transponder 2 year check

On Thursday, May 9, 2019 at 10:04:21 AM UTC-7, Paul Agnew wrote:
On Thursday, May 9, 2019 at 12:17:45 PM UTC-4, Darryl Ramm wrote:
Replying again, in the right thread this time.

You don’t have a simple option to leave a transponder turned off. Once installed you are required to use it in *controlled airspace*. 14 CFR 91.215....

On Thursday, May 9, 2019 at 5:10:06 AM UTC-7, Jonathan Foster wrote:
On Wednesday, May 8, 2019 at 10:08:20 PM UTC-6, Darryl Ramm wrote:
On Wednesday, May 8, 2019 at 8:36:37 PM UTC-7, wrote:
I have a trig transponder (no ADSB yet). This transponder is not legally required in a glider. So, do I still have to get the transponder checked every two years per 91.413?

https://www.law.cornell.edu/cfr/text/14/91.413

It appears so to me, but am I missing something?

Yes, there is no difference here between gliders (and other transponder partial exemption aircraft) and a VFR powered aircraft. It is clear in the regulations.

This may be a silly question if at the end of two years you decide not to use the transponder anymore but leave it in your panel always turned off. Would you still legally be required to have it checked?

If it's not currently useable due to the being out of currency, so to speak, I would think you could legally use 91.213 d(3) (ii) to deactivate it, placard it, and go fly.

Paul A.
Jupiter, FL

Please no. More responsibly/safely, if maybe less complaint with regulations, fly with the transponder turned on, get it tested ASAP. Thankfully lots of clubs/FBOs are good at arranging transponder check days and getting somebody out to test all the gliders at a site in one day so this hopefully never comes up a an issue.

There should be no real excuses nowadays to flying with a transponder tuned off. As JJ mentioned, the transponder being turned off in the ASG-29 involved in the middair with the Hawker 800 (a "fast twin" :-)) near Minden was pretty unfortunate (no, OK stupid). And more recently than that events like the ASH26E (no transponder installed) close encounter with a B737 going into Chicago is a reminder that transponders are important safety devices in busy airspace, especially with TCAS equipped fast jets and airliners, etc.

My understanding of the regs.....you have the equipment (transponder), it "shall be turned on for flight onless plackered (sp) as 'inoperative'" for that flight.
I do not believe there are exemptions for standard vs. experimental.
Basically, "you got it, you use it".

Excellent explanation, Darryl.

I used the setup instructions that were part of the installation manual
that came with my STC.Â* My IA inspected and signed off my work and my
Performance report came back "clean".

On 5/9/2019 11:04 AM, Darryl Ramm wrote:
On Thursday, May 9, 2019 at 5:49:22 AM UTC-7, son_of_flubber wrote:
If you have a Trig transponder and install TABS or ADSB-out, why can't you use the Public ADSB Compliance report in place of Transponder Compliance test?

The ADSB COmpliance report seems superior because it tests the whole system in the air for several hours, whereas the Transponder Compliance test is an artificial test done in the hangar for 30 seconds.

https://adsbperformance.faa.gov/paprrequest.aspx
What tests exactly? There are two transponder tests, Part 43 appendix E (altitude encoder test) and Part 43 appendix F (Transponder RF test).

The encoder test (required when the static system is opened, etc) could not be achieved by the FAA Public ADS-B Performance Report, it relies on the encoder being correct.

The transponder RF test verifies the transponder replies correctly to a Mode A, C and S interrogations and checks for some corner cases of known possible issues, the FAA Public ADS-B Performance Report does not provide that information, there is no guarantee that an aircraft will experience all those different interrogations during a flight, etc. and the system may not be able to tell what is going on in a "live" non-test environment. Things that might be doable very roughly like infer transmitted power would be relatively inaccurate, better to measure those at the aircraft.

Now, two year checks made a lot more sense when transponders were powered by unreliable traveling wave tubes and had lots of components inside. Modern solid state transponders, with highly integrated digital components are much more reliable. So two years may be overkill, but I'd not hold my breath waiting for that to change.

