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Sunfish
12th Apr 2013, 21:44
CASA requires that even private VFR flight even in an experimental aircraft, requires the presence of

1 magnetic compass.

2. Altimeter.

3. Airspeed indicator.

A serviceable watch meets the timepiece requirement

Furthermore, each of these items is required to be of an approved type, generally TSO'd.

Similarly, if radio is required for airspace or landing area, it too must be of an approved type.

Is there an exception to this rule anywhere? I can't find one. Furthermore, if it is certified, how can it be installed by an unlicensed person?

That means that the new Dynon radio, and a host of other stuff is illegal to
Use here.

I'm starting to think about cutting my losses.

baswell
12th Apr 2013, 22:44
AFAIK, no TSO'd instruments required in a non-certified aircraft.

Just get the cheapest, nastiest stuff you can find on Aircraft Spruce and you'll be good! :ok:

As for radios, the way I understand it, anything FCC (yes, FCC, not FAA) approved is fair game.

That includes local Australian made radios like X-Com too, by the way!

VH-XXX
12th Apr 2013, 23:49
Sunny aren't you a member of the SAAA and have you looked at their comprehensive website?

If you look for the article by David Francis you'll see that you only need for the transponder to be TSO'ed and most of them are these days. You also only need an approved radio for Night VFR.

The only dodgey thing I've seen around where you are headed is using the Dynon's non-TSO'ed built in altitude encoder coupled to a TSO'ed Garmin Transponder or similar.

Why not look at the Levin AHRS unit that talks to the iPad via wifi. For around a grand plus iPad you have a unit similar to the Dynon display at a fraction of the cost and software updates are the only limit for what can be displayed.

Sunfish
13th Apr 2013, 20:54
Checked a stack of CASRS and CAAPS and they don't say what any of you said........

They leave you dangling, which appears to be CASAs preferred position...


CAAP 42ZC:

Says that CASA exemption 13/13 allows us to fit unapproves products.

it does not.

What the CAAP DOES say is that a LAME must do the maintenance on any instrumetns required for IFR flight.

1 The exemption does not apply to:

(a) maintenance of aircraft instruments and equipment specifically required by CAR 1988 or the Civil Aviation Orders; or

(b) maintenance related to a condition of the special certificate of airworthiness or experimental certificate for the aircraft; or

(c) maintenance specified in an Airworthiness Directive or a direction issued by CASA applicable to the aircraft; or

(d) maintenance related to an instruction specified in the aircraft’s approved maintenance data.

http://www.saaa.com/Portals/0/PDFs/42zc_2.pdf

VH-XXX
13th Apr 2013, 22:03
By the way I didn't even mention IFR because I was under the impression that this was not relevant to you.

Many aircraft including GA registered LSA aircraft do not have TSO'ed instruments.

Jack Ranga
14th Apr 2013, 05:44
How much are you selling for Sunny?:E

baswell
14th Apr 2013, 23:22
I am guessing all the home builts flying with nothing by some Dynon stuff and a CoA signed off by CASA must all be breaking the law. :)

VH-XXX
15th Apr 2013, 00:30
That's right Baswell, they should cut their losses and get out whilst they can ;)
:ok:

Sunfish
15th Apr 2013, 01:37
Building fatigue. I'm almost finished the airframe. I then have to decide to spring for the engine.

I think I need to get current again and remind myself why I am doing all this.

Creampuff
15th Apr 2013, 01:50
Civil Aviation Safety Authority - Project CS 13/01 (http://www.casa.gov.au/scripts/nc.dll?WCMS:PWA::pc=PC_101318)

Sunfish
15th Apr 2013, 06:14
Thank you Creampuff. Project13/01 confirms what I think I've read: Unless there is some exemption for experimental aircraft, which I cannot find, then the compass, altimeter and airspeed systems must be TSO'd or approved specifically by CASA for any Australian aircraft.

Furthermore, radio equipment must also comply with TSO's if it is required by regulation in a particular class of airspace or operation.

The only let out I can see is if it is approved by a part 35 delegate, which I don't know about yet.


So you commit an offence under part 91 if you fly with an uncertified required instrument. And it's 50 penalty units. , and it says nothing about being only applicable to IFR, despite the commentary.

What now concerns me is if the installation is also required to be approved.

Arnold E
15th Apr 2013, 09:53
So you commit an offence under part 91 if you fly with an uncertified required instrument. And it's 50 penalty units. , and it says nothing about being only applicable to IFR, despite the commentary.

What now concerns me is if the installation is also required to be approved.
You worry too much, there are an awful lot of experimental aircraft in front of you with non certified gear, would take a 100 years for casa to get to you, even if they were interested.

