Details? What type plane? Equipment? Changes made to qualify? What was the process you went through?

Plane Type: King Air B200

Equipment: Dual G600, GDL-88, GTX-33ES, S-TEC 2100. It's up to you to determine if you have the necessary equipment, just like it's up to you to determine if your equipment makes you legal for IFR flight.

Changes made to qualify: Most planes that have the right equipment won't need any. The install shop that put in my GTX-33ES did not configure it properly 4 years ago. After a few hours with a new Garmin tech on a steep learning curve the configuration was fixed. If you have any latent ADS-B problems, you will see them on your public ADS-B performance report. You can request it here:
https://adsbperformance.faa.gov/PAPRRequest.aspx

Process step 1: Educate yourself about RVSM. You can do it on your own, but a lot of us generally like to CYA and get a fancy certificate. I actually learned a thing or two. Most courses are $100-300. I found this one for $39:
https://www.pilotproficient.com/courses ... g-program/

Process step 2: "Center, N12345 requests FL290 for 15 minute ADS-B test flight. Negative RVSM." I was turned down by one controller who said "If you're not RVSM, I can't clear you into RVSM airspace." This isn't correct - they can clear you, but they have to provide non-RVSM separation around you and their workload is higher. I didn't argue. I just waited for the next controller. It's not always possible, of course. I had the advantage of flying in the southwest at night - there's nobody else out here. It might be tough to do on the east coast during the day. For reasons related to the incorrect ADS-B configuration, I had to do multiple RVSM test flights.

Process step 3: Fill out and submit this form:
https://www.faa.gov/air_traffic/separat ... t_Form.pdf

Process step 4: Wait about a month. They're currently processing data from early January.

Process Step 5: Check for your tail number on the section 9 list here:
https://www.faa.gov/air_traffic/separat ... approvals/

The header on that list says "All Aircraft present in this segment of the database have obtained RVSM Airworthiness approval." There's healthy debate about what you need to do with *your* particular airframe & electronics configuration to maintain RVSM approval in terms of limitations and ICAs. That's obviously too much to go into here, but do your homework.

Because I did step 2 *before* I'd fixed my ADS-B issues, I ended up having quite a bit of communication back and forth with he NAARMO office by email. Everyone who replied was very helpful. Most operators will only need to do the test flight, submit the form, and wait for their tail to show up on the list.

Jim, do you have an RVSM installation STC or specifically RVSM approved equipment? Like a special altimeter, a static port mapping survey, etc? Or did you just go fly with ADSB and see if it worked?

None of the above. I did do a fair amount of research on the regs and my avionics setup before I decided to do the first test flight. From talking to other B200 operators, I decided a static port mapping survey was not needed. The B200 has dual cross-coupled static sources, as required.

The dual G600 setup is approved in several other RVSM STCs without modification to the G600s. You should review AC91-85B, section A.4.1 to confirm you have the minimum equipment, and section A.6 to confirm your particular installation is acceptable.
https://www.faa.gov/air_traffic/separat ... 91_85B.pdf

BTW, I found my ASE (error) was often zero and never more than 10 feet during my final ADS-B test flight. You don't get this info from a normal approval, but it came up during my exchanges with the NAARMO office. A pre-1997 aircraft is allowed 130 ft.

Jim, why did you feel compelled to do any test flight at all if your airframe is already on a group RVSM authorization? Assuming you have a 91.411 showing your new avionics reflect your static source's information similar to the prior "approved" altimeters (indicating similar static source mapping), the airframe has been proven already to comply with RVSM requirements.

If your AP wasn't holding +-130 feet, that's a different story, but that's not related to "unseen" ASE. That'd be an altimeter visibly bouncing around.



I'd want to do the same flight you did, but my plane is not part of a group or individual approval (Epic LT). It does, however, have all required equipment in 91 appendix G section 2 and can hold altitude +-65 feet in nonturbulent air.

