BeechTalk - BT

Username Protected · **Posted:** 28 Nov 2023, 16:30

Username Protected wrote:

On a related note, are the legacy jets (in the TP vs legacy citation thread) RVSM compliant through their certification?

Meaning, would they require hardware changes or creation of an RVSM program to fly them in that airspace?

That’s impossible to answer without a lot more information about the history of the plane, what was installed, and what’s currently installed.

They weren’t RVSM certified when they were first certified, as RVSM didn’t exist then. The Citation V was certified in 1988 and RVSM started in 1997.

OTH, I can’t imagine that any owner of any of those planes would have done something to them to make them non-RVSM compliant.

Username Protected · **Posted:** 28 Nov 2023, 16:46

Username Protected wrote:

On a related note, are the legacy jets (in the TP vs legacy citation thread) RVSM compliant through their certification?

Meaning, would they require hardware changes or creation of an RVSM program to fly them in that airspace?

That’s impossible to answer without a lot more information about the history of the plane, what was installed, and what’s currently installed.

They weren’t RVSM certified when they were first certified, as RVSM didn’t exist then. The Citation V was certified in 1988 and RVSM started in 1997.

OTH, I can’t imagine that any owner of any of those planes would have done something to them to make them non-RVSM compliant.

Username Protected · **Posted:** 28 Nov 2023, 18:30

Username Protected wrote:

I got it after the FAA and NAARMO did observation and collection of ADS-B data. Yes, all they’re doing is collecting data, but they do a lot of processing to your data and all the planes in your same area to determine your ASE. I had it explained to me and it’s pretty cool if you’re a geek.

Yeah, I know they do comparison of the ADSB baro altitude and GPS altitude and those of other aircraft near you. Obviously that's about the depth of detail I know. But interesting. More interesting is they were willing to let you use that data as demonstration that your ASE was inbounds. That's what a bunch of us were arguing was possible when it was first released, especially for turboprops in the low RVSM altitudes at non-mach speeds. See the last post on p. 3 of that thread with new verbiage from AC 91-85B that specifically says that wasn't what it was for.

You are an existence proof that Mike Ciholas was ultimately correct.

Username Protected · **Posted:** 28 Nov 2023, 19:06

Username Protected wrote:

Compliant means certified

This is going to go in circles again.

If you have an older turbine and are interested in talking to someone who has experience with the section 9 process, including direct communication with the local FSDO, NAARMO, and a lawyer with RVSM experience, DM me.

If that makes you nervous, or you need it for 135 or international flight, I’m sure there are good competent people on BT who can help you get certified.

Username Protected · **Posted:** 28 Nov 2023, 21:02

Username Protected wrote: “One of the things that we have verified with ADS-B height monitoring is that aircraft designed for RVSM operation typically perform very well. However, aircraft not designed for RVSM operations that are modified with ADS-B Out will likely not meet the ASE requirements specified in Part 91, Appendix G, Section 9(b), and therefore would not be eligible for RVSM operations. This is something you cannot see in-flight. I did do a very quick review of the aircraft records and could not find any previous RVSM approvals for this aircraft. If the airplane has not been properly modified for RVSM operation, it would be prudent to see the monitoring results prior to conducting further RVSM operations. I will follow-up with NAARMO next week to expedite your request.

The technicians will take a look at the data for both flights you mentioned and calculate your performance. If the performance is in anyway aberrant, we will reach back out to you and your responsible Flight Standards safety office. “

I won’t go into that letter point by point - you can all read and draw you own conclusions.

I did not get a letter from the FAA that said “You are legally allowed to fly in RVSM airspace in tail <xxxxx>.” I did get one that said I had been placed on the list with the heading “US IGA Operators with Domestic RVSM Authorization under Part 91 Section 9.” My tail is still on that list, with over a thousand other airframes - including experimentals.

Username Protected · **Posted:** 28 Nov 2023, 23:34

Username Protected wrote:

I did get one that said I had been placed on the list with the heading “US IGA Operators with Domestic RVSM Authorization under Part 91 Section 9.” My tail is still on that list, with over a thousand other airframes - including experimentals.

The rule is very clear. You have to meet certain PERFORMANCE requirements, then you can fly in RVSM airspace.

Section 9. Aircraft Equipped With Automatic Dependent Surveillance—Broadcast Out

An operator is authorized to conduct flight in airspace in which RVSM is applied provided:

(a) The aircraft is equipped with the following:

(1) Two operational independent altitude measurement systems.

