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IFR GPS requirements

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wgill10(at)comcast.net
Guest

Posted: Tue Jan 15, 2008 7:42 pm Post subject: IFR GPS requirements

Hello All,  

   

I have a Bendix-King KLN 94 GPS (IFR certified unit) in an RV-7. During discussions with an FAA inspector, I was told that I was not allowed to use this unit for IFR use until I completed a 337 form with a field approval, and completed the required test flight. I was not aware that the experimental ships had to jump through the same hoops as the Type Certificated aircraft. Can this possibly be true? I welcome all input on this subject.  

   

Bill  

RV-7  

Lee’s Summit, MO  

       [quote][b]

nuckolls.bob(at)cox.net
Guest

Posted: Tue Jan 15, 2008 8:17 pm Post subject: IFR GPS requirements

At 09:39 PM 1/15/2008 -0600, you wrote:



 	  Quote: 	
		  Hello All,



I have a Bendix-King KLN 94 GPS (IFR certified unit) in an RV-7. During 

discussions with an FAA inspector, I was told that I was not allowed to 

use this unit for IFR use until I completed a 337 form with a field 

approval, and completed the required test flight. I was not aware that the 

experimental ships had to jump through the same hoops as the Type 

Certificated aircraft. Can this possibly be true? I welcome all input on 

this subject.


	




   It would be interesting to see who he recommends for

   an IA to sign this off! Assuming you can get it submitted,

   it would be interesting to watch what happens to the document

   once it hit the appropriate offices for approval and filing.

   337's are the equivalent of a one-time STC against a particular

   certificated airframe.



   The guys here tell me to install it, go fly it, satisfy yourself

   that it is functioning as advertised and be done with it. Be

   cautious about getting into any serious discussions with

   a bureaucrat.

   Bob . . .

BobsV35B(at)aol.com
Guest

Posted: Wed Jan 16, 2008 1:18 am Post subject: IFR GPS requirements

Good Morning Bill,

  

 I agree with 'Lectric Bob's comment, but may I add a bit more?

  

 What it basically amounts to is that you are the certifying agent. As long  as the equipment operates in the manner required to meet the IFR requirements,  you are good to go. However, that does seem to mean that you should do the  checks that would be required for the flight testing to assure yourself that the  set is working properly. Just follow the directions given in the installation  manual for the test flight and so certify in the ship's papers. 

  

 I don't have the regulations memorized, but EAA has issued a paper on the  subject of IFR certification of experimental aircraft. It may have been authored  by Earl Lawrence, but I am not sure. Hopefully, someone more knowledgeable than  I will pipe up with a better reference. 

  

 In any case, don't get in an argument with a local FSDO inspector. 

  

 Remember, even though most of them are great guys who want to do a good  job, they are still at the very bottom of the food chain.

  

 Just listen and then do what you want! You are the responsible party. No  arguments needed.

  

 Happy  Skies,



Old Bob

AKA

Bob Siegfried

Ancient Aviator

628 West  86th Street

Downers Grove, IL 60516

630 985-8502 

Stearman  N3977A

Brookeridge Air Park LL22

  

  In a message dated 1/15/2008 9:44:48 P.M. Central Standard Time,  wgill10(at)comcast.net writes:

  	  Quote: 	
		        

Hello    All,   

    

I have a Bendix-King KLN 94 GPS    (IFR certified unit) in an RV-7. During discussions with an FAA inspector, I    was told that I was not allowed to use this unit for IFR use until I completed    a 337 form with a field approval, and completed the required test flight. I    was not aware that the experimental ships had to jump through the same hoops    as the Type Certificated aircraft. Can this possibly be true? I welcome all    input on this subject.   

    

Bill   

RV-7   

Lee’s Summit,    MO

	






Start the year off right.  Easy ways to stay in shape in the new year. 

