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Thread: TSO Com?

  1. #1

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    TSO Com?

    I am installing the neat Garmin GTR-200 in Cubs and Stearmans (not professionally - mostly for me) and am recommending it. One Stearman guy just asked if a TSO radio was required - I said that I did not think so except for commercial operations.

    Any opinions or references?

  2. #2
    FdxLou's Avatar
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    Bob
    I agree with you. No need for TSO unless Part 135, etc.
    Lou1

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    behindpropellers's Avatar
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    Quote Originally Posted by bob turner View Post
    I am installing the neat Garmin GTR-200 in Cubs and Stearmans (not professionally - mostly for me) and am recommending it. One Stearman guy just asked if a TSO radio was required - I said that I did not think so except for commercial operations.

    Any opinions or references?
    I think your answer lies on its certification basis. I believe both were certified under CAR3

  4. #4
    hotrod180's Avatar
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    I've heard that a TSO radio is required for IFR certification.
    Cessna Skywagon-- accept no substitute!

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    wireweinie's Avatar
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    TSO's were not invented yet when CAR 3 was written. No requirement for it in any of the CAR's. I've never seen it mentioned in Part 135 either but guys have let stuff like that get written into their ops specs. Then you don't have any choice.

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    WhiskeyMike's Avatar
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    Since were on the subject, does anyone have a used serviceable KX-155, or maybe a KY-97 at a good price? My KX-155 has gone kaput too many times. Good money after bad.

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    As I understand it, the King stuff has those orange tubes that are starting to die, and are a hundred bucks a pop to replace.

    This new Garmin has only two flaws: not enough RF squelch for big city work, and doesn't like 12 volt battery power. Other than that, it is the hottest thing going. We put one in a Great Lakes, and the internal intercom is like talking in your living room, even at full power, in the voice activated mode.

    As usual, you guys stepped up with immediate answers! As always, thanks for your great help.

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    Quote Originally Posted by WhiskeyMike View Post
    Since were on the subject, does anyone have a used serviceable KX-155, or maybe a KY-97 at a good price? My KX-155 has gone kaput too many times. Good money after bad.
    I have a serviceable KX-155 I would get rid of
    Make me an offer I cant refuse

  9. #9
    kcabpilot's Avatar
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    If you look on the Aircraft Spruce website they are telling you the GTR-200 is "for experimental aircraft only" and they are wrong. There is nothing in the FAR's that says a radio for a Part 91 aircraft needs to be TSO'd. The only thing that comes close and probably what most people are misinterpreting is the following from Appendix A of Part 43:

    (4)Appliance major alterations. Alterations of the basic design not made in accordance with recommendations of the appliance manufacturer or in accordance with an FAA Airworthiness Directive are appliance major alterations. In addition, changes in the basic design of radio communication and navigation equipment approved under type certification or a Technical Standard Order that have an effect on frequency stability, noise level, sensitivity, selectivity, distortion, spurious radiation, AVC characteristics, or ability to meet environmental test conditions and other changes that have an effect on the performance of the equipment are also major alterations.
    But this is about making alterations to an appliance outside of the manufacturer's recommendations, not about installation or use of a radio. You can talk to the tower with a hand held if you want to for all that matter.

    Unfortunately these days so many people have completely lost sight of the scope and meaning of Appendix A and this is why we now have STC's for sun visors

  10. #10
    wireweinie's Avatar
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    Quote Originally Posted by kcabpilot View Post
    Unfortunately these days so many people have completely lost sight of the scope and meaning of Appendix A and this is why we now have STC's for sun visors
    And that's putting it mildly. Getting an STC has become the easier way to get approval to manufacture a part as compared to something like a PMA approval.

    Good idea for a thread . . . everyone could list their 'favorite' STC'd item.

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  11. #11
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    CAR 3.721 regarding aircraft radios. Hard to believe the government ever used common sense but here it is.