Creampuff
15th Apr 2013, 10:13
Sunfish

Drop a PM to Jabawocky. He's coordinating an industry response to that CASA Project, which, according to CASA, is going to 'formalise' the regulatory position you've summarised.

I don't think Part 91 is law yet. The Project aims to amend the current old rules pending Part 91 becoming law in 2003 ... ("Safety through Clarity" is going to be fantastic!)

VH-XXX
15th Apr 2013, 10:50
Furthermore, radio equipment must also comply with TSO's if it is required by regulation in a particular class of airspace or operation.

Lots of radios aren't TSO'ed like Microair and Icom's - Icom has usually had both versions on the market, one certified and one not. Interesting comment in the link you have posted about how non TSO'ed gear is ok if the entire aircraft is approved. That would mean that a GA registered LSA aircraft such as a Jabiru could be filled with non-TSO'ed instruments and as long as it's approved under ATSM LSA standards, it's all good ! (in fact, the are full of Chinese instruments!)

Jabawocky
15th Apr 2013, 12:06
("Safety through Clarity" is going to be fantastic!)

Can't wait :ugh:

I think Sunny you need a lot more help. How about you PM me so I can put you in touch with a CASA AP that knows his stuff.......and far better than I do.

Deaf
15th Apr 2013, 13:33
That would mean that a GA registered LSA aircraft such as a Jabiru could be filled with non-TSO'ed instruments and as long as it's approved under ATSM LSA standards, it's all good ! (in fact, the are full of Chinese instruments!)

J160 (RAA - same as GA with type certificate) in 1996 had none TSO'ed instruments. The altimeter (non TSO chinese) became unreliable so got a (no tag - don't ask) altimeter of a TSO type; the instrument guy at MB fixed it (clean only) and provided tag and calibration certificate (VFR but within IFR specs) for less than a Falcon non TSO would have cost new.

The instrument guy also said CASA had told them not to fix or calibrate chinese altimeters.

Sunfish
15th Apr 2013, 21:34
Thank you for your helpful comments.

With respect to the Cosi Fan Tutti argument (Everybody is doing it) about using non approved gear, I am afraid I'm not a believer for Three reasons:

1. I have to consider the possibility that CASA knows what it is talking about and that there really is significantly increased risk in using a Non approved ASI and Altimeter. Yes I know, it sounds strange to think that the regulator might be right, but they make the rules. I know nothing about instrument accuracy. Until the rules change for VFR instruments, I have to follow them for my own safety, let alone others. As for IFR required instruments being approved, of course they should be.

2. I am a strong believer in Murphys law. It will be just my luck to get ramped and you can bet that if the question of VFR instrument approval requirements is not addressed and the law is changed as per the project, then you can bet that Inspectors will check the instruments and at least ground you if they don't comply. The RAA has found out the hard way that CASA has no compunction about enforcing the rules, nor should they, even if it does ground a signifigant portion of the fleet. Furthermore, a sudden series of orders amounting to a thousand or so certified altimeters might strain supply chains a little.

3. Not fitting an altimeter and ASI is not an option. Not only do the rules require them, I am acutely conscious of what can happen to reasonably sophisticated electronic systems where an intermittent fault can produce bizarre navigational results. I have had it happen to me and you can get confused very very quickly. The only safe immediate action in that situation is to switch off the glass screen and go back to Compass, Altimeter and ASI.


Then there is the question of radios. Dynon have just released what appears to be a delicious one. However Dynon says it ain't certified by anyone and isn't going to be. Not only does a radio have to be approved by the communication authority, CASA also has a series of operational requirements for aviation radios.

Some of you would be aware of the plea from the YMMB tower to help them track down a current source of interference, don't add to the problem.

To put it another way, if you make the entire experimental CofA approval process into a sham, then you are asking for trouble.

VH-XXX
16th Apr 2013, 00:29
The simple solution for you then is to purchase a TSO'ed ASI and Alt. Easy. Worst case, a second hand one from a broken Cessna or similar. Compasses are 2 a penny as they say.

I'm not sold on the radio being TSO'ed though as potentially 40%+ of the Australian aircraft fleet including RA-Aus have non TSO'ed radios.

Sunfish
16th Apr 2013, 01:13
VH - xxx:

VH-XXX The simple solution for you then is to purchase a TSO'ed ASI and Alt. Easy. Worst case, a second hand one from a broken Cessna or similar. Compasses are 2 a penny as they say.

I'm not sold on the radio being TSO'ed though as potentially 40%+ of the Australian aircraft fleet including RA-Aus have non TSO'ed radios.

