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ADBS-B Out

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BGray(at)glasair.org
Guest

Posted: Thu Jul 07, 2011 12:51 pm Post subject: ADBS-B Out

I posted this to the RV list and no one had any answers. How about you

guys?



***************************



Hi Guys,



I already have all the equipment I need for ADS-B Out for my Glasair

III. But it seems that in its rush to get the regulation out to the

public, the FAA did not provide any path for Experimental aircraft to

install/approve ADBS-B. 



The FAA has published an advisory circular on the subject (AC 20-165)

that states ALL ADBS-B installations must be approved before use. It

then goes on to state that approval requires an STC. It also broadly

hints that all equipment must be TSO'ed. You all must know that STC's do

not apply to us. To add further confusion, I was told by my local FSDO

that all STC's for approval were not being accepted and that the only

way to get approval was from the original aircraft manufacturer. I asked

the FSDO if we (the home builder) were considered the manufacturer and

was told the FAA felt that it was the kit manufacturer. I called the

EAA, they were clueless.



So, it seems that you (or we) can't get there from here. Any one have

any ideas?



Here's the link to the AC,



http://www.airweb.faa.gov/REGULATORY_AND_GUIDANCE_LIBRARY/RGADVISORYCIRC

ULAR.NSF/0/4D934250FE568A79862577310060CF03?OpenDocument





Bruce

WWW.Glasair.org

rleffler

Joined: 05 Nov 2006
Posts: 680

Posted: Thu Jul 07, 2011 1:17 pm Post subject: ADBS-B Out

Work with your ADS-B vendor to assist you to work through the issues.  It's

in their best interest as well as yours.



--

_________________
Bob Leffler
N410BL - Phase I
http://mykitlog.com/rleffler

BGray(at)glasair.org
Guest

Posted: Thu Jul 07, 2011 2:02 pm Post subject: ADBS-B Out

I wish it were that easy.



Garmin 530W TSO'ed

Garmin 330ES TSO'ed

RMI Microencoder Air Data Non-TSO'ed.



Garmin shrugged it's shoulders.



The stumbling block is going to be the air data system.



Unlike encoder certification by successfully completing a ground test,

there is NO ground/air testing protocol yet published for ADBS-B Out

approval.



Remember back in the early days of RNAV? You had to fly over known

landmarks and log the results to verify accuracy. That's what we need

here. But that would require ATC coordination. 



Bruce

WWW.Glasair.org 



--

r.r.hall(at)cox.net
Guest

Posted: Thu Jul 07, 2011 5:09 pm Post subject: ADBS-B Out

Based on this paragraph I don't think the AC applies to experimental, I could be wrong though.



1-2. Who This AC Applies to. This AC is for anyone who is applying for an initial type certificate (TC), supplemental type certificate (STC), an amended TC, or an amended STC for the installation and continued airworthiness of ADS-B Out equipment.



Since the TC STC area doesn't apply I think we are left without any guidance at this point.



Rodney

---- Bruce <BGray(at)glasair.org> wrote:

 	  Quote: 	
		   



 I posted this to the RV list and no one had any answers. How about you

 guys?



 ***************************



 Hi Guys,



 I already have all the equipment I need for ADS-B Out for my Glasair

 III. But it seems that in its rush to get the regulation out to the

 public, the FAA did not provide any path for Experimental aircraft to

 install/approve ADBS-B.



 The FAA has published an advisory circular on the subject (AC 20-165)

 that states ALL ADBS-B installations must be approved before use. It

 then goes on to state that approval requires an STC. It also broadly

 hints that all equipment must be TSO'ed. You all must know that STC's do

 not apply to us. To add further confusion, I was told by my local FSDO

 that all STC's for approval were not being accepted and that the only

 way to get approval was from the original aircraft manufacturer. I asked

 the FSDO if we (the home builder) were considered the manufacturer and

 was told the FAA felt that it was the kit manufacturer. I called the

 EAA, they were clueless.



 So, it seems that you (or we) can't get there from here. Any one have

 any ideas?



 Here's the link to the AC,



 http://www.airweb.faa.gov/REGULATORY_AND_GUIDANCE_LIBRARY/RGADVISORYCIRC

 ULAR.NSF/0/4D934250FE568A79862577310060CF03?OpenDocument





 Bruce

 WWW.Glasair.org

Flydad57(at)neo.rr.com
Guest

Posted: Thu Jul 07, 2011 5:15 pm Post subject: ADBS-B Out

I know I'm the manufacturer of my homebuilt experimental.  It says so on my 

airworthiness certificate and the data plate.  You can put anything you want 

in an E-AB.  Don't know why ADS-B stuff would be any different.  Just like a 

transponder, no?



