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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

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]

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."



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

---

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

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

Float Flyr

Joined: 19 Jul 2006
Posts: 2704
Location: Campbellton, Newfoundland

Posted: Tue Jan 19, 2010 4:29 pm Post subject: Encoder Certification

Calibration is generally done with a Barfield tester...  Bring $$$$.  



Noel



--

_________________
Noel Loveys
Kitfox III-A
Aerocet 1100 Floats

bakerocb

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

Posted: Wed Jan 20, 2010 5:02 am Post subject: Encoder Certification

1/20/2010



Hello Steve Thomas, You write: "I am the manufacturer of the airplane."



{Response} Nice try, but no cigar.



In the eyes of the FAA you are not the manufacturer of a type certificated 

airplane (which title carrys many significant qualifications, approvals, and 

inspections), but instead the "fabicator and assembler" of an experimental 

amateur built airplane.



The regulatory permission and description that allows our category of 

aircraft to exist does not use the word "manufactured". See here:



" 14 CFR 21.191   Experimental certificates. Experimental certificates are 

issued for the following purposes:



(g) Operating amateur-built aircraft. Operating an aircraft the major 

portion of which has been fabricated and assembled by persons who undertook 

the construction project solely for their own education or recreation."



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

understand knowledge."



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



Time: 06:49:15 AM PST US

Subject: Re: AeroElectric-List: Encoder Certification

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

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

bakerocb

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

Posted: Wed Jan 20, 2010 7:01 am Post subject: Encoder Certification

1/20/2010



Hello Again Jon Finley, Can we please beat on this subject a bit more with 

your help?



You write:



1) "..... almost all of our airspace is uncontrolled." and "There are huge 

expanses of this country where this is true."



{Response} I wonder if this is so. Years ago when I would freely roam the 

wild west in my many different flying machines I would eye the uncontrolled 

airspace (delineated by brown shading as opposed to white on the low 

altitude IFR charts) and wonder about its significance.



There was damn little brown shading then and probably much less now. Can you 

please obtain a copy of a recent low altitude IFR chart for your area and 

confirm that the statements you made above are true? I tend to doubt them. 

Note that all airspace in our country above 14,500 is Class E airspace and 

therefore is controlled.



2) "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)."



{Response} If you get above 10,000 feet MSL and not within 2,500 feet of the 

surface you will definitely be in the airspace identified by 91.215 (b) (5) 

(i). See here:



"(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.......



(i) In all airspace of the 48 contiguous states and the District of Columbia 

at and above 10,000 feet MSL, excluding the airspace at and below 2,500 feet 

above the surface; and....."



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

it turned on."



{Response} Note that 91.215 (b) (5) (i) in effect permits aircraft with no 

transponders to operate below 10,000 feet MSL and above 10,000 feet MSL if 

within 2,500 feet of the surface, even if that airspace is controlled, as 

long as the rest of 91.215 (b) is complied with.



Could it be that this vast amount of airspace is the airspace that you have 

in mind to operate in and not uncontrolled airspace per se?



Anyway the real issue here when it comes to requiring a transponder or not 

is not the existence or not of generic controlled airspace, but rather the 

specific airspaces identified in 91.215 (b). The term "controlled airspace" 

is not used once in the entire 91.215 (b) parargraph and this is the 14 CFR 

paragaph that regulates whether an aircraft must be equipped with a 

transponder or not.



Hoping to read about what you find out -- sure wish I had access to a set of 

low altitude IFR charts for the entire country.



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

understand knowledge."



PS: I just went on line and checked in the vicinity of Socorro NM. Yes there 

is some brown (uncontrolled airspace) out there, but one would be hard 

pressed to fly around and avoid all surrounding white (controlled airspace) 

unless a special navigation effort was made.



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



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

wjrhamilton(at)optusnet.c
Guest

Posted: Wed Jan 20, 2010 8:05 pm Post subject: Encoder Certification

Folks,

Using the term "controlled airspace" is a bit of a misnomer.



Airspace is categorized as A, B, C, D, E, F and G.



Only F and G are "uncontrolled", there is no F in the US, and very little G, outside Alaska.



For those with a long memory, what is now E, in the US was once called "Controlled/VFR Exempt".

