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lists(at)stevet.net
Guest

Posted: Sat Jan 16, 2010 10:04 am Post subject: Encoder Certification

A message to Stan Sutterfield:



You wrote last June:

 	  Quote: 	
		  This may not be the ideal forum for asking this question, but I'll try it  anyway.  I want to certify my RV-8 for IFR flight.  I know the FARs - I've  looked at  them.  I have the Blue Mountain EFIS One as primary instrumentation. I have the Blue Mountain EFIS Lite as a backup. Both EFISs are on different electrical busses - the main and the standby.  -  which can be tied together, if needed.  I asked a local avionics guy about doing a pitot-static and transponder  check for IFR.  He said I would have to install a separate altimeter and  encoder in order to get IFR certification.  The EFIS has a built-in  encod er.  Has anyone else encountered this obstacle?  Stan Sutterfield 	


There were several replies that mostly focused on finding the right avionics guy.  I have the exact same setup in my panel as do you and am ready for certification.  Can you share your experience?  Are you certified and flying?  Who did you use for your certification and how did you go about getting it?

I am in Southern California, and anyone else who can offer any advice on this topic will be welcome.  My local shop mostly deals with biz jets and large non-jets.  I don't think they will be very helpful with an experimental.  Also, exorbitantly expensive.  Do I need a transponder cert for my DAR inspection?  Can I fly somewhere else to get it done once I have flown off my hours?

 



Steve Thomas

________________________________________________________________________



 

  



 [quote][b]

flyboybob1(at)gmail.com
Guest

Posted: Sat Jan 16, 2010 11:14 am Post subject: Encoder Certification

Steve,  

  

 You  wrote:  << My local shop  ...   I don't think they will be very helpful with an  experimental.  Also, exorbitantly expensive.   >> 

  

 Never  let what you think prevent you from asking.  If you don't ask your local  shop it's a 0% chance they will calibrate your system at a reasonable  price.  If you do ask them all they can say is yes or no so you've got  a 50% chance they will help you at a reasonable price.  Your odds of  success are 50 times better if you ask! 

  

 Regards,

Bob  Lee

N52BL  KR2

Suwanee, GA  USA

92% done only 67% to go!  

   [quote][b]

bgray(at)glasair.org
Guest

Posted: Sat Jan 16, 2010 12:27 pm Post subject: Encoder Certification

I would advise you to check with the EAA. This subject has been aired before. I essence, by passing the certification criteria (ramp test), it meets the FAA’s standards. No TSO or separate encoder/altimeter is required. The EAA has chapter and verse. I would also suggest you find another shop who work on experimentals. Those heavy iron types are rather inflexible to new ideas.  

     

Bruce

 www.Glasair.org   

  

--

bakerocb

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

Posted: Sun Jan 17, 2010 6:12 am Post subject: Encoder Certification

1/17/2009



Hello Steve Thomas, You wrote:



1) "Can I fly somewhere else to get it done once I have flown off my hours?"



Here is what 14 CFR says:



"91.215   ATC transponder and altitude reporting equipment and use.



(d) ATC authorized deviations. Requests for ATC authorized deviations must 

be made to the ATC facility having jurisdiction over the concerned airspace 

within the time periods specified as follows:



(2) For operation of an aircraft with an inoperative transponder to the 

airport of ultimate destination, including any intermediate stops, or to 

proceed to a place where suitable repairs can be made or both, the request 

may be made at any time."



So you see that it is possible to fly your airplane without an operating 

transponder where one is required if you obtain ATC permission to do so. Why 

not do some research to:



A) Determine how amenable your local ATC coverage people are to letting you 

make a one time flight without a transponder IAW 91.215 (d) (2) above.



B) Find a facility that will do your transponder cert and design your flight 

test area to include that facility. Then make your request to ATC and on a 

flight subsequent to your first flight fly to that location to have the 

certification done. (I recommend that the first test flight be just a 20-30 

minute orbit over the originating field.)



It would not be reasonable to expect permission to perform the entire Phase 

one testing without a transponder unless you were able to do the testing in 

airspace that did not require a transponder.



2) "Do I need a transponder cert for my DAR inspection?"



The regulations do not require this -- see 91.215 (d) (2). But a DAR, or FAA 

inspector, has wide discretion and the power of the FAA Administrator in 

that original airworthiness inspection and he may choose to require one.



If you have not already established some contact and level of rapport with 

your prospective inspector you should start now -- and ask him that 

question. An FAA inspector would be my first choice. How are you doing with 

the program letter and all of the other paperwork required?



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

understand knowledge."



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



Time: 10:04:13 AM PST US

From: Steve Thomas <lists(at)stevet.net>

Subject: AeroElectric-List: Encoder Certification



A message to Stan Sutterfield:



You wrote last June:



 	  Quote: 	
		   This may not be the ideal forum for asking this question, but I'll try

it
	


 	  Quote: 	
		   anyway.



 I want to certify my RV-8 for IFR flight.  I know the FARs - I've

looked at
	


 	  Quote: 	
		   them.



