Vacuum system required for FIKI TKS

[gdwinc]

I was perusing the TKS supplement to my POH today and noticed that it included the following language:

"The following equipment must be installed and operational for flight into know icing conditions.... Dual vacuum pumps: M20R&S: Standard single pump installation, Standby Vacuum System Installation (860063-501)"

I read this that even if I installed a full glass panel and had no need for a vacuum system, I would have to keep both the standard vacuum pump and the electric standby vacuum pump operational.

I'm curious, have any other owners with a FIKI system deleted their vacuum system? 

[hais]

7 minutes ago, gdwinc said:

I was perusing the TKS supplement to my POH today and noticed that it included the following language:

"The following equipment must be installed and operational for flight into know icing conditions.... Dual vacuum pumps: M20R&S: Standard single pump installation, Standby Vacuum System Installation (860063-501)"

I read this that even if I installed a full glass panel and had no need for a vacuum system, I would have to keep both the standard vacuum pump and the electric standby vacuum pump operational.

I'm curious, have any other owners with a FIKI system deleted their vacuum system? 

Does the glass STC reference FIKI?

[gdwinc]

@hais That's a good question! I don't know if glass STC's reference FIKI.

I have steam gauges,  so at the moment I need my vacuum pumps. This becomes a more significant question for me as I contemplate the future of my panel.

[Mufflerbearing]

This is a great question.  To be FIKI, everything has to be doubled up and I wonder if this requirement is just to have dual vacuum if you have it.  Kind of like dual batteries, fiki pumps, and alternators.  To my knowledge, I don't believe there is anything directly related to the FIKI system that requires vacuum.  I too am interested in the answer to this question.

[StevenL757]

1 hour ago, gdwinc said:

I was perusing the TKS supplement to my POH today and noticed that it included the following language:

"The following equipment must be installed and operational for flight into know icing conditions.... Dual vacuum pumps: M20R&S: Standard single pump installation, Standby Vacuum System Installation (860063-501)"

I read this that even if I installed a full glass panel and had no need for a vacuum system, I would have to keep both the standard vacuum pump and the electric standby vacuum pump operational.

I'm curious, have any other owners with a FIKI system deleted their vacuum system? 

Ovation speed brakes (both the 100-series, and the 2000-series) are electrically-driven and not connected in any way to either the primary or standby vacuum systems on the Ovation.  I had a full glass airplane with suitable backup hardware to legally remove both vacuum systems before my airplane was sold, and my TKS supplement didn’t contain this language.

[ilovecornfields]

I don’t have a vacuum system in my FIKI Ovation. If the FAA wants to violate me for flying into known icing without a vacuum system on an airplane that has no vacuum operated equipment I think I would have some colorful language for them.

[gdwinc]

Thanks @ilovecornfields, it’s good to know there is at least one FIKI Ovation without a vacuum system!  Your logic makes perfect sense, and thus violation risk (or overzealous IA grounding risk) shouldn’t be an issue. 

[PT20J]

This is an interesting can of worms. I believe that FIKI is an FAA certification of a specific configuration of a specific make/model aircraft. Limitations listed in the AFM/POH are binding under FAR 91.9. Modifications to the aircraft that affect these limitations might void the FIKI certification unless approved by the FAA. I would think that the FAA would require some sort of validation that the modification had the equivalent or better level of safety/redundancy as the originally approved vacuum systems. Perhaps @Blue on Top might have some insights.

Skip

[V1VRV2]

Had my vacuum system pulled out during my panel renovation on my FIKI Ovation II last month. No one raised an eyebrow. Not my mechanic and not my avionics installer. Both are pretty thorough about legality. FIKI Ovation GX’s never had a vacuum system installed. Might want to check out the TKS Paperwork from that plane.

[larryb]

My dual vacuum system was removed 5 years ago in my FIKI Encore during my glass panel upgrade.

[Blue on Top]

11 hours ago, gdwinc said:

Thanks @ilovecornfields, it’s good to know there is at least one FIKI Ovation without a vacuum system!  Your logic makes perfect sense, and thus violation risk (or overzealous IA grounding risk) shouldn’t be an issue. 

Logic and the regulations don't necessarily go hand in hand.

This is a problem when multiple STCs, an STC and a Supplement, etc. are added to the same airplane.  For example, several Cessnas have wingtip extensions and they also have gross weight increases.  Installing both STCs is a bad idea and has never been proven that it is okay.  But, the FAA has nothing in place to stop those installations ... until one comes apart in flight.

My educated guess is that loss of attitude in FIKI conditions (and probably at night) was considered "catastrophic" (people or the plane will suffer fatal consequences).

I suggest calling the factory and talking to Kevin Hawley.  He is the Chief Engineer and was the person (from the TKS OEM) that was responsible for the original installation of the TKS system.  Because conditions have changed over the years (no vacuum AIs), the Supplement should be revised/amended to either remove that statement/limitation with a note, state why the limitation exists and/or state what needs to be accomplished today to remove that limitation.

Regretfully the limitation still exists.  It is unreasonable for an IA to know all the interconnections with various other systems are affected by the change they are making.  Legally still required ... until paperwork shows otherwise.  Court-wise is a totally different animal ... and normally not for the good.  Logic ... well ... the jury is more concerned about the best story teller.  Call Mooney. 

