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Shop Talk: Transponder Repair

Wish you had a better understanding of the regulations when talking to your mechanic or the avionics shop? Aircraft Electronics Association Vice President of Government/Industry Affairs Ric Peri answers your frequently asked questions.

Question: Can I remove my transponder from my aircraft and send it to an avionics repair station for my biennial ATC transponder tests and inspections as required by 14 CFR 91.413?

Answer: No. This is assuming of course that you are acting as the holder of a pilot certificate ( § 43.3g ) performing preventive maintenance and not as a mechanic (§ 43.3b) performing maintenance.

14 CFR Part 43 Appendix A, paragraph c describes the items that are included in “preventive maintenance” which § 43.3g allows the holder of a pilot certificate to perform. Paragraph 43xA.c (31) allows for the removal and replacement of “self-contained, front instrument panel-mounted navigation and communication devices that employ tray-mounted connectors that connect the unit when the unit is installed into the instrument panel.” However, the regulation specifically excludes the removal and replacement of “automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)” as preventive maintenance.

Therefore, this action would require the assistance from an individual who holds an FAA-issued mechanic certificate to be performed as maintenance rather than preventive maintenance.

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