 I have the Blue Mountain EFIS One as primary instrumentation.

 I have the Blue Mountain EFIS Lite as a backup.

 Both EFISs are on different electrical busses - the main and the

standby.
	


 	  Quote: 	
		    -

  which can be tied together, if needed.



 I asked a local avionics guy about doing a pitot-static and

transponder
	


 	  Quote: 	
		  

 check for IFR.  He said I would have to install a separate altimeter

and
	


 	  Quote: 	
		  

 encoder in order to get IFR certification.  The EFIS has a built-in

encod
	


 	  Quote: 	
		   er.



 Has anyone else encountered this obstacle?



 Stan Sutterfield


	


There were several replies that mostly focused on finding the right

avionics guy.  I have the exact same setup in my panel as do you and am

ready for certification.  Can you share your experience?  Are you

certified and flying?  Who did you use for your certification and how

did you go about getting it?



I am in Southern California, and anyone else who can offer any advice on

this topic will be welcome.  My local shop mostly deals with biz jets

and large non-jets.  I don't think they will be very helpful with an

experimental.  Also, exorbitantly expensive.  Do I need a transponder

cert for my DAR inspection?  Can I fly somewhere else to get it done

once I have flown off my hours?

Steve Thomas

bobsv35b(at)aol.com
Guest

Posted: Sun Jan 17, 2010 6:50 am Post subject: Encoder Certification

Good Morning O.C. and Steve Thomas,

  

 You (O.C.) have given your usual very accurate listing of current rules and  you did use language saying that there is airspace where the transponder is not  required. However, I get the feeling that Steve may not realize that the use of  a transponder is NOT required in the vast majority of airspace within the United  States of America. I want to emphasize that point

  

 I also recognize that he does wish to fly IFR and doing so does increase  the likelihood of his wanting to have a certified operational transponder.

  

 As long as he is operating in a space where no transponder is required,  there should be no rush to get it checked.

  

 The DAR has no need to evaluate the suitability of the aircraft for IFR  flight. He should just use the canned language that the aircraft is to be  flown day VFR only unless it is equipped  --  etc.  It is up to  the operator to make the IFR and night suitability determination.

  

 Please DO NOT ask the DAR to list it any way other than as  recommended. It will just muddy up the water.

  

 Have I once again placed my foot in my mouth?

  

 Happy Skies,

  

 Old Bob

 AKA

 Bob Siegfried

 Downers Grove, IL

 Stearman N3977A

  

  In a message dated 1/17/2010 8:14:44 A.M. Central Standard Time,  bakerocb(at)cox.net writes:

  	  Quote: 	
		  -->    AeroElectric-List message posted by:    <bakerocb(at)cox.net>



1/17/2009



Hello Steve Thomas, You    wrote:



1) "Can I fly somewhere else to get it done once I have flown    off my hours?"



Here is what 14 CFR says:



"91.215   ATC    transponder and altitude reporting equipment and use.



(d) ATC    authorized deviations. Requests for ATC authorized deviations must 

be made    to the ATC facility having jurisdiction over the concerned airspace 

within    the time periods specified as follows:



(2) For operation of an aircraft    with an inoperative transponder to the 

airport of ultimate destination,    including any intermediate stops, or to 

proceed to a place where suitable    repairs can be made or both, the request 

may be made at any    time."



So you see that it is possible to fly your airplane without an    operating 

transponder where one is required if you obtain ATC permission    to do so. Why 

not do some research to:



A) Determine how amenable    your local ATC coverage people are to letting you 

make a one time flight    without a transponder IAW 91.215 (d) (2) above.



B) Find a facility that    will do your transponder cert and design your flight 

test area to include    that facility. Then make your request to ATC and on a 

flight subsequent to    your first flight fly to that location to have the 

certification done. (I    recommend that the first test flight be just a 20-30 

minute orbit over the    originating field.)



It would not be reasonable to expect permission to    perform the entire Phase 

one testing without a transponder unless you were    able to do the testing in 

airspace that did not require a    transponder.



2) "Do I need a transponder cert for my DAR    inspection?"



The regulations do not require this -- see 91.215 (d) (2).    But a DAR, or FAA 

inspector, has wide discretion and the power of the FAA    Administrator in 

that original airworthiness inspection and he may choose    to require one.



If you have not already established some contact and    level of rapport with 

your prospective inspector you should start now --    and ask him that 

question. An FAA inspector would be my first choice. How    are you doing with 

the program letter and all of the other paperwork    required?



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

understand  knowledge."



	


  [quote][b]

Sam

Joined: 18 May 2008
Posts: 135

Posted: Sun Jan 17, 2010 7:15 am Post subject: Encoder Certification

Without looking at the regs, I seem to recall that if the aircraft is equipped with an operating transponder, it must be turned on.  My simple minded solution would to pull the transponder and stuff it into a flight bag.  You could even apply a sticker that says "INOP". 

 

Fly to the shop, then install it for the test.