The FAA Public ADS-B Performance Report are great for letting owners see that an ADS-B Out system is configured and working properly. Including being the *only* way for most glider pilots to know a 2020 Compliant or TABS ADS-B Out system is fully working... e.g. on a Trig transponder you can't just rely on seeing a lat/lon display on your transponder... the transponder can show you a lat/lon but you don't know the actual GPS reception is giving you a high enough NIC quality parameter, or that the SIL setup parameter is set correctly, ... things that can stop ATC or some airborne ADS-B In receivers being able to see your aircraft via ADS-B Out. And just asking ATC "can you see me" at times may not help, if you are within SSR coverage the controller can't tell if they are seeing you via SSR or ADS-B. And your buddy seeing you on a PowerFLARM also does not tell you if ATC or IFR/certified ADS-B In system can see your ADS-B position. ... so look at those performance reports. https://adsbperformance.faa.gov/paprrequest.aspx

Everybody flying with ADS-B Out should pull a report or two after installation to make sure things are OK, and maybe once a year or so after that. Those reports can be used by an A&P as part of a install in a type certified aircraft, or they can utilize ADS-B capable ground test equipment -- more $$$ than Mode-S transponder test gear -- which few folks working with gliders will have access to. For experimental aircraft installs there is no documentation needed of a test, but get one done yourself. And regardless of who installed and claimed to test or not what they did, pull your own report and check.

The FAA is looking at the equivalent of those reports as well. And they are likely to contact you eventually if there are glaring problems (and as I mentioned before they are likely to contact folks with TABS systems (which by definition are not 2020 Compliant)... the FAA has no way of knowing the install is not intended to be 2020 Compliant).

As always anybody with a Public ADS-B Performance Report and has questions about it can email the PDF report to me. I'm getting about one a week. GPS Antenna installation quality (affecting NIC), basic TT21/TT22 setup menu mistakes, flying on the edge of ADS-B ground coverage, or forgetting to get the transponder firmware updated, are the most likely causes of issues being flagged in those reports. I'm updating some of the Trig setup instructions (most folks have hopefully been using the notes that Richard and I wrote on the Craggy website) and will get those updated soon.







--
Dan, 5J

Yep Dan you did great with your TN70 install. I should have clarified the instructions I am talking about are for TN72 installs (either SIL=3/2020 Compliant or SIL=1/TABS). Anyhow they'll get updated soon and I'll post links here when that happens.

Darryl

On Thursday, May 9, 2019 at 11:20:53 AM UTC-7, Dan Marotta wrote:
Excellent explanation, Darryl.

I used the setup instructions that were part of the installation manual
that came with my STC.Â* My IA inspected and signed off my work and my
Performance report came back "clean".

On 5/9/2019 11:04 AM, Darryl Ramm wrote:
On Thursday, May 9, 2019 at 5:49:22 AM UTC-7, son_of_flubber wrote:
If you have a Trig transponder and install TABS or ADSB-out, why can't you use the Public ADSB Compliance report in place of Transponder Compliance test?

The ADSB COmpliance report seems superior because it tests the whole system in the air for several hours, whereas the Transponder Compliance test is an artificial test done in the hangar for 30 seconds.

https://adsbperformance.faa.gov/paprrequest.aspx
What tests exactly? There are two transponder tests, Part 43 appendix E (altitude encoder test) and Part 43 appendix F (Transponder RF test).

The encoder test (required when the static system is opened, etc) could not be achieved by the FAA Public ADS-B Performance Report, it relies on the encoder being correct.

The transponder RF test verifies the transponder replies correctly to a Mode A, C and S interrogations and checks for some corner cases of known possible issues, the FAA Public ADS-B Performance Report does not provide that information, there is no guarantee that an aircraft will experience all those different interrogations during a flight, etc. and the system may not be able to tell what is going on in a "live" non-test environment. Things that might be doable very roughly like infer transmitted power would be relatively inaccurate, better to measure those at the aircraft.

Now, two year checks made a lot more sense when transponders were powered by unreliable traveling wave tubes and had lots of components inside. Modern solid state transponders, with highly integrated digital components are much more reliable. So two years may be overkill, but I'd not hold my breath waiting for that to change.

The FAA Public ADS-B Performance Report are great for letting owners see that an ADS-B Out system is configured and working properly. Including being the *only* way for most glider pilots to know a 2020 Compliant or TABS ADS-B Out system is fully working... e.g. on a Trig transponder you can't just rely on seeing a lat/lon display on your transponder... the transponder can show you a lat/lon but you don't know the actual GPS reception is giving you a high enough NIC quality parameter, or that the SIL setup parameter is set correctly, ... things that can stop ATC or some airborne ADS-B In receivers being able to see your aircraft via ADS-B Out. And just asking ATC "can you see me" at times may not help, if you are within SSR coverage the controller can't tell if they are seeing you via SSR or ADS-B. And your buddy seeing you on a PowerFLARM also does not tell you if ATC or IFR/certified ADS-B In system can see your ADS-B position. ... so look at those performance reports. https://adsbperformance.faa.gov/paprrequest.aspx

Everybody flying with ADS-B Out should pull a report or two after installation to make sure things are OK, and maybe once a year or so after that. Those reports can be used by an A&P as part of a install in a type certified aircraft, or they can utilize ADS-B capable ground test equipment -- more $$$ than Mode-S transponder test gear -- which few folks working with gliders will have access to. For experimental aircraft installs there is no documentation needed of a test, but get one done yourself. And regardless of who installed and claimed to test or not what they did, pull your own report and check.

