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IFR GPS requirements/TSO-88C
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flagstone(at)cox.net
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PostPosted: Thu Jan 24, 2008 6:31 pm    Post subject: IFR GPS requirements/TSO-88C Reply with quote

Hi:

For those of you with non-certified EFIS systems that you also use to encode
your transponder, what do you have to do to comply with FAR 91.217(c) in
meeting the requirements of TSO-88C.

Thanks

Mark


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Bruce(at)glasair.org
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PostPosted: Thu Jan 24, 2008 8:21 pm    Post subject: IFR GPS requirements/TSO-88C Reply with quote

In essence, passing the bi-annual check, satisfies the regulation.

Bruce
www.Glasair.org


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sam(at)fr8dog.net
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PostPosted: Fri Jan 25, 2008 5:55 am    Post subject: IFR GPS requirements/TSO-88C Reply with quote

My FAA office required a certified encoder, I think it was about a $200.00 box. Yours may not be so stupid, because the EFIS encoder is a superior unit.
Sam

FLAGSTONE wrote: [quote]
Quote:
--> AeroElectric-List message posted by: "FLAGSTONE" <flagstone(at)cox.net> (flagstone(at)cox.net)

Hi:

For those of you with non-certified EFIS systems that you also use to encode
your transponder, what do you have to do to comply with FAR 91.217(c) in
meeting the requirements of TSO-88C.

Thanks

Mark








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BobsV35B(at)aol.com
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PostPosted: Fri Jan 25, 2008 6:10 am    Post subject: IFR GPS requirements/TSO-88C Reply with quote

Good Morning Sam,

Maybe I have missed something, but how did the FSDO get involved?

As near as I can tell, there is no need to ask them anything.

If you elect to fly your experimental airplane IFR, all that is required is that it meet the specified functional requirements. There is no requirement that any piece of equipment be TSO'd. The only requirement is that it perform properly.

What am I missing here?

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 1/25/2008 7:58:18 A.M. Central Standard Time, sam(at)fr8dog.net writes:
Quote:
My FAA office required a certified encoder, I think it was about a $200.00 box. Yours may not be so stupid, because the EFIS encoder is a superior unit.
Sam




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sam(at)fr8dog.net
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PostPosted: Fri Jan 25, 2008 8:36 am    Post subject: IFR GPS requirements/TSO-88C Reply with quote

The avionics shop that does the static check, wouldn't certify the test without an approved encoder. The avionics inspector from the FSDO was there when I made my inquiry as to what is required. He said I had to have a three things before a shop in his district would approve an installation. TSO altimeter, TSO encoder, and a TSO transponder.

BobsV35B(at)aol.com (BobsV35B(at)aol.com) wrote: [quote] Good Morning Sam,

Maybe I have missed something, but how did the FSDO get involved?

As near as I can tell, there is no need to ask them anything.

If you elect to fly your experimental airplane IFR, all that is required is that it meet the specified functional requirements. There is no requirement that any piece of equipment be TSO'd. The only requirement is that it perform properly.

What am I missing here?

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 1/25/2008 7:58:18 A.M. Central Standard Time, sam(at)fr8dog.net (sam(at)fr8dog.net) writes:
Quote:
My FAA office required a certified encoder, I think it was about a $200.00 box. Yours may not be so stupid, because the EFIS encoder is a superior unit.
Sam






Who's never won? Biggest Grammy Award surprises of all time on AOL Music.
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deej(at)deej.net
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PostPosted: Fri Jan 25, 2008 8:54 am    Post subject: IFR GPS requirements/TSO-88C Reply with quote

Sam Marlow wrote:
Quote:
The avionics shop that does the static check, wouldn't certify the
test without an approved encoder. The avionics inspector from the FSDO
was there when I made my inquiry as to what is required. He said I had
to have a three things before a shop in his district would approve an
installation. TSO altimeter, TSO encoder, and a TSO transponder.


You should chat with the EAA and ask if they would be willing to
talk to this person. In an experimental aircraft, the avionics shops
are not required to approve any installation - you do this as the
builder of the aircraft. All they have to do is run the tests to see if
the equipment passes or not.

