From: [email protected]
To: [email protected]
Subject: RE: [ercoupe-tech] Re: TSO vs. Non-TSO Instruments
Date: Fri, 5 Feb 2010 05:34:59 -0600
If you file a 337:
8300.10 CHG 21
5. GENERAL.
A. Definitions.
(1) Acceptable Data. The drawings and
specifications necessary to define the configuration
and design features of the repair or alteration. These
drawings and specifications include information on
weight, balance, operating limitations, flight
characteristics, dimensions, materials, and processes
that are necessary to define the repair or alteration.
The following are examples of acceptable data and
may be used as a basis for developing approved data
to substantiate repairs or alterations:
(m) Data describing a part or appliance used
in an alteration which is FAA-approved under a Parts
Manufacturer Approval (PMA). (An STC may be
required to obtain a PMA as a means of assessing
airworthiness and/or performance of the part.)
To: [email protected]
From: [email protected]
Date: Fri, 5 Feb 2010 03:57:55 +0000
Subject: [ercoupe-tech] Re: TSO vs. Non-TSO Instruments
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.
> >
>
>
>
>
>
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