Time For An FAA Reset On ADS-B

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Last week, without much fanfare, Seattle Avionics announced that it’s marketing a new portable dual-band ADS-B In product from uAvionix. It’s called the pingBuddy2 and sells for the eye-opening price of $149. Recall that I reported on uAvionix in this piece I shot at the AEA show in New Orleans last week.

The pingBuddy2 is significant for a couple of reasons. One is the utterly disruptive price. Heretofore, the dual-band portables have sold for six to nearly 10 times as much. I’m thinking here of the Stratus 2S, the Sagetech Clarity and the Levil Technology iLevil 3 SW. To be sure, these aren’t exact comparisons because the more expensive products include onboard GPS and AHARS that put some backup gyro capability on a tablet. One version of the iLevil even has pitot-static input. By comparison, the pingBuddy2 offers just ADS-B In for TIS-B and FIS-B access. You’re on your own to provide it with GPS position data, either through the tablet’s built-in GPS or an external like Garmin’s GLO.

The bigger picture here is that uAvionix, looking forward, is leveraging volume in the drone market to effect some interesting economy of scale. But at this point, it’s somewhat aspirational volume because the requirement for ADS-B on drones hasn’t materialized yet. My guess is it will, but it will take a while. But uAvionix, with its full line of miniature avionics, is betting on that future.

The plus for GA owners and pilots is that even though uAvionix’s market is overwhelmingly in the UAS space, it sees some opportunity to disrupt ADS-B prices for manned aircraft. The company told me late last week that it will be announcing something ahead of Sun ‘n Fun, most likely for the experimental market. This could represent a significant price break. Could that eventually result in significantly cheaper ADS-B Out solution for owners still balking about equipping? Well, maybe. But “significant” is in the eye of the beholder and the trick part here is will the vastly larger demand for UAS ADS-B materialize before the 2020 mandate deadline? My guess is it won’t, because the FAA hasn’t even settled on regulations for the larger drones that will fly in the airspace with manned aircraft, much less figured out how and when to require ADS-B for Part 107 operations.

The argument for those little drones having ADS-B—and you equipping your own airplane—is compelling. The low-power systems uAvionix is producing don’t need to ping ground stations or pipe data into TIS-B or be engaged with ADS-R. 

They just need a simple ADS-B Out pulse so you can see them in your equipped airplane. If you’re really worried about the risk of colliding with a small drone, that’s the argument for equipping both aircraft with ADS-B.

As a point of public policy, the FAA should now look at the potential of volume-driven ADS-B equipage and how it could reach its goal of full participation. Despite all the positive spin you may have heard, the rate of equipage is still lagging. Whether that’s related to cost or cost and other factors is anyone’s guess. My guess is that it’s not all cost. But cheaper—vastly cheaper—ADS-B Out solutions can’t possibly hurt the effort and may very well ignite the torrent of demand the FAA so desperately wants.

To achieve this, the agency simply needs to relax—or eliminate—any kind of TSO requirement for certified ADS-B. It’s lunacy and utterly counterproductive that an RV-8 can run around in the same airspace that a Skyhawk can, but the latter requires a more expensive certified ADS-B receiver. This is at the core of the squabble NavWorx is having with the FAA, which insists that the company’s GPS solution for its low-cost ADS-B boxes doesn’t meet the TSO requirement, even though it meets the TSO performance specs. The FAA is just making it that much more difficult and expensive to equip over an inconsequential technical fine point.

Removing the TSO and certification hoops would make it much more likely that a company like uAvionix could bring cheaper ADS-B to the market. Could we see an under $1000 solution suitable for certified airplanes? uAvionix thinks so, especially if the drone demand it sees over the horizon materializes. But it may not be in time to meet the 2020 witching hour. Still, better late than never.

And while we’re at it, why not just junk the entire idea of TSOs? It’s an idea whose time may be done.

Comments (48)

Wow!!! Excellent narrative. I'll buy the pingBuddy2 and will support your initiative to abolish TSOs.