(2) At least one automatic altitude control system that controls the aircraft altitude—

(i) Within a tolerance band of ±65 feet about an acquired altitude when the aircraft is operated in straight and level flight under nonturbulent, nongust conditions; or

(ii) Within a tolerance band of ±130 feet under nonturbulent, nongust conditions for aircraft for which application for type certification occurred on or before April 9, 1997, that are equipped with an automatic altitude control system with flight management/performance system inputs.

(3) An altitude alert system that signals an alert when the altitude displayed to the flightcrew deviates from the selected altitude by more than—

(i) ±300 feet for aircraft for which application for type certification was made on or before April 9, 1997; or

(ii) ±200 feet for aircraft for which application for type certification is made after April 9, 1997.

(4) A TCAS II that meets TSO C–119b (Version 7.0), or a later version, if equipped with TCAS II, unless otherwise authorized by the Administrator.

(5) Unless authorized by ATC or the foreign country where the aircraft is operated, an ADS–B Out system that meets the equipment performance requirements of § 91.227 of this part. The aircraft must have its height-keeping performance monitored in a form and manner acceptable to the Administrator.

(b) The altimetry system error (ASE) of the aircraft does not exceed 200 feet when operating in RVSM airspace.

No where in the rule does it says the airplane has to be CERTIFIED for RVSM flight. It only says the performance standard you have to reach. The rule doesn't clearly state HOW you demonstrate or document the capability, however, but a straightforward approach would be to simply test it and see.

My plane was not RVSM certified as delivered, but became so in mid 1990s. I then ripped that out and my Garmin avionics package is RVSM certified. But I operate under section 9 never the less.

I went to the FAA monitoring website, and my plane is listed under the section 9, with a recent flight just weeks ago.

https://www.faa.gov/air_traffic/separat ... _approvals

My plane qualifies because I have two independent altitude systems, an autopilot that can maintain +/- 130 ft in altitude hold, an altitude alerter that signals within +/- 300 ft of a deviation, and ADS-B out. I don't have TCAS II, so I don't need to meet that part of the rule. My entry in the FAA monitoring list confirms my plane's ability to keep ASE within 200 ft. I therefore check all the boxes.

I do not have an LOA under section 3, so I would not be allowed to operate internationally in RVSM airspace. I could get an LOA if I wanted to.

Mike C.

Username Protected · **Posted:** 29 Nov 2023, 07:27

Username Protected wrote:

My ADS-B configuration was royally screwed when I got the plane, which is why I had such extensive contact with NAARMO, the FSDO, and the FAA Separation Standards Analysis Branch. My ASE was discussed during these emails, but a normal operator will know their ASE is acceptable after the RVSM test flight when the tail shows up on the RVSM approved list.

Keep in mind that the list is of "operational approval". Not the same thing as airworthiness approval, which the FAA says you still need.

Username Protected · **Posted:** 29 Nov 2023, 07:56

Username Protected wrote:

I did not get a letter from the FAA that said “You are legally allowed to fly in RVSM airspace in tail <xxxxx>.” I did get one that said I had been placed on the list with the heading “US IGA Operators with Domestic RVSM Authorization under Part 91 Section 9.” My tail is still on that list, with over a thousand other airframes - including experimentals.

The NAARMO list and letters are just for monitoring. They are not policing the initial certification, but they can kick you out if you don't meet the monitoring limits. The experimentals are there because they are special in all ways. They -should- be doing initial testing to see if they meet the requirements in respect to ASE (and the other performance requirements) but that can be done without an FAA cert program.

There is a lot of turbine equipment that will likely pass at least some of the monitoring. Every jet I have ever maintained prior to RVSM had SSEC correction, so the gross errors in ASE were already mostly fixed, but none of them had the required accuracy to meet RVSM. Not many turboprops had SSEC correction prior to RVSM (The TBM did not). So flying in RVSM airspace without specific RVSM cert -might- work but carries risk.

Username Protected · **Posted:** 29 Nov 2023, 07:59

Username Protected wrote:

(b) The altimetry system error (ASE) of the aircraft does not exceed 200 feet when operating in RVSM airspace.[/i]

No where in the rule does it says the airplane has to be CERTIFIED for RVSM flight. It only says the performance standard you have to reach. The rule doesn't clearly state HOW you demonstrate or document the capability, however, but a straightforward approach would be to simply test it and see.

Part 91 doesn't say anything has to be certified, so that is a specious argument

Username Protected · **Posted:** 29 Nov 2023, 09:33

Username Protected wrote:

Part 91 doesn't say anything has to be certified

Sure it does.

For example, 91.227 says your ADS-B out equipment must meet certain TSO standards. No operator can demonstrate that operationally, it is a certification requirement.

