A aviation & planes forum. AviationBanter

If this is your first visit, be sure to check out the FAQ by clicking the link above. You may have to register before you can post: click the register link above to proceed. To start viewing messages, select the forum that you want to visit from the selection below.

Go Back   Home » AviationBanter forum » rec.aviation newsgroups » Soaring
Site Map Home Register Authors List Search Today's Posts Mark Forums Read Web Partners

ADSB out in tow planes



 
 
Thread Tools Display Modes
  #51  
Old June 4th 18, 03:21 AM posted to rec.aviation.soaring
Charles Longley
external usenet poster
 
Posts: 290
Default ADSB out in tow planes

What’s an informational 337? Never heard of one until now.

Charlie
A&P/IA
  #52  
Old June 4th 18, 05:50 AM posted to rec.aviation.soaring
Darryl Ramm
external usenet poster
 
Posts: 2,403
Default ADSB out in tow planes

On Sunday, June 3, 2018 at 7:21:37 PM UTC-7, Charles Longley wrote:
What’s an informational 337? Never heard of one until now.

Charlie
A&P/IA


Don't worry, you are not alone, this has caused a reasonable amount of confusion and not just with gliders. Have a read of FAA 8900.362 - Policy for Installation of ADS-B OUT Systems. https://www.faa.gov/regulations_poli...mentID/1029526 (no that policy really has not expired).

An "information only" 337 is what the FAA wants you to complete and send to FAA HQ in Oklahoma for an ADS-B out install. It's so they can track what is being installed. It's not the normal use of an 337 sent to the FSFDO for field approval for a major alteration. This has been discussed here in detail before in the thread linked in previous posts. There are multiple other FAA reference docs giving the same guidance listed in that other thread. The FAA may not formally refer to these as "information only" 377 but thats a term used by others, and by FAA folks when you talk to them.

The misconception that an ADS-B out install is by necessity a major alteration and requires a 337 (to the FSDO) has seemed to cause some glider owners unnecessary pain. Folks get confused and send the 337 to the FSDO and then the FSDO assumes they are seeking field approval for a major alteration, and you end up with folks trying to jump through hoops and find STC etc. and other items for install in a glider that are likely not required in the first place. And the pain starts with: there are no STCs for any transponder install in any glider. None, nada, zilch. And if you read the above policy, you'll see the STC mentioned, but it explains that is also a special case for an ADS-B Out install--the STC there is only required to establish the pairing of a particular transponder and GPS source, not the basis for a design approval for a major modification.

Since this confusion has created issues for some owners my effort to explain it here was is to avoid others suffering. Of course if an A&P IA has good reason to determine if any install actually is a major modification then that's a different discussion. Most installs of avionics in gliders are not considered major modifications, and the FAA has been supportive of that position, and there is no regulation that makes ADS-B Out installs special cases where they are automatically major alterations. The other thing I've suggested people do is let their A&P IA seek any clarifications about these from the FAA instead of trying to contact FSDO staff themselves.

There is no FAA notification required for ADS-B Out installs in experimental aircraft and none required for TABS/TSO-C199 (read that TSO for more info) install in any aircraft since 14 CFR 91.225/91.227 (the only thing that policy above applies to) don't apply to TABS... that's another whole point of potential confusion with owners or A&P contacting the FSDO and asking about "ADS-B Out" installs where they mean TABS and the FSDO will likely assume 2020 Complaint systems not TABS, and staff there may just not know what TABS is at all. And now we have at least one glider owners who has got an ADS-B Out non-compliance letter from the FAA for their TABS systems because the FAA ADS-B Out compliance reporting does not understand TABS. I'm helping respond to that letters (and can provide a draft of the response letter to anybody who wants one) and I hope this is a great opportunity to help educate more FAA folks on TABS and gliders in general.


  #53  
Old June 4th 18, 03:19 PM posted to rec.aviation.soaring
Dan Marotta
external usenet poster
 
Posts: 4,601
Default ADSB out in tow planes

Free beer in my hangar if you guys will come and have this discussion
face to face.* Maybe it could be settled once and for all.

On 6/3/2018 7:40 PM, JS wrote:
On Sunday, June 3, 2018 at 5:50:49 PM UTC-7, Darryl Ramm wrote:
On Sunday, June 3, 2018 at 5:23:34 PM UTC-7, 2G wrote:
On Sunday, June 3, 2018 at 4:56:55 PM UTC-7, Darryl Ramm wrote:
On Sunday, June 3, 2018 at 11:15:00 AM UTC-7, 2G wrote:
On Sunday, June 3, 2018 at 1:10:46 AM UTC-7, Darryl Ramm wrote:
On Saturday, June 2, 2018 at 10:38:50 PM UTC-7, 2G wrote:
On Friday, June 1, 2018 at 10:31:39 PM UTC-7, Darryl Ramm wrote:
On Friday, June 1, 2018 at 6:01:43 PM UTC-7, Charles Longley wrote:
One of our Pawnees has an ADSB out transponder now. (Evergreen Soaring) We’ve had glider pilots we’re towing that have FLARM ask us to turn off our transponder. We’ve told the glider pilots to turn their FLARM down or off. My recommendation is to either have a switch for your FLARM or know you can turn the volume down to a suitable level.