TSO'D gear will be purchased.

If 40% of the fleet have non CASA approved radios, then 40% of the fleet are breaching CAO 108.34.

http://www.casa.gov.au/download/orders/cao108/10834.pdf

VH-XXX
16th Apr 2013, 02:36
It appears that the problem lies within your use terminology for "approved" versus "TSO'ed." Be careful with that as there is sometimes a reason for it.

Have a look at the very last page of the above publication and you'll see that the Microair transceiver is listed there.

http://microair.com.au/admin/uploads/documents/M760AustralianCASAAPMAapproval1.pdf

The Microair as an example was approved by CASA before TSO testing was invented, back in the 90's so it's not TSO'ed but it IS approved.

The Microair transponder on the other hand, is TSO'ed as it was manufactured and approved after TSO was invented.

You'll need to do some careful research to determine which instrument is right for you based on information from the manufacturer.

Based on your evidence and articles my jury is out on whether or not experimental needs TSO'ed anything for Day VFR.

When you work it all out let me know as I'm about to buy some stuff for NVFR :ok:

Bonniciwah
16th Apr 2013, 03:44
So this explains is why you see Experimental panels with a 10 inch Skyview screen, and separate steam gauges. I thought they were back ups.

baswell
16th Apr 2013, 06:10
Plenty of aircraft around with nothing by Dynon and no steam gauges.

Or with non-TSO steam gauges as backup.

VH-XXX
16th Apr 2013, 06:21
I just made a phone call. A phone is a great device for talking with people versus guessing and theorizing, so I thought I'd give it a go. I hope this helps Sunny because I invested 5 minutes of my time on this.

- TSO'ed Flight and Navigation instruments are NOT required for Day VFR

- The project CS13/01 is ONLY for IFR aircraft

- ALL aircraft that plan to enter CTA, MUST have a TSO'd primary radio, but a secondary non approved non TSO'ed is ok. A factory built RAA or GA experimental aircraft for example fitted with a Dynon radio can NOT enter CTA legally (Dynon are currently seeking the required approvals for this)

- The paperwork that explains the Day VFR part was released in November last year as an amendment to 20.18

- All radio equipment must be TSO'ed for entry into CTA and this includes the transponder, so that affects the dynon transponder too

- Using the built in Dynon altitude encoder coupled to a TSO'ed transponder is questionable

I hope that clears things up and I am now also a little more educated.

Creampuff
16th Apr 2013, 06:38
I don’t understand how you reconcile this:TSO'ed Flight and Navigation instruments are NOT required for Day VFR. …. with this:ALL aircraft that plan to enter CTA, MUST have a TSO'd primary radio, but a secondary non approved non TSO'ed is ok. A factory built RAA or GA experimental aircraft for example fitted with a Dynon radio can NOT enter CTA legally (Dynon are currently seeking the required approvals for
this) …

All radio equipment must be TSO'ed for entry into CTA and this includes the transponder, so that affects the dynon transponder tooDid you mean this instead: “TSO’ed Flight and Navigation instruments are NOT required for Day VFR aircraft that do not plan to enter CTA?” :confused:

Jabawocky
16th Apr 2013, 07:08
Creamie, thats easy. Flight instruments, basically 6 pack stuff. Nav=VOR/ADF/GPS
Comm is the VHF and TXpder.

And the Jury is out on a lot of other stuff too.;)

Frank Arouet
16th Apr 2013, 07:33
Last I looked I was required to have an endorsement on the ADF and VOR. I admit this was for NVFR but when this was fashionable you could get a Class 4 (Day), which also endorsed you.

Use of these instruments unendorsed were for Visual fiddling and you couldn't even mark them on your flight plan unless endorsed.

My Bendix T12D made it legal for me to fly above 8/8 clouds and listen to cricket scores and it always pointed to the nearest thunderstorm. A great innovation.

Pity about the Morse thing considering I nearly went mad learning to copy 10 WPM.

What's a GPS again?

VH-XXX
16th Apr 2013, 11:36
By the way I've heard that people are wondering who I called for the details in my post above, my call was to Mick English of CASA whose name appears in the link above as the project implementer. He was most helpful and answered all of my questions with a degree of confidence.

Sunfish
16th Apr 2013, 20:17
Thank you for your good work VH-XXX. 27 posts before the definitive answer.

The CASA website copy of 20.18 that I was referencing (link below) is not amended. If it had been, this storm in a teacup wouldn't have happened.

OLDASSET (http://www.casa.gov.au/download/orders/cao20/2018.pdf)

Just goes to show that you need to look at the Comlaw website copy of any regs.

