IFR with non-certified instruments?

[rhofacker]

Anyone know if it's leagle to fly IFR using uncertified EFIS (e.g. Blue Mountain, etc.) as primary flight instrumentation in homebuilt/experimental aircraft?

[Marc Zeitlin]

Anyone know if it's leagle to fly IFR using uncertified EFIS (e.g. Blue Mountain, etc.) as primary flight instrumentation in homebuilt/experimental aircraft?

Oh, boy. Here we go again with this :-). See:

 

http://members.eaa.org/home/homebuilders/faq/Equipping%20a%20Homebuilt%20for%20IFR%20operations.html

 

You might need to be a member and have a login to read this.

 

So, certification means nothing in a homebuilt, but that does NOT change the requirement to be equipped per 91.205, which explicitly states:

 

"Two-way radio communications system and navigational equipment appropriate to the ground facilities to be used."

[Wayne Hicks]

The bottom line is:

(1) All equipment as per 91.205.

(2) BMA, Dynon, Grand Rapids (and others) qualify as gyros.

(3) Equipment doesn't need to be TSO'd.

(4) GPS is for supplemental navigation unless it it approved for enroute, terminal, and approach IFR operations.

 

If you want to read the specifics, it's all explained on the EAA website. The following are excerpts from that article.

 

Blue Mountain asked the "gyro" question, and the FAA and EAA responses are posted on the BMA website.

 

Minimum Requirements;

-- In order for the aircraft to be approved for IFR operations, the OpLims must contain the following or a similarly worded statement: "After completion of phase I flight testing, unless appropriately equipped for night and/or instrument flight in accordance with 91.205, this aircraft is to be operated under VFR, day only."

 

-- the aircraft can be operated under IFR once the initial flight test period is complete, so long as it's equipped in accordance with 14 CFR Part 91, section 91.205. For IFR flight, the following instruments and equipment are required:

 

(1) Instruments and equipment specified in paragraph (b) and, for night flight, instruments and equipment specified in paragraph ©.

(2) Two-way radio communications system and navigational equipment appropriate to the ground facilities to be used.

(3) Gyroscopic rate-of-turn indicator

(4) Slip-skid indicator.

(5) Sensitive altimeter adjustable for barometric pressure.

(6) A clock displaying hours, minutes, and seconds with a sweep-second pointer or digital presentation.

(7) Generator or alternator of adequate capacity.

(8) Gyroscopic pitch and bank indicator (artificial horizon).

(9) Gyroscopic direction indicator (directional gyro or equivalent).

 

-- What is a gyro? Any instrument that performs the function of the required gyroscopic instrument and presents info to the pilot in the same manner as the gyroscopic instrument will meet the requirement of 91.205, regardless of what mechanical or electronic means are used to generate the information and display. So BMA, Dynon, Grand Rapids EFIS can all be used.

 

-- What about TSO's? 91.205 makes no reference to TSO, Experimentals thus, the answer is NO, the instruments and equipment installed in your homebuilt under the requirements of 91.205 are not required to be "TSO'ed".

 

-- Transponders: While 91.205 doesn't list the transponder as required IFR equipment, 91.215 requires you to have one to navigate in/out of major IFR airspace. You don't have to have a TSO'd xponder!

 

-- GPS: A homebuilt with only a GPS installed would not be legal for IFR operations. Per Part 91.205(d), you must have the other "two-way radio communications system and navigational equipment appropriate to the ground facilities to be used. If you're going to file /G, your GPS and its installation must be certified for enroute navigation and if you want to shoot approaches, certified for terminal and approach navigation.

 

....Wayne Hicks

[rhofacker]

So, to fly IFR enroute, terminal and non-precision approaches I need a GPS certified to TSO C-129 Class A AND an aircraft specific certification by the FAA of the installation? (i.e. UPS GX-50, King KLN-89B, etc.)

 

I didn't see any info on whether or not the Blue Mountain (et. al) EFIS "GPS" was certified to the necessary TSO C-129 Class A for an IFR certified installation. Any body know?

[Marc Zeitlin]

So, to fly IFR enroute, terminal and non-precision approaches I need a GPS certified to TSO C-129 Class A AND an aircraft specific certification by the FAA of the installation? (i.e. UPS GX-50, King KLN-89B, etc.)

