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bakerocb
Joined: 15 Jan 2006
Posts: 727
Location: FAIRFAX VA
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 Posted: Fri Jun 12, 2009 4:10 am Post subject: IFR Certification |
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6/11/2009
Hello Stan, You wrote: "This may not be the ideal forum for asking this
question, but I'll try it anyway."
Actually, this (AeroElectric-List) is the ideal forum for asking this
question.
This topic has been hashed out extensively on the aeroelectric list. If you
are interested in better understanding the situation go to the aeroelectric
archives and search for "encoder approval". You will find many entries under
this search phrase and there are other search phrases that will also
generate past postings on this subject.
To save you some time searching take a look at some of the postings in
August , 2006 with the subject "encoder approval" or "non TSO'd encoder".
You received some good advice in response to your posting copied below --
just go to another agency capable of performing the required 14 CFR 91.411
"IFR certification" tests and have them perform the tests and provide the
paper work. You'll be joining hundreds of other amateur builders happily
flying IFR with non TSO'd altitude encoders that have passed the required
tests of 14 CFR 91.411.
'OC' Says: "The best investment we can make is the effort to gather and
understand knowledge."
PS: Stein Bruch wrote: " Basically the information provided to you is
completely false and not correct."
That is not entirely true. In defense of your local avionics guy he is
taking the same position that FAA headquarters took on the altitude
encoder -- that is, the altitude encoder must either be TSO'd or be tested
in accordance with 14 CFR paragraph 91.217 (b). The tests that FAA
headquarters described for compliance with 91.217 (b) are very elaborate and
extensive.
=================================================
Time: 10:23:41 AM PST US
From: Speedy11(at)aol.com
Subject: AeroElectric-List: IFR Certification
This may not be the ideal forum for asking this question, but I'll try it
anyway.
I want to certify my RV-8 for IFR flight. I know the FARs - I've looked at
them.
I have the Blue Mountain EFIS One as primary instrumentation.
I have the Blue Mountain EFIS Lite as a backup.
Both EFISs are on different electrical busses - the main and the standby.
-
which can be tied together, if needed.
I asked a local avionics guy about doing a pitot-static and transponder
check for IFR. He said I would have to install a separate altimeter and
encoder in order to get IFR certification. The EFIS has a built-in encod
er.
Has anyone else encountered this obstacle?
Stan Sutterfield
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bakerocb
Joined: 15 Jan 2006
Posts: 727
Location: FAIRFAX VA
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| Posted: Fri Jun 12, 2009 4:10 am Post subject: IFR Certification |
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6/12/2009
Hello Frank, You wrote: "Why pay twice if you don't have to?"
I agree. To determine if a flight without a transponder is legal go to 14
CFR 91.215.
Also note that permission for a flight without a transponder can be obtained
as described in 91.215 (d).
'OC' Says: "The best investment we can make is the effort to gather and
understand knowledge."
=====================================================
Time: 07:43:07 AM PST US
From: "Hinde, Frank George (Corvallis)" <frank.hinde(at)hp.com>
Subject: RE: AeroElectric-List: Re: IFR Certification
Don't if it was legal but I didn't do a VFR cert..I just labeled the Transp
onder "Inooperative" and flew it to get the IFR cert done...Why pay twice i
f you don't have to?
Frank
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bakerocb
Joined: 15 Jan 2006
Posts: 727
Location: FAIRFAX VA
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| Posted: Sat Jun 13, 2009 4:14 am Post subject: IFR Certification |
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6/13/2009
Hello Ira, You wrote: "If the boss at your local shop does not understand
the
regulations pertaining to OBAM aircraft, find another shop."
I agree that finding another shop is the best way to resolve this situation.
However outright condemnation of the boss for "not understand(ing) the
regulations pertaining to OBAM aircraft" is not warranted.
1) The issue is not OBAM (amateur built experimental aircraft) versus
standard type certificated aircraft.
2) 14 CFR 91.217 applies equally to both of those kinds of aircraft.
3) The fundamental issue relates to TSO'd versus non TSO'd altitude
encoders.
4) Note that 91.217 applies to flight under VFR as well as flight under IFR.
5) Headquarters FAA is in agreement with the boss's position of not
approving a non TSO'd altitude encoder unless the tests required by 14 CFR
paragraph 91.217 (b) have been accomplished.
6) FAA Headquaters says that the tests required by 91.217 (b) are far more
complex and demanding than the tests required by 91.411 and the associated
appendicies of 14 CFR part 43.
7) Some people dispute FAA Headquarters position on this issue, but no one
to date has adequately challenged them to change their position.
 My current recommendations on this issue are:
A) Understand the issues. (Hence this posting to you and fellow builders).
B) Let sleeping dogs lie because if FAA Headquarers really tried to enforce
their position it would cause chaos in the amateur built community because
of the large number of non TSO'd altitude encoders already flying, being
built into aircraft, and being manufactured.
Please let me know if you have any questions. Thanks.
'OC' Says: "The best investment we can make is the effort to gather and
understand knowledge."
==============================================
Time: 07:41:50 AM PST US
Subject: AeroElectric-List: Re: IFR Certification
From: "rampil" <ira.rampil(at)gmail.com>
My BMA system has served as my encoder for my Mode C for 5 years
in the NYC area. Islip Avionics had absolutely no issue with the
certifications.
If the boss at your local shop does not understand the
regulations pertaining to OBAM aircraft, find another shop. Especially,
since they would, if they finally elect to do the work, would take twice
as long and charge twice as much!
--------
Ira N224XS
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rampil
Joined: 04 May 2007
Posts: 870
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| Posted: Sat Jun 13, 2009 9:34 am Post subject: Re: IFR Certification |
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Actually I didn't condemn the boss, I simply referenced the boss
as the key to the problem. I am familiar with the issues you raised
which is why when finally got IFR certification for myself, I treated
my airframe to a brand new Sandia SAE5-35 TSO'd blind encoder.
For VFR into B, C airspace the BMA should be fine according to my
reading of the regs.
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_________________
Ira N224XS |
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bakerocb
Joined: 15 Jan 2006
Posts: 727
Location: FAIRFAX VA
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| Posted: Sun Jun 14, 2009 3:25 am Post subject: IFR Certification |
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6/14/2009
Hello Ira, Thanks for your input. You wrote:
1) "For VFR into B, C airspace the BMA should be fine according to my
reading of the regs."
Note that the wording of 14 CFR 91.217 makes no distinction between the
requirement for either a TSO'd altitude encoder (91.217 (c)) or a tested
altitude encoder (91.217 (b)) for mode C operations (automatic pressure
altitude reporting equipment) under IFR or VFR.
Further, no class of airspace is excluded from the requirements of 91.217 by
the wording therein.
Can you cite some regulation that says otherwise?
2) "I treated my airframe to a brand new Sandia SAE5-35 TSO'd blind
encoder."
A valid solution. When people have attempted to get the assistance of EAA to
change / clarify FAA Headquarter's position on this subject that is what EAA
has recommended -- just install a TSO'd altitude encoder.
'OC' Says: "The best investment we can make is the effort to gather and
understand knowledge."
================================================
Time: 10:35:39 AM PST US
Subject: Re: IFR Certification
From: "rampil" <ira.rampil(at)gmail.com>
Actually I didn't condemn the boss, I simply referenced the boss
as the key to the problem. I am familiar with the issues you raised
which is why when finally got IFR certification for myself, I treated
my airframe to a brand new Sandia SAE5-35 TSO'd blind encoder.
For VFR into B, C airspace the BMA should be fine according to my
reading of the regs.
--------
Ira N224XS
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