    RADIO EQUIPMENT; INSTALLATIONß 3.721 General. Radio equipment and
    installations in the airplane shall be free from
    hazards in themselves, in their method of
    operation, and in their effects on their
    components of the airplane.
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  12. #12

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    Definition of major alteration is in 1.1, supplemented with Part 43 appendix A, and AC 43-210A. I donít see the installation of a comm radio as meeting the level of a Major alteration, and even if you do find it to be a Major Alteration, AC 43.13-2B chapter 2 gives you approved data for the radio, and chapter 3 for the antenna. AC43.13-1b provides the data for wiring and circuit protection. No need for additional data, just account for all the elements identified in those 2 documents.


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    behindpropellers's Avatar
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    Quote Originally Posted by wireweinie View Post
    And that's putting it mildly. Getting an STC has become the easier way to get approval to manufacture a part as compared to something like a PMA approval.

    Good idea for a thread . . . everyone could list their 'favorite' STC'd item.

    Web
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    I think that is more because of the design data control than the engineering approval.

    Tim

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    TSO Com?

    Quote Originally Posted by wireweinie View Post
    And that's putting it mildly. Getting an STC has become the easier way to get approval to manufacture a part as compared to something like a PMA approval.

    Good idea for a thread . . . everyone could list their 'favorite' STC'd item.

    Web
    Iím working with guys doing an STC now for a helicopter system. Keep in mind, the STC is only the design and installation approval. You still need PMA to make the parts. STC & PMA May be easier than TSO approval. Keep in mind that TSO design and production approval and not installation approval.


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    kcabpilot's Avatar
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    I think in the case of something like Rosen sun visors they just decided - look, we can get people to pay six hundred bucks for these things and an STC effectively shuts up anybody who wants to claim that clamping a sun visor onto a strut is a “major” alteration simply because it’s not listed in the Type Certificate.

    Ironically many of those same people have no problem clamping an enormous iPad onto their control yoke, they are out there, believe me.

  16. #16
    hotrod180's Avatar
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    Quote Originally Posted by dgapilot View Post
    Definition of major alteration is in 1.1, supplemented with Part 43 appendix A, and AC 43-210A. I don’t see the installation of a comm radio as meeting the level of a Major alteration, and even if you do find it to be a Major Alteration, AC 43.13-2B chapter 2 gives you approved data for the radio, and chapter 3 for the antenna. AC43.13-1b provides the data for wiring and circuit protection. No need for additional data, just account for all the elements identified in those 2 documents.
    Back about 8 years ago, I pulled out the two junky com radios that came in my old C150TD and replaced them with an Icom A200.
    The guy who was gonna sign it off for me asked his PMI about required paperwork.
    He was told that a 337 was required, and if the radio was not TSO'd it would also require a field approval.
    Otherwise just an A&P signoff.
    Icom sold that radio both ways, the TSO'd one was a hundred bucks more.
    That field approval business sounded like BS to me, but since it's easier to just go along to get along,
    I spent the extra hundred bucks.
    I figured it was worth it to avoid the hassle.
    Cessna Skywagon-- accept no substitute!

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    As I said in an earlier post, the INSTALLER is the person that makes the major/minor decision, and if you document the decision process using FAA documents, an inspector may not agree with you, but he canít violate you for it! First rule is never ask a question you donít already know the answer to.


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    kcabpilot's Avatar
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    Yes, when I got my IA I saw it as an authority to appropriately interpret the regulations and make decisions, not just the ability to sign things off providing I have permission. It’s kind of like how some pilots seem to think they are working for ATC rather than the other way around.

  19. #19
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    Long long ago I handed the GADO (now FSDO) inspector a 337 for a radio installation that I did in a PA-18. He looked at it and gave it back to me saying you don't need a 337 for a radio installation. Then a good 20 -25 years later that very same FSDO inspector was speaking at the annual IA meeting telling everyone that 337s were required for radio installations. Well judging by the commotion there were a lot of other IAs who also had not been submitting 337s for radio installs.
    N1PA
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    wireweinie's Avatar
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    Some one will have to show me what part of a radio install is a major. And then they'll have to show me what requires a field approval for a non TSO'd radio. I don't care about AC's and instructions for Inspectors. I need to see it in the FARs. FAR's trump all opinion and advisory stuff.

