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 Post subject: Re: RVSM and ADSB
PostPosted: 25 Jan 2019, 00:26 
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Username Protected wrote:
The aircraft design ensures the aircraft will meet RVSM performance requirements, and

The whole point of section 9 is to NOT require approval to enter RVSM airspace and to change the process from one of design compliance to monitoring compliance.

Well, I’m just trying to interpret what seem like somewhat mixed signals between section 9 and this AC.


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Or an outfit that simply tests your airplane to section 9 criteria and signs it off as being compliant with that.

Ok, that’d work. I think AFM Supplement might still need to be produced somehow.
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 Post subject: Re: RVSM and ADSB
PostPosted: 25 Jan 2019, 12:27 
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Username Protected wrote:
This is totally ripe for someone with a friendly FSDO to establish a program to flight test individual aircraft, sign it off on a 337 if the test works, generate the appropriate AFM supplement, and charge owners a dollar or two for it.


Individual aircraft have always had the option of certifying for RVSM, but it has always required an STC. I don't see anything in the new 91 Appendix G or the new draft AC indicating this will go away.


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 Post subject: Re: RVSM and ADSB
PostPosted: 25 Jan 2019, 12:52 
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Username Protected wrote:
I don't see anything in the new 91 Appendix G or the new draft AC indicating this will go away.

Disagree, I agree with Mike that the language of the changes indicates a very different system for RVSM operations (checklist of equipment, verified operational performance). I think the possible big change is that the aircraft might(!) not need modifying, but could be “verified” as compliant via the “Initial” RVSM flight described in the AC to collect the FAA data and generated report as described. If the report says OK, then good to go. If not... we’ll, then either design work might need to be performed, or the operator might choose to just stay at FL280. But the potential cost to “just check” goes way down. It does not require lots of DERs and design, just a flight with a data lookup afterwards.

The big problem is the first tests, no one wants to be first, as well as documentation, so a shop with a good FSDO relationship could get a tacit go ahead to do such flights and documentation, and sell owners essentially nothing but a big CYA package. I’d pay a couple grand for the ability to operate RVSM with a bit of CYA documentation thrown in. I would not pay $100s of grand for a big STC design project. That’s the opportunity, to my mind.

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 Post subject: Re: RVSM and ADSB
PostPosted: 25 Jan 2019, 13:06 
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Username Protected wrote:
I don't see anything in the new 91 Appendix G or the new draft AC indicating this will go away.

Disagree, I agree with Mike that the language of the changes indicates a very different system for RVSM operations (checklist of equipment, verified operational performance). I think the possible big change is that the aircraft might(!) not need modifying, but could be “verified” as compliant via the “Initial” RVSM flight described in the AC to collect the FAA data and generated report as described. If the report says OK, then good to go. If not... we’ll, then either design work might need to be performed, or the operator might choose to just stay at FL280. But the potential cost to “just check” goes way down. It does not require lots of DERs and design, just a flight with a data lookup afterwards.

The big problem is the first tests, no one wants to be first, as well as documentation, so a shop with a good FSDO relationship could get a tacit go ahead to do such flights and documentation, and sell owners essentially nothing but a big CYA package. I’d pay a couple grand for the ability to operate RVSM with a bit of CYA documentation thrown in. I would not pay $100s of grand for a big STC design project. That’s the opportunity, to my mind.


Believe me, I want it to be easy as bad as everyone else. But I don't see where in the Draft AC you are relieved of the aircraft RVSM cert. The new rules greatly simplify authorization and continued operations, but do not change the equipment requirements.

Can you point to the section in the draft AC that allows some simplified equipment cert?

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 Post subject: Re: RVSM and ADSB
PostPosted: 25 Jan 2019, 13:16 
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Username Protected wrote:
Can you point to the section in the draft AC that allows some simplified equipment cert?

No, but the language in the actual rule does not require some kind of equipment cert. It requires a performance standard to be met. It does not say how one must meet it. And “Advisory Circulars”, are, well, “advisory” just like the title says.

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 Post subject: Re: RVSM and ADSB
PostPosted: 25 Jan 2019, 13:20 
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Username Protected wrote:
Can you point to the section in the draft AC that allows some simplified equipment cert?

An AC can't trump the language of the rule.

Section 2 requires an aircraft acceptable to the Administrator.

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.

Section 9 does not. Just a list of equipment and criteria, no acceptable to the Administrator language.. If you have the equipment that complies with section 9, you are good to go.