  [quote][b]

wgill10(at)comcast.net
Guest

Posted: Wed Jan 16, 2008 3:17 am Post subject: IFR GPS requirements

Bob,



This inspector said he has done over 50 field inspections via 337 in

experimental aircraft in the Kansas City area. He did not say who the

submitting agency was, but I believe it was a repair station that he has

oversight responsibility. Strange. I will take everyone's advice and

quietly stay back away from the FAA and proceed. I have done a flight

test in visual conditions performing GPS approaches (as well as LOC/ILS

approaches) and all went great. Thanks for your input.



Bill

 



--

Peter Laurence

Joined: 10 Jan 2006
Posts: 50

Posted: Wed Jan 16, 2008 5:33 am Post subject: IFR GPS requirements

Bill

  

 I did a bit of research on this subject last year.  The FAA inspector is WRONG!

  

 Peter Laurence

  

  

 [quote]   ---

bakerocb

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

Posted: Wed Jan 16, 2008 6:10 am Post subject: IFR GPS requirements

1/16/2008



Hello Bill, Avoid that poor soul -- he has not been around long enough or 

cared enough to learn that type certificated aircraft and amateur built 

experimental aircraft are treated very differently in the FAA's paperwork 

system.



What he has described in the way of paperwork approval just simply does not 

apply to your airplane.



Here is a quote from the signature section of the FAA Form 337:



 "I certify that the repair and/or alteration made to the unit(s) identified 

in item 5 above and described on the reverse or attachments hereto have been 

made in accordance with the requirements of Part 43 of the U.S. Federal 

Aviation Regulations and that the information furnished herein is true and 

correct to the best of my knowledge."



And here is a quote from FAR Part 43.1:



"(b) This part does not apply to any aircraft for which the FAA has issued 

an experimental certificate, unless the FAA has previously issued a 

different kind of airworthiness certificate for that aircraft."



Since part 43 does not apply to amateur built aircraft issued a Special 

Airworthiness Certificate in the Experimental Category for the purpose of 

operating amateur-built aircraft (FAR 21.191 (g)) how can one properly 

comply with the signature certification requirement on the FAA Form 337?



Several years ago a poster described his mistaken attempt to comply with all 

FAA type certificated regulatory and advisory circular requirements for the 

IFR GPS installation in his amateur built experimental airplane. He even 

flew a test flight with a terrified FAA inspector who spent the entire 

flight frantically looking out the window in fear of a mid air collision. 

The entire effort was wasted because no FAA agency or procedure for the 

approval existed -- just initial erroneous assumptions by uninformed FAA 

employees.



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

understand knowledge."



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



 From: "William Gill" <wgill10(at)comcast.net>Subject: IFR GPS requirements



Date: Jan 15, 2008



Hello All,



I have a Bendix-King KLN 94 GPS (IFR certified unit) in an RV-7. During

discussions with an FAA inspector, I was told that I was not allowed to

use this unit for IFR use until I completed a 337 form with a field

approval, and completed the required test flight. I was not aware that

the experimental ships had to jump through the same hoops as the Type

Certificated aircraft. Can this possibly be true? I welcome all input on

this subject.



Bill

RV-7

Lee's Summit, MO

jindoguy(at)gmail.com
Guest

Posted: Wed Jan 16, 2008 6:50 am Post subject: IFR GPS requirements

Peter, et al, It depends on what the inspector wrote into you ops limits. If he referenced 91.205 as a requirement for IFR flight, then you must get the system tested by an FAA certified shop. If not you can proceed as you wish. 

In the Ops Limits I received yesterday, Item 11:

"After completion of phase 1 testing, unless appropriately equipped for night and/or instrument flight in accordance with 91.205, this aircraft is to be operated VFR day only." 



Rick Girard



On Jan 16, 2008 7:27 AM, Peter Laurence <Dr.Laurence(at)mbdi.org (Dr.Laurence(at)mbdi.org)> wrote:

[quote]          Bill

  

 I did a bit of research on this subject last year.  The FAA inspector is WRONG!

  

 Peter Laurence

  

  

 [quote]   ---

BobsV35B(at)aol.com
Guest

Posted: Wed Jan 16, 2008 7:07 am Post subject: IFR GPS requirements

Good Morning Rick,

  

 That is exactly the way it should read!

