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Oops, pitot static transponder expires soon


M20 Ogler

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32 minutes ago, MikeOH said:

While that sounds swell and all, what should the log entry say?

Mine makes NO mention of ADSB compliance. Does yours? And to my question, should it? If so, show me the reg that required it!

Despite @philiplane explaining in excruciating detail all the steps in the process I still didn’t see where we owners could be shown a requirement! His claim that 91.411 and 91.413 somehow tie to the 91.225 and 91.227 regs doesn’t even rise to tenuous!

The log entry should reference the regs that require the certs (91.411 and 91.413, appropriate paragraphs) and the means of compliance (Part 43 app E, F). 

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37 minutes ago, PT20J said:

The log entry should reference the regs that require the certs (91.411 and 91.413, appropriate paragraphs) and the means of compliance (Part 43 app E, F). 

@PT20J

Of course, and my certs do. What they do NOT state is any specific certification that ADSB has been verified. Which is no surprise since the regs you cited do NOT require it.

Does YOUR 91.411/.413 log entry state ANYTHING about ADSB compliance? That is my question.

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I was ferrying a plane to Seattle a couple of weeks ago. The transponder quit on one leg. I called Seattle TRACON on the phone to get a wavier to fly under their Class B with no transponder. No hassle, it took 5 minutes. 
 

It was all moot anyway, the transponder started working as mysteriously as it quit. It was a Dynon system and it got a black X where the squak code goes and if you went to the menu page the transponder was grayed out. Pulled the circuit breaker but the batteries took over. Oh well, it’s not my plane.

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17 minutes ago, MikeOH said:

Does YOUR 91.411/.413 log entry state ANYTHING about ADSB compliance? That is my question.

No.

When my GTX 345 was initially installed, there was a log entry stating that it was tested and complies with 91.227, but the repair station told me that this is a one-time requirement and there is no regulatory requirement for periodic recertification of ADS-B Out equipment. I cannot find any such requirement in the regs.

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24 minutes ago, PT20J said:

No.

When my GTX 345 was initially installed, there was a log entry stating that it was tested and complies with 91.227, but the repair station told me that this is a one-time requirement and there is no regulatory requirement for periodic recertification of ADS-B Out equipment. I cannot find any such requirement in the regs.

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EXACTLY how mine was done, as well.

Until @philiplane came along earlier in this thread and claimed a 24 month requirementI have had ZERO indication that I am responsible for periodic recertification of my ADS-B out equipment.

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My guy has test equipment that does both mode C and S transponders. When he tests my transponder, the ADS-B gets checked weather required or not. I think it will pick up the 978 out also, so it will get checked. 
 

I suspect that most shops have this same type of equipment, so the argument is kind of moot. 

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6 hours ago, T. Peterson said:

Wow! What a thread. When even the heavy hitters can’t agree after quoting myriad regulations and legalize, what is an average smuck like me supposed to think? I have only learned that my cynicism and contempt for bureaucrats and their minions is justified. It is utterly absurd that our regulations are written so poorly and incomprehensibly. It seems like a purposeful attempt to entrap citizens rather than enhance safety.:angry:

I don't think the regulations are poorly written. They are actually pretty carefully crafted to reduce specificity to the minimum necessary to meet the intent. The lack of specificity actually gives us more latitude. In fact, AOPA has cautioned against asking for legal opinions unless there is a real need for clarification because, often as not, the opinion gives the FAA an opportunity to tighten the restrictions on a rule it has come to believe is too permissive.

What happens is that rules get added over time and eventually the body of rules becomes piecemeal and confusing. Then every couple of decades, the FAA rewrites and reorganizes some part to make it more clear. At these times there is an opportunity for public comments to include user inputs. 

One thing I learned years ago is that to really understand the FARs, you need to read the preambles that were published with the original rules to understand the intent of the rule. And, of course, you need to read the legal opinions to understand how the interpretations of the rules may have evolved over time.

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6 hours ago, MikeOH said:

EXACTLY how mine was done, as well.

Until @philiplane came along earlier in this thread and claimed a 24 month requirementI have had ZERO indication that I am responsible for periodic recertification of my ADS-B out equipment.

Actually, you are required to ensure your ADSB is functional on every flight in Rule airspace, so whether or not you believe it must be tested every 24 months along with the transponder, the onus is on you every time you fly. 

Again, contact your Friendly Aviation Advisors for more clarity on this. They're happy to help.