The FAA is looking at the equivalent of those reports as well. And they are likely to contact you eventually if there are glaring problems (and as I mentioned before they are likely to contact folks with TABS systems (which by definition are not 2020 Compliant)... the FAA has no way of knowing the install is not intended to be 2020 Compliant).

As always anybody with a Public ADS-B Performance Report and has questions about it can email the PDF report to me. I'm getting about one a week.. GPS Antenna installation quality (affecting NIC), basic TT21/TT22 setup menu mistakes, flying on the edge of ADS-B ground coverage, or forgetting to get the transponder firmware updated, are the most likely causes of issues being flagged in those reports. I'm updating some of the Trig setup instructions (most folks have hopefully been using the notes that Richard and I wrote on the Craggy website) and will get those updated soon.







--
Dan, 5J

On 5/9/19 12:01 PM, Charlie M. (UH & 002 owner/pilot) wrote:
My understanding of the regs.....you have the equipment (transponder), it "shall be turned on for flight onless plackered (sp) as 'inoperative'" for that flight.
I do not believe there are exemptions for standard vs. experimental.
Basically, "you got it, you use it".


I think the AIM differs from the FAR's on that point. Common sense
dictates that you just keep it on.

Hmmm...Â* Information Manual vs. Federal Regulation.Â* You decide which to
follow...

On 5/9/2019 2:20 PM, kinsell wrote:
On 5/9/19 12:01 PM, Charlie M. (UH & 002 owner/pilot) wrote:
My understanding of the regs.....you have the equipment
(transponder), it "shall be turned on for flight onless plackered
(sp) as 'inoperative'" for that flight.
I do not believe there are exemptions for standard vs. experimental.
Basically, "you got it, you use it".


I think the AIM differs from the FAR's on that point.Â* Common sense
dictates that you just keep it on.

--
Dan, 5J

Just to be clear, what UH posted is not correct, there is no requirement
in the regs that an installed transponder always be turned on.

It is kinda stupid not to use it at all times, but this is RAS after all.


On 5/10/19 8:54 AM, Dan Marotta wrote:
Hmmm...Â* Information Manual vs. Federal Regulation.Â* You decide which to
follow...

On 5/9/2019 2:20 PM, kinsell wrote:
On 5/9/19 12:01 PM, Charlie M. (UH & 002 owner/pilot) wrote:
My understanding of the regs.....you have the equipment
(transponder), it "shall be turned on for flight onless plackered
(sp) as 'inoperative'" for that flight.
I do not believe there are exemptions for standard vs. experimental.
Basically, "you got it, you use it".


I think the AIM differs from the FAR's on that point.Â* Common sense
dictates that you just keep it on.

91.215
(c)Transponder-on operation. While in the airspace as specified in paragraph (b) of this section or in all controlled airspace, each person operating an aircraft equipped with an operable ATC transponder maintained in accordance with § 91.413 of this part shall operate the transponder, including Mode C equipment if installed, and shall reply on the appropriate code or as assigned by ATC.

On Friday, May 10, 2019 at 10:35:54 AM UTC-6, kinsell wrote:
Just to be clear, what UH posted is not correct, there is no requirement
in the regs that an installed transponder always be turned on.


FAR 91.215 (c)
(c)Transponder-on operation. While in the airspace as specified in paragraph (b) of this section or in all controlled airspace, each person operating an aircraft equipped with an operable ATC transponder maintained in accordance with § 91.413 of this part shall operate the transponder, including Mode C equipment if installed, and shall reply on the appropriate code or as assigned by ATC.

On Friday, May 10, 2019 at 11:19:34 AM UTC-7, Paul Agnew wrote:
91.215
(c)Transponder-on operation. While in the airspace as specified in paragraph (b) of this section or in all controlled airspace, each person operating an aircraft equipped with an operable ATC transponder maintained in accordance with § 91.413 of this part shall operate the transponder, including Mode C equipment if installed, and shall reply on the appropriate code or as assigned by ATC.

You need to check the paragraph (b) mentioned above. Not all controlled airspaces (in the US) require the use of a transponder, even if it is installed.