UAvionix install

[FlyingMonkey]

13 minutes ago, Ed Cesnalis said:

Tom, you are correct but that is ambiguous. Someone may rely on it when prosecuting enforcement but will they prevail?

Tango Sierra, I can't find a reg or an FAR but I think I found the rub. "The operating limitations issued to the aircraft as a part of its airworthiness certificate will include language that outlines the procedure for approval of a major change. The owner/operator needs to follow the procedure as outlined in the operating limitations if they want to incorporate a major change to the aircraft."  So maybe you could do what you want if you could get the operating limitations to be permissive enough?

It doesn't look like you could go for a retractable gear modification because you would not have been able to get the operating limitations that would permit included in your AW cert. 

 

 

PART 21—CERTIFICATION PROCEDURES FOR PRODUCTS AND ARTICLES

Subpart B—Type Certificates

§21.191   Experimental certificates. Experimental certificates are issued for the following purposes:

(i) Operating light-sport aircraft. Operating a light-sport aircraft that—

 

(1) Has not been issued a U.S. or foreign airworthiness certificate and does not meet the provisions of §103.1 of this chapter. An experimental certificate will not be issued under this paragraph for these aircraft after January 31, 2008;

(2) Has been assembled—

(i) From an aircraft kit for which the applicant can provide the information required by §21.193(e); and

(ii) In accordance with manufacturer's assembly instructions that meet an applicable consensus standard; or

(3) Has been previously issued a special airworthiness certificate in the light-sport category under §21.190.

 

Not ambiguous.  The regs you quote state "operating a light sport aircraft".  LSA is very clearly defined elsewhere in the FARs, and the minute you deviate from that definition (including adding retract gear), you are no longer "operating a LSA" and your E-LSA AW certificate is no longer in effect.  You have violated its terms and are out of airworthiness.  It's no different from installing a Dynon D-100 in a Skyhawk as a primary flight instrument.  It's not allowed under part 23, you have violated the terms of the AW certificate and the Skyhawk is no longer airworthy under Part 23.

 

[Ed Cesnalis]

3 minutes ago, FlyingMonkey said:

Not ambiguous.  The regs you quote state "operating a light sport aircraft".  LSA is very clearly defined elsewhere in the FARs, and the minute you deviate from that definition (including adding retract gear), you are no longer "operating a LSA" and your E-LSA AW certificate is no longer in effect.  You have violated its terms and are out of airworthiness.  It's no different from installing a Dynon D-100 in a Skyhawk as a primary flight instrument.  It's not allowed under part 23, you have violated the terms of the AW certificate and the Skyhawk is no longer airworthy under Part 23.

 

Your argument is correct but still argument, there is ambiguity.  The operating limitations is where the point becomes moot. You are poised to find out for yourself, do you think you can provide for mods at issue here?  Not really retract but adjustable prop, flap settings and more horse power are the obvious game changers. Your limitations have to be approved by a human being so anything can happen.

If I was the DAR I would want to limit modifications that increase performance or complexity for the reasons you state above. If enforcement comes into play I bet the operating limitations and the pilots privileges could/would be argued not the interpretation of operating as a light sport.

[Ed Cesnalis]

Example of gray area:

LSA is defined by weight, performance and complexity.  Make it a retract and its complex and not LSA right?  

Here's a gray area example, a little complexity like in flight operable louvers to enhance cooling.  Not LSA but we all envision this level of enhancement in our ELSA.

 

[SportFlyer1]

Hmm, my head is starting to hurt. Although I just recalled another random regulation tidbit. An E-LSA must be an exact duplicate of an existing S-LSA model. So a company cannot sell an E-LSA kit unless they certified an S-LSA first. The RV-12 is a classic case. The company builds mainly kits and wanted to sell an E-LSA plane, so they grudgingly had to go through the ASTM certification for the RV-12. I believe Dan Johnson does an extensive talk about this in his revue of the Arion Lightning, which is a plane you can buy as S-LSA, E-LSA or EAB ... some fun.

[FlyingMonkey]

16 hours ago, Ed Cesnalis said:

Example of gray area:

LSA is defined by weight, performance and complexity.  Make it a retract and its complex and not LSA right?  

Here's a gray area example, a little complexity like in flight operable louvers to enhance cooling.  Not LSA but we all envision this level of enhancement in our ELSA.

 

I honestly don't understand what you are saying.  Louvers do not increase performance, only cooling.  There is no way they would take the airplane out of LSA specs, so they are allowed.  The only gray area is that the FAA trusts that any changes you make are properly vetted to not take the airplane out of LSA spec.  For example, if you changed the reflex on your flaps to -12°, that is a performance change and you'd have to test the change to make sure performance stays within the LSA performance envelope.