Posted by: Rafael Sierra | March 21, 2017 10:12 PM    Report this comment

While you are at it abolish certification for PRIVATE aircraft. Require manufacturer to state what design standard it was designed and built to and what testing was done. Up to the buyer then.
The number of homebuilts shows that formal FAA certification isn't valued all that highly by the customer base.

Posted by: Michael Borgelt | March 22, 2017 1:37 AM    Report this comment

Come to the dark side... we have advanced glass, modern engines, TSO-free equipment, and cookies...

Seriously, the idea that the FAA needs to watch over every step of every process used to make every part of every aircraft, witness every test in the flesh, and be notified in writing every time you move a fixture or work station on the production floor is old and tired, especially for light personal aircraft. No other industry sees this level of government micromanagement, even medicine--it's easier for a doctor to put something in your body than it is to put a new part on an airplane. Auto manufacturers don't have to deal with this, yet they manage to make orders of magnitude more vehicles on each of their product lines, at lower defect rates and better overall safety.

The FAA certification process (Part 21, 8110.4, etc) adds very little (if anything) to the safety of the final product. It merely generates massive amounts of paperwork and overhead cost. And the FAA's stance on changes--"as long as you don't change anything you can keep building it, but anything you change has to meet the *latest* standards, not just be better than the previous version"--strongly disincentivizes manufacturers from making improvements, because of the bureaucratic costs of improving the design.

Posted by: Robert Gatlin-Martin | March 22, 2017 6:05 AM    Report this comment

"Auto manufacturers don't have to deal with this"

The more I study this statement, the less I find it a capable argument. Yes, the automobile manufactures may not have it "as bad", but I was/am surprised just how bad they have it.

When most people think about automobile safety standards (Federal Motor Vehicle Safety Standards), what usually comes to mind is "crash protection". That's not even the tip of the iceberg.

From the type/positions of lights/controls/displays, to how fast the defroster clears the windows, there's a ton that goes into getting an automobile "certified"......and that's an ongoing endeavor if not for every new model year, every major model change (what, every 3-5 years or so?).

How many years ago was the newest 172 certified?

Posted by: Robert Ore | March 22, 2017 7:38 AM    Report this comment

I've concluded the FAA would rather see pilots dying than reform their overarching power. Can anyone argue it's OK for VFR-pilots who bumble into clouds spiral out to their death rather than allow an autopilot suitable for an RV-8 be installed in a Cessna 150? Are these deaths FAA-approved?

Posted by: John Beech | March 22, 2017 8:03 AM    Report this comment

How is it OK for VFR-pilots who bumble into clouds to spiral out to their death rather than allow an autopilot suitable for an RV-8 be installed in a Cessna 150? Are these deaths FAA-approved?

Posted by: John Beech | March 22, 2017 8:05 AM    Report this comment

I am not for getting rid of the process but I am upset the manufacturers are abusing certified aircraft owners. Take the Garmin GTN-650, same hardware in a marine unit is roughly $3000 the GTN 650 is $10,000 why? ADSB in and out for a home built is 1/3 the cost, they function in the same airspace, IFR or VFR with no issues, why isn't that equipment available to certified aircraft owners? The cost of the boxes themselves are fairly outrageous considering what you are getting and the technology used which is fairly simple. Myself along with many other owners are waiting on ADSB. Why? Well the cost has gone down by 1/2 in the past three years is one reason why. We feel it will get lower, someone is going to say hey there is the potential for 100,000 units here.

Posted by: John Majane | March 22, 2017 8:21 AM    Report this comment

The April 2015 FAA five slide show on TSO C199 for the "TABS" (Traffic Avoidance Beacon System) definition says: " Increase safety by providing a standard for a low cost surveillance solution for aircraft excepted in 14 CFR 91.215 and 91.225 - i.e. balloons, aircraft without electrical systems etc. " So not only is the standard for an RV-12 different than that for a C172, but now they're including balloons, gliders and non-electrical system airplanes in the lower performance position source standard.

