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1. 05:15 AM - Questions on avionics ()
2. 09:06 AM - Re: Questions on avionics (Doug Dodson)
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| Subject: | Questions on avionics |
4/19/2008
Hello Ira, You wrote: "........I was referring to encoding altimeters when I
said there
was no requirement for TSO."
If that encoding altimeter is the altitude encoder that is feeding the
transponder required by FAR Sec 91.215 then it must comply with either
91.217 (b) or (c). That is what this thread has been about.
See my response to Mike, copied below, for more information.
'OC'
-------------------------------------------------------------
4/18/2008
Hello Mike, Thanks for your three emails. You wrote:
1) "....you are looking to comply with the standard of the TSO without a
formal
proof."
A) I invite you to look at "Subpart O -- TSO Authorizations" of FAR Part 21.
You can access it here:
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=9dad7a792e03c09e14fc110ded0921cb&rgn=div6&view=text&node=14:1.0.1.3.9.15&idno=14
B) Then I invite you to look at TSO-C10b. You can access it here:
http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/072c91c58fdc6ce686256da4005f4d1b/$FILE/C10b.pdf
C) Then I invite you to look at TSO-C88b. You can access it here:
http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/625ebf9767dac15e8625727c006e10df/$FILE/TSO-C88b.pdf
D) Now I invite you (and here is the gotcha) to procure and look at all the
technical references contained in those TSO's. The TSO's themselves are just
sort of shell documents, pointers if you will. All the real technical guts
and standards that must be complied with are found in the references.
E) Now I ask you to picture the average homebuilder satisfying someone that
he is complying with the standards of the relevant TSO's without formal
proof.
2) "It says that the 'encoder' must meet the TSO standards. It doesn't say
that it must be TSO'd. That is a subtle legal difference."
I accept your "subtle legal difference". After you have gone through steps A
through D above I ask you to picture the average homebuilder satisfying
someone that his non TSO'd altitude encoder is meeting the standards of the
relevant TSO's .
3) "So answer me this: If you the builder /manufacturer determines that
your testing puts the encoder in compliances with the TSO standards......."
Again I ask you to picture the average amateur builder determining that his
testing puts the encoder in compliance with the TSO standards -- not some of
the standards, not just the performance standards, but the all of the TSO
standards. The reason that the EFIS manufacturers have not done this very
thing is because of the significant cost and bureacratic burden involved.
4) "...and you test the unit IAW 43.13 and it passes ......"
A) (I am not sure why you referenced 43.13. It does not appear to be
relevant here. Perhaps you meant FAR Sec 91.413. I will assume so.)
First off I, the amateur builder, am not permitted to perform the tests
required by 91.413 -- see sub paragraph (c) of 91.413.
B) "......what would be the ramifications?"
Second, assuming the tests required by 91.413 were properly performed by a
willing qualified person / entity, the automatic pressure altitude reporting
equipment containing the non TSO'd altitude encoder passed the tests, and
the test results were properly documented there probably would be no adverse
ramifications. But consider this:
B-1) Suppose a willing qualified person / entity is not readily available to
perform the 91.413 required tests because the non TSO'd altitude encoder is
not in compliance with 91.217? What are the ramifications then? Probably no
big deal, go find someone or some place that will perform the tests.
B-2) Suppose that there is a mid air collision between an amateur built
experimental aircraft and an airline aircraft with major loss of life. And
further suppose that the equipment in the amateur built experimental
aircraft had absolutely nothing to do with causing the accident, but the
media learns that the amateur built experimenal aircraft was not in
compliance with some Federal Aviation Regulation (91.217) . What are the
ramifications then?
5) "I don't see a violation of the rule as written."
I am not sure which rule you are referring to. If you are referring to
91.217 there are two choices:
A) Comply with subparagraph (c); ie have equipment that is TSO'd, or
B) Comply with the tests described in subparagraph (b). I think that the
tests required by 91.411 and 91.413 should be considered to meet the
requirements of 91.217 (b). Unfortunately, to date the FAA HQ does not agree
with me and they seem to have a little more authority than I do.
6) "Also their is no enforcement mechanism in place to even determine
whether your in compliance or not."
True enough. I think the FAA is too busy measuring the spacing between
lacings on wire bundles in the wheel wells of airliners to make very many
ramp checks on the avionics installed in amateur built experimental
aircraft, but see the ramifications comments above and make an informed
decision.
7) "You as the aircraft certifying authority as the builder......"
The Special Airworthiness Certificate in the Experimental Category for the
purpose of Operating Amateur Built Aircraft is signed and issued by an FAA
Representative who has been delegated that authority by the FAA
Administrator. The FAA Administrator is the certifying authority, not the
amateur builder.
8) "You ........ as the builder determine suitability as it pertains to the
regulations and no one else"
Try telling that to the FAA employee or DAR who comes to inspect your
amateur built experimental aircraft for its initial airworthiness
inspection. He will set you straight very quickly on who will make the
decisions regarding the suitability of your aircraft as it pertains to
regulations.