You do NOT need an aircraft specific certification - just equipment that meets the requirements. For ANY approaches, you will need a VOR in the plane (ref. the "ground based" requirement) - this is why the Garmin 430 etc. have a VOR built in.

 

I didn't see any info on whether or not the Blue Mountain (et. al) EFIS "GPS" was certified to the necessary TSO C-129 Class A for an IFR certified installation. Any body know?

The BMA unit is not certified in any way.

 

However, what the rules say is that the equipment must meet the TSO C-129A _standards_, NOT that it has to be certified in that category. __IF__ the BMA equipment meets the standards, you can use it (although you might have an argument on your hands if you ever have an accident and the FAA investigates). BMA will NOT tell you to use their stuff for IFR.

[Wayne Hicks]

The BMA GPS does not qualify as a certified GPS unit. You can only use it for supplemental navigation information (just like any other VFR panel-mount of handheld). You cannot file /G with it. You cannot shoot any approach with "GPS" in the title.

 

I don't remember the exact TSO and FAR numbers, but AIM Section 1 is very clear about the use of GPS for IFR operations. It must be certified to the FAA's standard to use it as the primary method of navigating enroute and for appproaches.

 

Heed also what Marc is saying. ATC expects you to be able to navigate on Victor airways. If you use GPS for primary navigation, YOU STILL MUST HAVE the traditional VOR capability as the backup.

 

If you must file an alternate airport, one only served by an ADF approach, then you must have an ADF receiver in the plane.

 

I've only got a limited amount of money to throw around. It is because of these little FAA IFR nuances that the money's going toward some type of IFR cert'd GPS rather than EFIS. I'm not going to have an ADF in the plane.

[rhofacker]

-- GPS: A homebuilt with only a GPS installed would not be legal for IFR operations. Per Part 91.205(d), you must have the other "two-way radio communications system and navigational equipment appropriate to the ground facilities to be used. If you're going to file /G, your GPS and its installation must be certified for enroute navigation and if you want to shoot approaches, certified for terminal and approach navigation.

 

....Wayne Hicks

 

Yeah, I see what you're saying: "your GPS and its installation must be certified for enroute navigation" That means: TSO-C129 certified (that makes sense). Now about that installation. If you bought the homebuilt the installation must be accomplished by Type Certificate, Supplimental Type Certificate, or Form 337 just like any other store bought airplane. That means your installation would have to be installed by an A&P and approved by the FAA and have appropriate justification on the Form 337 (similar acft, etc.) and that might mean getting a "First Time Air Worthiness Approval" (MUCH testing )depending on the GPS and the airplane and if it's been done/approved before.

 

But what about an airplane you built yourself? In general do you need 337s for major alterations and repairs to an airplane you built yourself? How do you get an STC for an airplane you built yourself?

 

We need a lawyer to explain all this Help!

[Wayne Hicks]

Sorry, I may have thrown you and with the words "certify" the "installation". An A&P is not required to "certify" our "installations."

 

When you put a GNS 430 in an Archer (for example), some A&P's gotta go up in the plane and VERIFY the INSTALLATION is working properly. I'm not sure of the paperwork involved, be me thinks there's a procedure followed and a form that gets filled out. The A&P also puts an entry and his/her signature into the plane's logbook TESTIFYING that the INSTALLATION was VERIFIED as FUNCTIONING properly.

 

As homebuilders, our process is a bit more loosey-goosey, but nonetheless important. As the builder, we must still VERIFY that the INSTALLATION is FUNCTIONING properly. (Or at least we're SUPPOSED to do that. It amazes me how many of us fly the 40-hour test period and don't test a damned thing except verifying the airplane doesn't fall out of the sky.....but that's another soap box.)

 

I'm not there yet, but I fully intend to follow the recommended in-flight checkouts (TBD). As the builder, we're still responsible for making the entry into our logbooks.

 

The certified guys must also insert the GPS operator's manual and its operating limitations as a supplement into the Pilot's Operating Handbook. I'm not sure if that's regulatory for homebuilts, but me thinks that's a good idea too.

 

Wayne Hicks