Bob Taylor

TigerCub N657RT



--------------------------------------------------

From: "Bruce" <BGray(at)glasair.org>

Sent: Thursday, July 07, 2011 4:47 PM

To: <aeroelectric-list(at)matronics.com>

Subject: ADBS-B Out



 	  Quote: 	
		   



 I posted this to the RV list and no one had any answers. How about you

 guys?



 ***************************



 Hi Guys,



 I already have all the equipment I need for ADS-B Out for my Glasair

 III. But it seems that in its rush to get the regulation out to the

 public, the FAA did not provide any path for Experimental aircraft to

 install/approve ADBS-B.



 The FAA has published an advisory circular on the subject (AC 20-165)

 that states ALL ADBS-B installations must be approved before use. It

 then goes on to state that approval requires an STC. It also broadly

 hints that all equipment must be TSO'ed. You all must know that STC's do

 not apply to us. To add further confusion, I was told by my local FSDO

 that all STC's for approval were not being accepted and that the only

 way to get approval was from the original aircraft manufacturer. I asked

 the FSDO if we (the home builder) were considered the manufacturer and

 was told the FAA felt that it was the kit manufacturer. I called the

 EAA, they were clueless.



 So, it seems that you (or we) can't get there from here. Any one have

 any ideas?



 Here's the link to the AC,



 http://www.airweb.faa.gov/REGULATORY_AND_GUIDANCE_LIBRARY/RGADVISORYCIRC

 ULAR.NSF/0/4D934250FE568A79862577310060CF03?OpenDocument





 Bruce

 WWW.Glasair.org

Matt Dralle
Site Admin

Joined: 08 Nov 2005
Posts: 26321
Location: Livermore CA USA

Posted: Thu Jul 07, 2011 6:32 pm Post subject: ADBS-B Out

That's a good point.  NavWorx, for example, ONLY sells non-TSO'd equipment so their only market is Experimental, right?  Seems like they wouldn't have a business model if you couldn't install their ADS-B transceivers in your homebuilt...



Matt



-

Matt Dralle

RV-8 #82880 N998RV "Ruby Vixen"

http://www.mattsrv8.com - Matt's Complete RV-8 Construction Log

http://www.mattsrv8.com/Mishap - Landing Mishap Rebuild Log

http://www.youtube.com/MattsRV8 - Matt's RV-8 HDTV YouTube Channel

Status: 170+ Hours TTSN - Rebuilding Fuselage After Landing Mishap...



At 02:09 PM 7/7/2011  Thursday, you wrote:

 	  Quote: 	
		  



Work with your ADS-B vendor to assist you to work through the issues.  It's

in their best interest as well as yours.

_________________
Matt Dralle
Matronics Email List Administrator

Matt Dralle
Site Admin

Joined: 08 Nov 2005
Posts: 26321
Location: Livermore CA USA

Posted: Thu Jul 07, 2011 6:41 pm Post subject: ADBS-B Out

At 01:47 PM 7/7/2011  Thursday, you wrote:

 	  Quote: 	
		  I asked

the FSDO if we (the home builder) were considered the manufacturer and

was told the FAA felt that it was the kit manufacturer. 


	


This seems blatantly wrong.  If I built an Experimental airplane of my own design from scratch, there is no question I am the manufacture of the aircraft.



To that end, on my RV-8, when I registered it, under "Model" I put "RV-8", under "Manufacture" I put "Matt Dralle (Van's Aircraft)".  



Only the "Builder" (i.e. manufacture) of the aircraft can hold the Mechanics cert for my RV-8.  Last time I did an inspection on it, *I* signed the log book off, not Van's Aircraft...



$.02



Matt

-

Matt Dralle

RV-8 #82880 N998RV "Ruby Vixen"

http://www.mattsrv8.com - Matt's Complete RV-8 Construction Log

http://www.mattsrv8.com/Mishap - Landing Mishap Rebuild Log

http://www.youtube.com/MattsRV8 - Matt's RV-8 HDTV YouTube Channel

Status: 170+ Hours TTSN - Rebuilding Fuselage After Landing Mishap...

_________________
Matt Dralle
Matronics Email List Administrator

wgreenley

Joined: 09 Jan 2010
Posts: 100
Location: Dowagiac, MI

Posted: Fri Jul 08, 2011 5:30 am Post subject: ADBS-B Out

I don't think this is totally true. I have a '56 172, CAR 3 certified, TSO's

are not a requirement for all the equipment since this is not required on

the TC. For instance a KX-170B radio.

Bill Greenley

RV-10 (waiting on wing kit delivery)



--

bakerocb

Joined: 15 Jan 2006
Posts: 727
Location: FAIRFAX VA

Posted: Fri Jul 08, 2011 6:43 am Post subject: ADBS-B Out

7/8/2011



Hello Bruce Gray, It is unfortunate that you assigned ADBS-B Out to the 

subject of your aeroelectric list post instead of ADSB-B Out. We may be 

stuck with that now as the identification of this thread. (Do you suppose 

the transposition of the letters "B" and "S" in that fashion was the result 

of some Freudian slip on your part?)



