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Author Topic: Garmin Auto Pilots and Engine Instruments  (Read 6203 times)

donv

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Re: Garmin Auto Pilots and Engine Instruments
« Reply #30 on: October 15, 2022, 11:57:52 am »
Bruce, I assume the problem with "previously compliant" aircraft is that their supplement says something to the effect that "this aircraft has been determined to comply with RVSM performance requirements, as long as equipment x, y, and z are installed?"

And then if you remove x, y or z then you are no longer compliant with that STC?

Bruce Byerly

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Re: Garmin Auto Pilots and Engine Instruments
« Reply #31 on: October 16, 2022, 04:12:32 pm »
Yes. It’s not very common to “decomply” with an STC but that’s what you’re doing when changing equipment that’s required for the STC. 

I’ve poked at RVSM for years but always run into the brick wall that you pointed out Don.  Seems like there is always a way so say “no” so it would be fantastic to have another way to do it. 

JimC

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Re: Garmin Auto Pilots and Engine Instruments
« Reply #32 on: October 17, 2022, 12:34:48 pm »
I've found two aviation lawyers that specialize in RVSM, both section 3 and section 9. They're both busy at NBAA this week, and I'm busy next week. Like I said, it'll be a while.

I'll pony up for at least one paid consultation and I'll share my findings. I think we'll all be happier to have an answer, no matter which way it goes.
500B, B200

donv

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Re: Garmin Auto Pilots and Engine Instruments
« Reply #33 on: October 17, 2022, 02:22:39 pm »
If you are going to pay them, have them write a letter to the FAA Office of Chief Counsel and get an official opinion. In the end, that is all that matters.

https://www.faa.gov/about/office_org/headquarters_offices/agc

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/Interpretations/
« Last Edit: October 17, 2022, 02:25:56 pm by donv »

Bruce Byerly

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Re: Garmin Auto Pilots and Engine Instruments
« Reply #34 on: October 17, 2022, 10:54:41 pm »
If you are going to pay them, have them write a letter to the FAA Office of Chief Counsel and get an official opinion. In the end, that is all that matters.

https://www.faa.gov/about/office_org/headquarters_offices/agc

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/Interpretations/

I’ll be at NBAA all week. Let me know what I can do to help. If there’s a pathway through this as you have endeavored, I’ll pay the bill Jim.

If anyone else is going, please stop by our booth at Naples Jet. We’re quickly recovering from the Hurricane and look forward to seeing you!

JimC

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Re: Garmin Auto Pilots and Engine Instruments
« Reply #35 on: October 18, 2022, 04:05:49 pm »
I'll pay to find out if I'm wrong. I'll let you pick up the tab if I'm right. ;)
500B, B200

JimC

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Re: Garmin Auto Pilots and Engine Instruments
« Reply #36 on: November 01, 2022, 11:43:42 am »
Update: Two lawyers, two strikes.

Lawyer one doesn't do section 9 and was giving me the sell on an LOA. Bad choice on my part.

Lawyer two listed Section 9 on her website, but when pressed admitted she hadn't actually walked anyone through the process as deep as I'd gone. It was clear both Don and I have spent more time with the AC than she has. She thought there was a 50/50 chance she could get a Chief counsel letter (The FAA is not required to respond to all requests.)

I received the suggestion to call AOPA legal, and that's my next step.
500B, B200

donv

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Re: Garmin Auto Pilots and Engine Instruments
« Reply #37 on: November 01, 2022, 01:49:24 pm »
Is the G-950 RVSM-capable?

JMA

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Re: Garmin Auto Pilots and Engine Instruments
« Reply #38 on: November 01, 2022, 01:57:49 pm »
Sorry, im late to the party on this one.  Correct, we have RSVM
Autopilot is down by throttle, will share some further pics as well.  Previously posted these. 
Will write further after the day is done for work.

JimC

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Re: Garmin Auto Pilots and Engine Instruments
« Reply #39 on: November 02, 2022, 06:31:42 pm »
Good news: I could not find, nor did I hear of, any record of anyone being violated for flying under section 9.
Bad news: Because nobody's been violated, there are *very* few lawyers with section 9 RVSM experience. Lawyers get good experience from defending clients.

I did find a lawyer with some experience, gave him what I had, and paid him to write an opinion letter. The last line of the letter reads "Based on the information you have provided, it is my opinion that your aircraft and operations in RVSM airspace are compliant with section 9."

I'm stopping this quest right here. When I asked him about getting a letter from the local FSDO, he said "Why would you poke a sleeping bear?"
500B, B200

donv

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Re: Garmin Auto Pilots and Engine Instruments
« Reply #40 on: November 02, 2022, 06:46:36 pm »
I'm certainly in agreement with your attorney about the FSDO-- and anything they told you would be meaningless in the end.

Hopefully nothing goes wrong and you never need to test that opinion! At a minimum, that should be a sign that you are attempting to comply in good faith.

Bruce Byerly

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Re: Garmin Auto Pilots and Engine Instruments
« Reply #41 on: November 04, 2022, 12:21:49 am »
Is the G-950 RVSM-capable?

Yes, that’s the problem.

JMA - hard to tell, but if that’s still a KFC300 as I recall, that’s not an RVSM approved configuration so you’d be there with Jim.

Maybe a conference call would be better. Sleeping bear is to be respected.


JMA

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Re: Garmin Auto Pilots and Engine Instruments
« Reply #42 on: November 14, 2022, 05:53:38 pm »
Full details to follow, sorry to not answer now, 2 home with pink eye.

donv

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Re: Garmin Auto Pilots and Engine Instruments
« Reply #43 on: November 15, 2022, 12:26:49 pm »
I can see the KFC-300 annunciator panel above the G600.

JMA

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Re: Garmin Auto Pilots and Engine Instruments
« Reply #44 on: November 28, 2022, 11:03:16 am »
Sorry for delay on this flu in the house and then holidays.  Just waiting to confirm all with the boss (aka dad), but I think Bruce is right though.