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#1
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Greetings all,
I know this must've been discussed here before, but I couldn't find anything definitive one way or the other when searching with Google. A friend who's starting an amateur-built experimental aircraft project recently emailed me to ask if there's a list of the *minimum* required instruments he must have installed in order to obtain an airworthiness certificate. I did a little research and came to the conclusion that no, if you intend only to operate non-aerobatic flight under Day VFR conditions, there's no regulatory requirement to have any instrumentation whatsoever. Now don't get me wrong here, I'm not suggesting having no instruments installed is a good idea. Not only that, it would undoubtedly attract the attention of an airworthiness inspector and create difficulties. During the airworthiness inspection of my own aircraft several years ago, the FAA inspector didn't look at or say anything about the instruments I had installed... and I don't have the full compliment spelled out in 91.205. The basis for my conclusion of not being required to have any instruments... FAR 91.205 "Powered civil aircraft with standard category U.S. airworthiness certificates: Instrument and equipment requirements." gives a list of required instruments for various types of flight. However, it applies ONLY to civil aircraft with a "standard" category airworthiness certificate. It states: "(a) General. Except as provided in paragraphs (c)(3) and (e) of this section, no person may operate a powered civil aircraft WITH A STANDARD CATEGORY U.S. AIRWORTHINESS CERTIFICATE in any operation described in paragraphs (b) through (f) of this section unless that aircraft contains the instruments and equipment specified in those paragraphs (or FAA-approved equivalents) for that type of operation, and those instruments and items of equipment are in operable condition." An amateur-built experimental aircraft is issued a "special" airworthiness certificate (not a "standard" airworthiness certificate): "Section 21.175: Airworthiness certificates: classification. (a) Standard airworthiness certificates are airworthiness certificates issued for aircraft type certificated in the normal, utility, acrobatic, commuter, or transport category, and for manned free balloons, and for aircraft designated by the Administrator as special classes of aircraft. (b) Special airworthiness certificates are primary, restricted, limited, light-sport, and provisional airworthiness certificates, special flight permits, and experimental certificates." Interestingly, FAA Order 8130.2D directs FAA inspectors and DARs to verify any installed instruments are marked appropriately, and maintained properly (via the operating limitations) but it doesn't require compliance with 91.205... "SECTION 7. EXPERIMENTAL AMATEUR-BUILT AIRWORTHINESS CERTIFICATIONS 128. CERTIFICATION PROCEDURES. The procedures in this chapter provide guidance material associated with airworthiness certification and the issuance of Form 8130-7. c. Aircraft Inspection. The FAA shall arrange with the applicant to make the aircraft available for inspection to determine that: (1) The identification plate meets the requirements of § 45.11, as applicable. (2) The information on the identification plate is correct, matches the information on Form 8130-6, and is in accordance with § 45.13, as applicable. (3) The aircraft nationality and registration marks are in accordance with part 45, subpart C, Nationality and Registration Marks. (4) The flight control system, engine(s), propeller(s), pitot static system, and ASSOCIATED INSTRUMENTS operate properly. (5) The INSTRUMENTS ARE MARKED APPROPRIATELY. (6) An emergency locator transmitter (ELT) is installed, if required (§ 91.207). 134. ISSUANCE OF EXPERIMENTAL AMATEUR-BUILT OPERATING LIMITATIONS. (9) Aircraft instruments and equipment installed and used under § 91.205 must be inspected and maintained in accordance with the requirements of part 91. Any maintenance or inspection of this equipment must be recorded in the aircraft maintenance records." Also, if you intend to use your experimental aircraft for exhibition or air racing, then according to FAA Order 8130.2D, you DO have to comply with 91.205... "140. SPECIAL CERTIFICATION REQUIREMENTS. The following provide information and guidance concerning airworthiness certification for experimental aircraft for the purpose(s) of exhibition and/or air racing. These steps are in the normal order of occurrence for the certification of these aircraft. c. Aircraft Inspection. The FAA will perform an inspection to the extent necessary to ensure that an inspection of the aircraft and aircraft systems has been accomplished in accordance with the inspection requirements as identified in paragraph 88b of this order. Additionally, the FAA will verify that instruments, instrument markings, and placards are as required by the CFR and are identified in the English language. Verify that all measurements are converted to standard U.S. units of measure for those instruments necessary for operation in the U.S. air traffic system. NOTE: Depending on the intended operation, the applicable reference would be § 91.205(b), VFR (day); § 91.205(c), VFR (night); or § 91.205(d), IFR. Operators should be alerted that there are specific requirements under part 91 for maintenance and inspection of the various aircraft instruments, and that those requirements are applicable for these aircraft if the instruments are installed, e.g., §§ 91.173 through 91.187, 91.215, 91.217, 91.219, 91.411, 91.413, etc." Best regards, John L. |
#2
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The Bleriot currently being built by Evergreen museum in McMinnville has
about 2 instruments. Oil pressure and temperature, I think. Maybe a sight glass for fuel. John A. Landry wrote: Greetings all, I know this must've been discussed here before, but I couldn't find anything definitive one way or the other when searching with Google. -- J Kimmel www.metalinnovations.com "Cuius testiculos habes, habeas cardia et cerebellum." - When you have their full attention in your grip, their hearts and minds will follow. |
#3
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John A. Landry wrote:
Greetings all, I know this must've been discussed here before, but I couldn't find anything definitive one way or the other when searching with Google. A friend who's starting an amateur-built experimental aircraft project recently emailed me to ask if there's a list of the *minimum* required instruments he must have installed in order to obtain an airworthiness certificate. snip I thought the minimums were something like: Tachometer (1 per engine) Oil pressure Mag compass Altimeter Temperature (for liquid-cooled) Oil temp (for air-cooled engines Fuel quantity (1 per tank) Lights (anticollision) Airspeed Manifold pressure (if constant speed prop) ELT Seat belts |
#4
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That sounds about right as far as I can remember, except, I believe the
ELT is not required if the plane is single place and I don't think lights are required if the plane is to be registered for day VFR only. But this doesn't address Mr. Landry's issue of "standard" vs "special" certificates. Neal |
#6
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John A. Landry wrote:
On 14 Oct 2005 10:07:34 -0700, in rec.aviation.homebuilt, said: But this doesn't address Mr. Landry's issue of "standard" vs "special" certificates. Neal, I guess I made my post because I was looking for supporting or consenting opinions from the group as to whether I can to a correct conclusion in trying to interpret the FAR's. of course I realize each FAA FSDO or MIDO would have their own interpretation (don't they always)? Best regards, John L. John, There is NO minimum equipment list in the FARs for an experimental category aircraft, no interpretation is necessary. The equipment requirement (and it only applies to other than day VFR) is spelled out in the Operating Limitations for the aircraft. From my freshly issued Operating Limitations: " 8. After completion of Phase 1 flight testing, unless appropriately equipped for night and/or instrument flight in accordance ?91.205, this aircraft is to be operated under VFR day only." So while there is no minimum list, the Operating Limitations placed on the aircraft at the time of airworthiness certificate issuance dictates the equipment and instrumentation needed for other than day VFR. If you are still not convinced, call your MIDO or FSDO and get them to tell you where to find the boilerplate they use when issuing Operating Limitations. It is in one of the ACs but I don't remember the exact number. CW |
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