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 Post subject: RVSM and ADSB
PostPosted: 09 Dec 2018, 22:36 
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Does anyone know if the FAA has eliminated the LOA application process for ADSB equipped aircraft?


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 Post subject: Re: RVSM and ADSB
PostPosted: 09 Dec 2018, 23:11 
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Not yet, maybe this summer????


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 Post subject: Re: RVSM and ADSB
PostPosted: 10 Dec 2018, 02:08 
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The NPRM came out in 2017, https://www.federalregister.gov/documen ... d-vertical
Final rule supposed to be implemented by end of this month but of course there's no punishment if they miss the deadline.


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 Post subject: Re: RVSM and ADSB
PostPosted: 10 Dec 2018, 11:38 
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Michael, if you are Soliatire shopping, if the rsvm change happens it becomes the best t prop ever. Becomes very efficient at 31k


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 Post subject: Re: RVSM and ADSB
PostPosted: 10 Dec 2018, 18:28 
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Username Protected wrote:
Michael, if you are Soliatire shopping, if the rsvm change happens it becomes the best t prop ever. Becomes very efficient at 31k

That's not what the NPRM says... Alas, the MU-2 will never be RVSM capable, ADS-B or not.

Basically the proposal is to eliminate the paperwork approval the operator of the aircraft has to get. It does not eliminate the requirement for RVSM certified and capable equipment in the airplane. The problem with old airplanes is the RVSM altimetry equipment requires possible changes to the aircraft static system (and skin around static ports...), as well as autopilot hold capability that has tight tolerance, etc.

From the document linked by Dave (my bold & italic):

SUMMARY:
This proposal would revise the FAA's requirements for application to operate in RVSM airspace. The proposal would eliminate the requirement for operators to apply for an RVSM authorization when their aircraft are equipped with qualified ADS-B Out systems and meet specific altitude keeping equipment requirements for operations in RVSM airspace. This proposal recognizes the enhancements in aircraft monitoring resulting from the use of ADS-B Out systems and responds to requests to eliminate the burden and expense of the current RVSM application process for operators of aircraft equipped with qualified ADS-B Out systems.

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 Post subject: Re: RVSM and ADSB
PostPosted: 10 Dec 2018, 18:51 
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I have been waffling between an MU-2 and another kick the can down the road (600 hours til death) Citation II. I had a lot of fun in the I and gained a lot of experience so the faster, higher, further II is a logical step. The II is waas, ADSB, Garmined and I've got my single pilot waiver so there's no training to do. We have a pile of II parts making the ownership experience cheap. The MU-2 is totally unknown and would require learning how to fly it along with the 50 hour "danger period" any new aircraft entails. I think I'm going to get the II as my serious travel need has declined to probably 50 hours a year. The fuel savings on the Solitaire do not outweigh the training and the speed/comfort of an old Citation for as little as I fly.

This II has been a fun project. We bought it without engines (well it had rental motors) and a bad tail (failed NDT inspection). It came off a 135 and has had excellent maintenance and only 7,500 hours. We purchased one of TR Wright's US customs Citations from the US Marshalls and installed the government motors and horizontal tail on it. All money went towards restitution BTW. No major inspections until 2020.


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 Post subject: Re: RVSM and ADSB
PostPosted: 10 Dec 2018, 18:56 
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Username Protected wrote:
(600 hours til death) Citation II.

How much does 600 hours worth of Citation II cost? And what's included? It seems like a viable strategy for someone willing to take on the hassles of restoration and upkeep. Also requires an airport where a jet is viable.

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 Post subject: Re: RVSM and ADSB
PostPosted: 10 Dec 2018, 19:47 
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Username Protected wrote:
(600 hours til death) Citation II.

How much does 600 hours worth of Citation II cost? And what's included? It seems like a viable strategy for someone willing to take on the hassles of restoration and upkeep. Also requires an airport where a jet is viable.


I own the hangar it is sitting in at the semi-private airport that's 3,900 feet (plenty). It has anti-skid and TRs. It's a nice airplane with decent paint and interior (8) , nice glass, really nice panel (2 530Ws, ADSB, GMX200). The project part is finished and it's flying. Phase 1-IV due in late 2019 and Phase V due in late 2020 so nothing serious due. The spread between purchase and part out is about $75,000 so that's $125 an hour. It trues out at 378 at FL280 (don't have the RVSM LOA yet). It does not seem to burn any more fuel than the Citation I on a per mile basis. The only downside is, it's freakin' HUGE.

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 Post subject: Re: RVSM and ADSB
PostPosted: 11 Dec 2018, 01:59 
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Username Protected wrote:
Basically the proposal is to eliminate the paperwork approval the operator of the aircraft has to get. It does not eliminate the requirement for RVSM certified and capable equipment in the airplane.

Not sure that's true.

Read this in the NPRM:

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.


Section 2 is the traditional RVSM aircraft approval process. If you comply with section 9, your AIRCRAFT doesn't have to go through section 2, so no RVSM approval for the aircraft.