In regular day to day flying, it is very hard to dodge E airspace in US, as it is most common airspace below below A.



Generally, B,C and D are terminal/tower airspace.



Below 10,000', for Part 91 operations, the requirement for a transponder relates to the transponder veil withing 30 miles of the airfields on which Class B is centered, or as otherwise noted/charted.



In my opinion, as an individual, you can only satisfy the requirements for a  Mode C encoder by having a TSO unit, with the necessary initial/recurrent testing.



How?? do you establish the 95% probability performance otherwise required in Part 91, already mentioned, a simple test of an installation does not do that, it does not establish the in-service performance is maintained.



Regards,

Bill Hamilton 

 	  Quote: 	
		   bakerocb(at)cox.net wrote:

 

 

 

 1/20/2010

 

 Hello Again Jon Finley, Can we please beat on this subject a bit more 

 with 

 your help?

 

 You write:

 

 1) "..... almost all of our airspace is uncontrolled." and "There are 

 huge 

 expanses of this country where this is true."

 

 {Response} I wonder if this is so. Years ago when I would freely roam 

 the 

 wild west in my many different flying machines I would eye the 

 uncontrolled 

 airspace (delineated by brown shading as opposed to white on the low 

 altitude IFR charts) and wonder about its significance.

 

 There was damn little brown shading then and probably much less now. Can 

 you 

 please obtain a copy of a recent low altitude IFR chart for your area 

 and 

 confirm that the statements you made above are true? I tend to doubt 

 them. 

 Note that all airspace in our country above 14,500 is Class E airspace 

 and 

 therefore is controlled.

 

 2) "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)."

 

 {Response} If you get above 10,000 feet MSL and not within 2,500 feet of 

 the 

 surface you will definitely be in the airspace identified by 91.215 (b) 

 (5) 

 (i). See here:

 

 "(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.......

 

 (i) In all airspace of the 48 contiguous states and the District of 

 Columbia 

 at and above 10,000 feet MSL, excluding the airspace at and below 2,500 

 feet 

 above the surface; and....."

 

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

 without 

 it turned on."

 

 {Response} Note that 91.215 (b) (5) (i) in effect permits aircraft with 

 no 

 transponders to operate below 10,000 feet MSL and above 10,000 feet MSL 

 if 

 within 2,500 feet of the surface, even if that airspace is controlled, 

 as 

 long as the rest of 91.215 (b) is complied with.

 

 Could it be that this vast amount of airspace is the airspace that you 

 have 

 in mind to operate in and not uncontrolled airspace per se?

 

 Anyway the real issue here when it comes to requiring a transponder or 

 not 

 is not the existence or not of generic controlled airspace, but rather 

 the 

 specific airspaces identified in 91.215 (b). The term "controlled 

 airspace" 

 is not used once in the entire 91.215 (b) parargraph and this is the 14 

 CFR 

 paragaph that regulates whether an aircraft must be equipped with a 

 transponder or not.

 

 Hoping to read about what you find out -- sure wish I had access to a 

 set of 

 low altitude IFR charts for the entire country.

 

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

 understand knowledge."

 

 PS: I just went on line and checked in the vicinity of Socorro NM. Yes 

 there 

 is some brown (uncontrolled airspace) out there, but one would be hard 

 pressed to fly around and avoid all surrounding white (controlled 

 airspace) 

 unless a special navigation effort was made.

 

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

 

 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

bakerocb

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

Posted: Thu Jan 21, 2010 4:35 am Post subject: Encoder Certification

1/21/2010



Hello Bill Boyd, You wrote:



1) "OC, I'm pretty sure my experimental airworthiness certificate has a 

blank on

it for "manufacturer.""



{Response} That is correct. FAA Form 8130-7 SPECIAL AIRWORTHINESS 

CERTIFICATE block B is entitled MANUFACTURER. This form is used for many 

different kinds of aircraft than just experimental amateur built. Some of 

these different kinds of aircraft could indeed have been created by an FAA 

recognized manufacturer such as Boeing, Piper, Cessna, etc.



2) "I've seen some builders put their last name there, while others put 

"Vans" or whatever."



{Response} Not likely. That form is filled out and signed by the FAA 

Representative, either an FAA Employee or a DAR,  who signs it in block E.



