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Question for the group: 

I'm told that the factory isn't doing LOAs yet for ADS-b (as of Nov 21, 2017 anyway).

I've decided to simply update my existing, factory installed Garmin GTX330 to 'ES' (extended squitter) which will make me ADS-B "OUT" compliant.

For "IN", I'm already happy with Stratus/Foreflight & iPad.  This quick/easy update should allow me to fly, and get the $500 FAA rebate I reserved.

I'm not actually sure I require an LOA as I'm upgrading existing factory equipment.   Like a software update for the Dynon units doesn't require an LOA - I'm not sure this should.

Adding ES to the GTX330 is a factory chip & software - no change to airframe, engineering, weight & balance.   

Since the factory or their US Importer/Distributor can't provide an LOA at this time - I'm really liking the idea that maybe I don't need one for this.

Any views on this?

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On 11/21/2017 at 5:24 PM, dbonnar said:

I'm told that the factory isn't doing LOAs yet for ADS-b (as of Nov 21, 2017 anyway).

Funny, I didn't think the factory was doing LOA's for ANYTHING! :P Sorry I couldn't resist the temptation. 

 

As for your questions for ADS-B, Oh if it were only that easy.

A couple of things dbonnar.....(what year is your SportCruiser?)

  1. A GTX-330ES alone does not make you 2020 compliant.
  2. Even if you did the 330 to 330ES upgrade you still need a WAAS GPS position source to be 2020 compliant, do you have one? You would need a WAAS 430 or 530 or ANY other WAAS position source to feed that into the 330. You cannot use a 696 or 796 for your position source if this is what came in your plane. 
  3. Upgrading your 330 to 330ES does qualify for the rebate. This is one of a few exceptions they are making. But without a position source you are not compliant. Also the installation must occur after the rebate reservation system was opened on September 19, 2016.
  4. I also wouldn't think you'd need a LOA for a software upgrade since you'll still have a GTX-330 as your transponder. 
  5. You can still use your Stratus for IN as that isn't a requirement for the 2020 mandate, you're only required to have OUT.

I hope this answered some of your questions and will point you in the right direction.

 

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Upon further research I see from the FAA registry you own a 2008 SportCruiser. I also see that you have the GNS-430. Can we assume it's the non-WAAS version?

Here’s a link to the FAA ADS-B website that may answer more questions you might have on the rebate and eligibility.

https://www.faa.gov/nextgen/equipadsb/

The 330ES can only use the 400W or 500W series GPS for it’s “certified “ position source according to their rules.

The cost to upgrade a non WAAS unit to WAAS is $3995 MSRP from Garmin. On top of the 330 to 330ES upgrade which is $1300 MSRP. 

Again, I can't imagine a LOA is needed to "upgrade" your existing equipment to become 2020 compliant. It'll still be the same equipment as installed by the manufacturer. It'll just be pricey that's all.

Just food for thought.......

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Excellent comments Shawn -thank you.  I'll detail my situation a bit more as others here might benefit from our dialog.

So far, my ADS-B journey has ended up very well as the FAA Rebate site tells me "the check is in the mail".

As you found on the FAA site, I have a 2008 SC, GNS430W & GTX330.  The factory standard in 2008 was a Garmin 328 transponder however we had heard about ADS-B regs and 'extended squitter' so we paid a bit more for an option to get the GTX330, which is "chip up-gradable" to ES.

Because I have a GNS430W, Nav/Com it can provide "position source" to the transponder.  I removed (very easy) the transponder and had my local radio guy send it off to Garmin for ES upgrade.  As you noted, that was $1300 to Garmin.  Got the GTX330 back and it's now a GTX330 ES with the addition of a board.   So far so good.

I needed to add one serial (RS-232) line from the GNS430W to the GTX330 ES so that the transponder could use the 430 as it's position source.   My radio guy created a 12 inch two wire line, with a molex connector in the center.   The molex connector allowed me to "cross-over" the "out" from the GTX330ES to the "in" of the GNS430W maintaining wire color coding consistency for a future radio guy to know what's going on.  By using the molex as a cross connect,  the "Ins" are blue/white and the "outs" are white on both units.  While only one serial data line is required, we wired two just for future capacity.   Seemed like the right thing to do.   I took the wire from my radio guy and took apart the SC panel myself, adding in the new serial connect between the two units.  I'm an LSRM/A and love doing as much as I can myself.  My radio guy was glad he didn't have to sit in the SC and doing panel wiring.

Now, having the GTX330ES "serial in" pin of the transponder wired to one of the "icarus position serial out" pins (I think that's right) of the GNS43W, we were ready to configure both units to know about each other.   

Other things that had to happen: 

GNS430 system software version was v3.x and GPS software also old, and it had to be brought up to 5.x for ADS-B.  My local radio guy didn't have the proper update chip so l flew to another shop and had them update my GNS430W System & GPS software to 5.4 (latest from Garmin).  $75 for one hour.

The config of the two units was the hardest part and I'll take a TON of pictures of the config screens for my documentation later.