[N201MKTurbo]

Why don't your have your IA call the FSDO and talk to them about this. The old guys at least aren't idiots. They can tell you what needs to be done to make this right.

But as @Blue on Top says, having the people who wrote the original document revise it would probably slide through a lot smoother than any field approval. 

The question is, why would Mooney do it for you? Revising a document is a lot of work. Who is going to pay for it? Mooney is struggling financially. Perhaps you should ask Mooney for a quote for doing the work?

[CAV Ice]

M20M with G1000 (s/n 27-0318 & 27-0326 and on) no vacuum pumps required. M20R no vacuum pump required with G1000 (s/n 29-0333 and on). M20TN no vacuum pump required.

***This information comes from the CAV Aerospace FMS 8100-FMS STC SA00306WI.  If it is a factory installation refer to the Mooney FMS*** 

Edited November 12, 2021 by CAV Ice
Aftermarket vs. Factory install

[ilovecornfields]

23 minutes ago, CAV Ice said:

M20M with G1000 (s/n 27-0318 & 27-0326 and on) no vacuum pumps required. M20R no vacuum pump required with G1000 (s/n 29-0333 and on). M20TN no vacuum pump required.

***This information comes from the CAV Aerospace FMS 8100-FMS STC SA00306WI.  If it is a factory installation refer to the Mooney FMS*** 

Thank you. I think the question was regarding a non G1000 M20R with no vacuum system and whether this makes it “non FIKI.”

I don’t know about others but I have a G500, battery operated standby AI, AHRS on a FS210 and another backup AHRS on a Sentry which has its own battery and displays to my battery-powered iPad. If I lose all my attitude indicators then something bad has happened.

Maybe the vacuum system requirement was there to ensure you survive an electromagnetic pulse with your FIKI certification intact, although that certainly wouldn’t be my concern at that point.

[201er]

2 hours ago, ilovecornfields said:

Maybe the vacuum system requirement was there to ensure you survive an electromagnetic pulse with your FIKI certification intact, although that certainly wouldn’t be my concern at that point.

Lightning strike maybe?

[LANCECASPER]

15 hours ago, V1VRV2 said:

Had my vacuum system pulled out during my panel renovation on my FIKI Ovation II last month. No one raised an eyebrow. Not my mechanic and not my avionics installer. Both are pretty thorough about legality. 

I doubt they ever read the limitation about FIKI  needing vacuum pumps, but that doesn't change the TKS supplement in your POH. Whether anyone ever questions you about that remains to be seen. Just don't use an IA who thinks that way. In fact ask ahead of time if you are using someone that hasn't worked on the airplane before. Hopefully you can get a new supplement for your POH.

[CAV Ice]

[ilovecornfields]

1 hour ago, CAV Ice said:

@CAV Ice for the win!

Thank you for a great product and excellent and timely support. My son still loves his TKS titanium keychain,  by the way. 

[gdwinc]

Thanks to @CAV Ice for pointing out the note on the Type Certificate Data Sheet.  So, from a regulatory perspective, we have the TCDS authorizing the removal of the vacuum system, but don't we still have an issue with the Supplement for the FIKI system including the requirement for a vacuum system?  In reading the TCDS, it includes the placard language that flight into known icing is prohibited so we cannot rely on the TCDS alone.

[exM20K]

When I bought my TN, I was also looking at TN Bonanza's, and I recall the TKS FIKI had to be carefully sequenced before or after (don't remember) the TN STC.  Tip tanks also disqualified bonanza from FIKI.  At the end of the day, I decided the Mooney Acclaim G1000/FIKI was the more certain choice that better fit my mission.

-dan

Edited November 12, 2021 by exM20K

[Blue on Top]

6 hours ago, gdwinc said:

Thanks to @CAV Ice for pointing out the note on the Type Certificate Data Sheet.  So, from a regulatory perspective, we have the TCDS authorizing the removal of the vacuum system, but don't we still have an issue with the Supplement for the FIKI system including the requirement for a vacuum system?  In reading the TCDS, it includes the placard language that flight into known icing is prohibited so we cannot rely on the TCDS alone.

TCDS trumps ALL other documents!  Of course the documents should agree, but ...

One of my first tasks for Mooney-Kerrville with the Fort Worth ACO (while new at Mooney-Chino) was, as a Flight Analyst DER, to make the TCDS, POH and Garmin agree on all the limiting airspeeds.  They all need to agree, but ...

Great job, @CAV Ice.

[Ulysse]

You are considering installing a TKS system on your Mooney? I was told it costs around 75k ! I have been wondering if it is worth it or if it would be better to just buy an aircraft which has it already.

[LANCECASPER]

18 hours ago, Ulysse said:

You are considering installing a TKS system on your Mooney? I was told it costs around 75k ! I have been wondering if it is worth it or if it would be better to just buy an aircraft which has it already.

On Ovations Bravos or Acclaims yes, but since they only made 38 Encores including yours, and I'm guessing less than half had TKS (probably much less than that) it's going to be tough.

[thinwing]

On 11/11/2021 at 8:43 PM, V1VRV2 said:

Had my vacuum system pulled out during my panel renovation on my FIKI Ovation II last month. No one raised an eyebrow. Not my mechanic and not my avionics installer. Both are pretty thorough about legality. FIKI Ovation GX’s never had a vacuum system installed. Might want to check out the TKS Paperwork from that plane.

this!