I have the following comments: A) When we call the same thing by two different names or two different things by the same name sooner or later we sow confusion. B) Many people, even in our community, do not know that OBAM stands for Owner Built And Maintained. Maybe a spell out of the acronym the first time it is used in a document would help. B) People who see the term OBAM over and over begin to think that it is indeed only the Owner or only the Builder who may Maintain the aircraft. This is misleading and needs to be clarified every once in a while, in fact just recently on this list. C) Use of the term OBAM causes people tend to think that every aircraft in our community must have been Built by the current Owner. But ownership by individuals subsequent to the builder is very common in our community. There are some significant issues involved with subsequent ownership. D) When we are attempting to clarify some regulatory point among ourselves and start to use terms like "registration", "certification", "airworthiness", "special", "standard", "category", "Operating Limitations", and "instrument and equipment requirements", it is helpful if we all use the same terms to mean the same thing and that these are the terms also found in the regulations. These are just some of the reasons that I use the term ABEA (Amateur Built Experimental Aircraft) from time to time when communicating within the community. The next time that I am in a courtroom I'll fuzzy it up a bit. OC -- The best investment we will ever make is in gathering knowledge. << AeroElectric-List message posted by: "Robert L. Nuckolls, III" <nuckollsr@cox.net> > >2) You wrote: "OBAM means "owner *built* and *MAINTAINED*" > >As you can see the term OBAM is a bit of a misnomer because, as described >above, any one can repair, work on, or maintain an amateur built >experimental aircraft. I think the acronym ABEA (Amateur Built >Experimental Aircraft) is both more inclusive and more accurate, but it >has not received wide spread use. Bureaucratic nomenclature not withstanding, the idea behind "OBAM" was to eliminate the terms "experimental" and "amateur" while substituting equally accurate words for public consumption. The average Joe on the street thinks getting into any little airplane is foolhardy. Pasting an "experimental" label on the "amateur" built machine only serves to elevate the listener/reader's level of tension/apprehension. Back when I gave depositions in accident investigations and analysis we took pains to avoid words like "impact", "crash", "shattered", etc in favor of equally accurate but less exciting words like "contact", "event", "failed", etc. When attempting to explain the finer details of an accident where 90% of the energy is expended in the first few hundred milliseconds of an event, it's challenging but useful to downplay the violence while focusing on the science. It's easier to keep the listener's attention to facts and logic if you avoid the kind of words one hears in abundance on the 6 o-clock news. It worked well in the courtroom and many of our aviation-ignorant fellow citizens are considered ideal jury material. Further, in many venues the owner of a TC aircraft has accomplished some pretty heavy maintenance and repairs albeit under the watchful eye of a "certified" individual who ultimately accepts responsibility for the work. Bob . . .>>




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