If the FAA meant you still had to comply with section 2, they wrote the rule wrong. No amount of post rule interpretation can change the rule language.

The aircraft exception occurs in FOUR PLACES in the new rule.

Aircraft approval was taken out of section 1.

Section 2 gives the section 9 exception.

Section 4 makes it really explicit:

The aircraft—

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

(ii) Complies with Section 9 of this appendix.


And of course, section 9 doesn't have any approval language.

This is no typo, the FAA carefully went through the entire rule and excepted aircraft out of section 2 approval.

Mike C.

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 Post subject: Re: RVSM and ADSB
PostPosted: 25 Jan 2019, 14:46 
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I talked to a POI this morning who was doing a 299 checkride for us, and he said that with ADSB we are good to go in RSVM airspace as our airplane is equipped. Which is factory Collins ADC left and regular altimeter on the right, SPZ200 AP, 750+650 w/ADSB.

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 Post subject: Re: RVSM and ADSB
PostPosted: 25 Jan 2019, 14:54 
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Still some open questions but it looks positive enough that I put off painting long enough to add a second static port and line to the plane I'm building.


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 Post subject: Re: RVSM and ADSB
PostPosted: 25 Jan 2019, 15:36 
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Username Protected wrote:
I talked to a POI this morning who was doing a 299 checkride for us, and he said that with ADSB we are good to go in RSVM airspace as our airplane is equipped. Which is factory Collins ADC left and regular altimeter on the right, SPZ200 AP, 750+650 w/ADSB.

What aircraft? And is that package “certified” as RVSM (using the old rules)?

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 Post subject: Re: RVSM and ADSB
PostPosted: 25 Jan 2019, 15:39 
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Username Protected wrote:
I talked to a POI this morning who was doing a 299 checkride for us, and he said that with ADSB we are good to go in RSVM airspace as our airplane is equipped. Which is factory Collins ADC left and regular altimeter on the right, SPZ200 AP, 750+650 w/ADSB.

What aircraft? And is that package “certified” as RVSM (using the old rules)?

'82 B200, No it was never certified under the old rules.
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 Post subject: Re: RVSM and ADSB
PostPosted: 25 Jan 2019, 15:41 
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'82 B200, No it was never certified under the old rules.

Awesome! Did the POI say anything about looking at results of the FAA generated report after an initial RVSM flight?

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 Post subject: Re: RVSM and ADSB
PostPosted: 25 Jan 2019, 16:17 
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'82 B200, No it was never certified under the old rules.

Awesome! Did the POI say anything about looking at results of the FAA generated report after an initial RVSM flight?

No he didn't. Nor did he address the training requirement for 135 ops as referenced in the draft AC. But I didn't specifically ask about it either. I figure I'll wait till they get back to work and get things sorted out before I test the waters.
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 Post subject: Re: RVSM and ADSB
PostPosted: 25 Jan 2019, 18:50 
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Username Protected wrote:
No he didn't. Nor did he address the training requirement for 135 ops as referenced in the draft AC. But I didn't specifically ask about it either. I figure I'll wait till they get back to work and get things sorted out before I test the waters.


Hi Rick! Wouldn't you have to revise your training manual and GOM to reflect RVSM, if not in there already? More paperwork, but could be worth it.


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 Post subject: Re: RVSM and ADSB
PostPosted: 25 Jan 2019, 20:25 
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Username Protected wrote:

And of course, section 9 doesn't have any approval language.

This is no typo, the FAA carefully went through the entire rule and excepted aircraft out of section 2 approval.

Mike C.


No approval language because it is the operator approval that is removed. Under the previous scheme, the FAA had to approve the aircraft that was being used for RVSM by the operator.

You are confusing operator aircraft approval with RVSM equipment certification.


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 Post subject: Re: RVSM and ADSB
PostPosted: 25 Jan 2019, 21:21 
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Username Protected wrote:
No approval language because it is the operator approval that is removed. Under the previous scheme, the FAA had to approve the aircraft that was being used for RVSM by the operator.

You are confusing operator aircraft approval with RVSM equipment certification.

Have you read it all? If not, you should... don't take someone else's word for it, either me on an internet forum nor your local FSDO guy who also may not have read it.

It certainly doesn't read that way. Basically you can still do it the old way if you want, but the new way (section 9) doesn't require any of that - either equipment or operator approvals. It requires a certain list of equipment plus that equipment must meet a performance spec (autopilot altitude hold performance, altitude warning, plus the ASE thing that has been discussed). It does not say you have to have any specific certification of that equipment.

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