3) "I'm not looking at my cert right now it's in the plane), but I'm 

reasonably sure the box I'm referring to is not labeled "Fabricator.""



{Response} I am looking at my SPECIAL AIRWORTHINESS CERTIFICATE right now. 

Block B, MANUFACTURER has N/A as an entry. Block D, BUILDER has my name.



I hope that every homebuilder who has read this thread is now convinced that 

they are not their aircraft's manufacturer, which is one of the 

qualifications listed in 14 CFR 91.411 as needed in order to perform the 

tests required by that paragraph (91.411 Atimeter system and altitude 

reporting equipment tests and inspection).



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

understand knowledge."



PS: I write not to pick on you Bill, but to encourage my fellow builders to 

move from the casual arena of "pretty sure" or "hearsay, gossip, and rumor" 

to the available facts (which are usually not that hard to come by) 

regarding our hobby.



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



Time: 06:00:47 AM PST US

Subject: Re: AeroElectric-List: Encoder Certification

From: Bill Boyd <sportav8r(at)gmail.com>



OC, I'm pretty sure my experimental airworthiness certificate has a blank on

it for "manufacturer."  I've seen some builders put their last name there,

while others put "Vans" or whatever.  I'm not looking at my cert right now

(it's in the plane), but I'm reasonably sure the box I'm referring to is not

labeled "Fabricator."



-Bill B

lessdragprod(at)aol.com
Guest

Posted: Thu Jan 21, 2010 9:23 am Post subject: Encoder Certification

Hi All,

    

   I just checked the FAA records:  William E. Boyd, Jr is the "manufacturer" of a RV-6A.

    

   There is no BUILDER block on the aircraft registration form.  What did you put on the 8050-1 form you sent to FAA Oklahoma City to register your aircraft?  I think this is the first form the FAA sees for a new homebuilt.

    

   Jim Ayers

   

 

 

   --

bakerocb

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

Posted: Thu Jan 21, 2010 2:52 pm Post subject: Encoder Certification

1/21/2010



Hello Again Jon Finley, Thank you for responding to my request (copied 

below) to review the charting of controlled and uncontrolled airspace in 

your area.



Before I respond to the specific points that you made in that charting 

regard I would like to again remind all of the readers regarding the non 

relevance of generic controlled airspace when it comes to determining 

whether or not an aircraft must be equipped with an operable coded 

transponder.



I repeat: "Anyway the real issue here when it comes to requiring a 

transponder or

not is not the existence or not of generic controlled airspace, but rather 

the

specific airspaces identified in 91.215 (b). The term "controlled airspace"

is not used once in the entire 91.215 (b) parargraph and this is the 14 CFR

paragaph that regulates whether an aircraft must be equipped with a 

transponder or not."



You wrote:



1) ".............. one has to actually look at a sectional (NOT IFR chart) 

to see where true "uncontrolled airspace" exists."



{Response} Is that really true? I don't have the current appropriate 

sectional and low altitude IFR charts of the areas out west to compare side 

by side, but the few sectional charts that I do have (outdated) of the areas 

where I think there should be some uncontrolled Class G airspace going from 

the surface up to 14,500 MSL feet do not identify this airspace. But this 

Class G airspace going from the surface up to 14,500 feet MSL is the 

airspace that I believe is shown in brown on the low altitude IFR charts.



2) "Said another way,one has to look at a sectional to see at what altitude 

the floor of Class E

airspace exists."



{Response} I agree, the sectionals do show where the floor of controlled 

Class E airspace is at either 700 feet (using magenta colored shading) or 

1,200 feet (using blue color shading) above the surface.



But do the sectionals in your area also show the uncontrolled Class G 

airspace that goes from the surface up to 14,500 feet MSL like the low 

altitude charts show with brown shading? If so how do the sectionals show 

this same airspace?



3) "There is quite a bit of area (many, many, many square miles) where Class 

E starts

at 14,500' AGL and a few locations where it starts at 11,500' and 12,000'."