Now, as you probably know, this gives me 'out' compliance only - which will meet the 2020 mandate.  The FAA doesn't seem to care that I did very little work and upgraded existing systems - I'll believe it when the $500 check clears.   

For "in", my plan is to continue to use my Stratus and iPad/Foreflight combination.  I've used that for trips to Oshkosh from CA and other cross-country jaunts.  I will likely buy a Stratus II before Osh 2018.  I love traffic and weather via Foreflight and it's easier to deal with vs the 430W screen.

I'm preparing an LOA request for the factory as I expect to need one due to added wiring in the panel.  From experience, if you completely write the LOA for them - you have a good chance they'll sign and return.  The key is make it simple for them to help!

Thanks again for your tips & comments.

Dave 

2008 SC

 

 

 

 

 

 

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5 hours ago, dbonnar said:

I'm preparing an LOA request for the factory as I expect to need one due to added wiring in the panel.  From experience, if you completely write the LOA for them - you have a good chance they'll sign and return.  The key is make it simple for them to help!

Thanks again for your tips & comments.

Dave 

2008 SC

I wish you all the luck with this. I did just that, all their work for them, and got nothing. If the tide is changing as CSA then maybe you'll see different results.

It's sort of putting the cart before the horse with the wiring modifications you did and then asking for an LOA. I'm sure there are some are screaming "you legally can't do that", but it's done right?

And thanks for the details as to what you did and how you accomplished your ADS-B out. I remember the GTX-328 (european version of he 327) in the Remos I first trained in.

I wouldn't think the 330 to 330ES would require an LOA since it is still the same equipment, but the wiring is another story. :ph34r:

I am aware of the configuration of the transponder, I went through almost all the same when I installed the 327 in my plane. I had to configure it to accept the altitude encoder data from the Dynon D-100, the GPS data from my Aera 660 and also ran the extra RS-232 data out for my ADS-B box. My old transponder had a parallel grey code converter that I was able to remove when I installed the 327.

It was the same for the GTR-200 COM I installed also. Data from the Aera 660 had to be fed into it and configured. All those Garmin gadgets have huge configuration menus to navigate and setup properly. They are not "plug and play". Once configured they are AWESOME.

All that said, I'm glad you got what you needed in the end and the rebate is on the way. I'm working on my ADS-B out right now, The GDL-82 with my GTX-327. I hope I get the response of "the check is in the mail" one day soon. :D

 

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On ‎10‎/‎20‎/‎2016 at 3:30 PM, ShawnM said:

Yes Ronin5573 and keep in mind you dont need an LOA if the new part you want to install is already in newer planes and included in the IPC and maintenance manual. This means these new parts have already been approved by the manufacturer, no LOA needed. Just simply follow the maintenance procedures to remove and replace and be sure it's done by the proper "authorized to perform" person per the manual. I'm going to upgrade my radio to the new Garmin GTR-225 and no LOA is needed.

 

My biggest wants for LOA is the newer Aera 660 GPS, Garmin GTX-345 for ADS-B in/out because it's an all-in-one unit and not a piece meal install with multiple components and the Dynon AOA to make the plane safer. All these make the plane safer and lessen the pilot workload in my opinion.

 

CAW, now CSA have been around for 10 years now and I'm very curious as to the number of LOA's that they've issued.

Are you sure about this "if its in a newer plane no LOA needed?"

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On 10/20/2016 at 4:30 PM, ShawnM said:

. . . you dont need an LOA if the new part you want to install is already in newer planes and included in the IPC and maintenance manual. This means these new parts have already been approved by the manufacturer, no LOA needed.

That does not seem right.

LOA's are serial number specific to each airplane in a manufacturers fleet.

If there is a "blanket" LOA, an MRA (Manufacturer Request for Alteration) still has to be submitted for each indvidual airplane. If approved by the manufacturer, then an LOA is issued, with approval and installation instructions/limitations.

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This was brought up many years ago in another topic. An aviation attorney stated that if the part you want to install is in the IPC and the Maintenance Manual (showing removal and installation procedure) then it's already approved by the manufacturer and no LOA is needed. It states in the maintenance manual who can perform the work and if that person performs the work then only a log entry is needed for the swap (or install).

You would not need a LOA or MRA or anything else from the manufacturer because they have already "approved" it's install as the item is in the newer fleet. 

Since the "part" is already in the newer fleet there are install and maintenance procedures already laid out in the manuals. If the part is electronic then there is already a wiring diagram available as well.

What more could the factory provide for you? It's already been done.

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I've been researching my list of 25 LSA manufacturers (of course there are more but this is a list I compiled from the Sebring show) and the issuance of LOA's since Sebring and it's near complete. I'm actually submitting the list to Joe Norris at EAA also. EAA requested LSA owners contact them and report thier experiences with their respective LSA manufacturer in regards to LOA's for repairs and upgrades.