 	  Quote: 	
		  	
Sam



On Sun, Jan 17, 2010 at 8:49 AM,  <bobsv35b(at)aol.com (bobsv35b(at)aol.com)> wrote:

 [quote]     Good Morning O.C. and Steve Thomas,

  

 You (O.C.) have given your usual very accurate listing of current rules and  you did use language saying that there is airspace where the transponder is not  required. However, I get the feeling that Steve may not realize that the use of  a transponder is NOT required in the vast majority of airspace within the United  States of America. I want to emphasize that point

  

 I also recognize that he does wish to fly IFR and doing so does increase  the likelihood of his wanting to have a certified operational transponder.

  

 As long as he is operating in a space where no transponder is required,  there should be no rush to get it checked.

  

 The DAR has no need to evaluate the suitability of the aircraft for IFR  flight. He should just use the canned language that the aircraft is to be  flown day VFR only unless it is equipped  --  etc.  It is up to  the operator to make the IFR and night suitability determination.

  

 Please DO NOT ask the DAR to list it any way other than as  recommended. It will just muddy up the water.

  

 Have I once again placed my foot in my mouth?

  

 Happy Skies,

  

 Old Bob

 AKA

 Bob Siegfried

 Downers Grove, IL

 Stearman N3977A



  

  In a message dated 1/17/2010 8:14:44 A.M. Central Standard Time,  bakerocb(at)cox.net (bakerocb(at)cox.net) writes:

  	  Quote: 	
		  -->    AeroElectric-List message posted by:    <bakerocb(at)cox.net (bakerocb(at)cox.net)>



1/17/2009



Hello Steve Thomas, You    wrote:



1) "Can I fly somewhere else to get it done once I have flown    off my hours?"



Here is what 14 CFR says:



"91.215   ATC    transponder and altitude reporting equipment and use.



(d) ATC    authorized deviations. Requests for ATC authorized deviations must 

be made    to the ATC facility having jurisdiction over the concerned airspace 

within    the time periods specified as follows:



(2) For operation of an aircraft    with an inoperative transponder to the 

airport of ultimate destination,    including any intermediate stops, or to 

proceed to a place where suitable    repairs can be made or both, the request 

may be made at any    time."



So you see that it is possible to fly your airplane without an    operating 

transponder where one is required if you obtain ATC permission    to do so. Why 

not do some research to:



A) Determine how amenable    your local ATC coverage people are to letting you 

make a one time flight    without a transponder IAW 91.215 (d) (2) above.



B) Find a facility that    will do your transponder cert and design your flight 

test area to include    that facility. Then make your request to ATC and on a 

flight subsequent to    your first flight fly to that location to have the 

certification done. (I    recommend that the first test flight be just a 20-30 

minute orbit over the    originating field.)



It would not be reasonable to expect permission to    perform the entire Phase 

one testing without a transponder unless you were    able to do the testing in 

airspace that did not require a    transponder.



2) "Do I need a transponder cert for my DAR    inspection?"



The regulations do not require this -- see 91.215 (d) (2).    But a DAR, or FAA 

inspector, has wide discretion and the power of the FAA    Administrator in 

that original airworthiness inspection and he may choose    to require one.



If you have not already established some contact and    level of rapport with 

your prospective inspector you should start now --    and ask him that 

question. An FAA inspector would be my first choice. How    are you doing with 

the program letter and all of the other paperwork    required?



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

understand  knowledge."



	


   	  Quote: 	
		  



ist" target="_blank">http://www.matronics.com/Navigator?AeroElectric-List

tp://forums.matronics.com

_blank">http://www.matronics.com/contribution



	


[b]

_________________
Sam Hoskins
www.samhoskins.blogspot.com

speedy11(at)aol.com
Guest

Posted: Sun Jan 17, 2010 8:42 am Post subject: Encoder Certification

All of this is correct, but why does ATC need to be involved?  Unless  you will be flying under airspace that requires a transponder, then there is no  need to contact ATC unless you want them to check your transponder code and mode  C.  If you are transiting under class B, then coordinate with approach  control by phone for instructions.

 My DAR did not ask for proof of pitot-static or transponder certification -  although I had them available.

 Stan Sutterfield

 Do not archive

  	  Quote: 	
		  1/17/2009



Hello Steve Thomas, You wrote:



1) "Can I    fly somewhere else to get it done once I have flown off my hours?"



Here    is what 14 CFR says:



"91.215   ATC transponder and altitude    reporting equipment and use.



(d) ATC authorized deviations. Requests    for ATC authorized deviations must 

be made to the ATC facility having    jurisdiction over the concerned airspace 

within the time periods specified    as follows:



(2) For operation of an aircraft with an inoperative    transponder to the 

airport of ultimate destination, including any    intermediate stops, or to 

proceed to a place where suitable repairs can be    made or both, the request 

may be made at any time."



So you see that    it is possible to fly your airplane without an operating 

transponder where    one is required if you obtain ATC permission to do so. Why 

not do some    research to:



A) Determine how amenable your local ATC coverage people    are to letting you 

make a one time flight without a transponder IAW 91.215    (d) (2) above.