-Dj

--
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Glastar Sportsman 2+2 Builder #7118 N421DJ
http://deej.net/sportsman/

"Many things that are unexplainable happen during the construction of an
airplane." --Dave Prizio, 30 Aug 2005


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rampil



Joined: 04 May 2007
Posts: 870

PostPosted: Fri Jan 25, 2008 9:31 am    Post subject: Re: IFR GPS requirements/TSO-88C Reply with quote

While I don't think redundancy is necessarily a bad thing, a TSO
blind encoder is not strictly necessary. Maybe the presence of the
FSDO guy in the shop spooked the boys. When I had my gold box
BMA EFIS/1 it was approved for its biennial without a peep as the
encoder for my SL-70 transponder. Well, not quite. The shop guys
had never before seen a transponder squawk within 1 foot of all 10
target altitudes from zero to 16000! This was after it had warmed up
for an hour or so.

Having said that, when I upgraded to the BMA Gen4, the panel lost
so much weight, that when I saw a good price on a TransCal encoder,
I bought it.


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sam(at)fr8dog.net
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PostPosted: Fri Jan 25, 2008 10:36 am    Post subject: IFR GPS requirements/TSO-88C Reply with quote

I understand I really only have to meet the specifications of the TSO, but the avionics shop won't do it unless it satisfies the local Feds. Which means if they did certify the static and transponder, and I wasn't TSO equipment, then they could lose there certificate.
I can't certify the static and txp checks as a builder, so I'm bound by my local FSDO bureaucracy!
Sam

Dj Merrill wrote: [quote]--> AeroElectric-List message posted by: Dj Merrill <deej(at)deej.net> (deej(at)deej.net)

Sam Marlow wrote:
Quote:
The avionics shop that does the static check, wouldn't certify the test without an approved encoder. The avionics inspector from the FSDO was there when I made my inquiry as to what is required. He said I had to have a three things before a shop in his district would approve an installation. TSO altimeter, TSO encoder, and a TSO transponder.


You should chat with the EAA and ask if they would be willing to talk to this person. In an experimental aircraft, the avionics shops are not required to approve any installation - you do this as the builder of the aircraft. All they have to do is run the tests to see if the equipment passes or not.

-Dj

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echristley(at)nc.rr.com
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PostPosted: Fri Jan 25, 2008 11:07 am    Post subject: IFR GPS requirements/TSO-88C Reply with quote

Sam Marlow wrote:
Quote:
I understand I really only have to meet the specifications of the TSO,
but the avionics shop won't do it unless it satisfies the local Feds.
Which means if they did certify the static and transponder, and I
wasn't TSO equipment, then they could lose there certificate.
I can't certify the static and txp checks as a builder, so I'm bound
by my local FSDO bureaucracy!
Sam
As the builder, it is my understanding that you 'certify' EVERYTHING on

the project. You're not asking that the avionics shop certify the
setup. You're just asking them to test it and provide you with the raw
data. It is *YOU* that gets to decide if it meets the requirements.

Or have I completely misunderstood it all?


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deej(at)deej.net
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PostPosted: Fri Jan 25, 2008 11:13 am    Post subject: IFR GPS requirements/TSO-88C Reply with quote

Sam Marlow wrote:
Quote:
I understand I really only have to meet the specifications of the TSO,
but the avionics shop won't do it unless it satisfies the local Feds.
Which means if they did certify the static and transponder, and I
wasn't TSO equipment, then they could lose there certificate.
I can't certify the static and txp checks as a builder, so I'm bound
by my local FSDO bureaucracy!
Sam


Hi Sam,
All they can do is run the tests and tell you if the equipment
passes the test, or not. As I understand it, their responsibility ends
there.

There have been many discussions about this that can be found in
this list's archives if you want to read more about it. Bottom line is
that your avionics shop and your local FSDO are not properly following
the guidelines set forth and documented by the FAA.

Within the last few months a similar situation was discussed on this
list that was happening (in Florida I think), and the builder contacted
the EAA, who in turn contacted the FAA, who in turn contacted the FSDO
and set them straight. In the end the builder used his EFIS encoder to
drive the transponder and it passed the tests, so he was all set to go.

In my sometimes-not-so-humble opinion, you would be doing builders
in your area a great service if you were to place a phone call to the
EAA to report this, and hopefully they will also be able to correct your
local FSDO's incorrect interpretation of the FAA rules.

-Dj

--
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Glastar Sportsman 2+2 Builder #7118 N421DJ
http://deej.net/sportsman/

"Many things that are unexplainable happen during the construction of an
airplane." --Dave Prizio, 30 Aug 2005


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frank.hinde(at)hp.com
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PostPosted: Fri Jan 25, 2008 11:15 am    Post subject: IFR GPS requirements/TSO-88C Reply with quote

I would call up your local inspector at FSDO...Explain to him what the requirements are and ask him to send an email to the local shop.