Hello Bob Taylor, You wrote:



1) "I know I'm the manufacturer of my homebuilt experimental.  It says so on 

my

airworthiness certificate ..........."



Are you absolutely positive of this statement? Please recheck the FAA FORM 

8130-7, SPECIAL AIRWORTHINESS CERTIFICATE for your EXPERIMENTAL - AMATEUR 

BUILT aircraft. Maybe your initial airworthiness inspector made a mistake in 

filling out that form. (Was the inspection done by a DAR?).



My FSDO issued certificate has N / A entered in both the NAME and ADDRESS 

boxes of Block B MANUFACTURER. In Block D it has my name in the BUILDER box.



This makes it very clear that in the eyes of the FAA I am the BUILDER and 

not the MANUFACTURER of my airplane. This is important because some 14 CFR 

regulations (such as 91.411 (b) (1) for example) give prerogatives to the 

manufacturer of an aircraft that are not given to the builder of an E-AB 

aircraft.



2) "..... and the data plate."



This really proves nothing. Except for the applicable and limited amount of 

information required on an E-AB aircraft data plate by 14 CFR 45.11 and 

45.13 (Builder's Name, Model Designation, and Builder's Serial Number) one 

may put anything else one chooses on that data plate. (One may note in 

passing that in the data plate terminology used in 45.13 even an aircraft 

manufacturer such as Piper or Cessna becomes a "Builder" rather than a 

"Manufacturer".)



3) "You can put anything you want in an E-AB."



Not really. This gets to be a complex issue and your statement can not be 

taken at face value.



Please see the introduction to the attached table MINIMUM INSTRUMENT AND 

EQUIPMENT REQUIREMENTS FOR POWERED AMATEUR BUILT EXPERIMENTAL AIRCRAFT for 

more insight into this issue.



4) "Just like a transponder, no?"



I would be inclined to agree. If the ADSB-B Out equipment has some sort of 

TSO approval by the FAA why not go ahead and install it. If every builder of 

E-AB aircraft had to comply with every word of every Advisory Circular that 

were written, for the most part, by FAA employees that have not a clue about 

the existence of E-AB aircraft, we would not have a single E-AB in the air.



'OC' Baker Says: "The best investment we can make is the time and effort to 

gather and understand knowledge."



=========================================================



Time: 06:15:31 PM PST US

From: "Robert Taylor" <Flydad57(at)neo.rr.com>

Subject: Re: ADBS-B Out

I know I'm the manufacturer of my homebuilt experimental.  It says so on my

airworthiness certificate and the data plate.  You can put anything you want

in an E-AB.  Don't know why ADS-B stuff would be any different.  Just like a

transponder, no?



Bob Taylor

TigerCub N657RT

ABEA_Minimum_Inst_Requirements_10.doc

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bakerocb

Joined: 15 Jan 2006
Posts: 727
Location: FAIRFAX VA

Posted: Fri Jul 08, 2011 7:28 am Post subject: ADBS-B Out

7/8/2011



Hello Bruce Gray, You wrote:



1) "ADBS-B Out"



It is unfortunate that you assigned ADBS-B Out to the

subject of your aeroelectric list post instead of ADSB-B Out. We may be

stuck with that now as the identification of this thread. (Do you suppose

the transposition of the letters "B" and "S" in that fashion was the result

of some Freudian slip on your part?)

2) "...the FAA did not provide any path for Experimental aircraft to

install/approve ADBS-B." and "The FAA has published an advisory circular on 

the subject (AC 20-165) that states ALL ADBS-B installations must be 

approved before use."



Since many portions of 14 CFR and the supporting Advisory Circulars are 

written by bureaucrats and approved by lawyers who do not have a clue 

regarding the existence of E-AB (Experimental- Amateur Built) aircraft one 

should not be surprised by lack of this path. (And maybe we should be 

grateful that they did not attempt to provide one since it would probably be 

nearly impossible to comply with.)



3) "I asked the FSDO if we (the home builder) were considered the 

manufacturer and

was told the FAA felt that it was the kit manufacturer."



Please see my response to Bob Taylor on this issue.



It is unfortunate that we have gotten all wrapped around the axle regarding 

the semantics of "builder" versus "manufacturer".  I think that we should 

call all kit providers just that, "Kit Providers". They are neither the 

manufacturers nor the builders of E-AB aircraft. And the E-AB builder is 

just that, the builder, not the manufacturer of his E-AB aircraft.



4) "I called the EAA, they were clueless."



I think that if you call the EAA and talk to or email Joe Norris 

(jnorris(at)eaa.org) you will find out that it is not the EAA that is clueless, 

but rather the FAA responses when the EAA attempts to query the FAA on our 

behalf on many issues.



5) "So, it seems that you (or we) can't get there from here. Any one have

any ideas?"