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4 minutes ago, philiplane said:

Actually, you are required to ensure your ADSB is functional on every flight in Rule airspace, so whether or not you believe it must be tested every 24 months along with the transponder, the onus is on you every time you fly. 

Again, contact your Friendly Aviation Advisors for more clarity on this. They're happy to help.

LOL!

I’m required to ensure my ENTIRE aircraft is airworthy before every flight!

When you can actually cite a reg requiring ADSB certification every 24 months just let us all know:D

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2 hours ago, PT20J said:

Actually, the FAA checks ADS-B for you every flight, and if it finds something amiss, they'll send you a letter.

You can check it yourself (which might not be a bad idea to do occasionally). 

https://adsbperformance.faa.gov/PAPRRequest.aspx

 

Not that it matters, but what do you believe is the value added with the 24 month test?  Seems to me it’s another opportunity to introduce maintenance induced failures.  And why 24 months?  Why not annually if it’s really needed during the annual inspection; it would simplify tracking and compliance.  I haven’t noticed anyone mention value added or potential performance degradation or failure modes.  Only checking the box …. 

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16 minutes ago, DCarlton said:

Not that it matters, but what do you believe is the value added with the 24 month test?  Seems to me it’s another opportunity to introduce maintenance induced failures.  And why 24 months?  Why not annually if it’s really needed during the annual inspection; it would simplify tracking and compliance.  I haven’t noticed anyone mention value added or potential performance degradation or failure modes.  Only checking the box …. 

It’s a vestige of the past when mechanical instruments wore out and developed leaks and tube-type transponders would degrade and lose power output.

My first job was the summer between high school and college. I had studied and passed the test for an FCC 1st class radiotelephone (now general class) license and got a weekend job at an am radio station baby sitting a 50 kW transmitter because FCC rules required an engineer with a 1st class license record a bunch of meter readings in a log every half hour and make adjustments. When the regs wre written, transmitters drifted a lot and needed frequent adjustment, but the modern equipment never needed any adjustments and the half hour logging merely interrupted my use of the studio and record library for making party tapes.

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16 minutes ago, DCarlton said:

Not that it matters, but what do you believe is the value added with the 24 month test?

The early altitude encoders would degrade with time and needed to be adjusted every few years.  Since it is a critical component for safe separation of aircraft in IFR conditions it is wise to have it kept accurate.  The newer encoders are much more robust and rarely have the same issues, but the rules must include all hardware. 

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2 minutes ago, BobbyH said:

The early altitude encoders would degrade with time and needed to be adjusted every few years.  Since it is a critical component for safe separation of aircraft in IFR conditions it is wise to have it kept accurate.  The newer encoders are much more robust and rarely have the same issues, but the rules must include all hardware. 

I’ve had an old one become intermittent and unreliable but not degrade in accuracy.  ATC identified the problem.  

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OK, back to this.  I was getting frustrated and was probably going to write stuff in a snarky and insulting way, which I don't want to do.  From past experience doing that is not helpful.  :lol:   I choose to believe that all of us are trying to do the right thing and get good information out to the Mooney community.

 

@philiplane You asked about the altimeter and encoder talking to each other....  They don't, which is why there is a correspondence test required between the altimeter and altitude encoder.  91.217 says (I'm paraphrasing here) that if you install an altitude digitizer or an altimeter, they must be tested to report the same altitude  *****OR***** they are both TSO'd.    So you don't even need to do the test if both the altimeter and encoder are TSO devices.  

I will once again bring up the point that the data correspondence test is between the altimeter and encoder, and while you *could* use the output of the transponder to see what the encoder is reporting for altitude (which is required by 91.411(c), no transponder is required to do this to comply with 91.413.    You could do it with a vacuum and multimeter, setting the altitude on the static system and looking at the altimeter, then probing each of the wires on the gray code output of the encoder. 

You also bring up the transponder transmitting at the right wattage and frequency... That is tested with Appendix F, on the bench.  Specifically frequency is subpart (a) and wattage (power) is subpart (d)     The only thing about altitudes in that appendix F is it says "Verify that the altitude reported in the replies to UF = 4 are the same as that reported in a valid ATCRBS Mode C reply."   That's bench checkable.

