TSO requirements

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C140A
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TSO requirements

Post by C140A » Sat May 11, 2019 6:21 pm

Hi guys,

Can anyone point me to where in CARS it actually says that a comm radio needs to be TSO'd in a VFR airplane. I have found references in places that point toward FAA rules, but I get lost pretty quick in the CARS. In some places in the FAA world they refer to a/c that were certified under CAR3 ( old aircraft) I'm specifically interested in wether or not I need to install a TSO'd comm in a 1949 Cessna 140.

Thanks
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photofly
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Re: TSO requirements

Post by photofly » Sat May 11, 2019 9:45 pm

Installing a radio is probably a minor modification, which requires specified data, approved data, or acceptable data.

Approved data includes (571.06)
"type certificates, supplemental type certificates, part design approvals, Canadian technical standard order (CAN-TSO) design approvals or repair design approvals, including equivalent foreign documents which have undergone the type design examination process set-out in Subpart 521 of the CARs or are otherwise accepted in Canada; and
(amended 2009/12/01; previous version)"

So if you have a TSO'd radio you're good to go. A non TSO'd radio could be installed, but what are you going to use as "acceptable data, specified data or approved data" to permit the installation?

Then there's CAR 521.31(1) & (2) and CAR 551.02 which specify that only a TSO'd radio meets the requirements for when a radio is required.

My interpretation (worth nothing) is that you could install a non-TSO'd radio and claim the manufacturer's instructions as "acceptable data" for the installation ("(a) drawings and methods recommended by the manufacturer of the aircraft, component, or appliance;") but that unless the radio is TSO'd it doesn't meet the equipment requirements for when a radio is required to be on board, such as under 605.14(k) - so no flight in classes C or D airspace or entering a MF zone.
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Re: TSO requirements

Post by C140A » Sun May 12, 2019 6:55 am

Ok, thanks for that. I guess there is no way around it then even though there are many non TSO comms( Flightline) that have very good functionality and great reviews from owners. I see that there has been some movement in the non TSO EFIS area, DYNON has an STC to be able to install their EFIS screens in many certified a/c now. I would think that common sense tells me that if they can get approval to install a non TSO EFIS system that has basic instruments required for safe flight such as altitude and airspeed then a VHF radio should be a no brainer. I can see where a TSO would and should be required for such things as ELT's for example, but a simple VHF where the worst thing to happen would be having to resort to loss of comms procedure.

Oh well, the wheels of progress grind slowly....
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Re: TSO requirements

Post by photofly » Sun May 12, 2019 7:55 am

The argument goes, that everyone else who flies in the same airspace as you has an interest in making sure that your radio:

• transmits audibly
• with not too much power
• can hear everyone else
• doesn't transmit on the wrong frequencies or create in-band or out-of-band interference for other users
• doesn't transmit at the wrong time, or get stuck and transmit all of the time
• doesn't adversely affect any other electronics installed in your plane that you need

Those kinds of things are included in the TSO for aircraft radios. So, one could argue, that *we* don't want your airplane to have a radio that doesn't meet the appropriate technical standard.

For instance ...would you like my VFR-only aircraft burning round a circuit 10 miles away from you with my own-design 200W transmitter (or one I bought on Alibaba, cheap) blasting interference across the entire band and interrupting everyone else's radio comms? Probably not. How about if I accidentally transmit over the tower frequency at a nearby international airport because my tuning calibration sucks? Probably not that either! Those are the things that should be prevented if only TSO'd radios are used.

Now, there are arguments to make it easier and cheaper to comply with the technical standards, but the concept is not a bad one.
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Re: TSO requirements

Post by torquey401 » Sun May 12, 2019 1:30 pm

No tso required. Kx170B and ICOM 220 aren't tso"ed and they are everywhere. I would discuss this with a proper avionics shop you trust to make sure.
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Re: TSO requirements

Post by Heliian » Sun May 12, 2019 1:52 pm

C140A wrote:
Sun May 12, 2019 6:55 am
DYNON has an STC
Bingpot

And photofly is correct, you can install non tso but not to meet the radio requirement.