B) Find a facility that will do your transponder cert    and design your flight 

test area to include that facility. Then make your    request to ATC and on a 

flight subsequent to your first flight fly to that    location to have the 

certification done. (I recommend that the first test    flight be just a 20-30 

minute orbit over the originating field.)



It    would not be reasonable to expect permission to perform the entire Phase    

one testing without a transponder unless you were able to do the testing    in 

airspace that did not require a transponder.



2) "Do I need a    transponder cert for my DAR inspection?"



The regulations do not require    this -- see 91.215 (d) (2). But a DAR, or FAA 

inspector, has wide    discretion and the power of the FAA Administrator in 

that original    airworthiness inspection and he may choose to require one.



If you have    not already established some contact and level of rapport with 

your    prospective inspector you should start now -- and ask him that 

question.    An FAA inspector would be my first choice. How are you doing with 

the    program letter and all of the other paperwork required?



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

understand    knowledge."



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



Time:    10:04:13 AM PST US

From: Steve Thomas <lists(at)stevet.net>

Subject:    AeroElectric-List: Encoder Certification



A message to Stan    Sutterfield:



You wrote last June:



 	  Quote: 	
		   This may not be the ideal    forum for asking this question, but I'll try

it
	


 	  Quote: 	
		      anyway.



 I want to certify my RV-8 for IFR flight.  I know    the FARs - I've

looked at
	


 	  Quote: 	
		   them.



 I have the Blue    Mountain EFIS One as primary instrumentation.

 I have the Blue Mountain    EFIS Lite as a backup.

 Both EFISs are on different electrical busses -    the main and the

standby.
	


 	  Quote: 	
		    -

  which can be tied    together, if needed.



 I asked a local avionics guy about doing    a pitot-static and

transponder
	


 	  Quote: 	
		  

 check for IFR.  He said    I would have to install a separate altimeter

and
	


 	  Quote: 	
		  

 encoder in    order to get IFR certification.  The EFIS has a built-in

encod
	


 	  Quote: 	
		      er.



 Has anyone else encountered this obstacle?



    Stan Sutterfield


	


There were several replies that mostly focused on    finding the right

avionics guy.  I have the exact same setup in my    panel as do you and am

ready for certification.  Can you share your    experience?  Are you

certified and flying?  Who did you use for    your certification and how

did you go about getting it?



I am in    Southern California, and anyone else who can offer any advice on

this topic    will be welcome.  My local shop mostly deals with biz jets

and large    non-jets.  I don't think they will be very helpful with    an

experimental.  Also, exorbitantly expensive.  Do I need a    transponder

cert for my DAR inspection?  Can I fly somewhere else to    get it done

once I have flown off my hours?

Steve  Thomas 	


 

  

  [quote][b]

speedy11(at)aol.com
Guest

Posted: Sun Jan 17, 2010 8:54 am Post subject: Encoder Certification

Steve,

 I believe that your assessment of your local avionics shops is correct -  that is, they service jets and large piston aircraft - and thus, they are  unlikely to be interested in doing a low dollar certification for you.

 However, I have to agree with Bob and recommend that you at least ask  them.  I've talked to the shop floor guys in large aviation businesses and  found that often they are very interested in doing an experimental cert - if for  no other reason than to say they've done it.

 Ask them - you have nothing to lose.

 Stan Sutterfield

 Do not archive

  	  Quote: 	
		  You    wrote:  << My local shop  ...  I don't think they will be    very helpful

with an experimental.  Also, exorbitantly    expensive.   >>



Never let what you think prevent you    from asking.  If you don't ask your

local shop it's a 0% chance they    will calibrate your system at a reasonable

price.  If you do ask them    all they can say is yes or no so you've got a 50%

chance they will help you    at a reasonable price.  Your odds of success are

50 times better if    you ask!

	


 

  

  [quote][b]

lists(at)stevet.net
Guest

Posted: Sun Jan 17, 2010 9:36 am Post subject: Encoder Certification

A discussion is already underway.  What is most important to me is to know the facts.  You cannot argue with "experts" if you don't know the facts.  Being able to do my own pitot-static check will also get me a long way to being able to discuss with some authority.  Being able to calibrate my BMA EFIS ahead of time will be a giant step in the right direction.



Thanks to all of you for this invaluable help!  I will report back and detail my experience.

 



Steve Thomas

________________________________________________________________________



 

 

On Jan 17, 2010, at 8:52 AM, Speedy11(at)aol.com (Speedy11(at)aol.com) wrote:

[quote]Steve,

I believe that your assessment of your local avionics shops is correct - that is, they service jets and large piston aircraft - and thus, they are unlikely to be interested in doing a low dollar certification for you.

However, I have to agree with Bob and recommend that you at least ask them.  I've talked to the shop floor guys in large aviation businesses and found that often they are very interested in doing an experimental cert - if for no other reason than to say they've done it.

Ask them - you have nothing to lose.

