PA-28-181 Required Equipment?

This is the part of 91.213 that needs to be addressed:

(2) The inoperative instruments and equipment are not -

(i) Part of the VFR-day type certification instruments and equipment prescribed in the applicable airworthiness regulations under which the aircraftwas type certificated;

You're parsing the sentence wrong and misreading this. The second half isn’t directing you to a type certificate, it says you need the regulations that aircraft was certificated under. The direct object is a regulation.
 
Have you looked up the TCDS yet? I doubt there is an MEL for that aircraft so a TCDS needs to be checked on the FAA website before heading to 91.205. I would help a brother out but their website appears down right now.

the TCDS for the PA-28 says nothing about electrical systems or modes of flight. Nor should it, it’s published engineering data.
 
You're parsing the sentence wrong and misreading this. The second half isn’t directing you to a type certificate, it says you need the regulations that aircraft was certificated under. The direct object is a regulation.

The regulations require the equipment.
 
TCDS attached. Required equipment for certification is per regulations cited in certification basis. Someone smarter than me can explain what that means for continued airworthiness and legality to operate.
 

Attachments

  • Cherokee Type Certificate Data Sheet 2A13 (1).pdf
    784.9 KB · Views: 9
The regulations require the equipment.

yes, but regulation that is the basis of the certification is part 23 and that contains no requirement for an electrical system not even at night except for IFR. No matter which sections the TCDS cites, there’s no day VFR requirement in any of it. For that, you’re back to part 91.

.
 
91.213 -> 91.205 IS the legal resolution of whether or not the OP can fly his airplane and for what kind of operations.

Wow did you read 91.213 or anything else in the thread?
 
Last edited:
yes, but regulation that is the basis of the certification is part 23 and that contains no requirement for an electrical system not even at night except for IFR. No matter which sections the TCDS cites, there’s no day VFR requirement in any of it. For that, you’re back to part 91.

.

We are not talking about whether an airplane requires an electrical system. The airplane already has an electrical system, and the OP is planning to continue to use it. The question is whether an associated component is required.
 
Have you looked up the TCDS yet? I doubt there is an MEL for that aircraft so a TCDS needs to be checked on the FAA website before heading to 91.205. I would help a brother out but their website appears down right now.

The TCDS will only list things such as the permitted engine and propeller models.
 
yes, but regulation that is the basis of the certification is part 23 and that contains no requirement for an electrical system not even at night except for IFR. No matter which sections the TCDS cites, there’s no day VFR requirement in any of it. For that, you’re back to part 91.

.

Not disagreeing in this case after seeing the TCDS. However, not all TCDS documents read the same so I was merely saying to check it first before going to 91.205. Many people forget that the TCDS needs to be checked as well.

P.S. 23.1351 (which is in the TCDS) has some pretty specific things of electrical systems. However, it must be superseded by something as it is no longer apart of FAR 23.
 
The TCDS will only list things such as the permitted engine and propeller models.

I'm going to have to disagree with you on this. While it does list those things it also lists FARs required to be met and sometimes has required equipment listed within the document as well.
 
Not disagreeing in this case after seeing the TCDS. However, not all TCDS documents read the same so I was merely saying to check it first before going to 91.205. Many people forget that the TCDS needs to be checked as well.

P.S. 23.1351 (which is in the TCDS) has some pretty specific things of electrical systems. However, it must be superseded by something as it is no longer apart of FAR 23.

I guess I jumped ahead because I’ve previously been through this for PA-28s specifically.

I knew about 1351, but every part is qualified by being essential to safe operation.
 
P.S. 23.1351 (which is in the TCDS) has some pretty specific things of electrical systems. However, it must be superseded by something as it is no longer apart of FAR 23.
23.1351 was removed with the rewrite of Part 23, but still applies to the PA-28. One of the specific things it requires is an ammeter if a generator or alternator is installed:
(d) Instruments. A means must exist to indicate to appropriate flight crewmembers the electric power system quantities essential for safe operation.

(1) For normal, utility, and acrobatic category airplanes with direct current systems, an ammeter that can be switched into each generator feeder may be used and, if only one generator exists, the ammeter may be in the battery feeder
 
While it does list those things it also lists FARs required to be met and sometimes has required equipment listed within the document as well.
Keep in mind the TCDS sole purpose is to define certain parameters of TC per Part 21 and Part 91.213(d) sole purpose is grant the ability to operate an aircraft with some certain instruments and equipment inoperative. Outside of the certification requirements specifically for VFR day and by extension the required items on the aircraft Equipment or KOL lists the other data listed on the TCDS is not directly applicable to a 91.213(d) deferral. Part 91.213(d) does not require a complete conformity check of the aircraft only specific checks and actions applicable to part being deferred.
23.1351 (which is in the TCDS) has some pretty specific things of electrical systems. However, it must be superseded by something as it is no longer apart of FAR 23.
FYI: Part 23 was completely rewritten a number of years ago and about 2/3rds of the regulations were moved into ACs as a method to stimulate now Part 23 aircraft certifications. Even though 23.1351 is no longer listed it still applies to the aircraft just as CAR 3 still legally applies. The current Part 23 applies to new type designs and some upgrades of older type designs.
However, not all TCDS documents read the same
You'll also find some of those documents are titled Aircraft Specifications and use a different numbering system. This was due to the switch to the FAA system from the CAA system. The current TCDS serve a different purpose than the previous Aircraft Specifications did with aircraft certification but were left in place and are sometimes retitled TCDS.
 
FYI: Part 23 was completely rewritten a number of years ago and about 2/3rds of the regulations were moved into ACs as a method to stimulate now Part 23 aircraft certifications. Even though 23.1351 is no longer listed it still applies to the aircraft just as CAR 3 still legally applies. The current Part 23 applies to new type designs and some upgrades of older type designs.
And there we are. I was looking for the historical FARs yesterday, but the site wasn't alive. I think they use Sundays to do maintenance on it. (The new system is also not user-friendly at all.)

Sometimes people try to justify an inoperative or missing component because it's expensive to rectify it. They don't want to admit that, so they look for some legal loophole, an excuse to let defects remain. It really comes down to cost. Airplanes are expensive for many reasons, and some of those reasons are pretty good. Age, for one, and low production numbers for another. We live in a world where almost everything is mass-produced in vast numbers, by automated machinery, but loadmeters for 40-year-old light airplanes are not one of them.

That rarity and cost of light airplanes and the cost of flying means that any person flying anything is among the most privileged people on the planet. If flying was cheap we wouldn't be so privileged.
 
Keep in mind the TCDS sole purpose is to define certain parameters of TC per Part 21 and Part 91.213(d) sole purpose is grant the ability to operate an aircraft with some certain instruments and equipment inoperative. Outside of the certification requirements specifically for VFR day and by extension the required items on the aircraft Equipment or KOL lists the other data listed on the TCDS is not directly applicable to a 91.213(d) deferral. Part 91.213(d) does not require a complete conformity check of the aircraft only specific checks and actions applicable to part being deferred.

FYI: Part 23 was completely rewritten a number of years ago and about 2/3rds of the regulations were moved into ACs as a method to stimulate now Part 23 aircraft certifications. Even though 23.1351 is no longer listed it still applies to the aircraft just as CAR 3 still legally applies. The current Part 23 applies to new type designs and some upgrades of older type designs.

You'll also find some of those documents are titled Aircraft Specifications and use a different numbering system. This was due to the switch to the FAA system from the CAA system. The current TCDS serve a different purpose than the previous Aircraft Specifications did with aircraft certification but were left in place and are sometimes retitled TCDS.

Thanks for the clarifications and knowledge.
 
Back
Top