Section 4. RVSM Operations

(1) The operator is authorized by the Administrator to perform such operations in accordance with Section 3 or Section 9 of this appendix, as applicable.

(2) The aircraft—

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

(ii) Complies with Section 9 of this appendix.


Your aircraft either meets section 2 (old style RVSM approval) *OR* meets section 9.

And here is section 9:

Section 9. Aircraft Equipped With Automatic Dependent Surveillance—Broadcast Out

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—

(i) Within a tolerance band of ±65 feet about an acquired altitude when the aircraft is operated in straight and level flight under nonturbulent, nongust conditions; or

(ii) Within a tolerance band of ±130 feet under nonturbulent, nongust conditions for aircraft for which application for type certification occurred on or before April 9, 1997 that are equipped with an automatic altitude control system with flight management/performance system inputs.

(3) An altitude alert system that signals an alert when the altitude displayed to the flight crew deviates from the selected altitude by more than—

(i) ±300 feet for aircraft for which application for type certification was made on or before April 9, 1997; or

(ii) ±200 feet for aircraft for which application for type certification is made after April 9, 1997.

(4) A TCAS II that meets TSO C-119b (Version 7.0), or a later version, if equipped with TCAS II, unless otherwise authorized by the Administrator.

(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. The aircraft must have its height-keeping performance monitored in a form and manner acceptable to the Administrator.

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


Unlike old style which required specific approval of an RVSM system design, section 9 states criteria that you need to meet, but an FAA approval is not one of them.

Basically, go down the checklist, if you can check each box, you are good to go.

In rough terms, for pre 1997 type basis airplanes:

Dual altimeters.
Autopilot that can hold altitude within 130 ft in smooth air.
Altitude alerter at 300 ft off.
ADS-B out.
Altimeter errors under 200 ft.

That's it. I'd think a Solitaire could do all the above quite easily with stock setup.

This is such as sane proposal, it provides real time monitoring of altitude so we no longer need to assure that through design and certification.

I expect this to trickle down to transponder mode C checks someday and eliminate that, too.

Mike C.

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 Post subject: Re: RVSM and ADSB
PostPosted: 11 Dec 2018, 02:26 
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Username Protected wrote:
Not sure that's true.


(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. The aircraft must have its height-keeping performance monitored in a form and manner acceptable to the Administrator.

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


Unlike old style which required specific approval of an RVSM system design, section 9 states criteria that you need to meet, but an FAA approval is not one of them.

Wow, that’d be great. How do we know the altimetry system error, though? Is that part of the pitot-static test, or something that must be certified during design?

Why does ADSB enable this? I thought ADSB merely reported what the aircrafts altimeter was at. Does it somehow enable something external to verify the accuracy of that report?

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 Post subject: Re: RVSM and ADSB
PostPosted: 11 Dec 2018, 02:59 
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Username Protected wrote:
Basically, go down the checklist, if you can check each box, you are good to go. In rough terms, for pre 1997 type basis airplanes:
Dual altimeters.
Autopilot that can hold altitude within 130 ft in smooth air.
Altitude alerter at 300 ft off.
ADS-B out.
Altimeter errors under 200 ft.
That's it.
My reading is the same as Mike's. The only question the NPRM doesn't address is how to show that each component meets the required performance.


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 Post subject: Re: RVSM and ADSB
PostPosted: 11 Dec 2018, 07:55 
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I would think “Altimeter errors under 200 ft” will be the biggest problem. Uncorrected altimeters up that high have large errors. How many MU-2’s have the equipment to achieve the less than 200 foot error?

Bottom line I believe is that you will still need the same equipment but not all the paper.


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 Post subject: Re: RVSM and ADSB
PostPosted: 11 Dec 2018, 08:10 
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Username Protected wrote:
I would think “Altimeter errors under 200 ft” will be the biggest problem. Uncorrected altimeters up that high have large errors. How many MU-2’s have the equipment to achieve the less than 200 foot error?

Bottom line I believe is that you will still need the same equipment but not all the paper.


Agreed. But the new language does open the door for alternative ways of demonstrating the errors. In the late '90s I was involved in Duncan Aviation's RVSM cert program. I argued for WAAS GPS measurements correlated against sounding balloons carrying WAAS GPS. Wasn't able to convince enough people that it was viable and the program went with the traditional towed static line.

With all the ADSB equipage, it is now much easier to demonstrate the ASE errors.


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 Post subject: Re: RVSM and ADSB
PostPosted: 11 Dec 2018, 18:09 
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I feel like in a few years if you put a garmin panel in a Solitaire you would be able to get this certification.

At ISA, going from FL280 to FL310 is a ~10% drop in fuel flow with a 1% drop in speed.


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 Post subject: Re: RVSM and ADSB
PostPosted: 11 Dec 2018, 20:02 
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I know some KA300’s can’t get RVSM because of their autopilot installed.

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