  

 The next step is to equip it in accordance with the specifications of 14  CFR Part 91, section 91.205 for the type of flight you wish to conduct and  make an entry into the ship's papers stating that you have done so. 

  

 No need to change anything on your ops spec and no need to contact any Fed.  

  

 Just install the equipment and test it in accordance with the  manufacturers directions. As long as you have the proper equipment, just  hop in the machine and go fly IFR and/or night 

  

 Happy  Skies,



Old Bob

AKA

Bob Siegfried

Ancient Aviator

628 West  86th Street

Downers Grove, IL 60516

630 985-8502 

Stearman  N3977A

Brookeridge Air Park LL22

  

  In a message dated 1/16/2008 8:53:03 A.M. Central Standard Time,  jindoguy(at)gmail.com writes:

  	  Quote: 	
		  In the    Ops Limits I received yesterday, Item 11:

"After completion of phase 1    testing, unless appropriately equipped for night and/or instrument flight in    accordance with 91.205, this aircraft is to be operated VFR day only."    



Rick  Girard

	






Start the year off right.  Easy ways to stay in shape in the new year. 

  [quote][b]

nuckolls.bob(at)cox.net
Guest

Posted: Wed Jan 16, 2008 7:34 am Post subject: IFR GPS requirements

At 05:13 AM 1/16/2008 -0600, you wrote:



 	  Quote: 	
		  



Bob,



This inspector said he has done over 50 field inspections via 337 in

experimental aircraft in the Kansas City area. He did not say who the

submitting agency was, but I believe it was a repair station that he has

oversight responsibility. Strange. I will take everyone's advice and

quietly stay back away from the FAA and proceed. I have done a flight

test in visual conditions performing GPS approaches (as well as LOC/ILS

approaches) and all went great. Thanks for your input.



Bill


	




   What he "has done" compared to what he is supposed

   "to do" may have some serious disconnect here. But

   then KC is the home of the Small Aircraft Directorate.

   As Thomas Paine noted many moons ago: When subject to

   dictatorships, monarchy, or oligarchy, at least we

   KNOW the source from which our irritations emanate.

   With democracies, we can only just begin to perceive

   the major players in a mass of individuals who's

   power needs to be metered through constitutional

   boundaries. It would not surprise me that what

   was recited to you by this individual was a portent

   of things to come. After all, the FAA is only here

   to help! With the numbers of TC light aircraft

   dwindling, he's only looking for more things to

   do.



   The prohibition against night and/or IFR flight

   speaks only to having the necessary equipment under

   part 91 rules to safely conduct such operations.

   It does not speak to whether it's silver plated,

   platinum plated, or holy-watered by individuals

   knighted by the oligarchy.



   A wise mentor of many years ago once advised me

   never to ask a question of anyone with power unless

   I already knew what that answer would be. Seems

   like a silly notion but as I grew older, it made

   a lot of sense. Folks with much power over my life

   leave a trail of activities that can be researched

   for predictors of their answers. If you don't like

   what the answer is going to be, then don't ask it.

   It many cases, the expenditure of $time$ to receive

   permission far exceeds the $time$ expended to

   beg forgiveness.



   So sifting through the pile of wreckage after

   bagging your remains they discover that your

   GPS was not holy-watered . . . what are they

   going to do, fine you?



   Bob . . .

aerobubba(at)earthlink.ne
Guest

Posted: Thu Jan 17, 2008 6:03 am Post subject: IFR GPS requirements

Hi Bill et al-



Re:  >Hello Bill, Avoid that poor soul -- he has not been around long

enough or 

 	  Quote: 	
		  cared enough to learn that type certificated aircraft and amateur built 

experimental aircraft are treated very differently in the FAA's paperwork 

system.

 
	


While I greatly appreciate and highly regard and respect the source of that

comment, I couldn't disagree more.  If this inspector has run 50

unnecessary 337's through the system, he has cost a lot of people a lot of

money, spread misinformation across the system, and will no doubt cause

other improperly educated or motivated inspectors to take the

'conservative' (ignorant) route at our collective expense.  In other words,

there has been a gross misuse of governmental power.  These kinds of topics

have gone to DC and back via OSH, and we have the tools to correct the

problem you are facing.  