{Response} And again it does not matter where Class E starts, 700 feet above 

the surface, 1,200 feet above the surface, 11,500 feet MSL, 12,000 feet MSL 

or 14,500 feet MSL when it comes to where one needs an operable coded 

transponder in an aircraft because it is paragraph 14 CFR 91.215 (b) (5) 

(i), (along with the other relevant paragraphs in 91.215 (b)), that 

determines transponder requirement. The relevant numbers in 91.215 (b) (5) 

(i) are to be below 10,000 feet MSL or within  2,500 feet of the surface in 

order to operate without a transponder. Even if one is operating in that 

uncontrolled Class G airspace between 10,000 feet MSL and the beginning of 

controlled Class E airspace at 14,500 feet MSL one must  have an operable 

coded transponder.



4) "Here, it is possible/legal (due to the airspace) to pull the transponder 

(or

leave it off) and fly to a repair shop (obviously depending on where the

repair shop is..).'



{Response} Agreed, as long as one is in compliance with 14 CFR 91.215 (b).



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

understand knowledge."



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



Time: 09:08:18 AM PST US

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

Subject: RE: AeroElectric-List: Encoder Certification



Bakerocb,



SkyVector.com is an awesome resource.  You can view any sectional or IFR

chart in the US (maybe more, I haven't tried) with it and do some very neat

trip planning.



You are absolutely right, one has to actually look at a sectional (NOT IFR

chart) to see where true "uncontrolled airspace" exists. Said another way,

one has to look at a sectional to see at what altitude the floor of Class E

airspace exists.



I admit that I took some liberty with my previous statement to make a point.

Obviously we have plenty of Class E space here.  The Class E airspace where

I live (E98) starts at 1200' AGL (about 6,000' MSL). That is true for most

of the northern half of the state except where an airport with an approach

exists (the Class E floor extends to 700'/ground at those locations). There

is quite a bit of area (many, many, many square miles) where Class E starts

at 14,500' AGL and a few locations where it starts at 11,500' and 12,000'.

With that in mind, I do not have a good guess at how much of my actual

flying is in uncontrolled airspace (i.e. beneath the floor of Class E) but I

would guess about 40%. When going x-country (i.e. hundreds of miles), a

higher altitude is typical which places me in Class E.  Most of my flying is

recreational (to from breakfast, sightseeing, having fun) and is fairly low

- I do get above 1200' AGL but also spend a lot of time below 1200' AGL.

Here, it is possible/legal (due to the airspace) to pull the transponder (or

leave it off) and fly to a repair shop (obviously depending on where the

repair shop is..).

Jon Finley



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

 	  Quote: 	
		   1/20/2010


	


 	  Quote: 	
		  


	


 	  Quote: 	
		   Hello Again Jon Finley, Can we please beat on this subject a bit more


	


 	  Quote: 	
		   with


	


 	  Quote: 	
		   your help?


	


 	  Quote: 	
		  


	


 	  Quote: 	
		   You write:


	


 	  Quote: 	
		  


	


 	  Quote: 	
		   1) "..... almost all of our airspace is uncontrolled." and "There are


	


 	  Quote: 	
		   huge


	


 	  Quote: 	
		   expanses of this country where this is true."


	


 	  Quote: 	
		  


	


 	  Quote: 	
		   {Response} I wonder if this is so. Years ago when I would freely roam


	


 	  Quote: 	
		   the


	


 	  Quote: 	
		   wild west in my many different flying machines I would eye the


	


 	  Quote: 	
		   uncontrolled


	


 	  Quote: 	
		   airspace (delineated by brown shading as opposed to white on the low


	


 	  Quote: 	
		   altitude IFR charts) and wonder about its significance.


	




 	  Quote: 	
		  


	


 	  Quote: 	
		   There was damn little brown shading then and probably much less now.


	


 	  Quote: 	
		   Can you


	


 	  Quote: 	
		   please obtain a copy of a recent low altitude IFR chart for your area


	


 	  Quote: 	
		   and


	


 	  Quote: 	
		   confirm that the statements you made above are true? I tend to doubt


	


 	  Quote: 	
		   them.


	


 	  Quote: 	
		   Note that all airspace in our country above 14,500 is Class E airspace


	


 	  Quote: 	
		   and


	


 	  Quote: 	
		   therefore is controlled.


	


 	  Quote: 	
		  


	


 	  Quote: 	
		   2) "If you read the full text of 14 CFR 91.215 (b), you will find that


	


 	  Quote: 	
		   folks


	


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


	


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


	


 	  Quote: 	
		   airspace listed in (b)(1) through (b)(5)."