I've been working with an approved engineering firm that specialized in RVSM flight test using trailing cones for ASE error. Just recently, they changed their process to use a carry-on GPS unit since the trailing cone setup is a pain on my plane. It'll probably be a unit similar to the E2GMU from CSSI, if not that exact unit.

Whether I decide to do a flight test on my own or I do flight test with approved engineering folks aboard, I'd still fly profiles that tests the full and basic RVSM envelope.

In plain English, I translate the full RVSM envelope to the following: you're testing a max altitude, slow and high airspeeds, at low and max weights.

What I don't understand is why that isn't laid out for an operator, just like criteria needed for an ADS-B performance report.

I'm a little worried that there's a conflict of interest coming from the engineering firm I'm working with. They've been great to work with, but it's not cheap at $18k, albeit significantly cheaper than pre-ADS-B tests where you're handed an STC when complete.

If a GPS box onboard helps, you can get a technician to fly out to you with an E2GMU, and suction mount some antennas on your plane for a test run for a few thousand bucks. That's a lot cheaper.

I'm also worried the FAA agencies/folks I've spoken with don't completely understand the difference between calculated ASE from a test flight and measured ASE with a trailing cone. AFAIK, calculated ASE is what's used for enforcement. Who cares how that differs from flight test?

Neema,

I don't believe my plane qualified under the group RVSM authorization. (I certainly may be wrong.)

I don't think the group approval included the specific combination of altimeters, transponder and autopilot that I have in my plane. I think that invalidates it for my airframe. Making sure that the autopilot flies properly in the cold thin air is just as important as making sure the ASE is within limits.

I completely agree with you that an Epic should go through a full RVSM test profile to the edges of the envelope. The single 15 minute flight at one weight & speed doesn't really cover it. I have been stepping up slowly - I've flown at 290, 300 and 310 with a range of weights and c.g.s but always at normal climb & cruise speeds. I haven't been above 310 yet - it's been too cold on the flights where I could have gone higher.

I also noticed very slight disconnects between the NAARMO/FAA folks and the "real world," but nothing that I considered worrisome.

Then on what basis do you believe your airframe is approved for RVSM?

Then on what basis do you believe your airframe is approved for RVSM?

Who did you use? AeroMech?

Who did you use? AeroMech?

What you have outlined is monitoring and operational approval, not airframe approval. This is from the FAA RVSM FAQ:

"An operator of a properly equipped and maintained aircraft with a certified RVSM design has reasonable assurance their aircraft ASE will not exceed 200’. An operator of a properly equipped and maintained aircraft that does not hold a RVSM certified design will need to complete appropriate engineering analysis and testing to assure their aircraft ASE will not exceed 200’. An aircraft operated as RVSM compliant (filing /W) under section 9 that exceeds 200’ ASE will be out-of-compliance with the rule and could also lead to investigation for reckless and or unsafe operations"

Who did your engineering analysis and testing?

I suspect we're going to end up disagreeing on the interpretation of Appendix G sections 2 and 9 here. Section 2 starts with "Except as specified in Section 9 of this appendix..." - and then section 9 is very straightforward.

I suspect we're going to end up disagreeing on the interpretation of Appendix G sections 2 and 9 here. Section 2 starts with "Except as specified in Section 9 of this appendix..." - and then section 9 is very straightforward.

It could be himself, no?

Section 9 gives criteria, but does not give process for assuring you meet criteria. I think some basic testing, which could be done by the operator themselves, could show you meet section 9 criteria. The criteria is not particularly obtuse or hard to measure.

Lots of regulations give criteria without process, so this isn't that unusual, in fact, most of the FARs are that way.

Mike C.

The section 9 list that you can get from the FAA has the header "All Aircraft present in this segment of the database have obtained RVSM Airworthiness approval."

If that's not correct, it's horribly misleading.

https://www.faa.gov/air_traffic/separat ... _SEC9A.pdf