If the ADSB-Out equipment that you have has some TSO markings on it, make 

the best installation that you can and go fly it.**



'OC' Baker Says: "The best investment we can make is the time and effort to 

gather and understand knowledge."



**PS: I can recall a posting by an individual many years ago when GPS was 

new. This builder attempted to comply with the then existing Advisory 

Circular on GPS installations to obtain some FAA approval. He wound up 

airborne with a terrified FAA bureacrat for an approval flight. The poor FAA 

employee spent the entire flight looking out the windows waiting the the 

inevitable mid air collision that was about to happen any second. The FAA 

employee never looked at the GPS equipment.



That experience cured that builder of ever again trying to get any E-AB 

aircraft equipment installation approved by the FAA.



==========================================================



Time: 01:51:50 PM PST US

From: "Bruce" <BGray(at)glasair.org>

Subject: ADBS-B Out

I posted this to the RV list and no one had any answers. How about you

guys?



***************************



Hi Guys,



I already have all the equipment I need for ADS-B Out for my Glasair

III. But it seems that in its rush to get the regulation out to the

public, the FAA did not provide any path for Experimental aircraft to

install/approve ADBS-B.



The FAA has published an advisory circular on the subject (AC 20-165)

that states ALL ADBS-B installations must be approved before use. It

then goes on to state that approval requires an STC. It also broadly

hints that all equipment must be TSO'ed. You all must know that STC's do

not apply to us. To add further confusion, I was told by my local FSDO

that all STC's for approval were not being accepted and that the only

way to get approval was from the original aircraft manufacturer. I asked

the FSDO if we (the home builder) were considered the manufacturer and

was told the FAA felt that it was the kit manufacturer. I called the

EAA, they were clueless.



So, it seems that you (or we) can't get there from here. Any one have

any ideas?



Here's the link to the AC,



http://www.airweb.faa.gov/REGULATORY_AND_GUIDANCE_LIBRARY/RGADVISORYCIRC

ULAR.NSF/0/4D934250FE568A79862577310060CF03?OpenDocument

Bruce

WWW.Glasair.org

BGray(at)glasair.org
Guest

Posted: Fri Jul 08, 2011 7:28 am Post subject: ADBS-B Out

It could have well been a Freudian slip.



Anyway, someone mentioned Navworx on this thread.



According to the data in the regulation (14 CFR �92.225) those aircraft

equipped with Extended Squitter (1090 ES) must meet TSO-C166b, those

equipped with Universal Access Transceivers (UAT) must meet TSO-C154c.

How does on meet TSO standards without getting approval? Navworx is non

TSO'ed, therefore not legal to use. 



Unless we crack this nut, in 2020 we will be denied the use of most

airspace.

Bruce

WWW.Glasair.org 



--

Float Flyr

Joined: 19 Jul 2006
Posts: 2704
Location: Campbellton, Newfoundland

Posted: Fri Jul 08, 2011 10:18 am Post subject: ADBS-B Out

I(s that not the reason for the 51% rule?  To specifically make the builder

the manufacturer?  The gathering of parts and the design is supposed to be

less than 50%.



One other thing, after selling a homebuilt aircraft, just check out who has

manufacturers' liability!



Noel



--

_________________
Noel Loveys
Kitfox III-A
Aerocet 1100 Floats

bakerocb

Joined: 15 Jan 2006
Posts: 727
Location: FAIRFAX VA

Posted: Fri Jul 08, 2011 8:34 pm Post subject: ADBS-B Out

7/8/2011



Hello Bob Taylor, You wrote:



1) "Every form that I filled out for my E-AB aircraft states that I am the

manufacturer (Taylor, Robert D.)."



A) Not true. See here, for example, FAA FORM 8130-6, APPLICATION FOR U. S. 

AIRWORTHINESS CERTIFICATE



http://www.faa.gov/documentLibrary/media/form/faa8130-6.pdf



Note that in Box 2 they ask for the AIRCRAFT BUILDER'S NAME (Make). The 

instructions in FAA Order 8130.2F for filling out this form specifically 

state that for an E-AB aircraft the name of the amateur builder is entered 

in Box 2.



B) Please LOOK at your airplane's FAA FORM 8130-7 SPECIAL AIRWORTHINESS 

CERTIFICATE  and tell us exactly what was typed into the NAME and ADDRESS 

boxes in Section B, MANUFACTURER and what was typed into the Section D, 

BUILDER box by that FAA inspector from the Cleveland MIDO when he inspected 

your airplane and created that form.



That will tell you (and us) in the eyes of the FAA who was the MANUFACTURER 

(undoubtedly N / A) and who was the BUILDER (your name) of your airplane.



2) "My aircraft was not a kit."