	


 	  Quote: 	
		  


	


 	  Quote: 	
		   {Response} If you get above 10,000 feet MSL and not within 2,500 feet


	


 	  Quote: 	
		   of the


	


 	  Quote: 	
		   surface you will definitely be in the airspace identified by 91.215 (b)


	


 	  Quote: 	
		   (5)


	


 	  Quote: 	
		   (i). See here:


	


 	  Quote: 	
		  


	


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


	


 	  Quote: 	
		   person


	


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


	


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


	


 	  Quote: 	
		   an


	


 	  Quote: 	
		   operable coded radar beacon transponder.......


	


 	  Quote: 	
		  


	


 	  Quote: 	
		   (i) In all airspace of the 48 contiguous states and the District of


	


 	  Quote: 	
		   Columbia


	


 	  Quote: 	
		   at and above 10,000 feet MSL, excluding the airspace at and below 2,500


	


 	  Quote: 	
		   feet


	


 	  Quote: 	
		   above the surface; and....."


	


 	  Quote: 	
		  


	


 	  Quote: 	
		   3) "So, given MY environment, I can fly without a transponder and/or


	


 	  Quote: 	
		   without


	


 	  Quote: 	
		   it turned on."


	


 	  Quote: 	
		  


	


 	  Quote: 	
		   {Response} Note that 91.215 (b) (5) (i) in effect permits aircraft with


	


 	  Quote: 	
		   no


	


 	  Quote: 	
		   transponders to operate below 10,000 feet MSL and above 10,000 feet MSL


	


 	  Quote: 	
		   if


	


 	  Quote: 	
		   within 2,500 feet of the surface, even if that airspace is controlled,


	


 	  Quote: 	
		   as


	


 	  Quote: 	
		   long as the rest of 91.215 (b) is complied with.


	


 	  Quote: 	
		  


	


 	  Quote: 	
		   Could it be that this vast amount of airspace is the airspace that you


	


 	  Quote: 	
		   have


	


 	  Quote: 	
		   in mind to operate in and not uncontrolled airspace per se?


	


 	  Quote: 	
		  


	


 	  Quote: 	
		   Anyway the real issue here when it comes to requiring a transponder or


	


 	  Quote: 	
		   not


	


 	  Quote: 	
		   is not the existence or not of generic controlled airspace, but rather


	


 	  Quote: 	
		   the


	


 	  Quote: 	
		   specific airspaces identified in 91.215 (b). The term "controlled


	


 	  Quote: 	
		   airspace"


	


 	  Quote: 	
		   is not used once in the entire 91.215 (b) parargraph and this is the 14


	


 	  Quote: 	
		   CFR


	


 	  Quote: 	
		   paragaph that regulates whether an aircraft must be equipped with a


	


 	  Quote: 	
		   transponder or not.


	


 	  Quote: 	
		  


	


 	  Quote: 	
		   Hoping to read about what you find out -- sure wish I had access to a


	


 	  Quote: 	
		   set of


	


 	  Quote: 	
		   low altitude IFR charts for the entire country.


	


 	  Quote: 	
		  


	


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


	


 	  Quote: 	
		   understand knowledge."


	


 	  Quote: 	
		  


	


 	  Quote: 	
		   PS: I just went on line and checked in the vicinity of Socorro NM. Yes


	


 	  Quote: 	
		   there


	


 	  Quote: 	
		   is some brown (uncontrolled airspace) out there, but one would be hard


	


 	  Quote: 	
		   pressed to fly around and avoid all surrounding white (controlled


	


 	  Quote: 	
		   airspace)


	


 	  Quote: 	
		   unless a special navigation effort was made.

bakerocb

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

Posted: Sun Jan 24, 2010 2:54 pm Post subject: Encoder Certification

1/24/2010



Hello John Grosse, You wrote: "I personally don't understand why you just 

wouldn't buy a transponder..."



{Response} Recall that this thread began with a posting by Steve Thomas (Msg 

# 48119 on Jan 16, 2010 using the subject "Encoder Certification")  who 

wanted to know if he

could fly away from his home base with his newly certified experimental

amateur built airplane without an operating and certified transponder in

order to have the appropriate transponder checks done at another location.