9) "Short of them scouring the wreckage for TSO tags they would have to make
an assumption."
I hope that it would never come to that, but the tenacity, search for
details, and the ill will of lawyers and journalists when they smell blood
and money should not be ignored. All I am seeking to do is to have people
make informed decisions -- I provide the information, they make the
decisions.
'OC' Says: "The best investment we can make is the effort to gather and
understand knowledge."
-------------------------------------
Time: 08:28:34 PM PST US
From: "Mike" <mlas@cox.net>
Subject: RE: AeroElectric-List: Questions on avionics
I would argue that you are not looking for a deviation to the TSO you
are looking to comply with the standard of the TSO without a formal
proof.
Mike
-----------------------------------------------------
Time: 08:34:11 PM PST US
From: "Mike" <mlas@cox.net>
Subject: RE: AeroElectric-List: Questions on avionics
Read the regulation. It says that the 'encoder' must meet the TSO
standards. It doesn't say that it must be TSO'd. That is a subtle
legal difference.
Mike
-----------------------------------------------------
----- Original Message -----
From: "MLAS" <MLAS@COX.NET>
Sent: Friday, April 18, 2008 9:37 AM
Subject: Re: Questions on avionics
> So answer me this: If you the builder /manufacturer determines that your
> testing puts the encoder in compliances with the TSO standards and you
> test the unit IAW 43.13 and it passes what would be the ramifications. We
> do live in a country made up by "Common Law" (short def: If it isn't
> prohibited then it's legal). I don't see a violation of the rule as
> written. Also their is no enforcement mechanism in place to even
> determine whether your in compliance or not. You as the aircraft
> certifying authority as the builder determine suitability as it pertains
> to the regulations and no one else. Short of them scouring the wreckage
> for TSO tags they would have to make an assumption.
>
> Mike
--------------------------------------------------------
Time: 03:45:49 AM PST US
Subject: AeroElectric-List: Re: Questions on avionics
From: "rampil" <ira.rampil@gmail.com>
And of course, I was referring to encoding altimeters when I said there
was no requirement for TSO. Transponders must be TSO
--------
Ira N224XS
Message 2
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| Subject: | Questions on avionics |
This discussion is symptomatic of what is driving light aircraft GA into
oblivion. If I get my transponder static check done and it passes, then
the system works today. I suppose it could break tomorrow, but so could
one that "legally" meets the TSO. At least I can afford to fix mine
since the engineers didn't have to pay any lawyers.
- Doug
-----Original Message-----
From: owner-avionics-list-server@matronics.com
[mailto:owner-avionics-list-server@matronics.com] On Behalf Of
bakerocb@cox.net
Sent: Saturday, April 19, 2008 5:12 AM
ira.rampil@gmail.com
Subject: Avionics-List: Questions on avionics
4/19/2008
Hello Ira, You wrote: "........I was referring to encoding altimeters
when I
said there
was no requirement for TSO."
If that encoding altimeter is the altitude encoder that is feeding the
transponder required by FAR Sec 91.215 then it must comply with either
91.217 (b) or (c). That is what this thread has been about.
See my response to Mike, copied below, for more information.
'OC'
-------------------------------------------------------------
4/18/2008
Hello Mike, Thanks for your three emails. You wrote:
1) "....you are looking to comply with the standard of the TSO without a
formal
proof."
A) I invite you to look at "Subpart O -- TSO Authorizations" of FAR Part
21.
You can access it here:
http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&sid=9dad7a792e03c09
e14fc110ded0921cb&rgn=div6&view=text&node=14:1.0.1.3.9.15&idno=14
B) Then I invite you to look at TSO-C10b. You can access it here:
http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/072c91c58
fdc6ce686256da4005f4d1b/$FILE/C10b.pdf
C) Then I invite you to look at TSO-C88b. You can access it here:
http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgTSO.nsf/0/625ebf976
7dac15e8625727c006e10df/$FILE/TSO-C88b.pdf
D) Now I invite you (and here is the gotcha) to procure and look at all
the
technical references contained in those TSO's. The TSO's themselves are
just
sort of shell documents, pointers if you will. All the real technical
guts
and standards that must be complied with are found in the references.
E) Now I ask you to picture the average homebuilder satisfying someone
that
he is complying with the standards of the relevant TSO's without formal
proof.
2) "It says that the 'encoder' must meet the TSO standards. It doesn't
say
that it must be TSO'd. That is a subtle legal difference."
I accept your "subtle legal difference". After you have gone through
steps A
through D above I ask you to picture the average homebuilder satisfying
someone that his non TSO'd altitude encoder is meeting the standards of
the
relevant TSO's .
3) "So answer me this: If you the builder /manufacturer determines that
your testing puts the encoder in compliances with the TSO
standards......."
Again I ask you to picture the average amateur builder determining that
his
testing puts the encoder in compliance with the TSO standards -- not
some of
the standards, not just the performance standards, but the all of the
TSO
standards. The reason that the EFIS manufacturers have not done this
very
thing is because of the significant cost and bureacratic burden
involved.