What are the chances of anyone finding out?
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Re: TSO requirements

Post by photofly » Sun May 12, 2019 2:12 pm

torquey401 wrote:
Sun May 12, 2019 1:30 pm
No tso required. Kx170B and ICOM 220 aren't tso"ed and they are everywhere. I would discuss this with a proper avionics shop you trust to make sure.
Can you elaborate on "they are everywhere"?

Given that there's a superficially identical version of both, with TSO (KX175b, A220T) are owners of type-certified aircraft choosing the non-TSO version? Why would the TSO'd version (which is more expensive) be available, if it was an option either way?
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Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
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C140A
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Re: TSO requirements

Post by C140A » Sun May 12, 2019 5:30 pm

photofly,

everything you say makes sense, but then why are non certificated aircraft (experimental) allowed to fly in the same airspace as everyone else with non TSO'd radios?
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C140A
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Re: TSO requirements

Post by C140A » Sun May 12, 2019 5:31 pm

Bingspot,

I suppose the problem might come up if the AME won't sign the annual if he sees it is a non TSO radio.
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torquey401
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Re: TSO requirements

Post by torquey401 » Sun May 12, 2019 8:20 pm

photofly wrote:
Sun May 12, 2019 2:12 pm
torquey401 wrote:
Sun May 12, 2019 1:30 pm
No tso required. Kx170B and ICOM 220 aren't tso"ed and they are everywhere. I would discuss this with a proper avionics shop you trust to make sure.
Can you elaborate on "they are everywhere"?

Given that there's a superficially identical version of both, with TSO (KX175b, A220T) are owners of type-certified aircraft choosing the non-TSO version? Why would the TSO'd version (which is more expensive) be available, if it was an option either way?
I have seen many KX170's flying around over the years. The model is labeled on the faceplate. ICOM units I have seen may or may not have been tso'ed - they are more difficult to discern.

Why are there KX175's? Maybe to give the consumer what he wants and is willing to spend more on. Maybe there are some installation that specify tso, but not a Cessna 140 or 172.

I can find no specific references for a com radio needing to be tso certified in the CARS. STD 551.107 talks to com radio installations only. By comparision, transponders, ELTs, CVRs, FDRs all specify TSO equipment in STD 551. Maybe I am missing something, as I haven't dug into this subject in a few years. It would be best for the original poster to contact TC or a knowledgeable shop to get a first hand answer.
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Re: TSO requirements

Post by photofly » Sun May 12, 2019 8:22 pm

C140A wrote:
Sun May 12, 2019 5:30 pm
photofly,

everything you say makes sense, but then why are non certificated aircraft (experimental) allowed to fly in the same airspace as everyone else with non TSO'd radios?
I don’t know. I find the regulations as opaque as you do. But here’s my best guess:

In CAR 551 there’s no specific design standard listed for a radio (there is an installation standard - 507.107) so the required design standard is therefore 551.02(b): “the equipment must provide the same level of safety as that established by the certification basis of the aircraft.”

This is different to an ELT or transponder, for which a TSO is listed in 551. (I don’t think you can get a non-TSO’d transponder, can you?)

See also 521.31(2).

So what does “the same level of safety as that established by the certification basis of the aircraft” mean? I can’t find a good reference, but it’s lower for an amateur-built aircraft than a type certified one.
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Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

C140A
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Re: TSO requirements

Post by C140A » Sun May 12, 2019 8:28 pm

"the equipment must provide the same level of safety as that established by the certification basis of the aircraft.”

Yes, I seen that....not that I understand what that actually means. Especially when in regards to a C140 for example that was certified in 1946, there would have been no radio even mentioned in that certification.

