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Lynn,
I believe that the information you are looking for was summarized by
Linda Abrams in the post I pasted below.
John Roach
N 2427 H
[COUPERS-TECH] Answers Re: TSO/Non-TSO
Linda Abrams
Fri, 12 Jan 2007 00:07:28 -0800
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Ed and All,
Here's what I've learned from several reliable sources on non-TSO'd radios;
nice that it's all starting to converge, finally.
I remain surprised that to date there doesn't seem to be an authoritative --
much less a comprehensive -- article addressing this subject. I suggested
such an article to Mary of the EAA magazine, and she said she will consider
doing a published article, clarifying all this. Ditto when I talked with
Rodney, the A&P in AOPA's Aviation Dept., that AOPA will consider it, too.
All of the next 6 points below are per Joe Norris at EAA: [NOTE WELL: ALL of
the discussion below applies ONLY to radios; he said there are different
rules for transponders, encoders & ELTs. N.B. further: it assumes you are
flying only VFR; there are different rules for IFR aircraft. Mix these up
to your sorrow. I'm not addressing IFR below, it is beyond my needs to
figure that one out. ]
The pecking order to check whether your VFR aircraft needs a TSO'd radio
is:
1) Check its certification basis. For Ercoupes, this is CAR4a. See whether
it HAS ANY radio requirements. (For Ercoupes, probably not, ergo N/A ?
Though I haven't looked yet...)
2) Check its Type Certificate. (For Ercoupes, probably ditto, though I
haven't looked yet...)
[Ed, I think you said you'd read through one or both of these; perhaps you
could insert a comment here?]
3) Check the general FAA & FCC Regs. Joe Norris says NOTHING in FAA regs
says a radio needs to be TSO'd, or even "meet requirements of TSO'd", so
long as it is legal per FCC to operate as an aviation radio, then it's legal
to install in any aircraft, even certificated aircraft. Repeating: there
ARE NO requirements in the FARs for RADIOs for VFR use to be TSO'd. Joe
says he has read the regs thoroughly and says if someone tells you to the
contrary, get them to state where in FARs it says so.
4) Caveat: some radio installation shops may THINK you need to have TSO'd
radios because their own internal repair station manual may only allow the
shop to put in TSO'd radios, so the shop folks assume it's because there's
FAA regs requiring it, when it's only their own shop internal requirements.
[I did talk to a shop today that appears to recognize this, and says they
have no problem installing non-TSO'd radios.]
5) You may not even need a 337. Those forms address the installation
process, NOT the radio itself, and are only needed at all IF the
installation involves a "major structural change." Putting the radio into
an existing hole, or hanging it beneath the panel does NOT need a 337.
Similarly, if you're putting a new antenna into an existing antenna mount
location, its not a "major structural change," therefore no 337 needed.
6) If your installation does not involve a "major structural change," all
you need is a logbook entry by the A&P who did it, plus (if necessary) a
weight & balance adjustment & equipment list adjustment (if your plane has
an equipment list).
I have also asked the AOPA legal services attorney who was so VERY
knowledgeable and helpful to me last summer, with all the Qs I had
surrounding acquisition of my 'Coupe. He is currently swamped, but will
look into the issue. I did read him my report of Joe Norris's remarks,
above, so he'll be on the same page we are whenever he gets back to me. One
caution he did have for us: even though a 337 may not be legally necessary
if all you're doing is putting a radio into an existing hole in the panel,
or hanging it underneath, without making any major alterations, you may well
run into people who THINK it is legally necessary, and so filing a 337
anyway, just as a precaution to have it in your files, may prevent a bump in
the road later on (for example, when you sell and your buyer has a
pre-purchase inspection).
Then "Rodney," an A&P in AOPA's Aviation Dept., also looked into this for
us. He called back today, saying he had checked with the:Aircraft
Electronics Association he said they confirmed to him that there is NO
requirement for a COM-only radio to be TSO'd. The Federal Communications
Commission does get into the act regarding frequency tolerances, and as we
already know, one can check the Bad Radios list on the FCC website. But
using a non-TSO'd radio in a certificated aircraft is not an FAA violation.
And lastly, one of our own sent an answer on that issue from a former A&P/IA
who is now a FSDO inspector. Since his answer agrees with what I got from
EAA & AOPA, I feel no need to seek his name, rank or serial number:
"If the radio is installed for a VFR application, it is a logbook entry and
doesn't have to be TSO'd. The ICOM A-200 is a good example. ICOM makes 2
flavors, TSO and non-TSO. For an IFR installation, where the radio is
required for IFR purposes, it will generally need to be TSO'd. In an Ercoupe
with a non-TSO, a logbook entry by an A&P is all you would need. No
Airworthiness Inspector would hammer an Ercoupe owner over a non-TSO'd radio
installation if it was installed correctly and documented...it would
actually be a step up from what we normally see in Part 91 airplanes, with
owners installing electrical stuff without the first idea of what they're
doing. If the owner ever has a pilot deviation and radio communications is
determined to be a factor, they would check the installation closely...but
TSO would not be an issue. "
And so, following all of this, Linda went out and bought a new XCOM radio
(not TSO'd). I hope to have someone install it next week, and I'll tell
you how it does. I think I'm now done with this issue...unless the AOPA
Legal Services guy gets back to me with anything different (but I don't
expect it will be). If he does, I'll post an update, but otherwise, no news
is good news.
Linda
[EMAIL PROTECTED] wrote:
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advice in this forum.]----
Hey Gang: Some time ago we had a discussion about TSO'd and non TSO'd
instrument requirements. As I remember, one of our group came up with
the FAA paragraph's that specifically spelled out the use of those
items. I saved the message, but unfortunately for me, my computer
bombed last fall, and I lost all of the saved messages before then.
I have reviewed most of last years Tech messages, and did not find
what I was looking for. Does anyone have the answer? I know there was
considerable discussion about radios. but I am specifically concerned
about instruments.
Lynn
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