4) "...and you test the unit IAW 43.13 and it passes ......"
A) (I am not sure why you referenced 43.13. It does not appear to be
relevant here. Perhaps you meant FAR Sec 91.413. I will assume so.)
First off I, the amateur builder, am not permitted to perform the tests
required by 91.413 -- see sub paragraph (c) of 91.413.
B) "......what would be the ramifications?"
Second, assuming the tests required by 91.413 were properly performed by
a
willing qualified person / entity, the automatic pressure altitude
reporting
equipment containing the non TSO'd altitude encoder passed the tests,
and
the test results were properly documented there probably would be no
adverse
ramifications. But consider this:
B-1) Suppose a willing qualified person / entity is not readily
available to
perform the 91.413 required tests because the non TSO'd altitude encoder
is
not in compliance with 91.217? What are the ramifications then? Probably
no
big deal, go find someone or some place that will perform the tests.
B-2) Suppose that there is a mid air collision between an amateur built
experimental aircraft and an airline aircraft with major loss of life.
And
further suppose that the equipment in the amateur built experimental
aircraft had absolutely nothing to do with causing the accident, but the
media learns that the amateur built experimenal aircraft was not in
compliance with some Federal Aviation Regulation (91.217) . What are the
ramifications then?
5) "I don't see a violation of the rule as written."
I am not sure which rule you are referring to. If you are referring to
91.217 there are two choices:
A) Comply with subparagraph (c); ie have equipment that is TSO'd, or
B) Comply with the tests described in subparagraph (b). I think that the
tests required by 91.411 and 91.413 should be considered to meet the
requirements of 91.217 (b). Unfortunately, to date the FAA HQ does not
agree
with me and they seem to have a little more authority than I do.
6) "Also their is no enforcement mechanism in place to even determine
whether your in compliance or not."
True enough. I think the FAA is too busy measuring the spacing between
lacings on wire bundles in the wheel wells of airliners to make very
many
ramp checks on the avionics installed in amateur built experimental
aircraft, but see the ramifications comments above and make an informed
decision.
7) "You as the aircraft certifying authority as the builder......"
The Special Airworthiness Certificate in the Experimental Category for
the
purpose of Operating Amateur Built Aircraft is signed and issued by an
FAA
Representative who has been delegated that authority by the FAA
Administrator. The FAA Administrator is the certifying authority, not
the
amateur builder.
8) "You ........ as the builder determine suitability as it pertains to
the
regulations and no one else"
Try telling that to the FAA employee or DAR who comes to inspect your
amateur built experimental aircraft for its initial airworthiness
inspection. He will set you straight very quickly on who will make the
decisions regarding the suitability of your aircraft as it pertains to
regulations.
9) "Short of them scouring the wreckage for TSO tags they would have to
make
an assumption."
I hope that it would never come to that, but the tenacity, search for
details, and the ill will of lawyers and journalists when they smell
blood
and money should not be ignored. All I am seeking to do is to have
people
make informed decisions -- I provide the information, they make the
decisions.
'OC' Says: "The best investment we can make is the effort to gather and
understand knowledge."
-------------------------------------
Time: 08:28:34 PM PST US
From: "Mike" <mlas@cox.net>
Subject: RE: AeroElectric-List: Questions on avionics
I would argue that you are not looking for a deviation to the TSO you
are looking to comply with the standard of the TSO without a formal
proof.
Mike
-----------------------------------------------------
Time: 08:34:11 PM PST US
From: "Mike" <mlas@cox.net>
Subject: RE: AeroElectric-List: Questions on avionics
Read the regulation. It says that the 'encoder' must meet the TSO
standards. It doesn't say that it must be TSO'd. That is a subtle
legal difference.
Mike
-----------------------------------------------------
----- Original Message -----
From: "MLAS" <MLAS@COX.NET>
Sent: Friday, April 18, 2008 9:37 AM
Subject: Re: Questions on avionics
> So answer me this: If you the builder /manufacturer determines that
your
> testing puts the encoder in compliances with the TSO standards and you
> test the unit IAW 43.13 and it passes what would be the ramifications.
We
> do live in a country made up by "Common Law" (short def: If it isn't
> prohibited then it's legal). I don't see a violation of the rule as
> written. Also their is no enforcement mechanism in place to even
> determine whether your in compliance or not. You as the aircraft
> certifying authority as the builder determine suitability as it
pertains
> to the regulations and no one else. Short of them scouring the
wreckage
> for TSO tags they would have to make an assumption.
>
> Mike
--------------------------------------------------------
Time: 03:45:49 AM PST US
Subject: AeroElectric-List: Re: Questions on avionics
From: "rampil" <ira.rampil@gmail.com>
And of course, I was referring to encoding altimeters when I said there
was no requirement for TSO. Transponders must be TSO
--------
Ira N224XS
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