That is exactly why the monitoring program exists - so that operators can verify that their ASE is compliant.

This is the root of the misunderstanding.

Compliant DOES NOT mean certified. “Aircraft design” DOES NOT mean certification.

If the FAA had intended to require certified, they would have used that word. They used compliant instead - over and over and over, including in the AC.

This is the root of the misunderstanding.

Compliant DOES NOT mean certified. “Aircraft design” DOES NOT mean certification.

If the FAA had intended to require certified, they would have used that word. They used compliant instead - over and over and over, including in the AC.

This is the root of the misunderstanding.

Compliant DOES NOT mean certified. “Aircraft design” DOES NOT mean certification.

If the FAA had intended to require certified, they would have used that word. They used compliant instead - over and over and over, including in the AC.

So there I was at FL280, staring at a weakening storm system of which I could *almost* get on top. "Just a thousand more feet should do it," I thought.

"Houston Center, Conquest five-kilo-echo, request non-RVSM flight level three-zero-zero," I confidently asked.

"Conquest five-kilo-echo, climb and maintain flight-level-three-zero-zero," came the quick response.

So there I sat, fat, dumb and happy at FL300, cruising on top of the storm system - until I switched frequencies to the next controller...

"Conquest five-kilo-echo, how did you get up there? You're not supposed to be at three-zero-zero...?"

And that, my friends, is how you fly in RVSM airspace in a non-RVSM Conquest. Only a few of us are trusted to do it.

When he asked how I got up there, I would have gone full on smartass...

No, it isn't. The FAA is very specific when it requires certification.

There are experimental aircraft with RVSM. That proves "aircraft design" doesn't mean "certified" since the aircraft isn't certified at all.

Mike C.

I don't think it is. Section 2 is the traditional RVSM certification path, the old way. It obviously still works to demonstrate the plane has the right equipment, but it isn't the only way.

Also, an AC is advisory. The words of the regulation are the legal requirements. Nothing in the rule says "certified". The rules says you must have certain equipment that meets certain performance criteria.

If you have the equipment and performance defined in section 9 of part 91 appendix G, you can go fly in RVSM airspace.

Mike C.

Are you saying just because you have the capability, you can do so, without taking the steps Jim took?

I don't think it is. Section 2 is the traditional RVSM certification path, the old way. It obviously still works to demonstrate the plane has the right equipment, but it isn't the only way.

Also, an AC is advisory. The words of the regulation are the legal requirements. Nothing in the rule says "certified". The rules says you must have certain equipment that meets certain performance criteria.

If you have the equipment and performance defined in section 9 of part 91 appendix G, you can go fly in RVSM airspace.

Mike C.

The stated intent of the new rule was to reduce the certification burden. If full certification is still required, then the new rule makes no sense at all. Of course, with government anything is possible.

The way it was explained to me over the phone is that the NAARMO list was to help reduce the certification burden by providing continuous monitoring of the ASE of all aircraft on that list while in RVSM airspace. You cannot get on that list without requesting it, and you must provide contact info. As so as NAARMO detects ASE out of compliance bounds, they contact you and you cannot fly RVSM again until you have found and fixed your problem.

NAARMO is providing continuous monitoring, not real-time monitoring. Their mandate says it’s supposed to be closer to real time but they haven’t been allocated the funds to do that. Your government at work, part II.

It’s possible I misunderstood the verbal conversations, so I’ve asked for confirmation of this in writing. I will post here when I have a reply.

That’s not what it says.

“ (b) The altimetry system error (ASE) of the aircraft does not exceed 200 feet when operating in RVSM airspace. “

That doesn’t say ASE must be in bounds for the entire flight envelope. It says you must be in bounds while operating in RVSM airspace. Most people do not operate in RVSM airspace at the extreme ends of the flight envelope. So… the text of the reg suggests that demonstrating via the NAARMO monitor that you meet the ASE during cruise flight - I.e. while operating in RVSM - is good enough.

That’s not what it says.

“ (b) The altimetry system error (ASE) of the aircraft does not exceed 200 feet when operating in RVSM airspace. “

That doesn’t say ASE must be in bounds for the entire flight envelope. It says you must be in bounds while operating in RVSM airspace. Most people do not operate in RVSM airspace at the extreme ends of the flight envelope. So… the text of the reg suggests that demonstrating via the NAARMO monitor that you meet the ASE during cruise flight - I.e. while operating in RVSM - is good enough.

The FAA published a document that disputes what some on here are claiming.

https://www.faa.gov/sites/faa.gov/files ... 242020.pdf

A couple of excerpts -

The FAA has observed operators of some aircraft (mostly Turbo-Props), certified to maximum altitudes which include RVSM flight levels that have not been previously operated or maintained as RVSM compliant, are considering RVSM operation. Aircraft having designs certified for RVSM, in accordance with Appendix G Section 2, at a minimum require inspection and testing to assure they meet the airworthiness requirements of their design.

Aircraft which have not been designed and certified for RVSM operations require evaluation by the operator to assure they are capable of meeting the 200 feet ASE standard in Appendix G, Section 9(b). This evaluation involves engineering analysis, flight-testing, and measurement of system level performance. Many individual operators may not be capable of performing this evaluation alone. For operators of aircraft without approved RVSM designs, the FAA recommends contacting appropriate engineering consultants to obtain the appropriate substantiating information required to determine RVSM compliance (See AC 91-85B, Authorization of Aircraft and Operators for Flight in RVSM Airspace – Chapter 2 – Aircraft Eligibility and Appendix A.7 – Altimetry System Performance Substantiation).

Most importantly -

Operation of an aircraft in RVSM airspace that does not meet the required ASE standard is unsafe and contrary to the regulations. ADS-B Out equipage as required by Appendix G, section 9 allows for enhanced monitoring of ASE performance but in no way assures ASE containment.

While in RVSM airspace during my test flights, I varied my speed from Vy (in climbs) to Vmo (in descents.) In level flight I ranged from LRC to max cruise. It’s easy to go through this entire range at multiple altitudes in one single flight.