ADS-B and RVSM

[KenFlo]

From what I am reading, Jan 22 a new rule goes into effect allowing ADS-B In and Out aircraft to fly in RVSM altitudes.  Minimum equipment requirements are two altimeters, auto pilot capable of +- 135 feet in smooth air, altitude alert if you exceed 300 feet from altitude assigned, and pilot trained in RVSM opns.  No more application required. 
  For you smart guys out there, am I reading this correctly? 

[SKYFLYER]

You are correct.

https://www.govinfo.gov/content/pkg/FR-2018-12-21/pdf/2018-27401.pdf

The proposed rule change actually had just two changes made in the final regs.

I for one am happy to see it.

[donv]

That is correct, although I don't believe it's quite that simple. What this did was do away with the requirement to get an LOA from the FAA to operate in RVSM airspace. The altimetry still has to be certified to meet RVSM standards, which is the expensive part.

[KenFlo]

The altimeter certification was part of the application package.  Not sure what documentation will be required going forward.  It may turn out that its not that bad since ATC has altitude readouts from the ADS-B.  Records are kept for each flight and those flights that exceed the baseline, operators will be notified.  Maybe as long as you have the minimum equipment specified in App G, all of the expensive testing and altimeters might not be needed.
  Pilots can take an on-line course for 40 bucks to meet the knowledge requirement.
More may be coming....I talked to AOPA and they are meeting soon with the FAA to discuss this and what will be expected.  At least this is a step in the right direction.
  I usually fly my 690B FL250-FL260...so I really don't have to have it, it would be nice if I could do 29-30 to get through some storms or take advantage of big tailwinds.  Thanks for the input!

[SKYFLYER]

For you to have RVSM will just be another rung on the ladder of safety knowing you can have those flight levels if you need them. The altimeter certs are pretty easy with the measuring stations along the Eastern seaboard. I suspect that there are some not far from you as well. The "alerter" is what most systems do not have and would need to be installed.
So an hour with an A&I onboard should get you the certs you need and both altimeters tweaked so that they are both within the limits at the RVSM flight levels.
Your auto-pilot will need the A&I to certify it meets the operational limits as well.

[donv]

I highly doubt the stock Commander altimetry system would meet the accuracy requirements for RVSM. That's why the RVSM certification is expensive-- it's not just the testing (which is a non-event).  It requires new equipment, and possibly upgrades to the pitot/static system. You also have to have 3 altimeters, which you already do if you have a G600 or G950.

[SKYFLYER]

His system is NOT "stock" as he has a G600 and the pitot/static system does not change... at least on mine it did not.
And I was referencing his aircraft NOT Commanders in general.

I agree that most original or "stock" Commander panels would not pass muster for RVSM.

[donv]

I have a G600 as well, and ADS-B, but I doubt it magically now qualifies for RVSM with no additional equipment or work. Although that would be cool if it were true!

[donv]

I just looked at the requirements. Both the autopilot and the altimetry system have to meet certain performance requirements. I doubt the AP-106  meets those requirements, at least in stock form, but again, I could be wrong. I really have no idea if the altimetry requirements are met with the G600-- maybe they are.

[donv]

I read a bit more. Unless you have information which says otherwise, all this does is remove the monitoring requirement and the requirement to apply for an LOA from the FAA. The equipment requirements and certification requirements remain the same, unless the FAA says otherwise.

[KenFlo]

No doubt there are some things to be sorted out here.  It might be possible with a G600 and KFC 300 to pass the system requirements.  And it may turn out that a flight check with an AI on board certifying the results with an annotation in the log book may be all that is required.
  I think the FAA whole point in this rule change is that ADS-B out gives ATC a very accurate altitude and position readout maybe eliminating expensive altimeters and RVSM certs.  Otherwise, what is the real point here.  The intent seems to be that ADS-B out aircraft provide ATC with sufficient, accurate,  and confident altitude information that allows aircraft to operate in RVSM altitudes with the requisite level of safety. Before that, the only way they had confidence that you could operate in those altitudes was to require expensive equipment, go through testing, and apply for the certification documenting all that you did.  Now they seem to be saying if your current system can fly to these standards and you have ADS-B, you can fly above FL280.
Time will tell but lets hope it gets easier rather than just eliminating paperwork.  I appreciate all of the comments!

[donv]

No, the real point was eliminating the very cumbersome and time-consuming FAA letter of authorization process. Since most new airplanes capable of flying above FL280 come from the factory already equipped for RVSM, why go through a big dog and pony show for the FAA to prove it again?

Unless someone can show me otherwise, there is no change to the equipment requirements.

[donv]

The Advisory Circular for RVSM has now been issued by the FAA:

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_91-85B.pdf

It discusses use of ADS-B for height monitoring, and is very clear on what constitutes an RVSM-capable aircraft:

To determine eligibility for RVSM operations, the limitations section of the Airplane
Flight Manual (AFM) or AFM Supplement (AFMS) should indicate the aircraft has been
determined to be capable of meeting the RVSM performance requirements of 14 CFR
part 91 appendix G.

[KenFlo]

Note: For operators and pilots authorized under part 91 appendix G, section 9, the aircraft may have qualified as Group or Non-Group aircraft described in Appendix A.

Twin Commanders are listed as a qualified group.  So does this mean 690B passes the AFM requirement?

[donv]

Does your AFM say it's RVSM-capable? Or do you have an AFM supplement which says so?

If the answer is "no" then it is not RVSM capable. Period.