[Ed Cesnalis]

26 minutes ago, FlyingMonkey said:

I honestly don't understand what you are saying.  Louvers do not increase performance, only cooling.  There is no way they would take the airplane out of LSA specs, so they are allowed.  The only gray area is that the FAA trusts that any changes you make are properly vetted to not take the airplane out of LSA spec.  For example, if you changed the reflex on your flaps to -12°, that is a performance change and you'd have to test the change to make sure performance stays within the LSA performance envelope.

You miss my message because you see LSA limitations as being performance related only but they have 4 areas, performance, weight, and complexity.

• Performance limitations 120kt and 39kts.
• Weight limitations 1320lbs
• Passengers - 2 seats
• Complexity limitations - retractable, in-flight adjustable prop, in fight adjustable 

My gray area example attacked complexity not performance because its more gray.  

 

The example being discussed is retract which is complexity not performance.

[FlyingMonkey]

4 minutes ago, Ed Cesnalis said:

You miss my message because you see LSA limitations as being performance related only but they have 4 areas, performance, weight, and complexity.

• Performance limitations 120kt and 39kts.
• Weight limitations 1320lbs
• Passengers - 2 seats
• Complexity limitations - retractable, in-flight adjustable prop, in fight adjustable 

My gray area example attacked complexity not performance because its more gray.  

 

The example being discussed is retract which is complexity not performance.

The only "complexity" items specified are ground-adjustable or fixed pitch prop, and fixed gear.  No other "complexity" items are mentioned.  It is a general principle of law that something that is not prohibited by law is assumed to be allowed.  Therefore, ANY modification that:

1) is not specifically addressed (gear, prop, etc);

AND

2) Does not take the aircraft out of LSA performance specs; 

is allowed.  There is nothing in the LSA definition that mentions anything adjustable in flight other than the prop and gear.  Would you consider carb heat or flaps to be "gray areas"?  After all, they are adjustable in flight!  

[Ed Cesnalis]

15 minutes ago, FlyingMonkey said:

The only "complexity" items specified are ground-adjustable or fixed pitch prop, and fixed gear.  No other "complexity" items are mentioned.  It is a general principle of law that something that is not prohibited by law is assumed to be allowed.  Therefore, ANY modification that:

1) is not specifically addressed (gear, prop, etc);

AND

2) Does not take the aircraft out of LSA performance specs; 

is allowed.  There is nothing in the LSA definition that mentions anything adjustable in flight other than the prop and gear.  Would you consider carb heat or flaps to be "gray areas"?  After all, they are adjustable in flight!  

You might have to go back to the discussions that resulted in the light sport rule to see that the intention behind limiting prop pitch adjustment, retract, and cooling louvers were to limit complexity.  Intent becomes less apparent when looking at the rule only.  

You have decided that only performance prop and gear are limited yet weight passengers and complexity are limited as well.

Another principal of law is that intent demonstrated during the drafting process can be used for clarification when litigated.   

I think we all know you won't get a jump seat installed yet it isn't specifically addressed or performance related.

[Ed Cesnalis]

26 minutes ago, FlyingMonkey said:

...  Would you consider carb heat or flaps to be "gray areas"?  After all, they are adjustable in flight!  

Flaps, carb heat and selectable fuel valves all existed during rule development and here the intent is that the benefit out-weighs complexity unlike retract.

We agree on in-flight prop so we agree on the concept of complexity we just don't agree that the line is non-ambiguous.

[FlyingMonkey]

What the rule intended doesn't really matter.  What matters is how the rule was written.  Words matter.

[Ed Cesnalis]

7 hours ago, FlyingMonkey said:

What the rule intended doesn't really matter.  What matters is how the rule was written.  Words matter.

There is case law in California with my name on it. The 3rd district created this bad law in order to force me to pay my ex-wife $4,000 / month in alimony even after she remarried.

The law is clear, alimony terminates upon remarriage and it takes 'magic language' to waive your right.

 

My wife alleged that intent overrid the language and that I could not rely on the law or the written agreement but had to look further into the drafting process and then argue intent.

I was screwed, I never intended such a thing, would any reasonable guy agree to that?

FAA enforcement might be litigated and its common for litigators to consider intent.  DARs have been around for a while and might be aware that the concern was unnecessary complexity.  

[coppercity]

On ‎7‎/‎31‎/‎2017 at 10:02 PM, coppercity said:

Slight delay as I decided to knock out the annual and 100 hr while things were apart.

Here are a few pics of the install so far.  I would estimate about 5-6hrs of install, some of that just deciding how to go about it.

I built up generic tray to mount the remote unit, and have room for other possible gadgets as they become available.   It also mounts like the old transponder tray and supports the comm radio.

