All,
Let's try to follow a chain of logic here.
1. Each Ercoupe was manufactured and individually accepted by a
factory CAA designee as being in full
conformance with their type certificate before original sale.
None had "TSO'd" instruments of any kind. The
tachs, oil temperature, oil pressure and ammeter instrumentation
were automotive production items. So was
the upholstery and seat cushioning. Modern Lexan polycarbonate is
far superior to the original Vinylite used
for the original windows. So, if your mechanic can get an
installation signed off-it's "legal".
2. Along comes new technology called a transponder...required for
access into newly-exclusive air space.
So for access into said space, a transponder is required. Let's
also presume that for technical reasons,
the transponder needs to comply with some pretty specific
parameters to serve the purpose intended with
reasonable efficiency and reliability, and the same is true for
radios, both communication and navigation.
So everybody accepts that 90 or even 360 channels are no longer
sufficient, and that really good frequency
control is "necessary", so the "need" for TSO on such equipment is
not based on any airframe requirement,
but on an "integrity and utility of the system" basis.
If a non-TSO'd radio or transponder is OK for installation in a
"experimental" airframe, airbourne operation
of that unit is functionally the same in an Ercoupe or a
homebuilt. If it can "pass" an encoding check, it should
be signed off without some bureaucrat attempting to unilaterally
establish a "TSO-only policy that bypasses the
mandatory FAA rulemaking procedures and comment period(s).
3. Now along comes "in the bird" storm scopes and collision avoidance
systems. Do these "for pilot eyes only"
installations have to be TSO'd? Not if you can get them signed
off. They are a desirable improvement to safe
operation, but not required. Desirable, but optional.
4. For supplemental gyro horizons, and heading indicators, turn
coordinators, T&B indicators, EGTs, CHTs, ice
detectors, angle of attack indicators, outside air temperature
indicators, suction gauges, fuel lines & clamps,
firesleeve & clamps, brake fluid, fuel pump repair kits, GPS
units, supplemental compasses, timepieces, strobes,
intercoms, headsets, and autopilots etc. are all options that do
NOT replace original equipment and are NOT
required that are clearly desirable to encourage owners to install
to improve safety.
Arbitrarily mandating that these items be the more expensive TSO
variety clearly raises the price of installation
and maintenance sufficiently to discourage installations. If the
FAA's "purpose" in "regulating interstate
commerce" is safety, and if present FAA policy has the effect of
discouraging even one such installation because
of increased cost, it would seem time for we, the people, to
demand reconsideration and redefinition of any FAA
mission and policy-making priorities and procedures that similarly
discourage improving the safety of flight.
We might even demand that the various regions get their respective
acts together and give pilots "due process"
and "equal protection" under the (same) law" our constitution
purports to guarantee each and every one of us.
(off soap box)
William R. Bayne
.____|-(o)-|____.
(Copyright 2009)
On Mar 10, 2009, at 00:42, heavensounds wrote:
Ed
What Al is saying is that his particular FSDO says a transponder can
not be certified for the encoding check if the altimeter does not meet
the TSO standards. Perhaps that makes sense for an IFR transponder
certification, but not for a VFR transponder certification?
Regardless of what makes sense, and regardless of what the regulations
say, in the real world, the interpretation of the local FSDO is what
rules.
I am not saying that's correct, nor that I agree. It's just reality.
If your local FSDO says you need TSO'd instruments in a particular
application, you better have TSO'd instruments, even if the
regulations don't support that.
This is the mathematical formula. Bureaucrats + power = abuse.
Eliacim
----- Original Message -----
From: Ed Burkhead
To: 'A.J. Demarzo'
Cc: [email protected]
Sent: Monday, March 09, 2009 10:09 PM
Subject: RE: [ercoupe-tech] altimeters
Al,
I can see justification for requiring that a transponder be TSOd. A
bad transponder doesn’t just mess up its own plane, it could, in
theory, lock up the entire transponder system in that area. Bad juju
in a controlled airport situation.
When it comes to transponders, how can an inspector know it “meets
the requirements” of the TSO if it doesn’t have the TSO
certification? So, your “jerk” requires that TSO certification.
However, this doesn’t apply to an altimeter or any other instrument
in the Ercoupe, at least not for our kind of flying.
Are we agreed that for instruments other than transponders, no TSO is
required? (Note that Linda has already jumped through the hoops to
figure out TSO requirements for the com radios.
http://edburkhead.com/Ercoupe/radio_tso_requirement.htm )
Ed
