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Thread: Did the EAA get involved in this: Luscombe owner wanting to turn ADS-B off and on

  1. #1

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    Did the EAA get involved in this: Luscombe owner wanting to turn ADS-B off and on

    I am trying to find some sort of follow up on this article from 12/2019

    https://www.aopa.org/news-and-media/...king-for-ads-b

    The petition shows pending:
    https://www.regulations.gov/docket/FAA-2019-1009

    I am wondering if anyone from the EAA was involved in this? My dream plane is a Luscombe or a Champ w/o an engine driven electrical system and my plan is to buy something along those lines after I get my commercial ticket. But I recently moved rather close to LAX, and while the desert makes a light, high wing taildragger more appealing, I also would like to maintain the option of flying through the LAX VFR Corridor to go to get a burger on Catalina island. Current regs basically require an electrical system if you install ADS-B, but if this petition goes through it could offer some worthwhile options for those of us who like more basic planes.
    1978 Grumman AA1C w/O-320

  2. #2
    EAA Staff Tom Charpentier's Avatar
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    We were not involved in the filing of this exemption request but we support it. Voluntary compliance with 91.225 shouldn't require the installation of a power-generation system, and it makes sense to square 91.225(f) with 91.215(c) for aircraft that wouldn't be required to have ADS-B anyway in most cases.

    Once an exemption is filed, the matter goes "ex-parte," meaning that the FAA is barred by law on commenting on its progress until a decision is made. Once further information is available, it will be posted to the Regulations.gov docket.
    Tom Charpentier
    Government Relations Director
    EAA Lifetime #1082006 | Vintage #722921

  3. #3

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    I don't quite understand your stated problem concerning having only 2 choices to either sell or move your airplane. How about removing the transponder /encoder/ ADS-B and using the battery only for the comm radio ? Being that the airplane was not certified with an engine driven electrical system, the only item required to operate from class C airspace is a comm radio and you can turn that off outside of class C. Whadda ya think ??

  4. #4
    Dana's Avatar
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    The no-electric exemption only applies to operations in the "mode c veil" around class B airspace. Inside class c or b, you need mode c and ADS-B, unless you get permission from ATC, in advance, every single time.

  5. #5

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    Ya know ...... I had to go back and read 91.225. It's interesting. Para.(e)'s first sentence seems to grant a blanket exclusion to non-electric system airplanes. Then the second sentence takes that blanket exclusion back. Further reading indicates that any airplane, with or without an electrical system, may operate within airspace outside of those areas listed in para. (b). The only advantage I can see of having and operating an airplane without an electrical system in areas listed in d(2) and d(4) is that you may go above 10,000 ft msl without ADS-B. The non electric system exclusion doesn't seem to hold any advantage for our small GA airplanes. And here I was counting on the non electric exclusion to operate my upcoming 7AC project in class C airspace.

    I operated an Aeronca L-3 for many years, from class C airspace from 1976 thru 1990. Equipped with a wind driven generator and only needed a com radio. No transponder. No encoder. Looking back at 91.215(b), all that changed in 1989. The current 91.215(b) reads nearly identical to 91.225(b).

    I must say "I am totally BUMMED !!"

    I now see your problem.

  6. #6

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    Just to clarify, I am not currently in a position because of this. My Yankee has an alternator, transponder and ADS-B, but I still hold on to the dream of one day selling my trainer and owning as simple of a flying machine as possible.

    I have been trying to watch this case to determine the feasibility of owning a plane like that near busy airspace. If this is approved, then my plans for my next plane will only be slightly different. If it is not approved then I may have to rethink my plans.

    Thanks for the info Tom.
    1978 Grumman AA1C w/O-320

  7. #7

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    I think this is a solution looking for a problem.

    Let's just suppose one has a J3 Cub or Luscombe without an electrical system, and the owner installs a navigation aid that is electrically based, such as a radio, transponder, or ADSB out hooked to a battery. Heck, let's throw in a starter that works only by battery on a total loss basis.

    Now let's suppose said owner/pilot turns on the radio/transponder/ADSB before entering airspace that require them. The pilot is happy. The FAA is happy. Everyone is happy.

    After leaving the airspace that require such things, suppose the pilot then turns them off to preserve the battery. The pilot is happy. The FAA couldn't care less. Black FAA helicopters are not going to chase down a J3 Cub to ask why the ADSB went offline; it's not required, and they have better things to do.

    Yes, the matter should be settled in the regulations, but I wonder if the risk of stupidity on the matter is worth it.
    The opinions and statements of this poster are largely based on facts and portray a possible version of the actual events.

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