Transponder/Altimeter inspection timing

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4RNB

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4RNB
Hello.

My last IFR inspections were completed July 22, 2020.

Are they due July 22 or do they expire July 31, 2022?

My IA says July 31 but there is a checkride coming up July 26th. My CFII is asking the DPE, but looking for anonymous internet opinions.
 
Has your instructor read the regulations requiring the checks? An inquiry with a DPE shouldn’t be necessary.

91.411 and 91.413 cover it.
 
4RNB said:
Hello.

My last IFR inspections were completed July 22, 2020.

Are they due July 22 or do they expire July 31, 2022?

My IA says July 31 but there is a checkride coming up July 26th. My CFII is asking the DPE, but looking for anonymous internet opinions.
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You have a checkride coming up and neither you nor the CFII know the answer to a pretty standard question that would be asked on an oral. I would be concerned.
 
dmspilot said:
You have a checkride coming up and neither you nor the CFII know the answer to a pretty standard question that would be asked on an oral. I would be concerned.
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Thank goodness I have two weeks further to prepare then. Like, I could learn the answers now, then go to the ride in two weeks. Thank you for sparing me a moment of your thoughts today.
 
I think people are ignoring the fact that the reg is vague. "in the previous 24 months" can be interpreted either way. Does someone have guidance in writing on how the Faa interprets it?
 
4RNB said:
Thank goodness I have two weeks further to prepare then. Like, I could learn the answers now, then go to the ride in two weeks. Thank you for sparing me a moment of your thoughts today.
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Are you going to ask the Internet for the answers to all of the hundreds of questions you might be asked? What source will you cite if you are asked to explain your answer? And what are you going to do if you are asked a question during the oral that you did not pre-ask on an anonymous message board?
 
The point is that some are acting like the guy and his CFI didn't bother to look up the reg. I don't think that's the case.
 
The point is I want to pass the check ride but not pester the DPE. If there is universal acceptance of end of July, but not the 25th month, I'm good. If there is debate or a gray area, I want to head this off at the pass.
 
Salty said:
Can be interpreted either way.
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Only if the FAA doesn't define it. Which they do.

FAA-H-8083-31:
Calendar month. A measurement of time used by the FAA for inspection and certification purposes. One calendar month from a given day extends from that day until midnight of the last day of that month.
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Salty said:
With a checkride coming up the answer is do it anyway.
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Why? There's no requirement for it to be done before the end of the month, checkride or not. In fact, NOT having it done yet gives the applicant an opportunity to show the examiner that he knows the regulations and when it's due. In general, I'd prefer to NOT have any optional maintenance done in the weeks leading up to a checkride, just in case something goes wrong during maintenance.

Salty said:
Can be interpreted either way.
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The use of the term "calendar months" in 91.411 and 91.413 is pretty well established, as it's the same meaning when it's used in 61.56 for flight reviews, 91.409 for annual inspections, 61.39 for knowledge test duration and the 3 hours of training prior to a checkride, and numerous other places.
 
RussR said:
Why? There's no requirement for it to be done before the end of the month, checkride or not. In fact, NOT having it done yet gives the applicant an opportunity to show the examiner that he knows the regulations and when it's due. In general, I'd prefer to NOT have any optional maintenance done in the weeks leading up to a checkride, just in case something goes wrong during maintenance.



The use of the term "calendar months" in 91.411 and 91.413 is pretty well established, as it's the same meaning when it's used in 61.56 for flight reviews, 91.409 for annual inspections, 61.39 for knowledge test duration and the 3 hours of training prior to a checkride, and numerous other places.
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He was looking for it in writing, not just "well that's what everyone" says. They do have it in writing as to what a calendar month is.
 
EdFred said:
Only if the FAA doesn't define it. Which they do.

FAA-H-8083-31:
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Thanks. First time I've seen that. Took a bit to actually find it since the pdf isn't indexed for search.

Now I'm struggling with seeing how it's not saying the exact opposite of what has been stated here as the right answer.
 
My last IFR inspections were completed July 22, 2020.
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One calendar month from a given day extends from that day until midnight of the last day of that month.
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From July 22, 2020 to July 31, 2020 is one calendar month according to the definition. add 23 more and you get to June 31, 2022
 
Or you could say the month of July 2022 is a calendar month. The previous 24 calendar months does not include the month of July 2022, so that range would extend to June 1 2020. But I don't think this definition really clarifies that.
 
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Salty said:
Or you could say the month of July 2022 is a calendar month. The previous 24 calendar months does not include the month of July 2022, so that range would extend to July 1 2020. But I don't think this definition really clarifies that.
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So you are saying going back a month previous to today does not include any days in the month of July? Ooooooooooooooooooooooooooookay.
 
EdFred said:
So you are saying going back a month previous to today does not include any days in the month of July? Ooooooooooooooooooooooooooookay.
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So you seem to be indicating that the inspection is due. It was my impression that folks were saying it is not due.
 