Currently the one that stands out the most is Cubcrafters. This is their procedure for a LOA/MRA request:

The Owner Support section of the website now contains a document called the LSA Major Repair and/or Alteration (MRA) Request Form and can be found here. This document has been created to help handle the flow of change requests in a more timely and organized fashion. Our goal is to process the requests and return an approval/rejection with an estimate within 48 hours of submission.

The request form is designed to give us all the information we need in order to determine if the requested changes can be made on your aircraft, while still maintaining design and performance specifications. Information required in the form includes:

  • Owner name and address
  • Aircraft make, model, serial number, and N-number
  • Airframe/Powerplant/Propeller manufacturer, type/model, serial number, total time since new, and total time since overhaul
  • Current weight and balance
  • Any previously installed MRA's, service instructions, etc.
  • A copy of the current equipment list
  • Requested changes

While many changes to an aircraft seem simple and may only require the minimum hour of work, others will require more research and time. Since changes and improvements to the manufactured aircraft are taking place on an ongoing basis, as well as the reality of aircraft equipment options, no two aircraft are exactly alike. With regards to MRA's, this means that a change that may be a simple remove and replace on one aircraft may involve modification of another, or may not even be possible.

One of the largest issues with modifications is staying under aircraft empty weight limits. By providing an MRA, we are vouching that these changes will still keep in the aircraft within LSA specifications. With so many aircraft being produced near the limits of empty weight, keep this in mind when considering a request.

The lower half of the form includes the estimate, approval, and payment options. The process for providing an MRA will be as follows:

  1. Print MRA request form from website and fill out the entire first page
  2. Send it to CubCrafters for evaluation
  3. MRA is either denied or approved
    • Denied - Justification will be provided and owner/customer notified (end of process)
    • Approved - Hour/cost estimate will be determined (proceed below)
  4. Estimate sent to customer for approval
  5. Estimate accepted and payment made to CubCrafters
  6. MRA will be put into queue and sent out to customer upon completion

Until we can get an interactive form on the website, feel free to email the first page's worth of information to CubCrafters, and we can fill the form out here and do the evaluation. Once the MRA is complete it will be mailed out, and a digital version will be emailed also if requested. You will also notice that hourly price has been set to $100.

There will be some instances where an MRA has already been performed and can basically be copied for future aircraft. In these cases, the minimum amount of time billed will be one hour ($100) to cover overhead costs. This means that the initial requester has to "eat the cost" of the work beyond one hour in creating the original MRA. Please understand that CubCrafters is not trying to make money off of MRAs, but is trying to recover costs in what is steadily becoming a larger portion of our responsibility as the manufacturer; fleet maintenance.

I apologize for the long post, but will continue to try and answer questions before they need to be asked. Feel to post any questions and comments.

Thank you.
Adam Sloon - Engineering
CubCrafters

What a welcomed breath of fresh air this would be. Why can't all manufacturers adopt this same procedure for LOA's and or MRA's? Seems like they have the procedure nearly perfected. 

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The full benefits of ADS-B can only be realized if all of the planes that fly in controlled airspace are equipped. The FAA has set January 1, 2020, as the deadline to equip for ADS-B Out in controlled airspace. DOT and the FAA offered a $500 rebate incentive for GA aircraft owners who equip their aircraft with required avionics technology.  Accelerating compliance is critical to ensuring that pilots, manufacturers, and retail facilities have adequate time and capacity to equip aircraft in a timely and efficient manner, ahead of a 2020 regulatory deadline.

https://www.faa.gov/news/fact_sheets/news_story.cfm?newsId=21274

Still no plan for equipping legacy aircraft with this mandatory update. Tic Toc

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3 hours ago, Deltafox said:

. . . I believe the GDL82 would be a great low-cost solution for your aircraft. . . . 

And so would uAvionix echoUAT+SkyFYX-EXT.

Thus far, that is my first choice. Will probably install this year.

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I like the GDL-82 approach and will likely follow (more likely, blatantly copy) Shawn's installation and center stack. 

My FAA rebate expired... no way I am able to comply by the due date.

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7 hours ago, Deltafox said:

The full benefits of ADS-B can only be realized if all of the planes that fly in controlled airspace are equipped.

This is not EXACTLY true Dave. If your plane is equipped with ADS-0B IN and OUT you will see:

  • all traffic equipped with ADS-B OUT of course
  • all traffic with a transponder only since they produce a response when being interrogated by air traffic control radar and this data is then sent back out to the ADS-B ground towers and then sent to your ABS-B IN equipped aircraft
  • all traffic without a transponder if they are in line of sight to ground based radar, if you can be seen by any ground based radar then your position will be sent out also

I agree time is ticking for the legacy group. I for one would vote for the Garmin GDL-82. It's Garmin, need I say anymore?

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On 2/11/2018 at 4:29 PM, WmInce said:

That does not seem right.

LOA's are serial number specific to each airplane in a manufacturers fleet.

If there is a "blanket" LOA, an MRA (Manufacturer Request for Alteration) still has to be submitted for each indvidual airplane. If approved by the manufacturer, then an LOA is issued, with approval and installation instructions/limitations.