Sorry that it got so drawn out and exhausting as we initially tried to help 

him and then got bogged down while trying to clarify some subsequent 

postings.



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

understand knowledge."



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



Time: 10:04:57 PM PST US

From: John Grosse <grosseair(at)comcast.net>

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

This whole discussion has me totally exhausted. I personally don't

understand why you just wouldn't buy a transponder... unless, of course.

you're smuggling drugs or are flying some WWI vintage rag bag with no

electrical system. Then I get it, and why would you even care?



John Grosse

bakerocb

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

Posted: Mon Jan 25, 2010 6:55 am Post subject: Encoder Certification

1/25/2010



Hello Angier Ames, You wrote 1) 2) and 3) below:



1) "Altitude encoders are required equipment for IFR flight in controlled 

airspace."



{Response} Not true for all controlled airspace -- just that airspace 

identified in 91.215 (b). Can you show otherwise?



2) "And unless the operation is conducted under part 121 or 135, as per 

FARS, 14CFR Section215(a), they do NOT need to be certified/ TSO'd."



{Response} Not true because 14 CFR Section 215 (a) says exactly the 

opposite. Read here:



"91.215   ATC transponder and altitude reporting equipment and use.



(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) "So, go to your basement and create your own altitude encoder. Your only 

obligation under Part 91 is to demonstrate that it meets the performance and 

environmental standards of any class of TSO-C47b or c  or TSO-C112."



{Response} More than a bit misleading. The FAA requirements of proving "the 

performance and environmental standards" of a TSO, or an alternate method of 

complying with the requirements, for avionics are very extensive, demanding, 

and expensive. This is why most of the altitude encoding EFIS' available to 

the experimental amateur built community are not TSO'd. There is extensive 

material in the aeroelectric list archives on the significance of 

paragraph14 CFR 91.217, particularly 91.217 (b). Just help yourself.



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

understand knowledge."



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



Time: 07:07:12 AM PST US

From: "Greenbacks, UnLtd." <N4ZQ(at)comcast.net>

Subject: AeroElectric-List: Re: Encoder Certification



Since we are all now exhausted by this subject, lets beat this dead

horse one more time.

Altitude encoders are required equipment for IFR flight in controlled

airspace. And unless the operation is conducted under part 121 or 135,

as per FARS, 14CFR Section215(a), they do NOT need to be certified/

TSO'd.



So, go to your basement and create your own altitude encoder. Your

only obligation under Part 91 is to demonstrate that it meets the

performance and environmental standards of any class of TSO-C47b or c

or TSO-C112.



Angier Ames

N4ZQ

kpc(at)speakeasy.net
Guest

Posted: Mon Jan 25, 2010 9:44 am Post subject: Encoder Certification

/set mode = "dead horse"

/enable beat





On Jan 25, 2010, at 9:35 AM, <bakerocb(at)cox.net> wrote:



 	  Quote: 	
		   



 1/25/2010



 Hello Angier Ames, You wrote 1) 2) and 3) below:



 1) "Altitude encoders are required equipment for IFR flight in  

 controlled airspace."



 {Response} Not true for all controlled airspace -- just that  

 airspace identified in 91.215 (b). Can you show otherwise?



 2) "And unless the operation is conducted under part 121 or 135, as  

 per FARS, 14CFR Section215(a), they do NOT need to be certified/  

 TSO'd."



 {Response} Not true because 14 CFR Section 215 (a) says exactly the  

 opposite. Read here:



 "91.215   ATC transponder and altitude reporting equipment and use.



 (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) "So, go to your basement and create your own altitude encoder.  

 Your only obligation under Part 91 is to demonstrate that it meets  

 the performance and environmental standards of any class of TSO-C47b  

 or c  or TSO-C112."



 {Response} More than a bit misleading. The FAA requirements of  

 proving "the performance and environmental standards" of a TSO, or  

 an alternate method of complying with the requirements, for avionics  

 are very extensive, demanding, and expensive. This is why most of  

 the altitude encoding EFIS' available to the experimental amateur  

 built community are not TSO'd. There is extensive material in the  

 aeroelectric list archives on the significance of paragraph14 CFR  

 91.217, particularly 91.217 (b). Just help yourself.



