IFR requirements

[Krynn]

Originally Posted by Indytim

Don't forget about IFR currency requirements. You need 3 types of approaches in real or sim conditions every 6 months. I don't think you can accomplish that, in your aircraft, with just GPS.

Three types of approaches? Hrm... Are you thinking of an Instrument Proficiency Check? If I recall correctly, all that's needed for currency is to log in the previous 6 months the following items: at least 1 hold, at least 1 intercept, and at least 6 instrument approaches (type not specified). If you're beyond 6 months, you've got another 6 months to get back current on your own by flying and logging the above items. If you go beyond 12 months, then you need to get an IPC done, which would require the 3 different types of approaches and the appropriate navigation instrumentation to do those.

[Indytim]

Originally Posted by Krynn

Three types of approaches? Hrm... Are you thinking of an Instrument Proficiency Check? If I recall correctly, all that's needed for currency is to log in the previous 6 months the following items: at least 1 hold, at least 1 intercept, and at least 6 instrument approaches (type not specified). If you're beyond 6 months, you've got another 6 months to get back current on your own by flying and logging the above items. If you go beyond 12 months, then you need to get an IPC done, which would require the 3 different types of approaches and the appropriate navigation instrumentation to do those.

You're right, I was wrong. I was thinking of the IPC.

61.57 Recent flight experience: Pilot in command.
c) Instrument experience. Except as provided in paragraph (e) of this section, no person may act as pilot in command under IFR or in weather conditions less than the minimums prescribed for VFR, unless within the preceding 6 calendar months, that person has:
For the purpose of obtaining instrument experience in an aircraft (other than a glider), performed and logged under actual or simulated instrument conditions, either in flight in the appropriate category of aircraft for the instrument privileges sought or in a flight simulator or flight training device that is representative of the aircraft category for the instrument privileges sought --
At least six instrument approaches;
Holding procedures; and
Intercepting and tracking courses through the use of navigation systems.

[edneff]

I recently had a condition inspection performed on my RV-7 by an A&P, IA. I asked him to do a pitot static check and a transponder check so it would be legal for IFR, *just in case*.

He took the airplane to an avionics shop since he was not equipped to do the checks. The mechanic at the avionics shop would not do the pitot static check because he said the plane was not properly equipped for IFR. This guy claimed that a standalone attitude indicator was required.

The panel in the plane is a Stein Air panel with Dual Garmin G3x displays, a GTN650 and a second Com radio, along with a Garmin 330 ES xpdr... Either one of the G3X displays is capable of providing attitude info, slip skid, compass heading and rate of turn independently should the other one fail. Also a backup battery capable of providing 90 minutes of back up power to the entire system.

He cited some obscure (to me) FAR which seemed to apply to TC airplanes equipped with certified Garmin panels... Not having chapter and verse to cite, I did not argue except to say that I did not agree.... Needless to say I will not use this guy again, but WHAT ARE THE RELEVANT FAR'S that I need to cite?

[n82rb]

find a different shop. there is no requirement for a standalone indicator in a glass cockpit experimental. he is mistaken. I do believe there is such a thing in the STC to install the garmins in a TC aircraft, that is where he is probably getting that from. He could also be looking at 23.1311 which requires backup in a certified system, but we all know that section 23 does not apply to EAB only FAR91.205 needs to be satisfied.

bob burns
RV-4 N82RB

[sglynn]

I keep reading that in order to be legal IFR we need to use TSOed GPS. Really? Nothing else in the experimental aircraft requiresTSOed equipment for IFR. (Transponder is for VFR). This EAA articles (link below) says as the builder we can certify our equipment meets TSO requirements but that is not the same thing as equipment that has been manufactured as TSOed.

https://www.eaa.org/en/eaa/aviation-...ifr-operations

Am I reading this correctly? Seems like the EFIS manufacturers Dynon, Grand Rapids, G3X etc, could help us self certify that our equipment can meet TSO requirements and then we can certify our home builts as IFR legal airplanes.

Right?