As for radios, I hope Dynon do get their radio approved because it saves space and complements the rest of the system. Since YMMB is class D and I also may wish to regularly transit around YMAV, I need something that is approved.


Dynon on their support forum said their radio was not approved by anyone - but I assume they must have forgotten their own FCC?

Next question. What would be the point of fitting a certificated versus uncertificated version of the same engine in anexperimental aircraft and would it remain certified is not maintained by a LAME?




Civil Aviation Order 20.18 Amendment Instrument 2012 (No. 2)

1 Name of instrument

This instrument is the Civil Aviation Order 20.18 Amendment Instrument 2012 (No. 2).

2 Commencement

This instrument commences on the day after registration.

3 Amendment of Civil Aviation Order 20.18

Schedule 1 amends Civil Aviation Order 20.18.

Schedule 1 Amendments

[1] Paragraph 3.2 omit A insert Subject to paragraph 3A.1, a

[2] Paragraph 3.3 omit A insert Subject to paragraph 3A.2, a

[3] Paragraph 3.4 omi An insert Subject to paragraph 3A.3, an

[4] New subsection 3A after subsection 3, insert

3A Operations to which flight and navigation equipment requirements do not apply

3A.1 Paragraph 3.2 does not apply to a helicopter that operates under the V.F.R., and for which an experimental certificate has been issued under paragraph 21.191 (g) or (h) of CASR 1998, if equipment is carried that provides a pilot with the same information that would be obtained by compliance with the requirements of Appendix VI for operations by day, or Appendix VIII if approved for operations by night.

3A.2 Paragraph 3.3 does not apply to a balloon that operates by day under the V.F.R.:

(a) being an aircraft for which a current certificate of airworthiness as a light sport aircraft (LSA) has been issued; or

(b) being an aircraft for which an experimental certificate has been issued under paragraph 21.191 (g), (h) or (j) or an LSA for which an experimental certificate has been issued under paragraph 21.191 (k) of CASR 1998;

if equipment is carried that provides a pilot with the same information that would be obtained by compliance with the requirements of Appendix X.

3A.3 Paragraph 3.4 does not apply to any other aircraft that operates under the V.F.R.:

(a) being an aircraft for which a current certificate of airworthiness as an LSA has been issued; or

(b) being an aircraft for which an experimental certificate has been issued under paragraph 21.191 (g), (h) or (j) or an LSA for which an experimental certificate has been issued under paragraph 21.191 (k), of CASR 1998;

if equipment is carried that provides a pilot with the same information that would be obtained by compliance with the requirements of Appendix I for operations by day, or Appendix IV if approved for operations by night.

3A.4 An aircraft referred to in paragraphs 3A.1 to 3A.3 that is approved to operate at night and is equipped with an Electronic Flight Information System (EFIS), or other means of electronically displaying the required information, must be provided with a battery-powered back-up, or another form of instrumentation independent of the aircraft electrical system, that is approved by an authorised person as suitable, in the case of a failure of the aircraft electrical system, for the purpose of enabling the pilot to divert to and use a safe landing site.

3A.5 If an aircraft equipped as required under paragraph 3A.4 has a battery-powered back-up to an EFIS, the back-up must be of sufficient capacity to power the EFIS panel or other display for 90 minutes and must be fully charged before the commencement of a flight at night.

3A.6 Subject to paragraph 3A.7, an Australian registered aircraft may be operated without compliance with the flight and navigation equipment requirements in subsections 3 and 4 of this Order if it can show compliance with an equivalent level of safety, as determined by the type certificating authority for the aircraft, taking into consideration its intended operation.

3A.7 The type certificating authority for the aircraft must be a recognised authority.

3A.8 In paragraph 3A.7, recognised authority means an authority of a country listed in regulation 21.012 of CASR 1998.

[5] Paragraph 4.1 omit An insert Subject to subsection 3A, an

[6] Paragraph 4.2 omit A insert Subject to subsection 3A, a

Civil Aviation Order 20.18 Amendment Instrument 2012 (No. 2) (http://www.comlaw.gov.au/Details/F2012L02556)

Jabawocky
17th Apr 2013, 04:26
Sunny.... the problem here is CASA have screwed up, what was modelled on the FAA back in 1998, Vs the version spruked by CASA in the last few months is a very wide gap. Hence the problem.

And basically when the dust settles I hope they learn a lot. And normallity will return.

The problem they have is they try too hard, and then make a mess....and then waste everyones time and money. Where is that video of a dog chasing its tail.

Trust me, I have a bunch of ex CASA and other highly qualified folk working on this. Problem is we are paying to fix their stuff ups.:rolleyes: