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IFR GPS requirements

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bakerocb

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

Posted: Wed Jan 16, 2008 6:10 am Post subject: IFR GPS requirements

1/16/2008



Hello Bill, Avoid that poor soul -- he has not been around long enough or 

cared enough to learn that type certificated aircraft and amateur built 

experimental aircraft are treated very differently in the FAA's paperwork 

system.



What he has described in the way of paperwork approval just simply does not 

apply to your airplane.



Here is a quote from the signature section of the FAA Form 337:



 "I certify that the repair and/or alteration made to the unit(s) identified 

in item 5 above and described on the reverse or attachments hereto have been 

made in accordance with the requirements of Part 43 of the U.S. Federal 

Aviation Regulations and that the information furnished herein is true and 

correct to the best of my knowledge."



And here is a quote from FAR Part 43.1:



"(b) This part does not apply to any aircraft for which the FAA has issued 

an experimental certificate, unless the FAA has previously issued a 

different kind of airworthiness certificate for that aircraft."



Since part 43 does not apply to amateur built aircraft issued a Special 

Airworthiness Certificate in the Experimental Category for the purpose of 

operating amateur-built aircraft (FAR 21.191 (g)) how can one properly 

comply with the signature certification requirement on the FAA Form 337?



Several years ago a poster described his mistaken attempt to comply with all 

FAA type certificated regulatory and advisory circular requirements for the 

IFR GPS installation in his amateur built experimental airplane. He even 

flew a test flight with a terrified FAA inspector who spent the entire 

flight frantically looking out the window in fear of a mid air collision. 

The entire effort was wasted because no FAA agency or procedure for the 

approval existed -- just initial erroneous assumptions by uninformed FAA 

employees.



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

understand knowledge."



-----------------------------------------



 From: "William Gill" <wgill10(at)comcast.net>Subject: IFR GPS requirements



Date: Jan 15, 2008



Hello All,



I have a Bendix-King KLN 94 GPS (IFR certified unit) in an RV-7. During

discussions with an FAA inspector, I was told that I was not allowed to

use this unit for IFR use until I completed a 337 form with a field

approval, and completed the required test flight. I was not aware that

the experimental ships had to jump through the same hoops as the Type

Certificated aircraft. Can this possibly be true? I welcome all input on

this subject.



Bill

RV-7

Lee's Summit, MO

bakerocb

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

Posted: Thu Jan 17, 2008 11:04 am Post subject: IFR GPS requirements

1/17/2008



Hello Rick, Thanks for your input and interest in this subject. You wrote:



1) "It depends on what the inspector wrote into you ops limits."



The FAA Inspector or DAR is directed by FAA Order 8130.2_ (edition F, with 

change 3 incorporated is the current version) what to write into the 

Operating Limitations when issuing the Special Airworthiness Certificate for 

an amateur built experimental aircraft. His prerogative to ad lib in this 

specific area (IFR GPS requirements) is extremely limited to non existent.



2) "If he referenced 91.205 as a requirement for IFR flight, then you must 

get the

system tested by an FAA certified shop." and "If not you can proceed as you 

wish."



These two statements are misleading / incorrect.



2A) First off, There is no "if" about it. He most certainly will reference 

91.205 as a requirement for IFR flight. He will do this by incorporating 

this statement into the Operating Limitations: "After completion of phase 1 

testing, unless appropriately equipped for night and/or instrument flight in 

accordance with 91.205, this aircraft is to be operated VFR day only." See 

paragraph 1 above.



2B) Second, Other than the normal regulatory requirements for periodic 

inspections of the altitude encoder, the altimeter, and the transponder 

(these inspection requirements also apply to type certificated aircraft) 

there is no requirement to "get the system tested by an FAA certified shop."



2C) Third, It is not clear what you mean when you write the word "system".



I have prepared a table that serves as a quick reference on this subject:



MINIMUM INSTRUMENT AND EQUIPMENT REQUIREMENTS FOR POWERED AMATEUR BUILT 

EXPERIMENTAL AIRCRAFT.



I will email a copy of this table to any reader requesting it.



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

understand knowledge."



-------------------------------------------------------



Time: 06:50:54 AM PST US

From: "Richard Girard" <jindoguy(at)gmail.com>

Subject: Re: AeroElectric-List: IFR GPS requirements



Peter, et al, It depends on what the inspector wrote into you ops limits. If

he referenced 91.205 as a requirement for IFR flight, then you must get the

system tested by an FAA certified shop. If not you can proceed as you wish.

In the Ops Limits I received yesterday, Item 11:

"After completion of phase 1 testing, unless appropriately equipped for

night and/or instrument flight in accordance with 91.205, this aircraft is

to be operated VFR day only."



Rick Girard

grosseair(at)comcast.net
Guest

Posted: Thu Jan 17, 2008 11:59 am Post subject: IFR GPS requirements

I'd like a copy please.



John Grosse



 	  Quote: 	
		  



 I have prepared a table that serves as a quick reference on this subject:



 MINIMUM INSTRUMENT AND EQUIPMENT REQUIREMENTS FOR POWERED AMATEUR 

 BUILT EXPERIMENTAL AIRCRAFT.



 I will email a copy of this table to any reader requesting it.

sales(at)6440autoparts.co
Guest

Posted: Thu Jan 17, 2008 12:18 pm Post subject: IFR GPS requirements

OC, I did a quick Google and came up with 

http://www.rainierultralightengines.com/forms/Minimum_Inst_Requirements.pdf



By Owen C. Baker, that,s the one, aint it ? Might save you a lot of time 

sending out individually.



Randy

---

flagstone(at)cox.net
Guest

Posted: Thu Jan 17, 2008 12:20 pm Post subject: IFR GPS requirements

Ditto



Mark

---

gaillard.peck.ctr(at)nell
Guest

Posted: Thu Jan 17, 2008 1:57 pm Post subject: IFR GPS requirements

I have prepared a table that serves as a quick reference on this

subject:

 	  Quote: 	
		   >

 > MINIMUM INSTRUMENT AND EQUIPMENT REQUIREMENTS FOR POWERED AMATEUR

 > BUILT EXPERIMENTAL AIRCRAFT.

 >

 > I will email a copy of this table to any reader requesting it.


	


Me too!



Gaillard.peck.ctr(at)nellis.af.mil



Thanks,



Gail Peck

RV-8 (tail almost complete)



--

wgill10(at)comcast.net
Guest

Posted: Thu Jan 17, 2008 2:09 pm Post subject: IFR GPS requirements

I'd like a copy please. Thanks.



Bill



--

NYTerminat(at)aol.com
Guest

Posted: Thu Jan 17, 2008 2:10 pm Post subject: IFR GPS requirements

I would like one too please.

  

 Bob Spudis

  

 In a message dated 1/17/2008 3:02:06 P.M. Eastern Standard Time,  grosseair(at)comcast.net writes:

  	  Quote: 	
		  -->    Avionics-List message posted by: John Grosse    <grosseair(at)comcast.net>



I'd like a copy please.



John    Grosse



 	  Quote: 	
		  



 I have prepared a table that serves as a    quick reference on this subject:



 MINIMUM INSTRUMENT AND    EQUIPMENT REQUIREMENTS FOR POWERED AMATEUR 

 BUILT EXPERIMENTAL    AIRCRAFT.



 I will email a copy of this table to any reader    requesting it.

	

	


 

  



Start the year off right.  Easy ways to stay in shape in the new year. 

  [quote][b]

longg(at)pjm.com
Guest

Posted: Thu Jan 17, 2008 2:42 pm Post subject: IFR GPS requirements

Gail,

It's probably easier to post it, but yes, I'd like a copy.



Thanks



Do Not Archive



--

jfrjr(at)roadrunner.com
Guest

Posted: Thu Jan 17, 2008 5:08 pm Post subject: IFR GPS requirements

Please send me a copy.  Jay Rowe jfrjr(at)roadrunner.com

  ---

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bakerocb

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

Posted: Fri Jan 18, 2008 6:27 am Post subject: IFR GPS requirements

1/18/2008



Hello Glen, You are absolutely correct and I apologize for that moment of 

weakness when I wrote to just avoid the ignorant bureaucrat.



If we don't (politely) confront these people who are misusing their 

position, either out of ignorance or ego, we will suffer further abuses down 

the line.



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

understand knowledge."



--------------------------------------------------



From: "glen matejcek" <aerobubba(at)earthlink.net>

Subject: AeroElectric-List: RE: IFR GPS requirements

Hi Bill et al-



Re:  >Hello Bill, Avoid that poor soul -- he has not been around long

enough or

 	  Quote: 	
		  cared enough to learn that type certificated aircraft and amateur built

experimental aircraft are treated very differently in the FAA's paperwork

system.


	


While I greatly appreciate and highly regard and respect the source of that

comment, I couldn't disagree more.  If this inspector has run 50

unnecessary 337's through the system, he has cost a lot of people a lot of

money, spread misinformation across the system, and will no doubt cause

other improperly educated or motivated inspectors to take the

'conservative' (ignorant) route at our collective expense.  In other words,

there has been a gross misuse of governmental power.  These kinds of topics

have gone to DC and back via OSH, and we have the tools to correct the

problem you are facing.



My personal experience with an amateur built rule hose-up was to be very

(politely) clear with the person involved about the nature and basis for

our disconnect, and then call OSH with the details.  Within 24 hours they

had achieved understanding with the head of the directorate involved, and

within another 24 the fed involved had been re-educated.  That ended the

problem for me, and, presumably, everyone who came along after.



Also, the feds now have a program to handle customer service issues in

house.  As I understand it, it's the equivalent of 'let me speak to your

supervisor', although I don't recall the precise terminology.  Mike, can

you fill us in?



While I don't advocate getting into hostile conflicts with The Man, I

strongly urge you (and anyone else having bogus reg interpretation issues)

to fight the good fight with the resources we have developed and paid for

through our EAA dues and those gate fees at OSH we are all unhappy about.

Heck, Brian got a law in Jacksonville repealed with a little help from his

friends.  What's one confused inspector?



glen matejcek

aerobubba(at)earthlink.net

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