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16 Apr 2024, 19:19 [ UTC - 5; DST ]


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 Post subject: Re: RVSM and ADSB
PostPosted: 03 Mar 2021, 22:28 
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Username Protected wrote:
Lots of regulations give criteria without process, so this isn't that unusual, in fact, most of the FARs are that way.

Mike C.


Exactly my point. And any of those that that affect airworthiness require FAA approval. The FAA is very clear that RVSM operation must have airworthiness approval, in addition to operational approval.


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 Post subject: Re: RVSM and ADSB
PostPosted: 03 Mar 2021, 23:22 
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Username Protected wrote:
The FAA is very clear that RVSM operation must have airworthiness approval

Quote where that is written.

Mike C.

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 Post subject: Re: RVSM and ADSB
PostPosted: 04 Mar 2021, 06:19 
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Username Protected wrote:
The FAA is very clear that RVSM operation must have airworthiness approval

Quote where that is written.

Mike C.


AC 91-85B

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 Post subject: Re: RVSM and ADSB
PostPosted: 04 Mar 2021, 09:33 
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Username Protected wrote:
AC 91-85B

Quote the exact passage.

Chapter 4 says the operator determines this under section 9:

"Operators and pilots seeking to operate in RVSM airspace under the provisions of part 91 appendix G, section 9 are not required to apply for authorizations. The operator or pilot needs to ensure all applicable requirements in part 91 appendix G to operate in RVSM airspace are met."

There's no "approval" in that chapter that I see.

Mike C.

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 Post subject: Re: RVSM and ADSB
PostPosted: 04 Mar 2021, 09:40 
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Terry,

Help me out here. Which part of the FARs do you think I violated or which part of the AC do you think wasn't followed correctly? I'm not trying to convince you I'm right, but I'm truly interested in knowing where I may have done it wrong.

The clip you put up earlier wasn't from the AC or the FARs - it was from a FAQ, and it was from a section about experimental aircraft.

My airframe is listed on an FAA document that says "All Aircraft present in this segment of the database have obtained RVSM Airworthiness approval." If I didn't get there correctly, I'd like to know how to do it right.

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 Post subject: Re: RVSM and ADSB
PostPosted: 04 Mar 2021, 12:39 
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Username Protected wrote:
Terry,

Help me out here. Which part of the FARs do you think I violated or which part of the AC do you think wasn't followed correctly? I'm not trying to convince you I'm right, but I'm truly interested in knowing where I may have done it wrong.

The clip you put up earlier wasn't from the AC or the FARs - it was from a FAQ, and it was from a section about experimental aircraft.

My airframe is listed on an FAA document that says "All Aircraft present in this segment of the database have obtained RVSM Airworthiness approval." If I didn't get there correctly, I'd like to know how to do it right.


You are right, that FAQ question mentions experimental, but they are just reiterating the same rules that apply to Part 23/25 aircraft.

Which airframe? The NAARMO report is just assuming that you followed the rules and you are part of a group. They don't check to see that you actually did.


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 Post subject: Re: RVSM and ADSB
PostPosted: 04 Mar 2021, 12:45 
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Username Protected wrote:
AC 91-85B

Quote the exact passage.

Chapter 4 says the operator determines this under section 9:

"Operators and pilots seeking to operate in RVSM airspace under the provisions of part 91 appendix G, section 9 are not required to apply for authorizations. The operator or pilot needs to ensure all applicable requirements in part 91 appendix G to operate in RVSM airspace are met."

There's no "approval" in that chapter that I see.

Mike C.


"Authorizations" is referring to the LOA, which is operational, not airworthiness. Chapter 4 says:

"4.1.1 Operators and pilots seeking to operate in RVSM airspace under the provisions of part 91 appendix G, section 9 are not required to apply for authorizations. The operator or pilot needs to ensure all applicable requirements in part 91 appendix G to operate in RVSM
airspace are met. The operator or pilot should:

1. Determine the aircraft is RVSM-compliant (see Chapter 2,
Aircraft Eligibility)
;"


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 Post subject: Re: RVSM and ADSB
PostPosted: 04 Mar 2021, 13:09 
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Username Protected wrote:
1. Determine the aircraft is RVSM-compliant (see Chapter 2,
Aircraft Eligibility)
;"


And Chapter 2 says:

"2.2.1 Aircraft may be produced RVSM-compliant or brought into compliance through the application of appropriate Service Bulletins (SB), Service Letters (SL), Engineering Change Orders (EO), or Supplemental Type Certificates (STC). For airworthiness guidance, see Appendix A, RVSM Airworthiness Certification.