Stan Sutterfield

Do not archive

[b]

dalamphere(at)comcast.net
Guest

Posted: Sun Jan 17, 2010 10:01 am Post subject: Encoder Certification

When I requested my airworthiness inspection from the  FAA inspector on my Wittman Tailwind , he insisted that I get my  pitot/static/transponder/encoder system checked by a certified shop to FAR  91.413, FAR43 App F - IFR standards -  FIRST before he would come out -  even tho the plane was not going to be used in IFR conditions. I found a guy  that was setup to do this at my hangar (Don Hendrix) and did a fine job. We  found some leaks in the static system partway through the tests that I corrected  before the test could be completed. He made some adjustments in the process of  the tests also.

  

 The FAA inspector felt that it was the safe thing to do  on a newly built plane and would eliminate one cause for first flight problems  later.

  

 I agree,  - - - now.. 

  

 Dave

 [quote]   ---

ianxbrown

Joined: 16 May 2009
Posts: 80

Posted: Sun Jan 17, 2010 10:43 am Post subject: Encoder Certification

I'd also agree.  Having both the pitot and the static system tested by a mechanic with the right equipment is very important.  After my own experience, I'd say VITAL to safe first flight testing.  Having done what I thought was a very good job of building my aircraft we discovered five separate tiny leaks in the system.  Finding them would have been a lot more complicated without the expert help.  Ian Brown, RV-9A

 

 clip When I requested my airworthiness inspection from the FAA inspector on my Wittman Tailwind , he insisted that I get my pitot/static/transponder/encoder system checked by a certified shop to FAR 91.413, FAR43 App F - IFR standards -  FIRST before he would come out - even tho the plane was not going to be used in IFR conditions. I found a guy that was setup to do this at my hangar (Don Hendrix) and did a fine job. We found some leaks in the static system partway through the tests that I corrected before the test could be completed. He made some adjustments in the process of the tests also.

bakerocb

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

Posted: Sun Jan 17, 2010 1:02 pm Post subject: Encoder Certification

1/17/2010



Hello Stan Sutterfield, You wrote:



1) "All of this is correct, but why does ATC need to be involved?"



Valid question. ATC does not need to be involved in approving non 

transponder flight operations if one is not flying in airspace where the 

aircraft must be transponder equipped.



Note my wording copied from below  "......where one is required....".



See 14 CFR 91.215 (b) (1) through (5) for a description of the airspace 

where the aircraft must be transponder equipped. We are assuming an aircraft 

that has been originally certificated with an engine-driven electrical 

system.



2) "Unless  you will be flying under airspace that requires a transponder, 

then there is no

need to contact ATC ..........skip....."



I agree, providing the word "under" is changed to the word "in" as "in" is a 

more inclusive word and also the wording used in 14 CFR 91.215.



3) "...........  coordinate with approach  control by phone for 

instructions."



Approach Control is part of the ATC (Air Traffic Control) system. When you 

talk to approach control you are talking to ATC.



4) "My DAR did not ask for proof of pitot-static or transponder 

certification ..........."



Good, I think that is the way that it should be done. However, as I 

mentioned earlier the inspector during the initial airworthiness inspection 

is endowed with the power of the Administrator and some inspectors swing a 

too heavy hammer. If one disagrees with the inspector one is left with 

either swallowing that disagreement or going over the inspector's head 

within the FAA.



One should proceed with caution in going over the inspector's head on a 

specific item because the inspector may find other areas to show that he is 

really the boss. I recall a particularly stubborn DAR that required 

direction from FAA Headquarters, at my request, through the supervising FSDO 

before he would yield on an inspection issue. He got so mad when he was over 

ruled that he refused to acknowledge to me that he had been wrong.



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

understand knowledge."



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

---

speedy11(at)aol.com
Guest

Posted: Mon Jan 18, 2010 10:08 am Post subject: Encoder Certification

Steve,

 You may already know about this, but EAA Chapter 1000 has a lot of test  pilot guys (Edwards AFB) and their web site has instructions on doing your own  pitot-static calibration.  You can see it at http://www.eaa1000.av.org/technicl/techidx.htm.

 Stan Sutterfield

  

  	  Quote: 	
		  A    discussion is already underway.  What is most important to me is to    

know the facts.  You cannot argue with "experts" if you don't know    the 

facts.  Being able to do my own pitot-static check will also get    me a 

long way to being able to discuss with some authority.  Being    able to 

calibrate my BMA EFIS ahead of time will be a giant step in the    right 

direction.



Thanks to all of you for this invaluable    help!  I will report back and 

detail my  experience. 	


 

  

  [quote][b]

bakerocb

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

Posted: Mon Jan 18, 2010 10:24 am Post subject: Encoder Certification

1/18/2010



Hello Sam Hoskins, You wrote:



1) "Without looking at the regs, I seem to recall that if the aircraft is 

equipped with an operating transponder, it must be turned on."