Made a new center panel to cover the hole.

GDL 39 on the top of the mushroom.

The control head took place of the backup altimeter.

Update:

 

MRA approved!  I will be doing some testing on the new uAvionix Skybeacon (UAT) with the original Garmin 327 first but will go back and install this system once that is complete. 

[S3flyer]

Just curious -- the echoES transponder is no longer shown on the uAvionics website.  Is it no longer available?

[coppercity]

11 hours ago, S3flyer said:

Just curious -- the echoES transponder is no longer shown on the uAvionics website.  Is it no longer available?

Hi Dave,

 

uAvionix is working on some "new features" on the Echo ES, should have some info to release soon

[207WF]

Does MRA approved mean FD LOA? 

[Madhatter]

I am putting off ADSB out as long as possible. Talked to an air traffic controller a couple days ago and she said the talk among other controllers is ANY incursion into unauthorized airspace whether intended or accident will result in a violation notice. It will be easy for them now and the anonymous mode will still give them your N number. Those in high density aereas need to be very carefull. I'm afraid big brother (1984) is here.

[S3flyer]

Your controller friends are wrong on anonymous mode.  FAR 91.227 allows 978 UAT ADS-B Out equipment to transmit a self-assigned (randomized) 24-bit address and no call sign.

This is from the FAA's FAQ:  Additionally, GA operators that employ UAT transceivers have the option in VFR operations, when they are squawking 1200 and flying below FL180, to select "anonymous mode", which enables the transceiver to broadcast a randomized flight ID and pseudo-ICAO address. The transceiver reverts back automatically to the assigned ICAO address and default flight ID when the beacon code is changed from 1200.

[Madhatter]

Air traffic has the info on the address, it can be cross checked by atc. Your N number will not be seen by others but atc has access to it. And in addition to that all radar tapes are kept for 6 mos before being destroyed.

[Madhatter]

Yes I believe you are correct but my trust in the system is not solid, so we should soon see results in this. I have a friend who violated a small portion of Charlston SC class C, they tracked him all the way to DC and nailed him. He had to take a checkride after the violation time. I guess it depends on who the controller is and how busy they are and how bad a day he is having.

[S3flyer]

1 hour ago, Madhatter said:

Air traffic has the info on the address, it can be cross checked by atc. Your N number will not be seen by others but atc has access to it. And in addition to that all radar tapes are kept for 6 mos before being destroyed.

Nope.  The ADS-B data packet is very well defined and has only one location for the address.  This can be easily checked by reading the packet itself with any number of nearly freely available receivers and you can also build one yourself (https://flightaware.com/adsb/piaware/build).  I can also point you to software libraries that decode the message.  ADS-B is in the clear so there is no current way to hide another address.  Google RTCA DO-260B for details of the data packet.

This does not mean that ATC cannot track you.  They can simply follow the random N-number back until they land and ask someone at the airport the real N-number.  Probably easy to do at a towered airport.  Probably not so easy at a non-towered.  

[FlyingMonkey]

10 hours ago, S3flyer said:

This does not mean that ATC cannot track you.  They can simply follow the random N-number back until they land and ask someone at the airport the real N-number.  Probably easy to do at a towered airport.  Probably not so easy at a non-towered.  

So if you think you might have violated airspace, fly to a non-towered airport, descend to treetop level, then turn off ADS-B and transponder and change course to a different non-towered airport (still at treetop level) and land there.  Got it.   

Kidding of course.  The cure for this problem would seem to be not violating airspace!

[S3flyer]

5 minutes ago, FlyingMonkey said:

So if you think you might have violated airspace, fly to a non-towered airport, descend to treetop level, then turn off ADS-B and transponder and change course to a different non-towered airport (still at treetop level) and land there.  Got it.   

Kidding of course.  The cure for this problem would seem to be not violating airspace!

Andy, this is way too complex -- I plan on just programming in your N-number so I'll be golden as I bust through Class B's across the country 

[FlyingMonkey]

1 minute ago, S3flyer said:

Andy, this is way too complex -- I plan on just programming in your N-number so I'll be golden as I bust through Class B's across the country 

  Great idea.  Lots of good problem solvers on this forum!   

[Madhatter]

I suppose I will reconsider adsb. A few years ago I owned a limited avionics repair station and did a lot of transponder work and installs. I then gave the repair station to a friend who still has it but I never kept up with the new adsb technology. Some of the current avionics people I talk to don't seem to totally understand all the details. I guess I need to do some research and look at the details.

[coppercity]

Here is the updated Echo Esx available soon.  Combined the Echo transponder and dual band ADSB receiver. 

 

https://www.uavionix.com/products/echoesx/