I also talked with Lou at Bristell Aircraft. He's on my list of manufacturers that I'm questioning about the issuance of a LOA's/MRA's. He stated the exact same thing to me word for word in his response to my email asking if Bristell will issues LOA/MRA's for changes.

To quote Lou from his email:

BRM Aero, Milan Bristela routinely supplies an LOA in about one week. Once the factory installs a new radio in a new S-LSA, any owner can install that radio in his plane without an LOA.

Regards,

Lou Mancuso, "The Landing Doctor"

Once the factory installs the part it's fair game for any owner to do the same without a LOA/MRA.

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40 minutes ago, ShawnM said:

To quote Lou from his email:

BRM Aero, Milan Bristela routinely supplies an LOA in about one week..

Again, that does not sound right. Regardsing S-LSA, there has to be fleet accountability.

In the above scenario, who submits the LOA, and who is the receiver of the LOA?

Once an alteration is initially installed by BRM, how does the factory track which S-LSA's, in their fleet, have which alterations?

If no accurate (and up to date) records are tracked, on individual airframes, how would the NTSB determine, if an S-LSA had proper and approved equipment installed, during an accident investigation?

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3 hours ago, WmInce said:

Again, that does not sound right. Regardsing S-LSA, there has to be fleet accountability.

In the above scenario, who submits the LOA, and who is the receiver of the LOA?

Once an alteration is initially installed by BRM, how does the factory track which S-LSA's, in their fleet, have which alterations?

If no accurate (and up to date) records are tracked, on individual airframes, how would the NTSB determine, if an S-LSA had proper and approved equipment installed, during an accident investigation?

That's the point, there is no LOA for the scenario we are talking about. It's not needed.

Here's a hypothetical for you...... I own a 2007 SportCruiser with a Garmin 396 and I want to install a Garmin 696. Let's say the factory started installing 696 units in 2010 (I dont know the exact year they started). So now the Garmin 696 is in the IPC (Illustrated Parts Catalog), there are directions in the maintenance manual for installation and service and there is a wiring diagram in the Airplane Wiring Manual. Any owner of a early SportCruiser who wants to install a 696 DOES NOT need a LOA or MRA. The item is approved by the factory and completely documented by the factory.

If there is an incident/accident and the plane in question is investigated by the NTSB all the equipment in the plane is allowed by the factory BECAUSE it's listed in all the manuals. This makes the equipment "proper and approved". All you need is a logbook entry. 

Why does the factory need to know which aircraft have alterations?  It's technically not an alteration because the factory is installing the same units in the newer fleet. I really think you are missing the point. If you install equipment that's NOT in the IPC or maintenance manual THEN that is an alteration that's NOT approved by the manufacturer. I know that's obvious.

The more I research the ASTM standards about repairs/alterations, I learn that an actual "LOA" is the "lazy man's" way of circumventing the actual MRA that is legally required by ASTM standards. No where in the ASTM F37 standards is the word LOA mentioned. Technically and legally a MRA (major repair / alteration) is required.

You should know this being the owner of a Flight Design aircraft having made changes to your own plane. Flight Design uses the form. They do not call it a LOA nor is that term mentioned anywhere in the document. Van's uses the MRA form, CubCrafters uses the form.

The MRA standards were actually just rewritten last year, voted in by the ASTM F37 committee in October of last year and should be applicable this year.

I'm really not making this stuff up or just spouting out "stuff I read on the internet" about LOA's and MRA's. I have been having real conversations with actual committee members of the ASTM F37 board who actually write the rule of law for light sport aircraft. They all work for various manufacturers and consulting companies. One works at Van's Aircraft, another at Terrafugia (the flying car company) and another for Streamline Designs (a consulting company). Adam at Streamline Designs is actually the committee chairman. Who better to give me the proper answers?

Don't take my word for it, do the research and study the ASTM F37 standards. Research F2483 in regards to maintenance manuals, F2245 that covers design standards or F2295 that covers COS (continued operational safety monitoring). There is an enormous amount of data out there waiting to be read, ask me how I know.  :D  

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14 hours ago, ShawnM said:

If your plane is equipped with ADS-0B IN and OUT you will see:

  • all traffic equipped with ADS-B OUT of course
  • all traffic with a transponder only since they produce a response when being interrogated by air traffic control radar and this data is then sent back out to the ADS-B ground towers and then sent to your ABS-B IN equipped aircraft
  • all traffic without a transponder if they are in line of sight to ground based radar, if you can be seen by any ground based radar then your position will be sent out also

I agree with Shawn’s summary

of “what airplane traffic will I see” 

if my airplane is equipped with ADS-B OUT (“Participating” in the Next Gen USA FAA ATC system) and also equipped  with ADS-B IN Traffic Receiving equipment 

with the following additional assumptions:

1) my fully equipped ADS-B OUT and IN aircraft is

within Range

of the FAA’s ADS-B ground transmission radio towers,

and NOT blocked by hilly terrain.