Salty said:
So you seem to be indicating that the inspection is due. It was my impression that folks were saying it is not due.
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We start from today. From today to June of 22 is 1 month. Till May of 22 is 2, April of 22 3...July of 21 is month 12...July of 20 is 24 months.
 
I fixed a typo where I said July and meant June. Which may have confused you and therefore myself in reading your response.
 
EdFred said:
We start from today. From today to June of 22 is 1 month. Till May of 22 is 2, April of 22 3...July of 21 is month 12...July of 20 is 24 months.
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So, you are saying that the inspection is due. Correct?
 
Sorry, but the definition does not help me understand how you get this

EdFred said:
We start from today. From today to June of 22 is 1 month. Till May of 22 is 2, April of 22 3...July of 21 is month 12...July of 20 is 24 months.
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The definition says that between June 22, 2020 and June 31, 2020 is a calendar month, how does that lead you to jumping to the same day in a previous month?
 
Salty said:
Sorry, but the definition does not help me understand how you get this
The definition says that between June 22, 2020 and June 31, 2020 it is a calendar month.
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We aren't counting forward. FAA currencies and certs count backwards. It also says previous. What's the previous month from today? June. What's the 24th? July 2020.
 
The problem is that the definition is written in reverse to this particular reg.

One calendar month from a given day extends from that day until midnight of the last day of that month.
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If I turn this around to previous, it would say "One calendar month from a given day extends from that day until midnight of last day of the previous month"

Applying that means that From July 11, 2022 to June 30, 2022 is 1 month, Add 23 calendar months more and you only get to July 31, 2022.
 
EdFred said:
We aren't counting forward. FAA currencies and certs count backwards.
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Not according to the actual regulation.

No persons may use an ATC transponder that is specified in 91.215(a), 121.345(c), or § 135.143(c) of this chapter unless, within the preceding 24 calendar months, the ATC transponder has been tested and inspected
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EdFred said:
We aren't counting forward. FAA currencies and certs count backwards. It also says previous. What's the previous month from today? June. What's the 24th? July 2020.
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Again, I'd like to see where the FAA says in writing they mean this. That definition didn't do it.
 
Salty said:
The problem is that the definition is written in reverse to this particular reg.


If I turn this around to previous, it would say "One calendar month from a given day extends from that day until midnight of last day of the previous month"

Applying that means that From July 11, 2022 to June 30, 2022 is 1 month, Add 23 calendar months more and you only get to July 31, 2022.
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It means a page on the calendar.

So whatever day it is today, this "calendar month" ends when you flip the page. Whether today is the 1st or the 29th.

Likewise, the "preceding calendar month" is whatever is on the page before this one. It's not between today and the first day on this page. That's still this calendar month. The two proceeding calendar months are the two pages before this one. And so on.

So the 24 proceeding calendar months are the 24 pages before this one. As long as the inspection is on one of those pages, you're good.

And that set of pages doesn't change until you get to the end of this page and flip to the next one, regardless of today's date.
 
Lindberg said:
It means a page on the calendar.

So whatever day it is today, this "calendar month" ends when you flip the page. Whether today is the 1st or the 29th.

Likewise, the "preceding calendar month" is whatever is on the page before this one. It's not between today and the first day on this page. That's still this calendar month. The two proceeding calendar months are the two pages before this one. And so on.

So the 24 proceeding calendar months are the 24 pages before this one. As long as the inspection is on one of those pages, you're good.

And that set of pages doesn't change until you get to the end of this page and flip to the next one, regardless of today's date.
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I believe you, but where is the Faa saying that? The link EdFred provided is regarding regs that are written a bit differently.
 
Salty said:
I believe you, but where is the Faa saying that? The link EdFred provided is regarding regs that are written a bit differently.
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Did you look at the legal interpretation I posted that gives an example?
 
Salty said:
I think people are ignoring the fact that the reg is vague. "in the previous 24 months" can be interpreted either way. Does someone have guidance in writing on how the Faa interprets it?
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No, the reg isn't vague. You open the aircraft log books and start with the previous month and count back 24 months. If the inspections were done in any of the 24 months prior to your search the plane is in compliance.
 
This is the Webster’s definition that the FAA is using…
Definition of calendar month


1: one of the months as named in the calendar
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so, “June”, “July”, “August”, etc.

91.411 says
Within the preceding 24 calendar months,
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This is July, 2022…any day this month is July, 2022. The 24 calendar months in question precede July 2022. Those 24 calendar months are:
July 2020
August 2020
September 2020
October 2020
November 2020
December 2020
January 2021
February 2021
March 2021
April 2021
May 2021
June 2021
July 2021
August 2021
September 2021
October 2021
November 2021
December 2021
January 2022
February 2022
March 2022
April 2022
May 2022
June 2022

if the check was done in any of those calendar months, it’s good for all of this calendar month.
 
BTW - my PPL was Jan 1 2020. My IFR checkride was middle of Jan 2022. I was still legal to fly even though I hadn’t had my bi annual yet because the 24 months post the month I got the PPL hadn’t expired yet. (So, if I hadn't passed the check ride I'd have to do the bi annual).
 
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