Regarding 91.227.... There is nothing in there that requires a periodic re-test.  It's available here: https://www.ecfr.gov/current/title-14/chapter-I/subchapter-F/part-91/subpart-C/section-91.227

 

Regarding the install..... Well, I will once again mention that I'm not making any claims about if a non-A&P can do that.   :)    BUT if the transponder has been bench checked IAW Appendix F, no further testing needs to be done in order to comply with 91.413 after the transponder is re-inserted into the aircraft.   

You mention 91.225, which is about ADS-B Out.  It's available here: https://www.ecfr.gov/current/title-14/chapter-I/subchapter-F/part-91/subpart-C/section-91.225    There is no periodic re-check requirement.  

You mention the instructions for continued airworthiness from the ADS-B manufacturer. There is nothing in the two I've looked at that require what I think you are talking about.

For the uAvionix wingtip unit I have installed.  It can be found here: https://uavionix.com/downloads/skybeacon/skyBeacon-Continued-Airworthiness-Manual-UAV-1002112-001.pdf  The important parts are on pages 13 through 15, in sections 8.3 through 8.6.  In 8.6 they do bring up altitude encoder testing, but this is only for IFR operations, so is not relevant for our discussion which was just the 91.413 requirement. And even then, it's only applicable if your ..."altitude encoder has been recently adjusted,"...

For the Garmin units, I found what I'm assuming is a valid maintenance manual here: http://www.n927sf.com/Current POH AFM FMS/Garmin GTX 345 Maintenance Manual - 190-00734-11_07.pdf  The instructions for continued airworthiness start on page 4.1 (page 41 of the PDF). For "testing" in table 4.1, they say to refer to 14 CFR 91.411 and 91.413 and part 41 appendixes E and F.  (appendi?   appendixes?)   There are annual 'Equipment Visual Inspection" requirements and a 10 year or 2,000 hour electrical bonding test, but that's it. 

 

If it matters, the shop that I have service my current aircraft does not add a line "found ADSB compliant" to the annual inspection log entry.  Nor does the mooney service center who has been doing the work on the Mooney I'm looking to buy.

Recommending a periodic PAPR is fine, but that's just a recommendation.   Yes, they send out letters to aircraft owners whose aircraft are out of spec.  But that does not make a requirement for a periodic re-check of your ADS-B out equipment.

If I take a transponder in for a check in accordance with part 43 appendix F and they charge me for performing a test to meet the requirements of 91.227 I'll be angry.  There is no reason to test that.  Not in 91.227, not in the Garmin maintenance manual, not in part 43 appendix F.

As you say, the Garmin service manual does include language about the regulatory test.  But if I'm not flying IFR, no testing at all is required to comply with 91.411.  And a bench check is sufficient to comply with 91.413. And after a removal, (as of Rev 7, but not before), 'sufficient' testing in accordance with part 43 Appendix E paragraph C must be completed.    Now *THAT* is a nebulous requirement.     What is sufficient testing?  Good job, Garmin.  NOT.   But this is not a periodic requirement, this is about removing, replacing, or modifying.

@N201MKTurbo I have had a few similar experiences.  A few years ago I was ferrying a plane into the Seattle area with a transponder that had long passed the 91.413 check time.  When airborne, but before the 30NM mode C veil, I called ATC on the radio for flight following and told them my transponder was inoperative.    They told me to proceed as requested.  I also told Renton tower before I entered their airspace.  When I bought my 182, on the flight back to Seattle (BFI) my very first flight in my new plane  the transponder died on the way, about 1 hour away from Seattle.  Fortunately I was on flight following and they told me before I inadvertently flew under the mode C veil with an inop transponder.

Totally weird side note about 91.225....  subpart (f) says ..." must operate this equipment in the transmit mode at all times unless -" and then (f)(2) says "Otherwise directed by ATC when transmitting would jeopardize the safe execution of air traffic control functions." .... So my conclusion is that if you are directed by ATC to turn it off for a reason other than jeopardizing the safe execution of air traffic control functions, you are prohibited from turning it off!   Now that's a wild condition!!! As a pilot, I wouldn't necessarily know why ATC asked me to turn it off.  But if they ever do, I'm totally asking them if it's because transmitting would jeopardize the safe execution of air traffic control functions.

 

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5 hours ago, jaylw314 said:

Just to clarify, if my transponder is out of 24 months, the plane can still fly VFR, it just can't go into rule airspace with it on, correct?  And I assume I would I need to placard it INOP?

That all sounds correct to me.   