 

2) my ADS-B IN Traffic receiver is a

DUAL BAND

(978 MHz UAT as well as 1090 MHz Extended Squitter)

ADS-B IN Traffic receiver.  

 

I believe thise assumptions are important to consider because:

1) in hilly terrain, or remote mountainous terrain perhaps in the western USA or especially Alaska, 

RECEPTION

of

ALL

ADS-B IN Traffic data will

NOT

be possible until YOUR aircraft CLIMBS to a suitable ADS-B IN RECEIVING altitude, typically 2000 to 3000 ft AGL.

 

2) some aircraft equipped with ONLY

First Generation ADS-B IN Single Band Traffic receivers (example - the first gen SKYVIEW ADS-B IN traffic receiver)

will

NOT

be able to see

ALL

AIRBORNE Traffic targets, even if these Targets are equipped with ADS-B OUT running on the more typical, More common  1090 MHz ES ADS-B OUT transmission frequency,

UNLESS

their ADS-B IN receiver is 

CAPABLE

of receiving on

BOTH 978 MHz and 1090 MHz.

 

Important Note - DUAL band ADS-B IN Traffic receivers can see “Air to Air” ADS-B OUT traffic transmissions on

BOTH 1090 MHz and 978 MHz,

and don’t always need to “connect” with the FAA Ground radio towers to see local airborne traffic.  

 

3) YES, the USA FAA Ground Radio towers will 

RETRANSMIT 

All Traffic targets

to ADS-B OUT and IN EQUIPPED AIRCRAFT

that are in range of, and not blocked by terrain from the FAA ground radio stations

And when these targets

TRANSMIT on 1090 MHz “Airborne”

the FAA Ground towers WILL RETRANSMIT

these 1090 MHz ADS-B OUT Traffic position signals onto your single band receiver’s

978 MHz (UAT only) receiving equipment frequency,

but your aircraft is

ONLY

Capable of “Seeing” these Retransmitted  ADSB-R 978 MHz signals

WHEN you are in range of and NOT blocked by terrain from the FAA ADS-B Radio towers,

EVEN IF youir aircraft is fully “Participating” — I.e., Equipped with ADS-B OUT equipment. 

 

4) an easy scenario to understand all of this.  

I was in hilly terrain, entering the downwind of a county airport. 

I had ADS-B OUT equipment running on my aircraft.  

I saw ZERO local traffic on my single band 978 MHz Traffic receiver. 

I was “announcing” my Traffic Pattern  position on the CTAF.

As I turned Base to Final,

I

HEARD

a King Air aircraft announce on CTAF

”KingAir N123XYZ NOW Direct-IN ON FINAL ”

to the same runway I was turning Base to Final towards.  

The KING AIR

WAS

transmitting on 1090 MHz ADS-B. (I talked to the KingAir Pilot on the ground after we easily deconflicted the Landing sequence on the Radio and both aircraft landed safely)

BUT 

my SINGLE band ADS-B IN Traffic RECEIVING equipment was NOT in range of the FAA ground radio towers and I was low enough - in the pattern in hilly terrain- where my single band equipment could NOT see any FAA  “Retransmission” (ADSB-R) of the King Air’s 1090 MHz ADS-B OUT signals over to my 978 MHz only Traffic equipment,

nor could my 978 MHz ONLY ADS-B IN equipment see “Air to Air” the King Air’s  1090 MHz ADS-B OUT transmissions. .  

 

Lessons Learned :

1) I have since upgraded from a Single Band Traffic ADS-B IN Receiver to a DUAL Band 978/1090 MHZ GARMIN GDL-39 ADS-B IN Traffic Receiver.

2) Pilot owners of first gen SKYVIEW ADS-B IN receivers should UPGRADE to the newest SKYVIEW DUAL Band equipment,

or ALSO  ADD a Garmin GDL39 ADS-B IN Dual Band 978/1090 MHz Traffic Receiver feeding their Garmin 796 GPS MAP Display via Bluetooth,

and

 

3) ALL PILOTS 

should be aware that if they fly in Hilly, Remote Terrain, those very good  FAA ADS-B Ground Radio stations’ TRAFFIC signals 

may

NOT

be RECEIVABLE  by your ADS-B OUT equipped aircraft ,

even while flying “only” Down at Traffic Pattern Altitude,

.....EXACTLY A Flying condition  

where ALL Traffic data is needed for Flight Safety and Safe Separation.   

 

Finally, 

4) “See and Avoid”

and USING effective “Pilot Controlled Airport” Radio Com Announcements in the traffic pattern 

Are ALWAYS good ideas to USE.

 

d

 

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1 hour ago, DavePilot said:

I agree with Shawn’s summary of “what airplane traffic will I see” if my airplane is equipped with ADS-B OUT (“Participating” in the Next Gen USA FAA ATC system) and also equipped  with ADS-B IN Traffic Receiving equipment with the following additional assumptions: .........

Thanks Dave, I guess I should have been a bit more specific about the "dual" band receivers. I just assumed that they are now all dual band receivers. I forgot that the early units were not. I've only ever had a dual band receiver with my GDL-39 3D. We can always count on your for the "details". 

