Matronics Email Lists :: View topic

Matronics Email Lists
Web Forum Interface to the Matronics Email Lists

Get Email Distribution Too! FAQ Search Memberlist Usergroups Register

Profile Log in to check your private messages Log in

ONGOING DISCUSSION

Matronics Email Lists Forum Index -> Avionics-List

View previous topic :: View next topic

Author Message

bakerocb

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

Posted: Wed Jan 20, 2010 11:47 am Post subject: ONGOING DISCUSSION

1/19/2010



Hello Jim, Good to hear from you.



You ask: "Does the following item (a) possibly relieve one from compliance

with the 24 calendar month criteria if the aircraft involved never operates

under "IFR conditions" in controlled airspace?"



 	  Quote: 	
		  "14 CFR 91.411 (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;"


	


{Response} Just avoiding all "IFR operations in controlled airspace" is not 

sufficient

to relieve one of the 14 CFR required periodic transponder checks. Let's see

if we can figure out why.



1) First, while operating in what airspace must one's aircraft be

"........equipped with an operable coded radar beacon transponder......"?

Paragraph 91.215 (b) answers that question:



"91.215 (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 .........."



So if one avoids flying in any of the transponder required airspace as

described in (b) (1) through (b) (5) then one does not need a transponder.

But if one flys, even under VFR, in any of that described airspace then they

must have an operable transponder installed. Note that the airspace below

10,000 feet MSL and within 2,500 feet of the surface is not transponder

required airspace. See 91.215 (b) (5) (i).**



2) What kind of transponder must we part 91 pilots have to fly in that

transponder required airspace? 91.215 (a) answers that question:



"91.215 (a) All airspace: U.S.-registered civil aircraft. For operations not

conducted under part 121 or 135 of this chapter, ATC transponder equipment

installed must meet the performance and environmental requirements of any

class of TSO-C74b (Mode A) or any class of TSO-C74c (Mode A with altitude

reporting capability) as appropriate, or the appropriate class of TSO-C112

(Mode S)."



3) Does that 91.215 (a) required installed transponder have to have any kind

of a periodic test? 91.413 answers that question:



"91.413   ATC transponder tests and inspections.



(a) No persons may use an ATC transponder that is specified in 91.215(a),

121.345(c), or §135.143(c) of this chapter unless, within the preceding 24

calendar months, the ATC transponder has been tested and inspected and found

to comply with appendix F of part 43 of this chapter; and..............."



4) When are we required to operate the 91.215 (a) required transponder that

has been tested as required by 91.413? Paragraph 91.215 (c) answers that

question:



"91.215 (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."



5) Note that the term IFR has not even come up yet in the questions and

answers in 1, 2, 3, and 4 above. So what is the big deal about transponders

and IFR controlled airspace?



The big deal is the requirement in 91.411 of complying with Appendix E as

well as Appendix F of Part 43 for a transponder used in IFR operations in

controlled airspace. See here:



"91.411   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;"



6) So if we have an aircraft with an engine-driven electrical system how do

we get out from under the 91.411 or 91.413 every two year transponder

checks? We could:



A) Never fly (VFRor IFR) within the 91.215 (b) transponder required

airspace. Then you will not be be required to either have a transponder or

have it checked if you do have one. If you do have a transponder installed,

but it has not been checked you are forbidden from operating it.



 B) Fly only VFR within the 91.215 (b) permitted airspace -- below 10,000

feet MSL or within 2,500 feet above the surface. There you will not be be

required to either have a transponder or have it checked if you do have one.

If you do have a transponder installed, but it has not been checked you are

forbidden from operating it.



C) Fly IFR only in Class G uncontrolled airspace, if you can find some.

There you will not be  required to either have a transponder or have it

checked if you do have one. If you do have a transponder installed, but it

has not been checked you are forbidden from operating it. You don't even

have to be in contact with ATC.



I think that item C above is largely theoretical in nature. Supposedly the

low altitude IFR charts show the uncontrolled Class G airspace below 14,500

MSL in brown. It has been quite awhile since I've flown out west where there

was still some brown showing, but there wasn't much left. All airspace above

14,500MSL is Class E air space and therefore considered controlled.



So you can see that it is possible to avoid the 14 CFR required periodic

transponder checks, but not very practical unless maybe you are an ag pilot

operating locally.



Comments or questions?



OC



**PS: See 91.215 (b) (2). I note that KHWY is within 30 miles of KIAD which

is listed in Appendix D, Section 1 to Part 91. Therefore airplanes operating

out of KHWY are required to have operable transponders.



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



---

- The Matronics Avionics-List Email Forum -

Use the List Feature Navigator to browse the many List utilities available such as the Email Subscriptions page, Archive Search & Download, 7-Day Browse, Chat, FAQ, Photoshare, and much more:

http://www.matronics.com/Navigator?Avionics-List

bakerocb

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

Posted: Thu Jan 21, 2010 4:48 am Post subject: ONGOING DISCUSSION

1/21/2010



Hello Raymond, You wrote; "Q. Who can test and inspect to verify compliance 

with E and F of the

chapter?"



{Response} The entities qualified to perform the 14 CFR Part 43 Appendicies 

E and F tests required by 14 CFR paragraphs 91.411 and 91.413 are listed in 

those paragraphs. They can be readily accessed at this web site by clicking 

on Regulations & Policies:



http://www.faa.gov/



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

understand knowledge."



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



Time: 12:59:27 PM PST US

From: ray <raymondj(at)frontiernet.net>

Subject: Re: AeroElectric-List: ONGOING DISCUSSION

Q. Who can test and inspect to verify compliance with E and F of the

chapter?



Raymond Julian

Kettle River, MN.

- The Matronics Avionics-List Email Forum -

Use the List Feature Navigator to browse the many List utilities available such as the Email Subscriptions page, Archive Search & Download, 7-Day Browse, Chat, FAQ, Photoshare, and much more:

http://www.matronics.com/Navigator?Avionics-List

Display posts from previous:

	Matronics Email Lists Forum Index -> Avionics-List	All times are GMT - 8 Hours
Page 1 of 1

Jump to:

You cannot post new topics in this forum
You cannot reply to topics in this forum
You cannot edit your posts in this forum
You cannot delete your posts in this forum
You cannot vote in polls in this forum
You cannot attach files in this forum
You can download files in this forum