That is correct. Here is what 14 CFR 91.215 (c) says:



"(c) Transponder-on operation. While in the airspace as specified in 

paragraph (b) of this section or in all controlled airspace, each person 

operating an aircraft equipped with an operable ATC transponder maintained 

in accordance with §91.413 of this part shall operate the transponder, 

including Mode C equipment if installed, and shall reply on the appropriate 

code or as assigned by ATC."



2) "My simple minded solution would to pull the transponder and stuff it 

into a flight

bag.  You could even apply a sticker that says "INOP". Fly to the shop, then 

install it for the test."



That would be a violation of 14 CFR 91.215 which says, in part:



"(b) All airspace. Unless otherwise authorized or directed by ATC, no person 

may operate an aircraft in the airspace described in paragraphs (b)(1) 

through (b)(5) of this section, unless that aircraft is equipped with an 

operable coded radar beacon transponder having either Mode 3/A 4096 code 

capability,.............."



91.215 goes on to provide some exceptions to the above requirement such as 

aircraft originally certified with no electrical system and getting 

permission from ATC to operate with no transponder. What you describe is not 

one of the exceptions.



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

understand knowledge."



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



Time: 07:16:01 AM PST US

Subject: Re: AeroElectric-List: Encoder Certification

From: Sam Hoskins <sam.hoskins(at)gmail.com>



Without looking at the regs, I seem to recall that if the aircraft is

equipped with an operating transponder, it must be turned on.  My simple

minded solution would to pull the transponder and stuff it into a flight

bag.  You could even apply a sticker that says "INOP".



Fly to the shop, then install it for the test.



Sam

jon(at)finleyweb.net
Guest

Posted: Mon Jan 18, 2010 7:10 pm Post subject: Encoder Certification

Bakerocb,  

   

Everything noted so far in this thread assumes controlled airspace.  If I missed where that was stated in this thread then ignore my comments.  No doubt that what has been said is applicable given the right environment (controlled airspace).  

   

If you read the full text of 14 CFR 91.215 (b), you will find that folks living in a place like me (middle of nowhere in New Mexico) can fly for hours and hours in most any direction and NOT come upon ANY of the airspace listed in (b)(1) through (b)(5).  Additionally, 91.215 (c), does not apply as almost all of our airspace is uncontrolled.  

   

So, given MY environment, I can fly without a transponder and/or without it turned on.  There are huge expanses of this country where this is true.  

   

If someone can prove the above wrong, I would be interested in hearing.  

   

Jon  

   

[quote] --

bobsv35b(at)aol.com
Guest

Posted: Mon Jan 18, 2010 7:51 pm Post subject: Encoder Certification

Good Evening Jon,

  

 I tried to make the same point a couple of days ago and my comment seems to  have been totally ignored by all. Maybe you will have better luck!

  

 Happy Skies,

  

 Old Bob

  

  In a message dated 1/18/2010 9:12:51 P.M. Central Standard Time,  jon(at)finleyweb.net writes:

 [quote]      

Bakerocb,   

    

Everything noted    so far in this thread assumes controlled airspace.  If I missed where    that was stated in this thread then ignore my comments.  No doubt that    what has been said is applicable given the right environment (controlled    airspace).   

    

If you read the    full text of 14 CFR 91.215 (b), you will find that folks living in a place    like me (middle of nowhere in New Mexico) can fly for hours and hours in most    any direction and NOT come upon ANY of the airspace listed in (b)(1) through    (b)(5).  Additionally, 91.215 (c), does not apply as almost all of our    airspace is uncontrolled.   

    

So, given MY    environment, I can fly without a transponder and/or without it turned    on.  There are huge expanses of this country where this is    true.   

    

If someone can    prove the above wrong, I would be interested in hearing.   

    

Jon   

    

[quote] --

bakerocb

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

Posted: Mon Jan 18, 2010 9:15 pm Post subject: Encoder Certification

1/18/2010



Hello Steve Thomas, You wrote:



1) "Being able to do my own pitot-static check will also get me a long way 

to being able to discuss with some authority."



A) There is no regulatory requirement for a pitot system check, but you may 

gain some confidence in the accuracy of your airspeed indicator by 

performing one.



B) The static pressure system check performed in order to meet the 

requirements of 14 CFR 91.411 quoted here:



"Altimeter system and altitude reporting equipment tests and inspections.



(a) No person may operate an airplane, or helicopter, in controlled airspace 

under IFR unless-



(1) Within the preceding 24 calendar months, each static pressure system, 

each altimeter instrument, and each automatic pressure altitude reporting 

system has been tested and inspected and found to comply with appendices E 

and F of part 43 of this chapter;"



Must be performed in accordance with the portion of 14 CFR 91.411 quoted 

here:



"(b) The tests required by paragraph (a) of this section must be conducted 

by-



(1) The manufacturer of the airplane, or helicopter, on which the tests and 

inspections are to be performed;



(2) A certificated repair station properly equipped to perform those 

functions and holding-



(i) An instrument rating, Class I;



(ii) A limited instrument rating appropriate to the make and model of 

appliance to be tested;



(iii) A limited rating appropriate to the test to be performed;



(iv) An airframe rating appropriate to the airplane, or helicopter, to be 

tested; or



(3) A certificated mechanic with an airframe rating (static pressure system 

tests and inspections only)."



