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IFR GPS requirements

 
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bakerocb



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

PostPosted: Wed Jan 16, 2008 6:10 am    Post subject: IFR GPS requirements Reply with quote

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


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bakerocb



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

PostPosted: Thu Jan 17, 2008 11:04 am    Post subject: IFR GPS requirements Reply with quote

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


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grosseair(at)comcast.net
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PostPosted: Thu Jan 17, 2008 11:59 am    Post subject: IFR GPS requirements Reply with quote

I'd like a copy please.

John Grosse

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.


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sales(at)6440autoparts.co
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PostPosted: Thu Jan 17, 2008 12:18 pm    Post subject: IFR GPS requirements Reply with quote

OC, I did a quick Google and came up with
http://www.rainierultralightengines.com/forms/Minimum_Inst_Requirements.pdf

By Owen C. Baker, that,s the one, aint it ? Might save you a lot of time
sending out individually.

Randy
---


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flagstone(at)cox.net
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PostPosted: Thu Jan 17, 2008 12:20 pm    Post subject: IFR GPS requirements Reply with quote

Ditto

Mark
---


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gaillard.peck.ctr(at)nell
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PostPosted: Thu Jan 17, 2008 1:57 pm    Post subject: IFR GPS requirements Reply with quote

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

Me too!

Gaillard.peck.ctr(at)nellis.af.mil

Thanks,

Gail Peck
RV-8 (tail almost complete)

--


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wgill10(at)comcast.net
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PostPosted: Thu Jan 17, 2008 2:09 pm    Post subject: IFR GPS requirements Reply with quote

I'd like a copy please. Thanks.

Bill

--


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NYTerminat(at)aol.com
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PostPosted: Thu Jan 17, 2008 2:10 pm    Post subject: IFR GPS requirements Reply with quote

I would like one too please.

Bob Spudis

In a message dated 1/17/2008 3:02:06 P.M. Eastern Standard Time, grosseair(at)comcast.net writes:
Quote:
--> Avionics-List message posted by: John Grosse <grosseair(at)comcast.net>

I'd like a copy please.

John Grosse

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.




Start the year off right. Easy ways to stay in shape in the new year.
[quote][b]


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longg(at)pjm.com
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PostPosted: Thu Jan 17, 2008 2:42 pm    Post subject: IFR GPS requirements Reply with quote

Gail,
It's probably easier to post it, but yes, I'd like a copy.

Thanks

Do Not Archive

--


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jfrjr(at)roadrunner.com
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PostPosted: Thu Jan 17, 2008 5:08 pm    Post subject: IFR GPS requirements Reply with quote

Please send me a copy. Jay Rowe jfrjr(at)roadrunner.com
---


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bakerocb



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

PostPosted: Fri Jan 18, 2008 6:27 am    Post subject: IFR GPS requirements Reply with quote

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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