Prior to 2020, implementation by aircraft owners is SO slow that they have to spend OUR tax money to cajole us into equipping. After 2020, they'll steal OUR Class A, B and C airspace if we don't equip. Either way, WE are paying.

The current process should immediately be relaxed to the TSO C199 standard for all but Class A and the 37 Class B airports! Most GA pilots can't fly in Class A and have no interest in flying IN Class B (not talking about the Mode C veil). If ALL of the remaining airspace was allowed to use the cheaper solutions -- especially if manufacturers began to supply cheaper all-in-one boxes -- an immediate rise in compliance would result. It IS about cost and being forced into doing it.

Trig is building a lower cost GPS position box for TABS named TN72. It's not yet on the market but is close. So if you chose to equip your Cub with a small battery powered TT22 transponder, you could hook a TN72 to it so that others would 'see' you. But if I want to do that with my C172, I cannot. What gives. Are those people on Independence Ave living in a parallel universe? Why is my C172 being treated as though it were a B747?

I held one of those uAvionics thingies in my hands a couple of weeks ago and was amazed.

Posted by: Larry Stencel | March 22, 2017 8:35 AM    Report this comment

When I hit the 10th acronym I didn't know, I stopped reading. I work in tech all day and the way folks love to pile this stuff on just turns me off. It's the same as when I used to fly to Oshkosh in my homebuilt - I don't go anymore because the focus is not on airplanes and flying anymore, it's on shiny new computers!

I'll go along and install this unwanted government intrusion when the following are true: 1) I can do the work myself, 2) the unit costs no more than a few hundred bucks tops, 3) I can selectively turn it off from the cockpit at my discretion.

Posted by: Ken Keen | March 22, 2017 9:01 AM    Report this comment

Mr. Ore, the issue isn't really the *performance* standards. Part 23, while a little prescriptive in parts (i.e. "thou shalt do it this way" vs. "thou shalt achieve this goal"), is by and large just sound, basic engineering sense.

The issue is the *administrative* requirements.

Auto manufacturers don't have to present a detailed plan stating how they're going to meet each requirement, who from the DOT is going to approve each part of the design, and laying out a program schedule from design to testing to delivery before they even get started with the design.

The DOT doesn't have to approve the company's internal processes (e.g. quality control, product tracking, design signoff, etc.) and reapprove them every time there's a change.

The DOT doesn't lock down the design of the car at (literally!) the nut and bolt level and require specific approval for every single change.

Auto manufacturers don't have to notify the DOT every time they move equipment around on the production line to improve efficiency.

Auto manufacturers don't have to recertify their production line if they move it to a different building, let alone another address.

The mere fact that Cessna is still producing the 172 in the same factory, with effectively the same engine, with magnetos and mechanical constant-flow injection with manual mixture control, is illustrative of the problem. An RV-10 with significantly better performance and overall efficiency costs far less to purchase already built--and that's for an airframe of comparable technology level. A carbon airframe built to leverage the strengths of composites rather than duplicating metal structure could do even better, at less cost.

The earlier post comparing non-TSO hardware to TSO hardware is also a good illustration. The massive difference in price between the TSO and non-TSO hardware, otherwise identical down to the stamps on the microchips, is due almost entirely to the paperwork and administrative burdens of producing things the "FAA way".

A four-seat personal airplane simply does not need every single component locked down to specifically approved configurations and should not require approval and experience working on large jets, helicopters, and other construction methods in order to do standard maintenance. Just as LSA owners can get approval to work on their personal aircraft, everyone should be able to do the same.

Contrary to the FAA's belief, I find it likely that older airplanes will find their value *increase* if something like the primary non-commercial proposal is enacted, and owners are able to modify and maintain their own airplanes without being constrained like "standard category" aircraft, even if there's no path to convert back. You couldn't pay me to own a certified airplane, but I might at least consider it if I can modify and maintain it like a homebuit.