Anyway, I see that most are just as confused and frustrated by our CAR's as me :D
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Hugh Jasshole
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Re: TSO requirements

Post by Hugh Jasshole » Mon May 13, 2019 8:04 am

I just read the Type Data Sheet for the C-120/140 and there is no mention of radio equipment. The radios in 1946 were huge tube filled things with only a few channels. Any modern radio would be 100 times better than a radio that the aircraft would have came with in 1946.
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torquey401
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Re: TSO requirements

Post by torquey401 » Mon May 13, 2019 7:57 pm

C140A wrote:
Sun May 12, 2019 8:28 pm
"the equipment must provide the same level of safety as that established by the certification basis of the aircraft.”

Yes, I seen that....not that I understand what that actually means. Especially when in regards to a C140 for example that was certified in 1946, there would have been no radio even mentioned in that certification.

Anyway, I see that most are just as confused and frustrated by our CAR's as me :D
From Cessna 140 TCDS A-768 ...

" Certification Basis:Type Certificate No. 768 (CAR 4a) ".

CAR 4a refers to the regs that the type design met when built. If you install a radio today, the installation must meet the original certification requirements. Reading those very old regs is kind of interesting.

Actual installation information can be found in AC43.13-2B, Chapter 2. Antennas are covered in Chapter 3.
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Re: TSO requirements

Post by photofly » Tue May 14, 2019 5:18 am

I think the answer is in CAR571.07:
571.07 (1) No person shall install a new part on an aeronautical product unless the part meets the standards of airworthiness applicable to the installation of new parts and, subject to subsections (2) and (3), has been certified under Subpart 61.
See also AC571-024 for guidance on what paperwork is required.

Note that amateur-built and owner-maintenance aircraft are exempt by 571.07(2)(d).

Short answer: It doesn't appear you need a TSO'd product specifically, but you do need an 8130-3, Statement of Conformity etc. from a manufacturer that (if in the USA) is a holder of PMA approval or TSO authorization. I would imagine that's what you don't get when you buy an ICOM A220.

If it was a Canadian manufacturer they would need to be approved under CAR561 and provide you with a Form One or a Statement of Conformity before you could bolt "it" (whatever "it" may be) to your type-certified airplane.
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Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

Heliian
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Re: TSO requirements

Post by Heliian » Tue May 14, 2019 6:16 am

If you're not using approved parts, you are using unapproved parts.

571.13 Installation of Parts (General)

The following definition applies to this Standard:
(amended 2002/03/01; no previous version)

“undocumented part” means a part lacking sufficient certification or history to make it eligible for installation on an aircraft without submitting it to a recertification process. (pièce sans appui documentaire)

Information Note:

Pursuant to section 571.13of the CARs, a part is to be inspected and its accompanying documentation verified prior to installation in accordance with a procedure that the Minister finds acceptable, having regard for the safety of the aircraft, to ensure that the part conforms to its type design. In the case of components removed from an aircraft for repair, overhaul or exchange, traceability to their most recent airworthy installation or to their most recent maintenance action will constitute evidence of conformity to type design.
(amended 2002/03/01; previous version)

Pursuant to section 571.13 of the CARs and subject to sections 571.07, 571.08, and 571.09 of the CARs, the following standards of airworthiness are applicable to the installation of a part:

(a) except in the case of aircraft that are operated pursuant to a special certificate of airworthiness in the owner-maintenance or amateur-built classification, only parts that are specified in the type design of an aeronautical product, or that are approved alternative parts, are eligible for installation in that product;
(amended 2007/12/30; previous version)

Information Note:

An approved alternative part may be a replacement part that has been given either Part Design Approval (TCCA PDA) by Transport Canada or a Parts Manufacturer Approval (FAA PMA) by the Federal Aviation Administration.
(amended 2007/12/30; no previous version)

(b) where a type certificate holder assigns a proprietary number during the design phase to a standard or commercial part, and the proprietary part number is the only part number shown in the parts catalogue or similar document, only a part bearing the type certificate holder’s proprietary number, or an approved alternative part, shall be installed;
(amended 2007/12/30; previous version)

Information Notes:

(i) In some cases, the type certificate holder of an aeronautical product will, through the part number contained in the parts catalogue, add a suffix or a prefix to what appears to be a standard industry part. Where this has occurred, the modified part number is accepted as proprietary to the aeronautical product type certificate holder, and the installation of the standard or commercial part is not permitted without an appropriate engineering approval as a modification.
(amended 2002/03/01; previous version)

(ii) In many cases, the illustrated parts catalogue may contain a standard or commercial part number. This may be especially true in the case of bearings and electronic components. Standard and commercial parts having the identical part number may be installed regardless of the part manufacturer.
(amended 2002/03/01; previous version)

(c) substitution of equivalent standard or commercial parts is permitted only when the substitution does not constitute a major modification in accordance with section 571.06 of the CARs. Substantiation requires that the characteristics of the substituted part meet, or exceed, all of the requirements of the type design of the part being replaced. Reliance on substitution guides alone is not considered adequate. The evaluation of the characteristics of that part is subject to a review of specific type certificate holder’s data such as technical drawings, specification sheets, or substantiation reports associated with that type design;
(amended 2002/03/01; previous version)

(d) the part to be installed must be correctly configured for the installation in the aeronautical product; and

(e) prior to installation, the part should be inspected to ensure that it corresponds with its documentation, there are no signs of obvious damage, corrosion or deterioration, and the shelf life, where applicable, has not been exceeded.

Information Note:

A person who has reasonable grounds to believe that a part installed or intended for installation in a type certified aeronautical product that was not manufactured or certified in accordance with the applicable regulations of the state of production, or that is improperly marked, or that is documented in such a manner as to mislead with regard to the origin, identity or condition of the part shall submit to the Minister a report of the suspected unapproved part, using the service difficulty reporting system set out in section 521.401 of the CARs.
(amended 2009/12/01; no previous version)
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torquey401
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Re: TSO requirements

Post by torquey401 » Tue May 14, 2019 5:03 pm

From Airworthiness Notice B044

Policy

It is the policy of Transport Canada, Aircraft Certification Branch, to accept radio equipment on the basis that it is either.

listed in the IC Radio Equipment List, or
has been imported by way of installation in an aircraft imported from the United States and carries a certification from the Federal Communication Commission (FCC).

Supposedly still valid.
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Re: TSO requirements

Post by Heliian » Tue May 14, 2019 5:21 pm

torquey401 wrote:
Tue May 14, 2019 5:03 pm
From Airworthiness Notice B044

Policy

It is the policy of Transport Canada, Aircraft Certification Branch, to accept radio equipment on the basis that it is either.

listed in the IC Radio Equipment List, or
has been imported by way of installation in an aircraft imported from the United States and carries a certification from the Federal Communication Commission (FCC).

Supposedly still valid.
We're down to an interpretation issue and have to look at case basis. If you have a Cessna 140 and want to put a good radio in but don't want to pay the tso prices, just put in the cheaper one, find someone who also doesn't care to sign it out and be done with it. The regs will also allow you to fly such vintage warbirds as the lanc with their antique equipment that doesn't meet the standard. Once you get into anything more complex, you should be outfitted to the letter.
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Re: TSO requirements

Post by photofly » Tue May 14, 2019 6:55 pm

torquey401 wrote:
Tue May 14, 2019 5:03 pm
From Airworthiness Notice B044

Policy

It is the policy of Transport Canada, Aircraft Certification Branch, to accept radio equipment on the basis that it is either.

listed in the IC Radio Equipment List, or
has been imported by way of installation in an aircraft imported from the United States and carries a certification from the Federal Communication Commission (FCC).

Supposedly still valid.
But look also at Airworthiness Notice B025:
Airworthiness Approval of Radio Equipment
The listing of aeronautical radio equipment on the Industry Canada (IC)/Department of Communications (DoC) Radio Equipment List (REL) does not imply airworthiness approval.

The equipment/installation airworthiness approval must be obtained through the normal airworthiness process as defined in the Airworthiness Manual.
!
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Ensign Ricky: Aw, crap.