So only if you hold one of the qualifications listed above, would you be 

able to perform the regulatory requirement of the static pressure system 

tests. But otherwise, as you point out, performing the test yourself could 

help you in your discussions. The equipment and  parameters to perform the 

test are described in 14 CFR Appendix E to Part 43 (a).



2) "Being able to calibrate my BMA EFIS ahead of time will be a giant step 

in the right

direction."



Good idea.



3) "I will report back and detail my experience."



I would appreciate that -- thank you.



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

understand knowledge."



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



Time: 09:36:20 AM PST US

From: Steve Thomas <lists(at)stevet.net>

Subject: Re: AeroElectric-List: Re: Encoder Certification



A discussion is already underway.  What is most important to me is to

know the facts.  You cannot argue with "experts" if you don't know the

facts.  Being able to do my own pitot-static check will also get me a

long way to being able to discuss with some authority.  Being able to

calibrate my BMA EFIS ahead of time will be a giant step in the right

direction.



Thanks to all of you for this invaluable help!  I will report back and

detail my experience.

Steve Thomas

bakerocb

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

Posted: Tue Jan 19, 2010 6:19 am Post subject: Encoder Certification

1/19/2010



Hello Jon Finley, Many thanks for your input and raising this point again. 

You wrote:



1) "Everything noted so far in this thread assumes controlled airspace."



I did not make this assumption.



2) "If I missed where that was stated in this thread then ignore my 

comments."



Here is my wording: "It would not be reasonable to expect permission to 

perform the entire Phase

one testing without a transponder unless you were able to do the testing in 

airspace that did not require a transponder."



This specifically raises the point that there is indeed airspace that does 

not require a transponder. I also point out that 14 CFR 91.215 (b) (1) 

through (b) (5) and 91.215 (c) identifies the airspace where you must have a 

transponder. If one is not flying in the airspace identified then there is 

no requirement for a transponder.



3) "If you read the full text of 14 CFR 91.215 (b),........"



Absolutely on point.



Up on my soap box now:  I have been working on people sized airplanes (as 

opposed to models) since 1950 and flying since 1958 -- all that time I was 

planning and gathering information with the intent of building my own 

airplane some day. When that day came and I started to build and the 

internet allowed me to see what other builders were thinking and writing I 

was appalled at the ignorance and assumptions regarding applicable 

regulations displayed by my fellow builders.



Here we had the greatest opportunity on our planet to do this wonderful 

homebuilding and flying thing and there were many builders so willing to 

operate on hearsay, gossip, and rumor and possibly violate regulations 

rather than educate themselves. Each notorious violation bringing us closer 

to the day when we could lose the opportunity to homebuild and fly.



So my mission in life became to educate my fellow homebuilders and pilots 

regarding what the regulations actually say with the hope and belief that 

education would encourage compliance. That is why many of my postings read 

the way they do.



4) "Additionally, 91.215 (c), does not apply as almost all of our airspace 

is uncontrolled."



Let's see what 14 CFR definitions says:

"Controlled airspace means an airspace of defined dimensions within which 

air traffic control service is provided to IFR flights and to VFR flights in 

accordance with the airspace classification.



Note: Controlled airspace is a generic term that covers Class A, Class B, 

Class C, Class D, and Class E airspace."



So as long as one is flying outside of the airspace identified in 91.215 (b) 

(1) through (5) and outside the definition of controlled airspace then one 

indeed does not need to have or operate a transponder.



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

understand knowledge."



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



Time: 07:10:22 PM PST US

From: "Jon Finley" <jon(at)finleyweb.net>

Subject: RE: AeroElectric-List: Encoder Certification



Bakerocb,

Everything noted so far in this thread assumes controlled airspace.  If I

missed where that was stated in this thread then ignore my comments.  No

doubt that what has been said is applicable given the right environment

(controlled airspace).



If you read the full text of 14 CFR 91.215 (b), you will find that folks

living in a place like me (middle of nowhere in New Mexico) can fly for

hours and hours in most any direction and NOT come upon ANY of the

airspace listed in (b)(1) through (b)(5).  Additionally, 91.215 (c), does 

not

apply as almost all of our airspace is uncontrolled.



So, given MY environment, I can fly without a transponder and/or without

it turned on.  There are huge expanses of this country where this is true.



If someone can prove the above wrong, I would be interested in hearing.

Jon

lists(at)stevet.net
Guest

Posted: Tue Jan 19, 2010 6:49 am Post subject: Encoder Certification

OC, 



As I read the regs. you quote below, it sounds like I am qualified to perform the tests.  



 	  Quote: 	
		   "(b) The tests required by paragraph (a) of this section must be conducted by-

 

 (1) The manufacturer of the airplane, or helicopter, on which the tests and inspections are to be performed;


	


I am the manufacturer of the airplane.  