FSDO is bound by federal aviation law, they can't go round making up their own rules...My guess is they are not clear on what the rules are so I would get on the EAA website and download the document about experimenatls and flying IFR...The EAA did an exposee on this very subject and got an "interpretation" of the law from the FAA itself.

So you need to get this document into the hands of the local FSDO inspector


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PostPosted: Fri Jan 25, 2008 11:27 am    Post subject: IFR GPS requirements/TSO-88C Reply with quote

You can have Radio Shack and WallyWorld stuff behind the panel. For IFR certification, the Avionics shop doesn't pass judgment on what they think of the equipment, but simply if it meets the accuracy requirements. If it meets the accuracy requirements at all the appropriate altitudes, then they give you approval and they can keep their opinions of what they think of the setup to themselves.

Chuck Jensen
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PostPosted: Fri Jan 25, 2008 12:26 pm    Post subject: IFR GPS requirements/TSO-88C Reply with quote

I can't do a static check or transponder ck, without thousands of dollars worth of equipment. So I have to depend on an avionics shop for this. It doesn't matter if I built it or Beech built it, it still has to be checked by an approved shop with approved equipment, every 24 months.

Ernest Christley wrote: [quote]--> AeroElectric-List message posted by: Ernest Christley <echristley(at)nc.rr.com> (echristley(at)nc.rr.com)

Sam Marlow wrote:
Quote:
I understand I really only have to meet the specifications of the TSO, but the avionics shop won't do it unless it satisfies the local Feds. Which means if they did certify the static and transponder, and I wasn't TSO equipment, then they could lose there certificate.
I can't certify the static and txp checks as a builder, so I'm bound by my local FSDO bureaucracy!
Sam
As the builder, it is my understanding that you 'certify' EVERYTHING on the project. You're not asking that the avionics shop certify the setup. You're just asking them to test it and provide you with the raw data. It is *YOU* that gets to decide if it meets the requirements.

Or have I completely misunderstood it all?

































































































































































































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PostPosted: Fri Jan 25, 2008 12:42 pm    Post subject: IFR GPS requirements/TSO-88C Reply with quote

Yes, but they won't do it period. I've tried to deal with the FAA on
several similar matters, I'm an IA, but it's just a loosing battle. They
have their little kingdom, cushy chairs, and GS pay schedules, and they
do make up their own rules, as they go.
I've given up............let someone else fight that battle, that's what
we pay dues to EAA for, right.

Chuck Jensen wrote:
[quote]

You can have Radio Shack and WallyWorld stuff behind the panel. For IFR certification, the Avionics shop doesn't pass judgment on what they think of the equipment, but simply if it meets the accuracy requirements. If it meets the accuracy requirements at all the appropriate altitudes, then they give you approval and they can keep their opinions of what they think of the setup to themselves.

Chuck Jensen
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BobsV35B(at)aol.com
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PostPosted: Fri Jan 25, 2008 12:48 pm    Post subject: IFR GPS requirements/TSO-88C Reply with quote

Good Afternoon Sam,

You are absolutely correct that it needs to be checked in accordance with the regulatory requirements and that you are unlikely to have the equipment and expertise to do the checks required. The local avionics shop is probably the best place to get the checks performed.

However, they don't have to approve it.

All they need to do is provide you with the data they found. You are the certifying entity and it is up to you to decide if it meets the regulatory requirements or not.

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 1/25/2008 2:29:03 P.M. Central Standard Time, sam(at)fr8dog.net writes:
Quote:
I can't do a static check or transponder ck, without thousands of dollars worth of equipment. So I have to depend on an avionics shop for this. It doesn't matter if I built it or Beech built it, it still has to be checked by an approved shop with approved equipment, every 24 months.

Ernest Christley wrote:



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[quote][b]


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deej(at)deej.net
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PostPosted: Fri Jan 25, 2008 12:52 pm    Post subject: IFR GPS requirements/TSO-88C Reply with quote

Sam Marlow wrote:
Quote:


Yes, but they won't do it period. I've tried to deal with the FAA on
several similar matters, I'm an IA, but it's just a loosing battle.
They have their little kingdom, cushy chairs, and GS pay schedules,
and they do make up their own rules, as they go.
I've given up............let someone else fight that battle, that's
what we pay dues to EAA for, right.

