I just got my RVSM Manual 2 weeks ago for my CE-501
FAA told me that now, as long as I meet the RVSM requirements and equipment, the only thing different today is I would not need the LOA
Nothing else changes at this time

The underlying assumption is that the error is proportional. It may not be. But I like the general idea for low 30s checking at FL280.

The problem is, though, you still don't have a way to check at FL280. Maybe ATC can get access to the ASE for you? Anybody know?

Mike C.

The underlying assumption is that the error is proportional. It may not be. But I like the general idea for low 30s checking at FL280.

The problem is, though, you still don't have a way to check at FL280. Maybe ATC can get access to the ASE for you? Anybody know?

Mike C.

It doesn't quite work that way. I tested an altimeter this morning that was dead nuts on from -1000 to 18K. It went off the rails after that. -50 at 20K. -75 at 22K. -150 at 25K. +20 at 30K. Happens all the time.

Some of the voices on BT say that ADS-B grants you permission to fly above 28K if your autopilot works and your altimeter is accurate. I disagree. The intent of the new reg is to eliminate the LOA requirement. Not circumvent the accuracy requirements. You still need the proper equipment. Don't take my word for it though. Don't take Mr. C's word either. Call your FSDO and find out what they say. Their opinion is the only one that matters.

The underlying assumption is that the error is proportional. It may not be. But I like the general idea for low 30s checking at FL280.

The problem is, though, you still don't have a way to check at FL280. Maybe ATC can get access to the ASE for you? Anybody know?

Mike C.

FSDOs get things wrong, too, as evidenced by the interpretations varying by district around the country.

There are a fair number of people saying the airplane certification part has not changed. They have not read the rule carefully.

Mike C.

Wait until Jan 22, 2019.

Document the required equipment in section 9(a).

Dual altimetry systems (dual static ports systems?)

Video the AP holding altitude within 135 ft in smooth air.

Show alerter at +/- 300 ft.

Have 1090ES ADS-B out.

Document AFM limitations allow > FL280.


FAA starts enforcement actions, present your evidence to the administrative law judge, and show that you complied with the regulation on a point by point basis.

If the FAA meant the equipment list in section 9(a) wasn't sufficient to fly in RVSM airspace, then they wrote the rule WRONG.

Mike C.

FSDOs get things wrong, too, as evidenced by the interpretations varying by district around the country.

There are a fair number of people saying the airplane certification part has not changed. They have not read the rule carefully.

Mike C.

I don't see how you reached that conclusion.

Section 2 now says:

SECTION 2. AIRCRAFT APPROVAL
(a) Except as specified in Section 9 of this appendix, an operator may be authorized to conduct RVSM operations if the Administrator finds that its aircraft comply with this section.

Note the exception for section 9.

Section 4 now says:

SECTION 4. RVSM OPERATIONS
...
(2) The aircraft—

(i) Has been approved and complies with Section 2 this appendix; or

(ii) Complies with Section 9 of this appendix.

Note that the aircraft no longer needs approval to operate under section 9, just that it complies. Note that section 2, the old way, requires approval. That's a BIG change.

Section 9 says (pertinent to pre 1997 without TCAS II):

An operator is authorized to conduct flight in airspace in which RVSM is applied provided:

(a) The aircraft is equipped with the following:

(1) Two operational independent altitude measurement systems.

(2) At least one automatic altitude control system that controls the aircraft altitude—
(ii) Within a tolerance band of ±130 feet...

(3) An altitude alert system that signals an alert when the altitude displayed to the flightcrew deviates from the selected altitude by more than—
(i) ±300 feet

(5) Unless authorized by ATC or the foreign country where the aircraft is operated, an ADS-B Out system that meets the equipment performance requirements of § 91.227 of this part.

It is now a simple list of equipment, just 4 things.

Aircraft approval has changed.

Mike C.

Their opinion is also an opinion until clarified by writing a question to and response from the chief counsel...

The language Mike cites is pretty straightforward. I think folks in the broader FAA just haven’t caught on to its implications yet. I suspect whoever wrote it knew what they were doing though.

Jim Marks was in charge of this. He is with FAA in Washington. He usually replies. Mike please email him and let us know his response. This way you can get all your questions answered.

james.marks@faa.gov

The chief counsel also produces an opinion.

What is binding (unless appealed) is the decision from an ALJ. An ALJ has to rule on the basis of the language, not what the FAA intended or thought it had written.


It's hard to view it as an accidental oversight since the aircraft approval change appears multiple times throughout the language and consistently allows section 9 equipment without an approval process, nor having "acceptable to the administrator" language.

Mike C.

My understand is that Jim is not considered essential staff during the shutdown and thus isn't working presently, so is unlikely to be responsive to his work email.

Further, whatever he says is not rule or official interpretation. The actual words are the rule and only an ALJ ruling is actually binding.

Mike C.

Agreed strictly legally, but it would probably be a pretty interesting perspective nonetheless.

One thing that I haven’t seen mentioned here for the new ruling is what I found in the fine print. TCAS II is required equipment. I don’t think many of us have that. Am I reading this correctly? TCAS II is different than just TCAS or a TAS system as many of us have. TCAS II gives you RA’s, Resolution Advisories.