    If any mechanic tries that crap about 'it's the way we do it here' or 'I've always done it this way' but wont show you the justification in the regs, find a better mechanic/IA and refer the old one to FAR 65.71, (a) (2).

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  21. #21
    kcabpilot's Avatar
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    I remember when AD's were rarely longer than about three paragraphs. Nowadays you'd be lucky to find one under 20 pages long.
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  22. #22
    wireweinie's Avatar
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    Quote Originally Posted by kcabpilot View Post
    I remember when AD's were rarely longer than about three paragraphs. Nowadays you'd be lucky to find one under 20 pages long.
    Not to worry. They still carry three paragraphs worth of info.

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  23. #23
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    Quote Originally Posted by wireweinie View Post
    ….. If any mechanic tries that crap about 'it's the way we do it here' or 'I've always done it this way' but wont show you the justification in the regs, find a better mechanic/IA and refer the old one to FAR 65.71, (a) (2).
    Sometimes it's a better idea to pick your battles.
    Save the "good fight" for something worth fighting for.
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    Quote Originally Posted by hotrod180 View Post
    Sometimes it's a better idea to pick your battles.
    Save the "good fight" for something worth fighting for.
    I disagree. If an inspector insists on you doing something his way without a regulatory basis, it will happen over and over again. If you know the regulations and published policy, hold them to their own game. If he canít cite a regulatory requirement he is only being a bully.


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    skywagon8a's Avatar
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    Quote Originally Posted by dgapilot View Post
    I disagree. If an inspector insists on you doing something his way without a regulatory basis, it will happen over and over again. If you know the regulations and published policy, hold them to their own game. If he can’t cite a regulatory requirement he is only being a bully.
    I agree with dgapilot. I once submitted a 337 for an alteration based on a pre 1955 337 approval (the equivalent of an STC). The FSDO sat on it for an extended period of time (more than 30 days) when the FSDO inspector came to inspect the alteration. (floats on a Cessna T-50) He fiddled around giving me the impression that he had no idea what he was doing. Then he refused to accept the 337. Well then I went over his head to a friend of mine. Shortly thereafter the FSDO inspector disappeared from the area. I later heard that he had been transferred to somewhere in South East Asia.

  26. #26
    hotrod180's Avatar
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    You kinda make my point for me.
    If your PMI wants to see an (unnecessary) to make him happy, maybe in the long run it's worth it.
    If you make an issue of it, don't be surprised if he doesn't cooperate when it's time to do a field approval or something.
    Yeah, maybe you can go over his head, but is it worth the hassle?
    I have the bad habit of tilting at windmills, sometimes just on principal,
    but I like to think that I'm getting at least a little smarter about such things as I get older.
    Cessna Skywagon-- accept no substitute!

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    wireweinie's Avatar
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    If I have to follow regulations when doing my job and the owner/pilot has to follow regs when flying, then the feds have to follow the regulations when doing their job. Not holding their feet o the fire over bogus mandates just encourages more bad behavior. If you don't push back, the inspector will come to the conclusion that HIS word will be followed no matter what. Then he spreads that attitude to other mechanics and owners. I'm not seeing where asking to see pertinent regulations is causing a battle. If you have blow back from an inspector over following regulations vs inspector's demands, call the FSDO and get another inspector.

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  28. #28

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    I am a "middle of the road" guy. I know that an inspector must provide a written response if he/she decides not to approve a field approval request but I have never insisted on it. Instead, I gently and persistently (and politely) push for approval. So far, I have not actually been turned down - I hold five different braking system approvals, and two wing mods. Oh, and a tricky weight and balance approval for a large single engine airplane that was weighed out of cg.

    The secret is to make them friends. Then they help.

    I do not file 337s for radio installations. I do file them each and every time a major change happens (STC on/off). If I have a pre-1955 approval in my hand, it is by definition approved data, and no inspector is involved.

  29. #29
    hotrod180's Avatar
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    Quote Originally Posted by bob turner View Post
    ….The secret is to make them friends. Then they help......
    Bingo! "You catch more flies with honey than you do with vinegar".
    Unfortunately, although I believe this, all my life I have had trouble remembering it and making it work.
    Hence, a lot of head-butting, and a lot of unnecessary pushback.
    Last edited by hotrod180; 11-17-2018 at 10:43 AM.
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    Bump - for a new Decathlon owner buying a 225

  31. #31
    wireweinie's Avatar
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    What's the question?