Unless the EAA knows there is a problem, they can't do much about
it. Any chance you'd be willing to give them a call to let them know
there is an issue with your local FSDO? Hopefully they can then take it
from there.

-Dj

--
Dj Merrill - N1JOV
Glastar Sportsman 2+2 Builder #7118 N421DJ
http://deej.net/sportsman/

"Many things that are unexplainable happen during the construction of an
airplane." --Dave Prizio, 30 Aug 2005


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PostPosted: Fri Jan 25, 2008 1:05 pm    Post subject: IFR GPS requirements/TSO-88C Reply with quote

Your correct Bob, but the shop is afraid of loosing it's certificate if they certify it meets requirement on non TSD'd equipment. They do, have to certify it meets min requirements, just look at the log book entry.


BobsV35B(at)aol.com (BobsV35B(at)aol.com) wrote: [quote] Good Afternoon Sam,

You are absolutely correct that it needs to be checked in accordance with the regulatory requirements and that you are unlikely to have the equipment and expertise to do the checks required. The local avionics shop is probably the best place to get the checks performed.

However, they don't have to approve it.

All they need to do is provide you with the data they found. You are the certifying entity and it is up to you to decide if it meets the regulatory requirements or not.

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 1/25/2008 2:29:03 P.M. Central Standard Time, sam(at)fr8dog.net (sam(at)fr8dog.net) writes:
Quote:
I can't do a static check or transponder ck, without thousands of dollars worth of equipment. So I have to depend on an avionics shop for this. It doesn't matter if I built it or Beech built it, it still has to be checked by an approved shop with approved equipment, every 24 months.

Ernest Christley wrote:





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PostPosted: Fri Jan 25, 2008 1:15 pm    Post subject: IFR GPS requirements/TSO-88C Reply with quote

Are you kidding, walk into a FSDO and challenge them. I'd never get another 337 approved. Not me, I'm done dealing on that level. If one of you guy's want to, that's well and good, I'll even drive you.
I just want to enjoy flying, and not argue and bicker with every new FAA guy that thinks he's God's gift to aviation.

Dj Merrill wrote: [quote]--> AeroElectric-List message posted by: Dj Merrill <deej(at)deej.net> (deej(at)deej.net)

Sam Marlow wrote:
Quote:
--> AeroElectric-List message posted by: Sam Marlow <sam(at)fr8dog.net> (sam(at)fr8dog.net)

Yes, but they won't do it period. I've tried to deal with the FAA on several similar matters, I'm an IA, but it's just a loosing battle. They have their little kingdom, cushy chairs, and GS pay schedules, and they do make up their own rules, as they go.
I've given up............let someone else fight that battle, that's what we pay dues to EAA for, right.

Unless the EAA knows there is a problem, they can't do much about it. Any chance you'd be willing to give them a call to let them know there is an issue with your local FSDO? Hopefully they can then take it from there.

-Dj

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PostPosted: Fri Jan 25, 2008 1:34 pm    Post subject: IFR GPS requirements/TSO-88C Reply with quote

Sam Marlow wrote:
Quote:
Are you kidding, walk into a FSDO and challenge them.


That is not at all what I said... Smile I simply suggested making a
phone call to the EAA and let them handle it, which leaves you out of
the direct confrontation.

If we as individuals do not stand up for ourselves, or at the very
least notify the organizations that represent us, then we give the power
to "every new FAA guy that thinks he's God's gift to aviation" to act in
whatever way they wish.

-Dj

--
Dj Merrill - N1JOV
Glastar Sportsman 2+2 Builder #7118 N421DJ
http://deej.net/sportsman/

"Many things that are unexplainable happen during the construction of an
airplane." --Dave Prizio, 30 Aug 2005


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Joined: 04 May 2007
Posts: 870

PostPosted: Fri Jan 25, 2008 1:45 pm    Post subject: Re: IFR GPS requirements/TSO-88C Reply with quote

Sam,

The simple problem is that you picked the wrong avionics shop.
Thats all. Or, as I said before, the guys were spooked by Mr FSDO
standing there as you said.

My airframe log note from my local shop simply says, that as per the
relevant regs, my system meets the accuracy required for flight in
the NAS.

The point of calling the EAA is simply so they can cite for you all the
needed CFRs and other publications to make it clear to the shop that
homebuilts follow a different protocol. I assure you that my local
shop is a major national shop which does 135 and warbird work as well
as part 91 and homebuilts. They know the score and what they are doing
is fully complying with all the regs.


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