I searched but didnt find any obvious thread that addressed this. I read 91.225 and im not sure its 100% clear. If i buy a 73 year old champ that has never had an electrical system, can i fly it within the mode c veil, or more specifically, under the bravo shelf after jan 1 2020? I think the answer is yes based on 91.225 (e). There are lots of references between sections that almost seem to be designed to be confusing.
The basic understanding I have is, if you have to have a transponder now, you have to have ADS-B Out after the deadline. In your case, a non-electrical system plane, that has never had an electrical system installed, you don't have to have a transponder now and therefore you wouldn't need ADS-B. As you've stated though, it is worded to be confusing!
Key words are "engine-driven electrical system: https://www.faa.gov/about/office_or...017/schober - (2017) legal interpretation.pdf
Not exactly. The Mode C Veil/ADS-B exemption is based on engine driven electrical system, not absent a transponder. 14 CFR 91.225 (e) The requirements of paragraph (b) of this section do not apply to any aircraft that was not originally certificated with an electrical system, or that has not subsequently been certified with such a system installed, including balloons and gliders. These aircraft may conduct operations without ADS-B Out in the airspace specified in paragraphs (d)(2) and (d)(4) of this section. Operations authorized by this section must be conducted - (1) Outside any Class B or Class C airspace area; and (2) Below the altitude of the ceiling of a Class B or Class C airspace area designated for an airport, or 10,000 feet MSL, whichever is lower.