Section 9 of RVSM doesn't have that, it has specific PERFORMANCE criteria.

If I demonstrate my airplane meets those, then I can fly RVSM under section 9.

Except in two cases, the rule says "is equipped", not "meets standard". One case is ADS-B out, it has to be certified per 91.227, and the other case is TCAS II, which has to meet a TSO if equipped (I am not).

A person can check off the requirements in section 9 and then go fly RVSM. A video documenting you have two altitude systems, your AP can hold within 65 feet, it can level off within 135 ft (for altitude preselect), and it can alert when you deviate +/- 200 or 300 ft, then you have demonstrated you meet the performance requirements of section 9. You then check your flight with the FAA RVSM monitor program per 9(b).

Just because it is customary to meet section 9 requirements by claiming you have a CERTIFIED RVSM installation doesn't mean that's the ONLY way to meet section 9.

Mike C.

Username Protected · **Posted:** 29 Nov 2023, 09:58

Username Protected wrote:

Just because it is customary to meet section 9 requirements by claiming you have a CERTIFIED RVSM installation doesn't mean that's the ONLY way to meet section 9.

Mike C.

The FAA already disagrees with you. Until they say something different I think it is a huge risk for any operator trying to fly RVSM without cert.

That's my take, you have yours, I'll leave it at that

Username Protected · **Posted:** 29 Nov 2023, 10:24

Username Protected wrote:

You are conveniently ignoring the ASE requirement. You can't demonstrate that even with the monitoring program.

I'm not ignoring it.

It says "while operating" in RVSM airspace. It doesn't say "certified" to maintain a particular ASE by design. The FAA specifically gives you a procedure for an initial check flight.

Quote:

The FAA already disagrees with you.

Reference a document that supports your claim and quote the specific passage.

I will cite:

https://www.faa.gov/documentLibrary/med ... 00.500.pdf

It does not say "RVSM certified", it says "RVSM compliant". It then further says:

The initial RVSM operation of an aircraft must be in airspace where sufficient ADS-B data can be collected for the FAA to evaluate RVSM performance. This airspace is currently defined in § 91.225(a) between flight level (FL) 290 and FL 410, inclusive. A coverage map of FAA-monitored ADS-B airspace can be found at http://www.faa.gov/nextgen/
programs/adsb/coverageMap/.

After initial operations, the aircraft’s altitude-keeping equipment performance must have been monitored within the previous 24 months in airspace where the FAA can monitor the ADS-B Out signal and found to be in RVSM compliance.

Operators are able to confirm aircraft performance is RVSM-compliant by checking the North American Approvals Registry and Monitoring Organization (NAARMO) altitude-keeping equipment performance monitoring website (described below).

Ultimately, the regulations are what is written down in words and those words say you can fly in RVSM airspace if you have the operational performance prescribed in section 9 and you do an initial monitored flight that passes.

Mike C.

Username Protected · **Posted:** 29 Nov 2023, 11:00

Here's how it was stated in a course I recently took...

Username Protected · **Posted:** 29 Nov 2023, 11:24

Username Protected wrote:

You are conveniently ignoring the ASE requirement. You can't demonstrate that even with the monitoring program.

That is exactly why the monitoring program exists - so that operators can verify that their ASE is compliant.

“Operators who elect to utilize Part 91 Appendix G, section 9 to access RVSM airspace must verify their altitude-keeping performance. The current list of aircraft and their most recent successful monitoring date can be found at RVSM Approvals in the file labeled US IGA Operators with Domestic RVSM Authorization under Part 91 Section 9 (ADS-B).”

https://www.faa.gov/air_traffic/separat ... ng_methods

Username Protected · **Posted:** 29 Nov 2023, 11:28

Username Protected wrote:

Reference a document that supports your claim and quote the specific passage.

You are confusing "compliant" with "authorized".

FAA AC 91-85B

"CHAPTER 4. AUTHORIZATIONS FOR OPERATORS OF RVSM AIRCRAFT
EQUIPPED WITH A QUALIFIED ADS-B OUT SYSTEM"
...
4.1.1
...
1. Determine the aircraft is RVSM-compliant (see Chapter 2, Aircraft
Eligibility);"

"CHAPTER 2. AIRCRAFT ELIGIBILITY
...
2.2 Aircraft Eligibility. An aircraft is an “RVSM-Compliant Aircraft” when:
1. The aircraft design ensures the aircraft will meet RVSM performance
requirements; and
2. The aircraft has been properly maintained on an ongoing basis to conduct such operations."

"aircraft design" is FAA speak for certification.

The RVSM Thread