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

 and understand knowledge."



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



 Time: 07:07:12 AM PST US

 From: "Greenbacks, UnLtd." <N4ZQ(at)comcast.net>

 Subject: AeroElectric-List: Re: Encoder Certification



 Since we are all now exhausted by this subject, lets beat this dead

 horse one more time.

 Altitude encoders are required equipment for IFR flight in controlled

 airspace. And unless the operation is conducted under part 121 or 135,

 as per FARS, 14CFR Section215(a), they do NOT need to be certified/

 TSO'd.



 So, go to your basement and create your own altitude encoder. Your

 only obligation under Part 91 is to demonstrate that it meets the

 performance and environmental standards of any class of TSO-C47b or c

 or TSO-C112.



 Angier Ames

 N4ZQ

gyoung

Joined: 09 Jan 2006
Posts: 211
Location: Republic of Texas

Posted: Mon Jan 25, 2010 3:38 pm Post subject: Encoder Certification

<LOOP UNTIL Reader.Count = 0>

 /set mode = "dead horse"

 /enable beat

</LOOP>

 



 	  Quote: 	
		   On Jan 25, 2010, at 9:35 AM, <bakerocb(at)cox.net> wrote:

 

 > 

 >

 > 1/25/2010

 >

 > Hello Angier Ames, You wrote 1) 2) and 3) below:

 >

 > 1) "Altitude encoders are required equipment for IFR flight in 

 > controlled airspace."

 >

 > {Response} Not true for all controlled airspace -- just 

 that airspace 

 > identified in 91.215 (b). Can you show otherwise?

 >

 > 2) "And unless the operation is conducted under part 121 or 135, as 

 > per FARS, 14CFR Section215(a), they do NOT need to be certified/ 

 > TSO'd."

 >

 > {Response} Not true because 14 CFR Section 215 (a) says exactly the 

 > opposite. Read here:

 >

 > "91.215   ATC transponder and altitude reporting equipment and use.

 >

vipin

Joined: 02 Dec 2010
Posts: 3

Posted: Sun Dec 05, 2010 8:05 pm Post subject: Re: Encoder Certification

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

more inclusive word

_________________
Slimming Pills
Slimming Pill

bakerocb

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

Posted: Mon Dec 06, 2010 5:28 am Post subject: Encoder Certification

12/6/2010



Hello vipin,



On Jan 24, 2010 Angier Ames wrote: "And unless the operation is conducted 

under part 121 or 135, as  per FARS, 14CFR Section215(a), they do NOT need 

to be certified/ TSO'd."



On Jan 25, 2010 I wrote: "{Response} Not true because 14 CFR Section 215 (a) 

says exactly the opposite......"



On Dec 05, 2010 8:05 pm you wrote: "I agree, providing the word "under" is 

changed to the word "in"....."



{Response 1} Wow! I am both astounded and curious. Why are you responding to 

a Jan 25, 2010 posting to this thread almost a year  later on Dec 5, 2010?



{Response 2} It is not clear whether you are agreeing with what Angier wrote 

or what I wrote in response.



{Response 3} I am reluctant to post again to this thread because some 

readers became a bit bored / disgusted with it, but your preference for the 

word "in" instead of the word "under" when it comes to which part of the 

regulations apply to a particular kind of operation does not change what the 

FARs actually say. Here is the quote that applies, directly extracted from 

14 CFR 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 ............."



{Response 4} Perhaps you are thinking of operating "in" a particular kind of 

airspace instead of operating "under" a particular part of the regulations 

that apply to that operation.



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

gather and understand knowledge."



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



Posted: Sun Dec 05, 2010 8:05 pm    Post subject: Re: Encoder Certification



Time: 08:10:10 PM PST US

Subject: Re: Encoder Certification

From: "vipin" <vvipin84(at)hotmail.com>

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

more inclusive word



--------

Read this topic online here:



http://forums.matronics.com/viewtopic.php?p=322416#322416

luluxiu

Joined: 20 Jul 2011
Posts: 3

Posted: Thu Jul 21, 2011 5:07 pm Post subject: Re: Encoder Certification

I agree, provided the word "under" words "in the" to "Medium" is a more inclusive word...

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