The question I have is does FLARM show up on ADSB in?
As discussed here before the solution to spurious PowerFLARM alerts in the glider to the towplane ADS-B Out may be to put a PowerFLARM in the towplane so the PowerFLARM in the glider knows it's a towplane and more tolerant of it being close to the glider. There is unfortunately no way for an ADS-B out signal to contain any information to tell PowerFLARM it's a towplane. The FLARM signal does carry that information. it would be great if somebody could experiment with a PowerFLARM portable in the towplane to see if it indeed does solve the issue.

Be careful turning those transponders off, they provide visibility to other aircraft with ADS-B In, TCAS, ATC, all gliders with PowerFLARM with 1090ES In option etc. And if in controlled airspace its a violation of 14 CFR 91.215... and since the towplane is transmitting ADS-B data for all to see and the signal starts going of in flight that may well get noticed. The likely better option if necessary here is for the glider to turn off or turn down the volume on their PowerFLARM while on tow.
If you have a transponder installed, you are required to operate it at all times unless otherwise directed by ATC (i.e. Oshkosh).

Tom
That's not quite accurate, you are required to operate an installed transponder at all times in *controlled airspace*. 14 CFR § 91.215 (c). So they can be turned off in Class G airspace. Maybe a good aviation quiz night question, or BFR question. But to the point, yes turning them off is a bad idea.
Wrong: 91.215 states where you MUST operate your transponder - it says nothing about allowing a pilot to turn it off. The matter is addressed in section 4−1−20 of the AIM (https://www.faa.gov/air_traffic/publ..._10-12-17.pdf), "Transponder Operation:"

4. Transponder and ADS-B Operations in
the Air. EACH PILOT OPERATING AN AIRCRAFT EQUIPPED WITH AN OPERABLE ATC TRANSPONDER, MAINTAINED IN ACCORDANCE WITH 14 CFR SECTION 91.413 OR ADS-B TRANSMITTER, MUST OPERATE THE TRANSPONDER/TRANSMITTER, INCLUDING MODE C/S IF INSTALLED, ON THE APPROPRIATE MODE 3/A CODE OR AS ASSIGNED BY ATC. EACH PERSON OPERATING AN AIRCRAFT EQUIPPED WITH ADS-B OUT MUST OPERATE THIS EQUIPMENT IN HE TRANSMIT MODE AT ALL TIMES WHILE AIRBORNE UNLESS OTHERWISE REQUESTED BY ATC.

Notice the use of ALL CAPS: the FAA is shouting this requirement out at us. Furthermore, the glider involved in the Minden mid-air collision with the Hawker jet was faulted for not operating his transponder (https://www.ntsb.gov/_layouts/ntsb.a...A277 A&akey=1) even though they were not in controlled airspace at the time.

Tom

(With apologies to John Adams) We are a nation of laws not Aeronautical Information Manuals.

AIM is not a regulation. The 14 CFR § 91.215 regulation is *very* clear. And those regulations, and case law, is what determines what is legally required.

And being told where you are required to do something, also implies where you are not required to. The regulation does not need to discuss the transition between those states that are bleeding obvious. Nobody should be confused that the meaning here is going from required to be on to not required to be on might mean the pilot might... wait for it... ta.. da.. turn it off. And specially since the regulation does not say you cant' turn it off in that transition then you bloody well can.

And secondarily the section of the AIM you are referring to is discussing the provision of ATC services, which relies on transponders and ADS-B out, and if you are receiving those service than what you are quoting above is kind obvious, and fully consistent with 14 CFR § 91.215. Even if it was inconsistent with a regulation FAR/AIM cannot change that regulation or how you are required to comply with it.

I think this is the second time on r.a.s. recently where you quoted stuff claiming it proves some point of yours and instead had you dug a bit deeper you would have seen it was consistent with what others are saying.

----

And for those playing along at home...

Of course, in practice turning off transponders and ADS-B Out systems is a bad idea.

Turning off a transponder (unless directed by ATC) in controlled airspace ((everything except Class G) is also a violation of 14 CFR § 91.215.

Turning off an ADS-B Out system (unless directed by ATC) in *any* airspace is a violation of 14 CFR § 91.225(f) "Each person operating an aircraft equipped with ADS-B Out must operate this equipment in the transmit mode at all times." Well that's great given the goals of ADS-B and how it differs from ATC surveillance radar and meaning of controlled airspace.