As far as the terrain, I also forget that there are "hilly" place outside Florida. :P Hell, I forget there are even "places" outside Florida. With all the snow birds here now I think the entire country is here driving on our roads. Not to mention all those damn Canadians that are here. I can't drive a mile without seeing a Canadian license plate.:D

Luckily here in Florida I get ADS-B coverage in the pattern at my airport but that's no time to be staring at my Aera 660 looking for traffic, eyes outside and fly the plane. There could be a King Air on short final. :ph34r:

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On 3/7/2018 at 8:17 AM, ShawnM said:

I've been researching my list of 25 LSA manufacturers (of course there are more but this is a list I compiled from the Sebring show) and the issuance of LOA's since Sebring and it's near complete. I'm actually submitting the list to Joe Norris at EAA also. EAA requested LSA owners contact them and report thier experiences with their respective LSA manufacturer in regards to LOA's for repairs and upgrades.

Currently the one that stands out the most is Cubcrafters. This is their procedure for a LOA/MRA request:

The Owner Support section of the website now contains a document called the LSA Major Repair and/or Alteration (MRA) Request Form and can be found here. This document has been created to help handle the flow of change requests in a more timely and organized fashion. Our goal is to process the requests and return an approval/rejection with an estimate within 48 hours of submission.

The request form is designed to give us all the information we need in order to determine if the requested changes can be made on your aircraft, while still maintaining design and performance specifications. Information required in the form includes:

  • Owner name and address
  • Aircraft make, model, serial number, and N-number
  • Airframe/Powerplant/Propeller manufacturer, type/model, serial number, total time since new, and total time since overhaul
  • Current weight and balance
  • Any previously installed MRA's, service instructions, etc.
  • A copy of the current equipment list
  • Requested changes

While many changes to an aircraft seem simple and may only require the minimum hour of work, others will require more research and time. Since changes and improvements to the manufactured aircraft are taking place on an ongoing basis, as well as the reality of aircraft equipment options, no two aircraft are exactly alike. With regards to MRA's, this means that a change that may be a simple remove and replace on one aircraft may involve modification of another, or may not even be possible.

One of the largest issues with modifications is staying under aircraft empty weight limits. By providing an MRA, we are vouching that these changes will still keep in the aircraft within LSA specifications. With so many aircraft being produced near the limits of empty weight, keep this in mind when considering a request.

The lower half of the form includes the estimate, approval, and payment options. The process for providing an MRA will be as follows:

  1. Print MRA request form from website and fill out the entire first page
  2. Send it to CubCrafters for evaluation
  3. MRA is either denied or approved
    • Denied - Justification will be provided and owner/customer notified (end of process)
    • Approved - Hour/cost estimate will be determined (proceed below)
  4. Estimate sent to customer for approval
  5. Estimate accepted and payment made to CubCrafters
  6. MRA will be put into queue and sent out to customer upon completion

Until we can get an interactive form on the website, feel free to email the first page's worth of information to CubCrafters, and we can fill the form out here and do the evaluation. Once the MRA is complete it will be mailed out, and a digital version will be emailed also if requested. You will also notice that hourly price has been set to $100.

There will be some instances where an MRA has already been performed and can basically be copied for future aircraft. In these cases, the minimum amount of time billed will be one hour ($100) to cover overhead costs. This means that the initial requester has to "eat the cost" of the work beyond one hour in creating the original MRA. Please understand that CubCrafters is not trying to make money off of MRAs, but is trying to recover costs in what is steadily becoming a larger portion of our responsibility as the manufacturer; fleet maintenance.

I apologize for the long post, but will continue to try and answer questions before they need to be asked. Feel to post any questions and comments.

Thank you.
Adam Sloon - Engineering
CubCrafters

What a welcomed breath of fresh air this would be. Why can't all manufacturers adopt this same procedure for LOA's and or MRA's? Seems like they have the procedure nearly perfected. 

Thank you for sharing Shawn. I truly like the way Cubcrafters is going about consideration and issuance of LOA's. I do have a question or concern though....there is this ONE line where number of hours are to be listed. Imagine the response from our (SC) folks when they are asked that do add A or B to their SC will result in 30 hours of testing and developing in order to get EASA approval thus costing someone $3k. That will set this group on fire and will cause another reason for uproar. Just sayin'

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2 minutes ago, Izzy said:

Thank you for sharing Shawn. I truly like the way Cubcrafters is going about consideration and issuance of LOA's. I do have a question or concern though....there is this ONE line where number of hours are to be listed. Imagine the response from our (SC) folks when they are asked that do add A or B to their SC will result in 30 hours of testing and developing in order to get EASA approval thus costing someone $3k. That will set this group on fire and will cause another reason for uproar. Just sayin'

Thanks for the response Izzy. I will admit that this is a valid concern and possibly an isolated situation with one particular manufacturer. Cubcrafters stated that the original requester will "eat the cost" of the initial MRA request and the number 2 guy will get it basically for free. So can you request the first ADS-B MRA from CSA? :P 

The last thing this forum needs is another uproar! (you know I can start one if you like, I'm getting rather good at it) :D

I just posted this info from Cubcrafters so others could see how their process works and that it's an easy, online request.  