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  32. #32
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    Quote Originally Posted by bob turner View Post
    Bump - for a new Decathlon owner buying a 225
    Quote Originally Posted by wireweinie View Post
    What's the question?

    Web
    I believe Bob's original post was asking for feedback on the Garmin GTR-200. (Lots of thread drift...)

    Now it looks like Bob's repeating the inquiry, but this time asking for feedback on the GTR-225 for a Decathlon owner.
    Jim Parker
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  33. #33
    wireweinie's Avatar
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    The -225 is a better radio. Use good practices when installing it and the antenna and it will work well for years. Just make sure the owner/pilot is ok with working the buttons. You don't want to talk him into installing a radio that he hates changing frequencies on.

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    Sorry. The Decathlon guy's question was "do I need TSO?" The answers I got in this thread were the best way to answer him. I was having conceptual difficulties linking him here, so I bumped it. Then I figured out that the link worked.

  35. #35

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    I did say, in post #1, that we have a number of these neat radios installed. Frequency selection is standard, with two knobs and a flip-flop button.

    But you can program it for easily accessed memory frequencies - I have them all programmed for two different ways to access memory. Everybody loves it.

    Best of all - even in the Stearman, the internal intercom is the best I have ever used. Voice actuated!

    Only bad thing - RF Squelch is inadequate. We can hear approach control on our north runway frequency, and during the Covid lockdown (when a UHF and VHF frequency were combined with one controller keying both) it was almost intolerable.

    This is an unusual situation - Garmin refuses to even listen to me any more. They say they did that so you can hear from way far away . . .

  36. #36
    BC12D-4-85's Avatar
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    https://static.garmin.com/pumac/190-01553-00_n.pdf

    Might not help but the RF Squelch is menu adjustable page 3-8. A RF gain control would be a simpler way to prevent overdriving the receiver when strong signals are present. Maybe receiver frequency selectivity is the problem, or the controller's transmitter equipment needs a tuneup.

    Gary

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    We have it maxed out. Our north freq. is 125.7. The offending frequencies are 132.2 and I think 257.875. Both need to be keyed simultaneously.

    other radios, including my SL-40 and one of the older Garmin GPS- comms, do not have that problem.

    The GTR also opens up over the departure end, where an auto dealership has a noisy emitter. It is so loud we find ourselves scrambling to turn the volume down.

    The radio is otherwise spectacular. I am in love with the memory circuits and intercom.

  38. #38
    BC12D-4-85's Avatar
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    Too bad they can't apparently address the issue via a firmware or software update. May be some intermodulation distortion and/or selectivity challenges going on as well. I'd inquire about this next time you have a conversation. From their Owner's Manual - typical jargon but should apply:

    NOTE
    This device complies with Part 15 of the FCC Rules. Operation is subject to the following two conditions: (1) this device may not cause harmful interference, and (2) this device must accept any interference received, including interference that may cause undesired operation.

    Gary

  39. #39

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    First time I contacted them they seemed ready to help. About two years ago they stopped answering me, after explaining that the receiver was designed to listen to a tower from over a hundred miles out.

    just what I want to do - call the tower an hour out!

    I am living with it. During the height of Covid panic, Socal had a single controller on both frequencies. We were getting crystal-clear approach clearances to Palomar, Miramar, and Ramona. But the Great Lakes guys were going nuts - it was intolerable for about a month.

    Now both controllers have to simultaneously key, and what we get is garbled stuff - not complete clearances.

    No other comms have this problem.
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  40. #40
    BC12D-4-85's Avatar
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    Weird response from Garmin....maybe it's a faulty design soon to be replaced. Usually peaking receiver sensitivity has to be accompanied by dealing with increased signal to noise ratio problems. A variable RF gain plus variable digital filtering can help.

    Not uncommon for east asian companies to deny issues exist then offer upgraded products and save face. Question: Does disabling the intercom function have any effect on receiver performance?

    Gary
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