ADSB-Out . . Creeping toward 2020

[Steve Pierce]

I figured out a long time ago that I know more about the regulations and airplanes than my FSDO inspectors. The scary thing is that the majority of the ones I deal with are perfectly happy not knowing. I feel your frustration Homer.

[smcnutt]

It's the bureaucratic cya. Anything that provides conflicting or inconsistent language gives them cover for inaction. The last thing they want to do is be the person who sets policy by interpreting new and unclear regulations. That would single them out for criticism or at least scrutiny by those higher up. Because those higher up the chain also follow the same philosophical aversion to setting policy. Setting policy is reserved for those at the top - who are so far removed as to have no clue why the existing policy is not clear.

In a bureaucracy to stand out as a leader is to be a rogue/lose cannon and that could be disruptive to the function of the whole. Those people are driven out. Kind of like a drone bee who decides to do something different - the other bees will attack /kill him to maintain the order of the hive.

I appreciate your efforts Homer and good luck. It's not a world that I could stand to deal with.

[Phil P]

Is there any possibility of searching the country for a FSDO that has an FAA person interested in promoting this idea and then submitting the proposal there?

[eskflyer]

Homer,
I truly hope you do not give up on this. Can you take it too the next level up the food chain. By them the faa not allowing this they are making it more dangerous out in their airspace. IF it is good enough for the elsa and others then it is good enough for our birds.

Thanks for your work on this .

[bjboyle]

I sometimes wonder if the answer to try to convert our aircraft to experimental. Have you seen this done Steve? Only downside I' see is that it would likely be experimental restricted and require yearly program letters.

[Dennis Savarese]

Quite honestly, Program Letters are no big deal. I owned and few a Yak 52 for 12 years, including before they removed the 300 NM proficiency area in 2007. I would send my program letter in each January with the events I planned on attending. All other flying was for "proficiency". Even after the FAA removed the 300 nm restriction, we still had to submit an annual program letter. Then if we attended an event that was not on the Program Letter, we would simply send a fax to the FSDO at least 24 hours prior to the event letting the FSDO know that XXXX airplane, Nxxxx, would be attending the event on such and such a date.
Dennis

Many people think you have to get permission. That is the farthest from the truth. You must notify the your FSDO of any event or training you will be attending that was not on the original program letter for that year.

[andya]

I don't understand the language about the GPS receiver not being part of the ADS-b unit, is it not that way on the version they make
that is TSO'd????

[Dennis Savarese]

Yes, it definitely is part of the unit according to the NavWorx information on their web site. "* Internal ADS-B Compliant WAAS GPS".

Homer, are you going to let the issue die or are you going to elevate it? Maybe talk with the EAA legal beagles about the situation? Especially when your FSDO makes a statement the FAA considers the AC to be mandatory when written right in the AC it clearly says, "not mandatory". If your FSDO people can produce a document which states this specific AC is considered mandatory by the FAA, then and only then would it be mandatory. Not just because "we said so"!

I also agree it is NOT a major alteration by the definition within the FAR's AND the English language. But who am I to interpret the FAR's and apply an English language interpretation to the wording in the FAR's. Your FSDO is attempting to write regulations. Not following the exact wording in the regulations. If we go to FAR 43 Appendix A, it clearly defines Major Repair and Major Alteration. Anything other than "Major" means it is minor and as you know, a minor repair or alteration is a log book entry signed off by an IA. Here are the exact words from Appendix A.

Appendix A to Part 43—Major Alterations, Major Repairs, and Preventive Maintenance (a) Major alterations—(1) Airframe major alterations. Alterations of the following parts and alterations of the following types, when not listed in the aircraft specifications issued by the FAA, are airframe major alterations:
(i) Wings.
(ii) Tail surfaces.
(iii) Fuselage.
(iv) Engine mounts.
(v) Control system.
(vi) Landing gear.
(vii) Hull or floats.
(viii) Elements of an airframe including spars, ribs, fittings, shock absorbers, bracing, cowling, fairings, and balance weights.
(ix) Hydraulic and electrical actuating system of components.
(x) Rotor blades.
(xi) Changes to the empty weight or empty balance which result in an increase in the maximum certificated weight or center of gravity limits of the aircraft.
(xii) Changes to the basic design of the fuel, oil, cooling, heating, cabin pressurization, electrical, hydraulic, de-icing, or exhaust systems.
(xiii) Changes to the wing or to fixed or movable control surfaces which affect flutter and vibration characteristics.

Lastly, note the wording right on the 337.
6. FORM INSTRUCTIONS. The person who performs or supervises a major repair or major alteration must prepare Form 337.

[Homer Landreth]

Good Morning All; With great regret, I have determined that it is futile to continue any more effort on this issue. My bottom line conclusion is at his time there is no way the FAA will buy in to any Field approval for non-TSO ADSB-Out into Registered aircraft. IT has to be STC and to be STC it has to be fully compliant with a TSO. (Don't care about what 91-227 and 91-225 says) The ADSB6000-EXP unit can be used in every LSA aircraft flying and any Experimental airplane flying, but not my or your Piper or Cessna. The Experimental plane in the Hangar next to me and my Tripacer will taxi out on the same taxiway, to the same runway, take off into the same airspace, have the same transponder on, but his UART can be a Non-TSO and mine has to be TSO ( WTF reasoning is that ???) Sometimes I can be Persistant, and sometimes Stupid, and on a really bad day i can be both at the same time, but on this issue I have been told several times over that the installation of a non-TSO unit WILL NOT BE APPROVED. I have been since January on this and that is all I can do. I got my final "GET OFF MY LAWN" edict from the FSDO yesterday and I am four days waiting for my promised call from the ACO. So I am sending up the surrender flag on the issue. In discussion with NAVWORX (who have been most cooperative and helpful) Bill Moffett said he would consider STC for the -EXP unit if he could get a time frame from the FAA for a reasonable estimate for how long the paperwork would take to get it added to an AML. I asked that question of the FAA and they said they could not make that estimate since that is an administrative controlled activity. Anyway, i gave my "best and final status update" to Mr. Moffett and thanked him for his efforts so far but it appears that an STC is the only answer and obviously any STC decision is a business decision on his part. I will be the first one in line to buy the STC -EXP unit when and if it comes, but if it doesn't I will buy their TSO unit that is available down stream at compliance time.

[Homer Landreth]

I don't understand the language about the GPS receiver not being part of the ADS-b unit, is it not that way on the version they make
that is TSO'd????

Their TSO unit can contain a GPS Receiver, or not, if not contained it communicates with a separate third party GPS. The EXP contains it's own GPS