So if your transponder is also doing 2020 Complaint 1090ES Out then now you can't turn it off in any airspace because doing so would turn off the ADS-B Out.

Ah but now what about TABS ADS-B Out systems? Does 14 CFR 91.225(f) cover that as well? I would say no as 14 CFR § 91.225 is all about regulations applying to "2020 Compliant" ADS-B out systems specified in 14 CFR § 91.227. And if 14 CFR § 91.225 and/or § 92.227 applied to TABS then we have all sorts if other issues. An illogical rat hole that nobody including the FAA likely would want to go down.

Not that any of this actually matters (just leave stuff tuned on) but if it did then a letter to the FAA Office of the Chief Counsel would help clarify this question about TABS. And they tend to take a pretty clear and supportive view of stuff that if it's not really explicit then its allowed (transponder carriage exemptions for gliders come to mind, glider pilots (including me in the past) assumed they might imply more restrictive regulations than they do, the Office of the Chief Counsel on multiple occasions clarified they don't).

See now, hopefully we are pretty well armed for a boozy Aviation quiz night questions about turning off transponders and ADS-B Out. ...
The AIM is subtitled "Official Guide to Basic Flight Information and ATC Procedures." What part of "Official" don't you understand? The section I quoted is in no way qualified by other paragraphs - it stands on its own. The AIM is an excellent resource in regards to how the FAA interprets FARs - your interpretation and five bucks will buy you a cup of coffee at Starbucks.

And, did you not read the NTSB findings on the Minden glider-jet mid-air? They ALSO agree with me.

If you think you can legally turn off your transponder anytime you want in uncontrolled airspace, you are skating on thin ice. You can deviate from regs if it is a flight safety issue, however.

And I believe I corrected your false claim that all ADS-B Out installations are a minor modification.

I never said that. I was correcting you claim that all ADS-B Out installs (in type certified aircraft) are major modifications. You seemed to made the common mistake that because FAA policy asks for a 337 they are therefore major changes. I said they do require a "notification only" 337s but are not necessarily a major modifications, only if they are for the usual reasons. You then went and got an FAA FSDO person who agreed with what I had been trying to tell you. You seem to have really confounding problems following simple logic/reasoning and keep inverting stuff, or finding contradictions where they don't exist.

I'd already made the comment in this thread about what is allowed by regulations and you commented later saying something different. I don't care what you personally think about anything, but when you keep stating stuff on r.a.s. again and again that is simply just wrong I am going to correct you.

Wonder if Las Vegas bookies have odds on this?
Jim


--
Dan, 5J
  #54  
Old June 4th 18, 03:38 PM posted to rec.aviation.soaring
Charles Longley
external usenet poster
 
Posts: 290
Default ADSB out in tow planes

I don’t know if I agree with you. If an ADSB out can be installed in any type certified aircraft without a 337 why do the manufacturers bother with a STC? I’ve installed a Stratus transponder in a Pawnee using the policy you quoted. I didn’t consider it an informational 337 when I did it. The FAA gets information on which airplanes have ADSB when they’re flown in the national airspace system.

Experimental aircraft are a whole different subject.
  #55  
Old June 4th 18, 05:27 PM posted to rec.aviation.soaring
Darryl Ramm
external usenet poster
 
Posts: 2,403
Default ADSB out in tow planes

On Monday, June 4, 2018 at 7:38:18 AM UTC-7, Charles Longley wrote:
I don’t know if I agree with you. If an ADSB out can be installed in any type certified aircraft without a 337 why do the manufacturers bother with a STC? I’ve installed a Stratus transponder in a Pawnee using the policy you quoted. I didn’t consider it an informational 337 when I did it. The FAA gets information on which airplanes have ADSB when they’re flown in the national airspace system.

Experimental aircraft are a whole different subject.


This has been flogged to death on r.a.s. in the recent past, and the person who was then confused about it went to his FSDO, which confirmed what I was saying. But I'll spare your the pain of wading though that tangled ball.

I did try to addressed exactly the reason an STC is usually needed in the post before. The STC is needed (as the easiest way) to establish a valid pairing between a ADS-B Out tranmitter (e.g. transponder) and a GPS source. You are expected (by that FAA policy) to follow that STC for the configuration related to that device pairing (or if a single box, presumably the setup in that box related to the GPS source). This stuff is in pretty clear English (especially section (6)) of the FAA policy doc I gave you the link to.

You are not required to treat the install as a major alteration and to use that STC for an approval basis just because this is an ADS-B install (if you think you are please explain exactly what establishes that). If you otherwise determine the install is a major alteration then an STC specific to the install in that aircraft is going to provide the basis for a field approval, and you would file a 337 with the FSDO. If it's not a major alteration then you just need an STC that establishes the pairing of those devices, and it does not need to be specific to that aircraft.