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I was ferrying a Cessna across town a few years ago that was 10 years out of annual and transponder cert. I had a waiver from TRACON. I contacted them for a short while and said my transponder was on waivers and I would shut it down if it was goofy. They said it looks fine leave it on.

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20 hours ago, N201MKTurbo said:

I was ferrying a plane to Seattle a couple of weeks ago. The transponder quit on one leg. I called Seattle TRACON on the phone to get a wavier to fly under their Class B with no transponder. No hassle, it took 5 minutes. 
 

It was all moot anyway, the transponder started working as mysteriously as it quit. It was a Dynon system and it got a black X where the squak code goes and if you went to the menu page the transponder was grayed out. Pulled the circuit breaker but the batteries took over. Oh well, it’s not my plane.

That’s because that’s not how that works. Next time you have a transponder issue try pulling the breaker that says “transponder”. There is no battery associated with it. There is a battery attached to the displays. 
 

if I was flying someone else’s airplane and something broke on my watch, I’d have a little bit more care than that. Not much, but a little. 
 

f I ever heard a ferry pilot say “whatever it’s not mine” in a situation like this they would not be my ferry pilot. 

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33 minutes ago, N201MKTurbo said:

I was ferrying a Cessna across town a few years ago that was 10 years out of annual and transponder cert. I had a waiver from TRACON. I contacted them for a short while and said my transponder was on waivers and I would shut it down if it was goofy. They said it looks fine leave it on.

Last spring the transponder for my 182 was misbehaving. Sometimes, no matter code I put in, it was showing up to ATC as '7777', which they said was "live military operations in US airspace"....   But then it would start replying normally again.  It didn't seem to be affected by me power cycling it  After about 3 flights with a radio call from ATC in the middle that started with  "Uhhh... N12345...."  I replaced the KT76 with a GTX327.  I'd been holding out for a big panel upgrade, but decided I didn't think I could justify turning that transponder back on any more.

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12 minutes ago, chriscalandro said:

That’s because that’s not how that works. Next time you have a transponder issue try pulling the breaker that says “transponder”. There is no battery associated with it. There is a battery attached to the displays. 
 

if I was flying someone else’s airplane and something broke on my watch, I’d have a little bit more care than that. Not much, but a little. 
 

f I ever heard a ferry pilot say “whatever it’s not mine” in a situation like this they would not be my ferry pilot. 

I did pull the transponder breaker. It didn't change anything. 

What would you have me do? abandon the airplane at the nearest possible airport which didn't have any services? Spend days trying to get the transponder resolved? On your nickle BTW. Or just fly the plane where you wanted flown, which is what I did.

When I said Whatever, it's not mine, that ment I don't have to worry about fixing it! If you wanted to hire me to manage the repair, that's another discussion.

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7 minutes ago, wombat said:

Last spring the transponder for my 182 was misbehaving. Sometimes, no matter code I put in, it was showing up to ATC as '7777', which they said was "live military operations in US airspace"....   But then it would start replying normally again.  It didn't seem to be affected by me power cycling it  After about 3 flights with a radio call from ATC in the middle that started with  "Uhhh... N12345...."  I replaced the KT76 with a GTX327.  I'd been holding out for a big panel upgrade, but decided I didn't think I could justify turning that transponder back on any more.

I'm surprised they didn't tell you to turn it off. But they are pretty good at their jobs, as long as they know that Cessna squawking 7777 is you, they can deal with that. I think it is easier for them to work a bad transponder than a primary target.

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30 minutes ago, chriscalandro said:

That’s because that’s not how that works. Next time you have a transponder issue try pulling the breaker that says “transponder”. There is no battery associated with it. There is a battery attached to the displays. 
 

if I was flying someone else’s airplane and something broke on my watch, I’d have a little bit more care than that. Not much, but a little. 
 

f I ever heard a ferry pilot say “whatever it’s not mine” in a situation like this they would not be my ferry pilot. 

Besides, I spent 4 hours before this flight reading the Dynon operators manual and an hour talking to a hangar neighbor who has a Dynon about how to work it. I didn't charge the guy for any of this. 

I remember reading that there was a way to reboot the Dynon, but I couldn't remember how to do it. I poked at it for a bit, but to no avail. I had the operator's manual on my IPad, but trying to read it while flying a plane with a heavy wing in moderate turbulence with no autopilot of any kind, just wasn't working for me. 

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