Will it really take 30 hours? Will it really cost $100 and hour? Maybe a very complex request might take time but simple equipment upgrades might not. 

In my research so far of the 25 manufacturers on my list no LOA/MRA has cost more than $150. This data/figure has come from the requester (aircraft owner) of the LOA/MRA. I have asked a survey question on a couple of aviation forums and have received a lot of responses from various owners.

The longest time needed so far was from Pipistrel-USA and their LOA/MRA can take up to 3 weeks, but they will issue them. That's the longest one.

My real point to my post is the fact that other manufacturers offer MRA's and it's a streamlined and online request process that any owner can do. Another point is that the manufacturer responds and processes the requests and returns an approval/rejection with an estimate within 48 hours of submission. CSA never even responded to me, this is why I chose to keep this topic alive and hammer away at CSA for their lack of customer support in my case. How would you feel if you were me?  

The real truth is that I honestly dont expect CSA to ever issue another LOA/MRA for the legacy fleet, or any SportCruiser for that matter. Could I be wrong, sure, it's happened a few times. :D Obviously I'm certainly ok with this decision because I'm out from under their control now since I'm E-LSA. I just know how frustrating and disappointing the whole situation was for me and that many other owners on this forum feel the same way. 

I know this topic has been beat to death (by me) but I feel it's a valid concern for those shopping around for a LSA aircraft and to anyone considering purchasing a SportCruiser. I think they should be informed, good or bad. No?

The good you ask, I love my SportCruiser, it's an amazing airplane. Even my antique 2007, now that it has some amazing upgrades. :D

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On 3/18/2018 at 11:06 PM, ShawnM said:

Thanks for the response Izzy. I will admit that this is a valid concern and possibly an isolated situation with one particular manufacturer. Cubcrafters stated that the original requester will "eat the cost" of the initial MRA request and the number 2 guy will get it basically for free. So can you request the first ADS-B MRA from CSA? :P 

The last thing this forum needs is another uproar! (you know I can start one if you like, I'm getting rather good at it) :D

I just posted this info from Cubcrafters so others could see how their process works and that it's an easy, online request.  

Will it really take 30 hours? Will it really cost $100 and hour? Maybe a very complex request might take time but simple equipment upgrades might not. 

In my research so far of the 25 manufacturers on my list no LOA/MRA has cost more than $150. This data/figure has come from the requester (aircraft owner) of the LOA/MRA. I have asked a survey question on a couple of aviation forums and have received a lot of responses from various owners.

The longest time needed so far was from Pipistrel-USA and their LOA/MRA can take up to 3 weeks, but they will issue them. That's the longest one.

My real point to my post is the fact that other manufacturers offer MRA's and it's a streamlined and online request process that any owner can do. Another point is that the manufacturer responds and processes the requests and returns an approval/rejection with an estimate within 48 hours of submission. CSA never even responded to me, this is why I chose to keep this topic alive and hammer away at CSA for their lack of customer support in my case. How would you feel if you were me?  

The real truth is that I honestly dont expect CSA to ever issue another LOA/MRA for the legacy fleet, or any SportCruiser for that matter. Could I be wrong, sure, it's happened a few times. :D Obviously I'm certainly ok with this decision because I'm out from under their control now since I'm E-LSA. I just know how frustrating and disappointing the whole situation was for me and that many other owners on this forum feel the same way. 

I know this topic has been beat to death (by me) but I feel it's a valid concern for those shopping around for a LSA aircraft and to anyone considering purchasing a SportCruiser. I think they should be informed, good or bad. No?

The good you ask, I love my SportCruiser, it's an amazing airplane. Even my antique 2007, now that it has some amazing upgrades. :D

Thanks for posting this Shawn. I’d like to talk with you about the market research you’ve mentioned here. Feel free to give me a call when you’re available. 407-467-1178. 

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On 3/7/2018 at 8:17 AM, ShawnM said:

I've been researching my list of 25 LSA manufacturers (of course there are more but this is a list I compiled from the Sebring show) and the issuance of LOA's since Sebring and it's near complete. I'm actually submitting the list to Joe Norris at EAA also. EAA requested LSA owners contact them and report thier experiences with their respective LSA manufacturer in regards to LOA's for repairs and upgrades.

Currently the one that stands out the most is Cubcrafters. This is their procedure for a LOA/MRA request:

The Owner Support section of the website now contains a document called the LSA Major Repair and/or Alteration (MRA) Request Form and can be found here. This document has been created to help handle the flow of change requests in a more timely and organized fashion. Our goal is to process the requests and return an approval/rejection with an estimate within 48 hours of submission.