Manufactures here clearly need STCs for the pairing basis. Manufacturers also need some STCs for installs as a major alteration approval basis because well those installs are really major alterations, manufactures also like to have STCs to cover stuff where they may not really raise to the level of major alterations but some A&Ps (and FSDO staff) might be nervous about doing stuff without an STC. Many of the existing install STCs were also developed in the past where the installs process was more complex.

The FAA cannot get information they want from the equipment installed in aircraft from direct monitoring of the ADS-B Out signal. There is no data transmitted over ADS-B Out that describes the transmitter or GPS source manufacturer or model (I wish there was), and no way to collect from that the magic info of which A&P signed off on the install. Which given how many ADS-B Out install fail from basic setup/software configurations I suspect they want to know and track down those responsible--to help avoid more, the FAA seems to be being very supportive/helpful with installs but there are so many problems with installs for them to track down. Since an ADS-B Out install is not necessarily a major alteration a 337s would not necessarily be filed with the FSDO so the FAA is seeking a way here to collect all this information and using a 337 form in an unusual way to do that. They would never have bothered with creating that extra process if all installs were major modifications with 337s going to the FSDOs.

I hope you did followed the process the FAA expects for the ADS-B Out equipment you installed in the Pawnee. If you also decided that install required a major alteration approval for other reasons then that that was your decision. I hope you submitted the "notification only" 337 to Oklahoma, if not you may want to go ahead and do that. Not doing that might eventually get the club a "please explain" letter.

  #56  
Old June 5th 18, 03:07 AM posted to rec.aviation.soaring
Charles Longley
external usenet poster
 
Posts: 290
Default ADSB out in tow planes

Did you not read my post? I said I sent a 337 in per the FAA’s guidance. I disagree with you that it was a “notification” 337. But everyone is entitled to their opinion.
  #57  
Old June 5th 18, 03:37 AM posted to rec.aviation.soaring
Darryl Ramm
external usenet poster
 
Posts: 2,403
Default ADSB out in tow planes

On Monday, June 4, 2018 at 7:07:57 PM UTC-7, Charles Longley wrote:
Did you not read my post? I said I sent a 337 in per the FAA’s guidance. I disagree with you that it was a “notification” 337. But everyone is entitled to their opinion.


I read your post, very carefully, and its not clear what you have done. Did you send a 337 to Oklahoma or the FSDO? Did you treat the installation was a major modification, and if so would you mind explaining why? Did you get the FSDO to approve Block 3 before sending it to Oklahoma? Did Oklahoma send you back the 337 with Block 3 approved? I appreciate your help here explaining exactly what you did, I suspect we may be talking at crossed purposes.

I again want to reiterate that ADS-B Out installations in gliders (I know you did a towplane) should normally be minor modifications, and therefore do not need major modification approval, but do require a "notification only" 337 filed with FAA HQ.

  #58  
Old June 5th 18, 04:39 AM posted to rec.aviation.soaring
Charles Longley
external usenet poster
 
Posts: 290
Default ADSB out in tow planes

I followed FAA guidance and installed a Stratus transponder with its associated GPS antenna in accordance with the STC. The STC only has a few models in it not including the Pawnee. I filled out the 337 per FAA guidance and sent it off to OK City. It wasn’t a field approval but was a Major Alteration so no need to send it to the local FSDO. Again per FAA guidance. I don’t expect to get the 337 back. I expect it to just be filed with the aircrafts records as usual.

To reiterate there is no such thing as a “notification” 337..

I haven’t been asked to or researched putting an ADS-B out transponder into a glider so I can’t really speak to that. When I install the PowerFLARM brick into my glider in the fall I’ll get the ADSB out option and do the appropriate research/ paperwork.
 




Thread Tools
Display Modes

Posting Rules
You may not post new threads
You may not post replies
You may not post attachments
You may not edit your posts

vB code is On
Smilies are On
[IMG] code is On
HTML code is Off
Forum Jump

Similar Threads
Thread Thread Starter Forum Replies Last Post
Flarm reporting my own ADSB Out [email protected] Soaring 14 March 22nd 18 04:31 AM
PowerFlarm for ADSB source? [email protected] Soaring 7 February 24th 15 06:01 PM
Stratus / Foreflight ADSB 6X Soaring 5 December 17th 13 10:34 AM
ADSB is only the start... Martin Gregorie[_5_] Soaring 0 October 1st 09 01:27 PM
Santa and ADSB Mal Soaring 0 December 15th 06 08:42 PM


All times are GMT +1. The time now is 10:55 AM.


Powered by vBulletin® Version 3.6.4
Copyright ©2000 - 2024, Jelsoft Enterprises Ltd.
Copyright 2004-2024 AviationBanter.
The comments are property of their posters.