My personal experience with an amateur built rule hose-up was to be very

(politely) clear with the person involved about the nature and basis for

our disconnect, and then call OSH with the details.  Within 24 hours they

had achieved understanding with the head of the directorate involved, and

within another 24 the fed involved had been re-educated.  That ended the

problem for me, and, presumably, everyone who came along after.



Also, the feds now have a program to handle customer service issues in

house.  As I understand it, it's the equivalent of 'let me speak to your

supervisor', although I don't recall the precise terminology.  Mike, can

you fill us in?



While I don't advocate getting into hostile conflicts with The Man, I

strongly urge you (and anyone else having bogus reg interpretation issues)

to fight the good fight with the resources we have developed and paid for

through our EAA dues and those gate fees at OSH we are all unhappy about. 

Heck, Brian got a law in Jacksonville repealed with a little help from his

friends.  What's one confused inspector? 



glen matejcek

aerobubba(at)earthlink.net

bakerocb

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

Posted: Thu Jan 17, 2008 11:04 am Post subject: IFR GPS requirements

1/17/2008



Hello Rick, Thanks for your input and interest in this subject. You wrote:



1) "It depends on what the inspector wrote into you ops limits."



The FAA Inspector or DAR is directed by FAA Order 8130.2_ (edition F, with 

change 3 incorporated is the current version) what to write into the 

Operating Limitations when issuing the Special Airworthiness Certificate for 

an amateur built experimental aircraft. His prerogative to ad lib in this 

specific area (IFR GPS requirements) is extremely limited to non existent.



2) "If he referenced 91.205 as a requirement for IFR flight, then you must 

get the

system tested by an FAA certified shop." and "If not you can proceed as you 

wish."



These two statements are misleading / incorrect.



2A) First off, There is no "if" about it. He most certainly will reference 

91.205 as a requirement for IFR flight. He will do this by incorporating 

this statement into the Operating Limitations: "After completion of phase 1 

testing, unless appropriately equipped for night and/or instrument flight in 

accordance with 91.205, this aircraft is to be operated VFR day only." See 

paragraph 1 above.



2B) Second, Other than the normal regulatory requirements for periodic 

inspections of the altitude encoder, the altimeter, and the transponder 

(these inspection requirements also apply to type certificated aircraft) 

there is no requirement to "get the system tested by an FAA certified shop."



2C) Third, It is not clear what you mean when you write the word "system".



I have prepared a table that serves as a quick reference on this subject:



MINIMUM INSTRUMENT AND EQUIPMENT REQUIREMENTS FOR POWERED AMATEUR BUILT 

EXPERIMENTAL AIRCRAFT.



I will email a copy of this table to any reader requesting it.



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

understand knowledge."



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



Time: 06:50:54 AM PST US

From: "Richard Girard" <jindoguy(at)gmail.com>

Subject: Re: AeroElectric-List: IFR GPS requirements



Peter, et al, It depends on what the inspector wrote into you ops limits. If

he referenced 91.205 as a requirement for IFR flight, then you must get the

system tested by an FAA certified shop. If not you can proceed as you wish.

In the Ops Limits I received yesterday, Item 11:

"After completion of phase 1 testing, unless appropriately equipped for

night and/or instrument flight in accordance with 91.205, this aircraft is

to be operated VFR day only."



Rick Girard

rv9jim(at)juno.com
Guest

Posted: Thu Jan 17, 2008 1:40 pm Post subject: IFR GPS requirements

Hi Bob,

        Could you send me a copy of the list?  I am setting up for lite

IFR but having the right stuff is important also.



Jim Nelson

 N15JN

RV9-A

bhcishere(at)ca.rr.com
Guest

Posted: Thu Jan 17, 2008 2:05 pm Post subject: IFR GPS requirements

Bob,



I could sure use a copy of your table.



