Seems to me like this is the root of what needs to be better defined... any references on what makes an aircraft RVSM compliant? Does it still need to be explicitly STC’d as such? I’m sure plenty of training options will crop up to make “knowledgeable pilots”.

Seems to me like this is the root of what needs to be better defined... any references on what makes an aircraft RVSM compliant? Does it still need to be explicitly STC’d as such? I’m sure plenty of training options will crop up to make “knowledgeable pilots”.

Seems to me like this is the root of what needs to be better defined... any references on what makes an aircraft RVSM compliant? Does it still need to be explicitly STC’d as such? I’m sure plenty of training options will crop up to make “knowledgeable pilots”.

What about operating in the Caribbean and Mexico? Still require an LOA?

I think the equipment portion HAS changed, specifically how it is approved or not.

Previously, section 2 required the Administrator to find your aircraft has meet the RVSM requirements. This was done by TC, STC, SB, etc. The section 2 language is now:

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.

Now, section 9 has NO such language about the administrator. Merely a list of performance criteria. The Administrator doesn't approve the aircraft any more, the aircraft simply has to comply with the criteria in section 9. Section 9:

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 flightcrew 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.

By my reading of the rule, an owner/pilot could simply go through their aircraft and check off they meet the requirements, and then go fly in RVSM airspace, no STC, TC, SB required.

For pre 1997 aircraft, the checklist is pretty simple:

1. Two altimeters.
2. AP holds altitude with +/- 130 ft in altitude hold mode.
3. Altitude alert at +/- 300 ft.
4. TCAS II (if TCAS equipped, many owner flown planes aren't).
5. 1090ES ADS-B out (which we need anyway).
6. ASE within 200 ft.

Most can check off the first five just by inspection and an operational check. The last one is trickier, but can be done by certain tests.

I do not think you need an RVSM STC kit any more, just an airplane equipped to meet the criteria. This is because section 9 has no "acceptable to the Administrator" clause or requirement unlike section 2, the old way.

Mike C.

That last one was always the hard part, it is 99% of an RVSM STC

But you don't need an STC, just check you meet the requirement.

In fact, an OEM could simply test a type, publish an SB that says "the type as an ASE that is under 200 ft at RVSM altitudes". Done. No STC required.

Mike C.

But you don't need an STC, just check you meet the requirement.

In fact, an OEM could simply test a type, publish an SB that says "the type as an ASE that is under 200 ft at RVSM altitudes". Done. No STC required.

Mike C.

Not yet. No guidance has been released that I'm aware of. Until we get that all we have is the rule itself, in the text Mike C. provided.

I'm cautiously optimistic that Mike's interpretation is nearer the mark than Terry's. Certainly Terry's claim that "the equipment portion has not changed" can't be true, as the new Sec. 9 is an alternative for aircraft approval to the previous Sec. 2, which would be pointless if it were unchanged. For reference, the old (existing) rule is here: https://www.law.cornell.edu/cfr/text/14 ... to_part_91
The existing Sec. 2 very clearly specifies "The applicant for authorization shall submit the appropriate data package for aircraft approval" and that "to approve an aircraft … the Administrator must find" that it complies with the requirements.

In the new Sec. 9, all of this language is absent. It only specifies what standards the equipment must meet, it says nothing about proving to anyone that it meets those standards. It doesn't even say how to prove that it meets those standards. Will it be like 3 landings in 90 days before carrying passengers, no paperwork required? Or signed off by the IA at the annual? Nobody really knows yet. Until guidance is published, some time after Jan 20th, that's where we stand.

But you don't need an STC, just check you meet the requirement.

In fact, an OEM could simply test a type, publish an SB that says "the type as an ASE that is under 200 ft at RVSM altitudes". Done. No STC required.

Mike C.

Do we have a definition of “altimetry system error” somewhere? Could I simply have my altimeter(s) tested to 35000’ and show the test card errors are less than 200’? Or is there a more concrete definition that encompasses more than that?

Do we have a definition of “altimetry system error” somewhere? Could I simply have my altimeter(s) tested to 35000’ and show the test card errors are less than 200’? Or is there a more concrete definition that encompasses more than that?

Most of the RVSM systems I've seen don't have electronic altimeters with calibration curves, so it must be possible with "natural" systems to do RVSM with tight enough tolerance.

Certainly that should be the case for turboprops looking to get into the low 30s, one would imagine as that is a lot easier than FL410.

Mike C.

Most of the RVSM systems I've seen don't have electronic altimeters with calibration curves, so it must be possible with "natural" systems to do RVSM with tight enough tolerance.

Certainly that should be the case for turboprops looking to get into the low 30s, one would imagine as that is a lot easier than FL410.

Mike C.