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Re: TSO requirements

Post by torquey401 » Tue May 14, 2019 8:31 pm

[/quote]

We're down to an interpretation issue and have to look at case basis. If you have a Cessna 140 and want to put a good radio in but don't want to pay the tso prices, just put in the cheaper one, find someone who also doesn't care to sign it out and be done with it. The regs will also allow you to fly such vintage warbirds as the lanc with their antique equipment that doesn't meet the standard. Once you get into anything more complex, you should be outfitted to the letter.
[/quote]

I do care. I don't think the regs require a tso'ed com radio. A tso'ed transponder, yes. A tso'ed elt, yes.

Different strokes for different folks I guess.
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Re: TSO requirements

Post by torquey401 » Tue May 14, 2019 9:26 pm

photofly wrote:
Tue May 14, 2019 6:55 pm
torquey401 wrote:
Tue May 14, 2019 5:03 pm
From Airworthiness Notice B044

Policy

It is the policy of Transport Canada, Aircraft Certification Branch, to accept radio equipment on the basis that it is either.

listed in the IC Radio Equipment List, or
has been imported by way of installation in an aircraft imported from the United States and carries a certification from the Federal Communication Commission (FCC).

Supposedly still valid.
But look also at Airworthiness Notice B025:
Airworthiness Approval of Radio Equipment
The listing of aeronautical radio equipment on the Industry Canada (IC)/Department of Communications (DoC) Radio Equipment List (REL) does not imply airworthiness approval.

The equipment/installation airworthiness approval must be obtained through the normal airworthiness process as defined in the Airworthiness Manual.
!
Installation approval via Std 551 and data found in manufacturer's installation recommendations and AC43.13-2b. Should be a minor mod.
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Re: TSO requirements

Post by C140A » Wed May 15, 2019 2:20 pm

Everything that Heliian is saying about unapproved PARTS, I completely agree with. I would not want a control cable, bell crank, etc that are critical to flight to be made in someones basement. That goes for an ELT or Nav radio as well, again something that could kill me. But a VHF comm? I'm with a few of the posters, common sense says that an airplane that was certified in 1946 when radios weighed 50 lbs and were a luxury item that any VHF radio designed (but not TSO'd) for aviation should be far better that what was out in 1946.

Again, makes no sense that an experimental aircraft can fly in the same VFR airspace with a non TSO'd VHF but a certified one can't. I asked this question to a couple TC inspectors a couple days ago...they also could not see the logic in that one.

Sometimes common sense is not that common....
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Re: TSO requirements

Post by photofly » Wed May 15, 2019 3:00 pm

Did you ask them if it was ok to install a non-TSO radio? What did they say?
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Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

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Re: TSO requirements

Post by C140A » Wed May 15, 2019 3:13 pm

Well at first they said no, it has to be TSO'd as per the original certification then when I said the 140 was certified without a radio then they said it would need a STC for any install. When I brought up the amateur build argument they had no explanation. To end it without actually going on the record and reading between the lines they led me to believe that probably there would not be an issue if it came down to it. They also said that US STC's are not all accepted in Canada....I didn't know that.
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Re: TSO requirements

Post by photofly » Wed May 15, 2019 4:34 pm

C140A wrote:
Wed May 15, 2019 3:13 pm
Well at first they said no, it has to be TSO'd as per the original certification then when I said the 140 was certified without a radio then they said it would need a STC for any install. When I brought up the amateur build argument they had no explanation. To end it without actually going on the record and reading between the lines they led me to believe that probably there would not be an issue if it came down to it. They also said that US STC's are not all accepted in Canada....I didn't know that.
I think you have just proved that TC inspectors aren't very good at interpreting the regulations, either.

The procedure for foreign STCs is described in SI 513-003. They typically don't quibble about FAA STC's when the US is the state of design of the aircaft.
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Kirk: This is a dangerous mission. Likely, one of us will die. The landing party will be me, Spock, McCoy, and Ensign Ricky.
Ensign Ricky: Aw, crap.

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