[BobTurner]

That is basically correct. The FARs in part 91 say "suitable" navigation equipment. You then have to turn to FAR 1.1 (definitions) which says nothing about VOR or ILS or ADF etc but does define "suitable Rnav including gps". Basically it says suitable is whatever the FAA says it is in their non regulatory publications like AIM and advisory circulars. This makes these usually non regulatory publications regulatory, for ifr gps! The legal phrase is "regulatory by reference". There are other examples in the FARs.
Can we self certify? The answer is yes, you can state the box meets the TSO requirement even if the manufacturer does not. In principle. But in practice TSO145/146 is so complicated that no mere mortal could answer 'yes, it meets the TSO requirements' honestly. I heard that Garmin, King, etc., spent tens of million dollars on engineering time demonstrating compliance. Even then, they had to get a waiver/AMOC on a bunch of stuff. Look in the front of a Garmin gps installation manual for details. The TSOs are incredibly complex. I know GRT attempted to certify a lower cost ifr gps; as far as I can tell that project proved too complex, and is on the back burner now.
BTW, transponders and, starting in 2020, ADSB-out boxes, must also 'meet the requirements' of a TSO. At least one manufacturer is testing the waters with an ADSB-out box that they claim 'meets the requirements' but does not actually have a TSO. So far, the FAA seems okay with it, as far as I can tell.

[RV7A Flyer]

Originally Posted by sglynn

I keep reading that in order to be legal IFR we need to use TSOed GPS. Really? Nothing else in the experimental aircraft requiresTSOed equipment for IFR. (Transponder is for VFR). This EAA articles (link below) says as the builder we can certify our equipment meets TSO requirements but that is not the same thing as equipment that has been manufactured as TSOed.

https://www.eaa.org/en/eaa/aviation-...ifr-operations

Am I reading this correctly? Seems like the EFIS manufacturers Dynon, Grand Rapids, G3X etc, could help us self certify that our equipment can meet TSO requirements and then we can certify our home builts as IFR legal airplanes.

Right?

Good luck with this. The GPS navigator needs to meet certain TSOs, and that means the electronics, the databases AND the software. I think it's academic whether it "meets the TSO" or "is TSO'd", since no homebuilder out there is going to test his equipment (antenna, cabling, electronics, displays, software, etc.) to a TSO C146 (and others) level.

[Walt]

Originally Posted by edneff

He took the airplane to an avionics shop since he was not equipped to do the checks. The mechanic at the avionics shop would not do the pitot static check because he said the plane was not properly equipped for IFR. This guy claimed that a standalone attitude indicator was required.

Interesting, doing an "IFR Cert" on the altimeter, encoder, static system and transponder per 91.411/91.413 has nothing to do with the aircraft being actually equipped for IFR. The "Operator" is responsible to ensure the aircraft is equipped as required for the flight. As a repair station I have no right, or obligation, to determine if the aircraft can actually be operated under IFR conditions.

As a repair station I don't ever certify any aircraft for IFR, I certify only that it passed the tests as required by 91.411, 91.413

[SteinAir]

Originally Posted by sglynn

.......Am I reading this correctly? Seems like the EFIS manufacturers Dynon, Grand Rapids, G3X etc, could help us self certify that our equipment can meet TSO requirements and then we can certify our home builts as IFR legal airplanes.

Right?

Not to be facetious here, but do you really want to be bombing along at 180+kts seeing traffic reports based on a GPS to and from other aircraft that have been "self certified" to be "almost as good because I think so" to keep you separated, or flying down through the clouds with something that might be "close" to accurate and the only way you really know is that you self certified that it is? This goes way beyond just hoping something is good enough and it is incredibly more complicated than simply being "almost just as good because I said so, or someone makes a statement on a website".....

To the other point, if your shop won't do a pitot static check because they think they need to worry about IFR "certification", then they are just either completely mis-informed, or incompetent. As Walt stated, that is not their job as part of that check - only to verify that the equipment as installed meets said aformentioned requirements of the test. Certified or not, a "shop" is not legally able to make your aircraft qualified from a legal standpoint....they can simply state that the installed equipment either passes/meets the published test requirements...or not.

I get calls from owners and other shops regularly and have to explain this to them. I've said it many times before and I'll say it again. CALL the shop you intend to use before you go there and verify they have a clue about experimental avionics and aircraft along with real world experience. If they don't, go to someplace that does.

Just my 2 cents as usual.

Cheers,
Stein