Thank You,



Bryan



 	  Quote: 	
		   

 I have prepared a table that serves as a quick reference on this subject:

 

 MINIMUM INSTRUMENT AND EQUIPMENT REQUIREMENTS FOR POWERED AMATEUR BUILT 

 EXPERIMENTAL AIRCRAFT.

 

 I will email a copy of this table to any reader requesting it.

 

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

 understand knowledge."

BobsV35B(at)aol.com
Guest

Posted: Thu Jan 17, 2008 3:14 pm Post subject: IFR GPS requirements

Good Afternoon OC,

  

 I would appreciate a copy of your listing!

  

 BobsV35B(at)aol.com (BobsV35B(at)aol.com)

  

 Happy  Skies,



Old Bob

AKA

Bob Siegfried

Ancient Aviator

628 West  86th Street

Downers Grove, IL 60516

630 985-8502 

Stearman  N3977A

Brookeridge Air Park LL22

  

  In a message dated 1/17/2008 1:07:41 P.M. Central Standard Time,  bakerocb(at)cox.net writes:

  	  Quote: 	
		  MINIMUM    INSTRUMENT AND EQUIPMENT REQUIREMENTS FOR POWERED AMATEUR BUILT    

EXPERIMENTAL AIRCRAFT.



I will email a copy of this table to any    reader requesting it.



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

understand  knowledge."

	






Start the year off right.  Easy ways to stay in shape in the new year. 

  [quote][b]

hammer408(at)comcast.net
Guest

Posted: Thu Jan 17, 2008 5:08 pm Post subject: IFR GPS requirements

Good evening OC:

  

 I also would appreciate a copy.

  

 Thanks

  

 hammer408(at)comcast.net (hammer408(at)comcast.net)

  

 Henry

  

 [quote]   ---

bakerocb

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

Posted: Fri Jan 18, 2008 6:27 am Post subject: IFR GPS requirements

1/18/2008



Hello Glen, You are absolutely correct and I apologize for that moment of 

weakness when I wrote to just avoid the ignorant bureaucrat.



If we don't (politely) confront these people who are misusing their 

position, either out of ignorance or ego, we will suffer further abuses down 

the line.



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

understand knowledge."



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



From: "glen matejcek" <aerobubba(at)earthlink.net>

Subject: AeroElectric-List: RE: IFR GPS requirements

Hi Bill et al-



Re:  >Hello Bill, Avoid that poor soul -- he has not been around long

enough or

 	  Quote: 	
		  cared enough to learn that type certificated aircraft and amateur built

experimental aircraft are treated very differently in the FAA's paperwork

system.


	


While I greatly appreciate and highly regard and respect the source of that

comment, I couldn't disagree more.  If this inspector has run 50

unnecessary 337's through the system, he has cost a lot of people a lot of

money, spread misinformation across the system, and will no doubt cause

other improperly educated or motivated inspectors to take the

'conservative' (ignorant) route at our collective expense.  In other words,

there has been a gross misuse of governmental power.  These kinds of topics

have gone to DC and back via OSH, and we have the tools to correct the

problem you are facing.



My personal experience with an amateur built rule hose-up was to be very

(politely) clear with the person involved about the nature and basis for

our disconnect, and then call OSH with the details.  Within 24 hours they

had achieved understanding with the head of the directorate involved, and

within another 24 the fed involved had been re-educated.  That ended the

problem for me, and, presumably, everyone who came along after.



Also, the feds now have a program to handle customer service issues in

house.  As I understand it, it's the equivalent of 'let me speak to your

supervisor', although I don't recall the precise terminology.  Mike, can

you fill us in?



While I don't advocate getting into hostile conflicts with The Man, I

strongly urge you (and anyone else having bogus reg interpretation issues)

to fight the good fight with the resources we have developed and paid for

through our EAA dues and those gate fees at OSH we are all unhappy about.

Heck, Brian got a law in Jacksonville repealed with a little help from his

friends.  What's one confused inspector?



glen matejcek

aerobubba(at)earthlink.net

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