2.2.2 To determine eligibility for RVSM operations, the limitations section of the Airplane Flight Manual (AFM) or AFM Supplement (AFMS) should indicate the aircraft has been determined to be capable of meeting the RVSM performance requirements of 14 CFR part 91 appendix G.
"


Last edited on 04 Mar 2021, 13:09, edited 1 time in total.

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 Post subject: Re: RVSM and ADSB
PostPosted: 04 Mar 2021, 13:09 
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Username Protected wrote:
Terry,

Help me out here. Which part of the FARs do you think I violated or which part of the AC do you think wasn't followed correctly? I'm not trying to convince you I'm right, but I'm truly interested in knowing where I may have done it wrong.

The clip you put up earlier wasn't from the AC or the FARs - it was from a FAQ, and it was from a section about experimental aircraft.

My airframe is listed on an FAA document that says "All Aircraft present in this segment of the database have obtained RVSM Airworthiness approval." If I didn't get there correctly, I'd like to know how to do it right.


Is your specific tail number on that list, or just the same “airframe” ?

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Tom DeWitt
Previous: TBM850/T210M/C182P
APS 2004


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 Post subject: Re: RVSM and ADSB
PostPosted: 04 Mar 2021, 13:15 
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Username Protected wrote:
Is your specific tail number on that list, or just the same “airframe” ?


Tail number and serial number.

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 Post subject: Re: RVSM and ADSB
PostPosted: 04 Mar 2021, 14:02 
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Username Protected wrote:
Is your specific tail number on that list, or just the same “airframe” ?


Tail number and serial number.


King Air 300/350? Maybe it is already certified. Anything in the AFM or an AFMS for RVSM?

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 Post subject: Re: RVSM and ADSB
PostPosted: 04 Mar 2021, 14:09 
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In Jim's case, what about this section from AC 91-85B for group approval planes:

A.3.1.4

4. The avionics units installed on each aircraft to meet the minimum RVSM
equipment requirements (see paragraph A.4) should be manufactured to the
manufacturer’s same specification, and have the same equipment part number
and software part number (or version and revision).
Note: Aircraft which have avionics units which are of a different
manufacturer or equipment part number, software part number (or version and
revision) may be considered part of the Group if the applicant demonstrates to
the appropriate FAA office this standard of avionic eq


How do you go about demonstrating the standard to the FAA office? Seems like a NAARMO altitude monitoring test may suffice? Doesn't give much color here


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 Post subject: Re: RVSM and ADSB
PostPosted: 04 Mar 2021, 14:20 
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Username Protected wrote:

King Air 300/350? Maybe it is already certified. Anything in the AFM or an AFMS for RVSM?


Terry, I think he was in a King Air 200. Regardless, almost all of them have a group approval. I think one question is if it's still considered in the group since avionics and AP have changed.

BE20s and BE30s are in Category 2 group approvals in this document. I understand that to mean as long as enough (60%) of them are monitored in a 2 year period, the group approval is valid


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 Post subject: Re: RVSM and ADSB
PostPosted: 04 Mar 2021, 19:17 
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Username Protected wrote:

King Air 300/350? Maybe it is already certified. Anything in the AFM or an AFMS for RVSM?


Terry, I think he was in a King Air 200. Regardless, almost all of them have a group approval. I think one question is if it's still considered in the group since avionics and AP have changed.

BE20s and BE30s are in Category 2 group approvals in this document. I understand that to mean as long as enough (60%) of them are monitored in a 2 year period, the group approval is valid


Group approval monitoring is something for the TC or STC holder to manage.

If your aircraft is in a group, the SB or ICA will specify the equipment needed.

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 Post subject: Re: RVSM and ADSB
PostPosted: 04 Mar 2021, 20:29 
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Username Protected wrote:
Is your specific tail number on that list, or just the same “airframe” ?


Tail number and serial number.


It was always my understanding that once your tail number was on that list you were an approved RVSM operator.

However, my device center guided the process and everything I learned about RVSM came when the LOA process was still in effect. I am very aware that things have changed, and I no longer have reason to stay abreast of the new rules.
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Tom DeWitt
Previous: TBM850/T210M/C182P
APS 2004


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