Does not matter. Every E-AB aircraft, regardless of its initial source or 

manner of creation, will have "TO OPERATE AMATEUR BUILT AIRCRAFT" in the 

PURPOSE box of SECTION A, and the amateur builder's name in the BUILDER box 

of Section D of that aircraft's FAA FORM 8130-7, SPECIAL AIRWORTHINESS 

CERTIFICATE.



'OC' Baker Says: "The best investment we can make is the time and effort to 

gather and understand knowledge."



================================================



From: "Robert Taylor" <Flydad57(at)neo.rr.com>

To: <bakerocb(at)cox.net>

Sent: Friday, July 08, 2011 10:41 PM

Subject: Re: ADBS-B Out

 	  Quote: 	
		   Every form that I filled out for my E-AB aircraft states that I am the 

 manufacturer (Taylor, Robert D.).  The model is TigerCub.  No, my 

 inspector was not a DAR.  He was from the Cleveland MIDO office.  My 

 aircraft was not a kit.  It was built/manufactured by me.



 Bob Taylor

 TigerCub N657RT



 ==================================

 From: <bakerocb(at)cox.net>

 Sent: Friday, July 08, 2011 10:40 AM

 To: <aeroelectric-list(at)matronics.com>; <Flydad57(at)neo.rr.com>; 

 <BGray(at)glasair.org>

 Subject: ADBS-B Out



> 7/8/2011

>

> Hello Bruce Gray, It is unfortunate that you assigned ADBS-B Out to the

> subject of your aeroelectric list post instead of ADSB-B Out. We may be

> stuck with that now as the identification of this thread. (Do you suppose

> the transposition of the letters "B" and "S" in that fashion was the 

> result

> of some Freudian slip on your part?)

>

> Hello Bob Taylor, You wrote:

>

> 1) "I know I'm the manufacturer of my homebuilt experimental.  It says so 

> on

> my

> airworthiness certificate ..........."

>

> Are you absolutely positive of this statement? Please recheck the FAA 

> FORM

> 8130-7, SPECIAL AIRWORTHINESS CERTIFICATE for your EXPERIMENTAL - AMATEUR

> BUILT aircraft. Maybe your initial airworthiness inspector made a mistake 

> in

> filling out that form. (Was the inspection done by a DAR?).

>

> My FSDO issued certificate has N / A entered in both the NAME and ADDRESS

> boxes of Block B MANUFACTURER. In Block D it has my name in the BUILDER 

> box.

>

> This makes it very clear that in the eyes of the FAA I am the BUILDER and

> not the MANUFACTURER of my airplane. This is important because some 14 

> CFR

> regulations (such as 91.411 (b) (1) for example) give prerogatives to the

> manufacturer of an aircraft that are not given to the builder of an E-AB

> aircraft.

>

> 2) "..... and the data plate."

>

> This really proves nothing. Except for the applicable and limited amount 

> of

> information required on an E-AB aircraft data plate by 14 CFR 45.11 and

> 45.13 (Builder's Name, Model Designation, and Builder's Serial Number) 

> one

> may put anything else one chooses on that data plate. (One may note in

> passing that in the data plate terminology used in 45.13 even an aircraft

> manufacturer such as Piper or Cessna becomes a "Builder" rather than a

> "Manufacturer".)

>

> 3) "You can put anything you want in an E-AB."

>

> Not really. This gets to be a complex issue and your statement can not be

> taken at face value.

>

> Please see the introduction to the attached table MINIMUM INSTRUMENT AND

> EQUIPMENT REQUIREMENTS FOR POWERED AMATEUR BUILT EXPERIMENTAL AIRCRAFT 

> for

> more insight into this issue.

>

> 4) "Just like a transponder, no?"

>

> I would be inclined to agree. If the ADSB-B Out equipment has some sort 

> of

> TSO approval by the FAA why not go ahead and install it. If every builder 

> of

> E-AB aircraft had to comply with every word of every Advisory Circular 

> that

> were written, for the most part, by FAA employees that have not a clue 

> about

> the existence of E-AB aircraft, we would not have a single E-AB in the 

> air.

>

> 'OC' Baker Says: "The best investment we can make is the time and effort 

> to

> gather and understand knowledge."

>

> =========================================================

>

> Time: 06:15:31 PM PST US

> From: "Robert Taylor" <Flydad57(at)neo.rr.com>

> Subject: Re: ADBS-B Out

> I know I'm the manufacturer of my homebuilt experimental.  It says so on 

> my

> airworthiness certificate and the data plate.  You can put anything you 

> want

> in an E-AB.  Don't know why ADS-B stuff would be any different.  Just 

> like a

> transponder, no?

>

> Bob Taylor

> TigerCub N657RT

>

bakerocb

Joined: 15 Jan 2006
Posts: 727
Location: FAIRFAX VA

Posted: Sat Jul 09, 2011 5:24 am Post subject: ADBS-B Out

7/9/2011



Hello Noel Loveys, You wrote:



1) "To specifically make the builder the manufacturer?"



