Bill, Same thing. Hearsay-- Show me where in FARs it says any instrument has to be PMA'ed for installation in a CAR-3 or CAR-4 certified aircraft operated under Part 91 unless it replaces a PMA'ed instrument specified in the Type Certificate. Our aircraft have no such requirement.
PMA is a manufacturing standard, not a stand-alone requirement. Dave --- In [email protected], Bill BIGGS <webacr...@...> wrote: > > > If the instrument is FAA-PMA it is OK. Example: there are two versions of the > KX170B, if you look on the faceplate some have TSO. > > > Bill > > > To: [email protected] > From: bigbrownpi...@... > Date: Thu, 4 Feb 2010 16:22:04 +0000 > Subject: [ercoupe-tech] TSO vs. Non-TSO Instruments > > > > > > Folks, > > I decided to revive this thread based on some additional information Vince > Hammons found in AC 43.13-2A, Chapter 11, Adding or Relocating Instruments. > Paragraph 212 states "First, determine what regulation (CAR 3, 4b, FAR 23 25, > etc.) is the basis for the type certificate. That regulation establishes the > structural and performance requirements to be considered when instruments are > to be added or relocated." It then goes on to discuss how to determine > structural integrity and location. Under Paragraph 212 b. (1), it states "In > the absence of specific requirements, installation of IFR flight instruments > in a "T" arrangement is recommended. Under Paragraph 213 INSTALLATION, it > says "Mount all instruments so they are visible to the crewmember primarily > responsible for their use." The chapter continues discussing vacuum gyro > installation requirements, markings and placards. > > Not to belabor the point, but in the absence of any instruments or > requirements in the Type Certificate, this chapter provides the approved data > for non-original instrument installations in our aircraft. Again, I can find > no reference to TSO requirements for aircraft certified prior to Part 23 and > aircraft that never had TSO instruments originally installed under the type > certificate. (The possible exception being the altimeter in cases where it > interfaces with the transponder due to the requirement for the transponder to > meed TSO standards). I could even make the case for Part 23 aircraft that > there is no requirement for TSO instruments unless the Type Certificate > specifically requires them, and that any additional instruments that are > added, but do not replace TSO instruments do not have to be TSO'ed. > > I'd welcome a discussion of any different opinions based on FACT, not > word-of-mouth ("My mechanic or FBO told me it has to be TSO..." "The catalog > says it's non-TSO, for Experimental Aircraft Only" are hearsay, IMO). Also, > I'd love to hear from A.I.'s with different opinions and how they arrived at > them. I'm taking an extremely narrow, legalistic view here. Ultimately, it is > up to the owner/operator and his/her A&P/A.I. to determine what they will > install and sign off; and to submit the appropriate documentation (some will > say that a 337 isn't even required because it is not a major modification). > Basically, if you can't find someone to do the work and sign it off as a > legal installation, you're toast! But based on the research Vince and I have > done, we're comfortable installing a TruTrak ADI in my Ercoupe that did not > have an attitude indicator/gyro horizon, as well as adding a dual Westach oil > pressure/oil temperature gauge and a Westach CHT/EGT gauge. > > YMMV. > > Best, > Dave > > --- In [email protected], "bigbrownpilot@" <bigbrownpilot@> wrote: > > > > > > I spoke to Peter Heffly yesterday about his installation of a Daynon > > D-100 in Don Kuehl's Ercoupe. Peter runs the avionics shop at Granbury > > Regional (KGDJ), and Don's airplane was based there until he sold it > > recently. > > > > Peter is reading the applicable regulations and coming to the same > > conclusion as many of us-- there is no requirement for TSO equipment in > > the Ercoupe. > > > > Here are the facts: > > > > 1. The FAA is clear, TSO is NOT a stand-alone requirement for Part 91, > > Small Aircraft. It may be required for aircraft under part 135 or for > > certain types of operations, or for specific equipment (transponders, > > ELTs, etc.) TSO is a manufacturing standard. > > > > 2. The Ercoupe line was certified under CAR-3 and CAR-4a. The airplane > > was equipped with basic instruments (altimeter, airspeed, VSI, heading) > > that were NOT TSOed. The standard and requirement for certified > > aircraft did not exist at the time. > > > > 3. FAR Part 23 does not supercende the certification in TCDS A-718 or > > A-787 > > > > 4. FAR 91.205 does not require any of the instruments to be TSOed. In > > fact, many Ercoupes continue to fly with just the basic (Non-TSO) > > equipment listed. > > > > 5. FAA approval is still required to install equipment in a certified > > production aircraft. A 337 submitted by a licensed mechanic that is not > > returned as disapproved by the FAA constitutes approval. > > > > Therefore, Peter concludes that installing a Dynon in an Ercoupe is > > authorized as long as it does not replace any of the equipment that the > > Ercoupe was certified with. > > > > YMMV-- as in Prof. Ed's case, some avionics shops and A&P's simply > > aren't willing to assume the liability for a non-TSO installation. And > > some simply fall back on the generalization that TSO equipment is > > required in a production aircraft. But I have yet to find anything that > > specifically prohibits installing a non-TSO part in an aircraft operated > > under Part 91 (with the exceptions noted) as long as you are not > > replacing a TSO part that was originally part of the TCDS. Of course, > > you still have to get FAA approval. > > > > P.S.-- We had the same kind of "word of mouth" regulations in the Air > > Force that were wrongly interpreted. They actually taught us at CCTS > > that you could not do a 360-degree turn in cell formation, when the > > actual restriction was no 360-degree turns during stream operations. > > Two entirely different things-- basically you could not do a 360-degree > > turn when there was another 3-ship cell behind you (streams of 3-ship > > bomber formations flying into combat or during an ORI), but an > > individual cell 360 was allowed. > > > > > > > > _________________________________________________________________ > Hotmail: Trusted email with powerful SPAM protection. > http://clk.atdmt.com/GBL/go/201469227/direct/01/ >