The request form is designed to give us all the information we need in order to determine if the requested changes can be made on your aircraft, while still maintaining design and performance specifications. Information required in the form includes:

  • Owner name and address
  • Aircraft make, model, serial number, and N-number
  • Airframe/Powerplant/Propeller manufacturer, type/model, serial number, total time since new, and total time since overhaul
  • Current weight and balance
  • Any previously installed MRA's, service instructions, etc.
  • A copy of the current equipment list
  • Requested changes

While many changes to an aircraft seem simple and may only require the minimum hour of work, others will require more research and time. Since changes and improvements to the manufactured aircraft are taking place on an ongoing basis, as well as the reality of aircraft equipment options, no two aircraft are exactly alike. With regards to MRA's, this means that a change that may be a simple remove and replace on one aircraft may involve modification of another, or may not even be possible.

One of the largest issues with modifications is staying under aircraft empty weight limits. By providing an MRA, we are vouching that these changes will still keep in the aircraft within LSA specifications. With so many aircraft being produced near the limits of empty weight, keep this in mind when considering a request.

The lower half of the form includes the estimate, approval, and payment options. The process for providing an MRA will be as follows:

  1. Print MRA request form from website and fill out the entire first page
  2. Send it to CubCrafters for evaluation
  3. MRA is either denied or approved
    • Denied - Justification will be provided and owner/customer notified (end of process)
    • Approved - Hour/cost estimate will be determined (proceed below)
  4. Estimate sent to customer for approval
  5. Estimate accepted and payment made to CubCrafters
  6. MRA will be put into queue and sent out to customer upon completion

Until we can get an interactive form on the website, feel free to email the first page's worth of information to CubCrafters, and we can fill the form out here and do the evaluation. Once the MRA is complete it will be mailed out, and a digital version will be emailed also if requested. You will also notice that hourly price has been set to $100.

There will be some instances where an MRA has already been performed and can basically be copied for future aircraft. In these cases, the minimum amount of time billed will be one hour ($100) to cover overhead costs. This means that the initial requester has to "eat the cost" of the work beyond one hour in creating the original MRA. Please understand that CubCrafters is not trying to make money off of MRAs, but is trying to recover costs in what is steadily becoming a larger portion of our responsibility as the manufacturer; fleet maintenance.

I apologize for the long post, but will continue to try and answer questions before they need to be asked. Feel to post any questions and comments.

Thank you.
Adam Sloon - Engineering
CubCrafters

What a welcomed breath of fresh air this would be. Why can't all manufacturers adopt this same procedure for LOA's and or MRA's? Seems like they have the procedure nearly perfected. 

Good afternoon Shawn, 

I guess it's been finally made public and unfortunately a fact that must be accepted as is.....

Charlie Lima posted in another thread -

Hello everyone

I spoke to Cruiser today concerning a tow bar replacement, and requested information on the LOA's issue.  I am detailing what I was told, June 04, 2018 AM/EST 😞

1):   Do not request LOA's.  They will not be issued.  It does not matter if you are pre-bankruptcy, ( 2007, 2008 & 2009 if I understand the dates correctly), or post bankruptcy and new management, ( 2010 and after ).

A note for all current and future owners of the SportCruiser....CSA will not issue any LOA's. Yes, I know that they were issued in the past as I've seen original documentation proving so under previous management but, current management does not feel that issuing LOA's is something they should have to do....I'm guessing as to the reason as I fought long and hard on this topic, since my very first conversation with Lukas back in September 2017.

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8 minutes ago, Izzy said:

A note for all current and future owners of the SportCruiser....CSA will not issue any LOA's. Yes, I know that they were issued in the past as I've seen original documentation proving so under previous management but, current management does not feel that issuing LOA's is something they should have to do....I'm guessing as to the reason as I fought long and hard on this topic, since my very first conversation with Lukas back in September 2017.

Well there goes a bit more of the market share out the door. :o

I know you stated in the past Izzy that it was because of the EASA certification but the other EASA certified manufacturers such as Tecnam, Evektor and Flight Design (who are all EASA certified) issue MRA's (LOA) to customers who request to make minor changes. That can't be used for an excuse by CSA.
 

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18 minutes ago, ShawnM said:

Well there goes a bit more of the market share out the door. :o

I know you stated in the past Izzy that it was because of the EASA certification but the other EASA certified manufacturers such as Tecnam, Evektor and Flight Design (who are all EASA certified) issue MRA's (LOA) to customers who request to make minor changes. That can't be used for an excuse by CSA.
 

Yes, you are correct. I stated that the reluctance to issue LOA was due to strict EASA regulations or mandate as that was the response provided by Lukas every time the topic came up. But, under further research in to the matter LOA are not being issued due to EASA regulation as it's truly a choice not to do so. A point which was proven by your study of all of the other SLSA manufacturers issuing LOAs. I spoke with Lou Mancuso at Bristell and I asked him about the LOA process in which the answer is quite simple....Milan Bristela is working in the factory along with his son and they're number one focus is customer service and making sure that the customers are treated as they should be. Needless to say this statement was music to my ears as that's what I was hoping to hear at some point from anyone at the SportCruiser organization. 

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