I don't understand why people are straining to be considered the 

"manufacturer" of a product (namely one single E-AB aircraft) in the eyes of 

the FAA.**



 When one looks at the totality of the FAA definitions, and the FAA 

regulations based on those definitions, it is absurd to consider the amateur 

builder of a single E-AB to be the "manufacturer" of that aircraft. Let run 

through a brief audit trail of what applies:



A) First, can an individual building an E-AB become a manufacturer? The 

answer is, yes. See the definition of a Person from 14 CFR 1.1 General 

Definitions here:

"Person means an individual, firm, partnership, corporation, company, 

association, joint-stock association, or governmental entity. It includes a 

trustee, receiver, assignee, or similar representative of any of them."



Now let's extract some definitions from FAA Order 8120.2G. You can look at 

it here:



http://www.faa.gov/documentLibrary/media/Order/8120.2G.pdf

B) Second, what does a manufacturer do? See here:



"o. Manufacturer. A person as defined by 14 CFR part 1, Definitions and 

Abbreviations, who causes a product or article(s) to be produced. A 

manufacturer may be a PAH or a supplier to a PAH."



C) Third, what does it mean to produce a product or article(s).



"s. Produce. To manufacture, or cause to be manufactured, a product or 

article(s)."



D) Fourth, how does one go about having approval to produce a product or 

article? See here:



"u. Production Approval. A document issued by the FAA to a person that 

allows the production of a product or article in accordance with its 

approved design and approved quality system, and can take the form of a PC, 

a PMA, or a TSO authorization."



E) So all the individual person building an E-AB needs to formally become 

the manufacturer of that procuct, instead of being the builder of an E-AB, 

is to get the FAA to issue him a PC, a PMA, or a TSO authorization. In order 

to get the needed document from the FAA he can start by reading FAA Order 

8120.2G -- Go for it!



2) "One other thing, after selling a homebuilt aircraft, just check out who 

has

manufacturers' liability!"



Do you really think that the semantic distinction between suing the 

"builder" or the "manufacturer" of an E-AB would stop some vulture lawyer 

from initiating a lawsuit? Or would have any affect on the outcome of such a 

law suit?



'OC' Baker Says: "The best investment we can make is the time and effort to 

gather and understand knowledge."



**PS: Apparently some E-AB aircraft builders feel that being the 

"manufacturer" of that aircraft, rather than just the "builder" will give 

them some special manufacturer's privileges such as that granted in 14 CFR 

91.411 (b) (1) for example.



Really? Take a look at what it takes for even an approved aircraft 

manufacturer to perform all the tests required by 91.411 and see how many 

individual E-AB builders would have the equipment and expertise to perform 

those tests even if given permission to do so.



======================================================



Time: 11:18:02 AM PST US

From: "Noel Loveys" <noelloveys(at)yahoo.ca>

Subject: RE: ADBS-B Out

I(s that not the reason for the 51% rule?  To specifically make the builder

the manufacturer?  The gathering of parts and the design is supposed to be

less than 50%.



One other thing, after selling a homebuilt aircraft, just check out who has

manufacturers' liability!



Noel

BGray(at)glasair.org
Guest

Posted: Sat Jul 09, 2011 9:41 am Post subject: ADBS-B Out

Now I'm really confused. 



How can the FAA consider the Kit Manufacturer the "Manufacturer"?



I know of no kit manufacturer who has a PC, PMA, TC, or Production

Approval. What they may have is a letter that their kit meets the 51

percent rule.



Bruce

WWW.Glasair.org 



--

bakerocb

Joined: 15 Jan 2006
Posts: 727
Location: FAIRFAX VA

Posted: Sun Jul 10, 2011 5:49 am Post subject: ADBS-B Out

7/10/2011



Hello Bruce, You wrote: "What they may have is a letter that their kit meets 

the 51

percent rule."



That is correct. Let's take another look at some of the paragraphs that I 

extracted from:



http://www.faa.gov/documentLibrary/media/Order/8120.2G.pdf



"o. Manufacturer. A person as defined by 14 CFR part 1, Definitions and

Abbreviations, who causes a product or article(s) to be produced. A

manufacturer may be a PAH or a supplier to a PAH."



"u. Production Approval. A document issued by the FAA to a person that

allows the production of a product or article in accordance with its

approved design and approved quality system, and can take the form of a

PC, a PMA, or a TSO authorization."



Note that paragraph o does not have the word "only" between the words "may" 

and "be".



Also paragraph u does not have the word "only" between the words "can" and 

"take".



There is nothing in the regulations or FAA Order 8120.2G that prohibit the 

FAA Administrator from using the word "manufacturer" in the letter that 

informs the kit provider, and prospective kit purchasers, that his kit meets 

the major portion rule.