Steve Thomas

________________________________________________________________________





On Jan 18, 2010, at 9:11 PM, <bakerocb(at)cox.net> <bakerocb(at)cox.net> wrote:



 	  Quote: 	
		   

 

 1/18/2010

 

 Hello Steve Thomas, You wrote:

 

 1) "Being able to do my own pitot-static check will also get me a long way to being able to discuss with some authority."

 

 A) There is no regulatory requirement for a pitot system check, but you may gain some confidence in the accuracy of your airspeed indicator by performing one.

 

 B) The static pressure system check performed in order to meet the requirements of 14 CFR 91.411 quoted here:

 

 "Altimeter system and altitude reporting equipment tests and inspections.

 

 (a) No person may operate an airplane, or helicopter, in controlled airspace under IFR unless-

 

 (1) Within the preceding 24 calendar months, each static pressure system, each altimeter instrument, and each automatic pressure altitude reporting system has been tested and inspected and found to comply with appendices E and F of part 43 of this chapter;"

 

 Must be performed in accordance with the portion of 14 CFR 91.411 quoted here:

 

 "(b) The tests required by paragraph (a) of this section must be conducted by-

 

 (1) The manufacturer of the airplane, or helicopter, on which the tests and inspections are to be performed;

 

 (2) A certificated repair station properly equipped to perform those functions and holding-

 

 (i) An instrument rating, Class I;

 

 (ii) A limited instrument rating appropriate to the make and model of appliance to be tested;

 

 (iii) A limited rating appropriate to the test to be performed;

 

 (iv) An airframe rating appropriate to the airplane, or helicopter, to be tested; or

 

 (3) A certificated mechanic with an airframe rating (static pressure system tests and inspections only)."

 

 So only if you hold one of the qualifications listed above, would you be able to perform the regulatory requirement of the static pressure system tests. But otherwise, as you point out, performing the test yourself could help you in your discussions. The equipment and  parameters to perform the test are described in 14 CFR Appendix E to Part 43 (a).

 

 2) "Being able to calibrate my BMA EFIS ahead of time will be a giant step in the right

 direction."

 

 Good idea.

 

 3) "I will report back and detail my experience."

 

 I would appreciate that -- thank you.

 

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

 

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

 

 Time: 09:36:20 AM PST US

 From: Steve Thomas <lists(at)stevet.net>

 Subject: Re: Re: Encoder Certification

 

 A discussion is already underway.  What is most important to me is to

 know the facts.  You cannot argue with "experts" if you don't know the

 facts.  Being able to do my own pitot-static check will also get me a

 long way to being able to discuss with some authority.  Being able to

 calibrate my BMA EFIS ahead of time will be a giant step in the right

 direction.

 

 Thanks to all of you for this invaluable help!  I will report back and

 detail my experience.

 

 

 Steve Thomas

nuckolls.bob(at)aeroelect
Guest

Posted: Tue Jan 19, 2010 7:45 am Post subject: Encoder Certification

At 08:47 AM 1/19/2010, you wrote:

 	  Quote: 	

OC,

As I read the regs. you quote below, it sounds like I am qualified 

to perform the tests.

 > "(b) The tests required by paragraph (a) of this section must be 

 conducted by-

 >

 > (1) The manufacturer of the airplane, or helicopter, on which the 

 tests and inspections are to be performed;

I am the manufacturer of the airplane.

   Only one small caveat . . . manufacturers of

   type certificated airplanes are expected/commanded

   to jump lots of hoops not the least of which is

   calibration traceability, proper equipment,

   and training of persons tasked with operating

   the equipment.

   If one understands the physics, spirit and intent

   of a pitot-static system check, it can be accomplished

   with the most rudimentary of pressure measuring devices

   (including a water manometer you might build up from

   hardware store materials), a pump (can and often is

   hand operated) and a calculator or set of charts that

   converts observed pressures to observed panel readings.

   Of course, the FIRST (and most common) dragon to

   slay is leaks. This requires no calibration, only

   the ability to apply a pressure, stop it off,

   watch for changes, and then soap the joints looking

   for bubbles . . . and finally, to see that panel

   indications do not drift with time faster than

   what's allowed. In other words, SOME degree of

   leaking is permitted in some venues.

   After the system is tight, then you need to

   worry with the numbers. Not at all difficult

   if you're interested in educating and equipping

   yourself to the task . . . but convincing the

   odd institutionally educated bureaucrat that

   you KNOW what your doing is . . . well . . .

   problematic.

   It would be interesting to hear of your experience

   in this endeavor. One thing that WOULD help is

   to document the test procedure you use. If

   pressures are read with a device subject

   to calibration, then having a quality assurance

   or cert document (not more than a year old) for that

   device would be helpful. Or calibrate it yourself

   using a water manometer. Fortunately, its

   EASY to get a measuring tape with some assurance

   of accuracy.

   While we may all rightfully claim to be "the

   manufacturer" of our projects, there may be a

   price of membership for taking on that title.

   Bob . . .

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