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Gang, Most of the information in question is available through the FAA's website www.faa.gov AC23-21 is a good reference to have handy (although it is only one of several pieces of information needed/available). Tom > ----[Please read http://ercoupers.com/disclaimer.htm before following any > advice in this forum.]---- > > > 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 > > ----[Please read http://ercoupers.com/disclaimer.htm before following any > advice in this forum.]---- > > > > 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: >> ----[Please read http://ercoupers.com/disclaimer.htm before following >> any 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 >> >> >> >> ------------------------------------------------------------------------ >> AOL now offers free email to everyone. Find out more about what's free >> from AOL at *AOL.com* <http://www.aol.com?ncid=AOLAOF00020000000339>. >> ============================================================================== >> To leave this forum go to: http://ercoupers.com/lists.htm >> >> >> >> > > ============================================================================== > To leave this forum go to: http://ercoupers.com/lists.htm > > > > ============================================================================== To leave this forum go to: http://ercoupers.com/lists.htm