Some additional comments on this specific issue:



1) Since the FAA writes the various types of documents based upon their 

authority in the US Code they get to choose the wording (subject to public 

review of draft regulations) in those documents.



2) When the bureaucrats and document approving lawyers wrote FAA Order 

8120.2G they did not have the existence of E-AB (Experimental - Amateur 

Built) aircraft or kit creators in their mind. (A very common situation 

through out the FAA.)



3) There were a number of english language words available to that FAA 

letter writer to describe the kit creators. Words such as "creators", 

"assemblers", "manufacturers", and, my favorite word when writing on this 

subject to avoid confusion with the builder who actually turns the kit into 

an airplane, "providers". It seems logical for the writers to use the common 

generic word "manufacturer", without creating any greater implication of the 

word, when referring to the kit providers.



4) The power of the Administrator (and of the individuals within the FAA 

acting on his behalf) is pretty complete, he can use the words that he 

chooses to mean what he wants them to mean.



5) In a sense the type of letter to the kit provider that you refer to could 

be considered a form of Production Approval thereby making the kit provider 

a PAH (Production Approval Holder), but the FAA makes an effort to avoid 

using the word "approval" regarding E-AB aircraft since there are no 

published standards available to measure any E-AB approval against. (Before 

people leap up to point out that indeed some approval requirements are 

placed on E-AB aircraft I invite them to read again the Introduction to the 

attached table MINIMUM INSTRUMENT AND EQUIPMENT REQUIREMENTS FOR POWERED 

AMATEUR BUILT EXPERIMENTAL AIRCRAFT.)



5) So the use of the word "manufacturer" in the letters that you write of to 

the kit provides should not create a significant problem or needed source of 

confusion. And it certainly does not bear directly on the issue of whether 

in the eyes of the FAA the builder of an E-AB meets the criteria of being a 

"manufacturer" wherever that term is used throughout the FAA written 

regulations.**



'OC' Baker Says: "The best investment we can make is the time and effort to 

gather and understand knowledge."



**PS: I would appreciate it if any E-AB builders who want to be considered 

"manufacturers" would identify to us the specific regulation(s) that they 

think would benefit them by this categorization.



=========================================================

Time: 10:41:13 AM PST US

From: "Bruce" <BGray(at)glasair.org>

Subject: RE: ADBS-B Out

Now I'm really confused.



How can the FAA consider the Kit Manufacturer the "Manufacturer"?



I know of no kit manufacturer who has a PC, PMA, TC, or Production

Approval. What they may have is a letter that their kit meets the 51

percent rule.



Bruce

WWW.Glasair.org

ABEA_Minimum_Inst_Requirements_10.doc

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ABEA_Minimum_Inst_Requirements_10.doc

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Flydad57(at)neo.rr.com
Guest

Posted: Sun Jul 10, 2011 11:47 am Post subject: ADBS-B Out

Just to close the loop regarding some comments I made the other day, my 

paperwork does not indicate that I am the "manufacturer".  My bad.  It DOES 

show the MAKE of my aircraft to be a Taylor, Robert D..  That's what lead me 

to think it said I was the manufacturer.  I was not looking to be the 

maufacturer in order to gleen some advantage via the regulations, I just 

thought (mistakenly) that that was what the paperwork said.



Regardless the above, I do think that I can put whatever equipment I wish 

into my aircraft.

Bob Taylor

TigerCub N657RT



--------------------------------------------------

From: <bakerocb(at)cox.net>

Sent: Sunday, July 10, 2011 9:46 AM

To: <aeroelectric-list(at)matronics.com>; <BGray(at)glasair.org>

Subject: ADBS-B Out



 	  Quote: 	
		   7/10/2011



 Hello Bruce, You wrote: "What they may have is a letter that their kit 

 meets

 the 51

 percent rule."



 That is correct. Let's take another look at some of the paragraphs that I

 extracted from:



 http://www.faa.gov/documentLibrary/media/Order/8120.2G.pdf



 "o. Manufacturer. A person as defined by 14 CFR part 1, Definitions and

 Abbreviations, who causes a product or article(s) to be produced. A

 manufacturer may be a PAH or a supplier to a PAH."



 "u. Production Approval. A document issued by the FAA to a person that

 allows the production of a product or article in accordance with its

 approved design and approved quality system, and can take the form of a

 PC, a PMA, or a TSO authorization."



 Note that paragraph o does not have the word "only" between the words 

 "may"

 and "be".



 Also paragraph u does not have the word "only" between the words "can" and

 "take".



 There is nothing in the regulations or FAA Order 8120.2G that prohibit the

 FAA Administrator from using the word "manufacturer" in the letter that

 informs the kit provider, and prospective kit purchasers, that his kit 

 meets

 the major portion rule.



 Some additional comments on this specific issue:



 1) Since the FAA writes the various types of documents based upon their

 authority in the US Code they get to choose the wording (subject to public

 review of draft regulations) in those documents.



 2) When the bureaucrats and document approving lawyers wrote FAA Order

 8120.2G they did not have the existence of E-AB (Experimental - Amateur

 Built) aircraft or kit creators in their mind. (A very common situation

 through out the FAA.)



 3) There were a number of english language words available to that FAA

 letter writer to describe the kit creators. Words such as "creators",

 "assemblers", "manufacturers", and, my favorite word when writing on this

 subject to avoid confusion with the builder who actually turns the kit 

 into

 an airplane, "providers". It seems logical for the writers to use the 

 common

 generic word "manufacturer", without creating any greater implication of 

 the

 word, when referring to the kit providers.



 4) The power of the Administrator (and of the individuals within the FAA

 acting on his behalf) is pretty complete, he can use the words that he

 chooses to mean what he wants them to mean.



 5) In a sense the type of letter to the kit provider that you refer to 

 could

 be considered a form of Production Approval thereby making the kit 

 provider

 a PAH (Production Approval Holder), but the FAA makes an effort to avoid

 using the word "approval" regarding E-AB aircraft since there are no

 published standards available to measure any E-AB approval against. 

 (Before

 people leap up to point out that indeed some approval requirements are

 placed on E-AB aircraft I invite them to read again the Introduction to 

 the

 attached table MINIMUM INSTRUMENT AND EQUIPMENT REQUIREMENTS FOR POWERED

 AMATEUR BUILT EXPERIMENTAL AIRCRAFT.)



 5) So the use of the word "manufacturer" in the letters that you write of 

 to

 the kit provides should not create a significant problem or needed source 

 of

 confusion. And it certainly does not bear directly on the issue of whether

 in the eyes of the FAA the builder of an E-AB meets the criteria of being 

 a

 "manufacturer" wherever that term is used throughout the FAA written

 regulations.**



 'OC' Baker Says: "The best investment we can make is the time and effort 

 to

 gather and understand knowledge."



 **PS: I would appreciate it if any E-AB builders who want to be considered

 "manufacturers" would identify to us the specific regulation(s) that they

 think would benefit them by this categorization.



 =========================================================

 Time: 10:41:13 AM PST US

 From: "Bruce" <BGray(at)glasair.org>

 Subject: RE: ADBS-B Out

 Now I'm really confused.



 How can the FAA consider the Kit Manufacturer the "Manufacturer"?



 I know of no kit manufacturer who has a PC, PMA, TC, or Production

 Approval. What they may have is a letter that their kit meets the 51

 percent rule.



 Bruce

 WWW.Glasair.org

bakerocb

Joined: 15 Jan 2006
Posts: 727
Location: FAIRFAX VA

Posted: Mon Jul 11, 2011 3:55 am Post subject: ADBS-B Out

7/11/2011



Hello Robert Taylor, You wrote:



1) "...... my paperwork does not indicate that I am the "manufacturer".  My 

bad."



Thank you for your response and for confiming that information.



2) "....... I do think that I can put whatever equipment I wish into my 

aircraft."



Almost true, but see these words extracted from the introduction to the 

attached table:



"However, depending upon other portions of the FAR's, some items in certain 

circumstances must not only be installed in experimental amateur built 

aircraft, but must interface properly with ATC (Air Traffic Control) 

equipment, other aircraft, or other entities external to the aircraft. 

Altitude encoders, Transponders, communication radios, exterior lighting, 

some IFR navigation equipment, and ELT's (Emergency Locator Transmitters) 

are examples of such equipment."



If equipment that must interface properly with entities external to the 

aircraft has been installed in the E-AB aircraft and the FAA requires 

equipment markings (such as a TSO), or, alternatively, testing to prove 

proper functioning, and the equipment installed does not interface properly, 

or is not properly marked, or has not been tested to the FAA's satisfaction, 

then they can demand that the aircraft not operate with that equipment.



'OC' Baker Says: "The best investment we can make is the time and effort to 

gather and understand knowledge."



===========================================================

Time: 12:47:06 PM PST US

From: "Robert Taylor" <Flydad57(at)neo.rr.com>

Subject: Re: ADBS-B Out

Just to close the loop regarding some comments I made the other day, my

paperwork does not indicate that I am the "manufacturer".  My bad.  It DOES

show the MAKE of my aircraft to be a Taylor, Robert D..  That's what lead me

to think it said I was the manufacturer.  I was not looking to be the

maufacturer in order to gleen some advantage via the regulations, I just

thought (mistakenly) that that was what the paperwork said.



Regardless the above, I do think that I can put whatever equipment I wish

into my aircraft.

Bob Taylor

TigerCub N657RT

ABEA_Minimum_Inst_Requirements_10.doc

Description:

Download

Filename:

ABEA_Minimum_Inst_Requirements_10.doc

Filesize:

35.5 KB

Downloaded:

1192 Time(s)

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