Posted by: Robert Gatlin-Martin | March 22, 2017 9:10 AM    Report this comment

"When I hit the 10th acronym I didn't know, I stopped reading." Ken, I used to count and complain about acronyms and obscure words used in this blog but now I like them. My vocabulary has gone from 472 words to 475. I not only sound smarter and feel superior, I also fly better. Clear prop!

Posted by: Rafael Sierra | March 22, 2017 9:31 AM    Report this comment

"Most GA pilots can't fly in Class A and have no interest in flying IN Class B (not talking about the Mode C veil)."

Those of us who live close to Class B airspace certainly have interest in flying in the airspace, either directly with a clearance, or through a VFR corridor. Depending on the speed of the aircraft flown, it could mean a savings of 10-30 minutes flying time. And that's just to get from one side to the other, never mind the GA airports beneath the Class B. Sure, one could fly over or under the airspace (and still need ADS-B Out), but sometimes neither are practical or desirable.


The TSO standards themselves aren't necessarily the issue, but the fact that simple GA aircraft like the 172 need to be held to the same standards as a 787 is the problem. What we need is what has been talked about before: a "primary non-commercial" standard that these GA aircraft can be placed in and treated similarly to LSAs and homebuilts (i.e. non-TSO'ed equipment).

Posted by: Gary Baluha | March 22, 2017 9:33 AM    Report this comment

You comment on the disruptive price but seem to ignore the other lower cost ADS-B option.

Stratux has been around for just shy of two years at this point and offers dual band ADS-B in along with GPS for around $130. There is even work being done on AHRS and the additional cost to add it is around $15. Stratux is about the most widely supported ADS-B in unit as far as EFB software goes since it is becoming a major selling feature. It is really sad how little coverage the aviation press has given it, I guess since it is not a commercial product there are no potential advertising dollars.

There are products based on Stratux software that are permanently installable in certified aircraft under the NORSEE rules.

After working on this project the true cost for much of this hardware has been shocking in just how cheap it actually is. Those $350 TSO USB power supply's are a glaring example of how little TSO manufacturers want to compete on price.

Posted by: Ryan Dewsbury | March 22, 2017 10:23 AM    Report this comment

Gary ... when I typed that statement, I knew someone would challenge me. It's just one of many possible alternatives to achieve the same objective. I used to fly in SoCal ... so I know the problem. And, I used to fly near MCO ... same story. Now I fly where transponders aren't required and the cows don't care. I've a good mind to yank the damn thing out and fuhgetaboutit. Except ... I DO see benefit in ADS-B. It's just like strobes ... you may never know when these things saved your bacon. Last blog's 'privacy' issues, notwithstanding.

I am really PO'ed that the primary non-commercial addendum recommended to the FAA by the Aviation Rulemaking Committee (ARC)(which worked on the issue for YEARS! never made it into the final FAR Part 23 rewrite. Appendix G.3 of that document addressed the very issues we're discussing here. Appendix G.4 addressed the P-NC issue. Worth noting, the document was addressed to Earl Lawrence, at that time the Manager of the Small Aircraft Directorate. Since then, he has been 'promoted' to deal with the UAS issue ... his departure is a giant loss to GA because he was formerly a long time EAA employee and knows what he's doing.

When you see so many post-War airplanes like the Aeroncas, Cubs, Luscombes, T-Craft, et al STILL being flown -- 70 years later -- something is wrong. Technology HAS moved forward. Safety IS important. New vs old IS desirable. But when you look at the cost, most people either can't afford or can't justify the expenditure. If the FAA was really interested in safety, they WOULD make it possible to build a decent airplane at the lowest possible price ... to consensus vs TSO standards and for owner maintenance. But -- alas -- that just ain't the way it is. So here we blather.

Maybe ... just maybe ... someone in the FAA ought to make them all read these blogs. There are oodles of good ideas floating around and going nowhere ... other than to serve as a place to vent.

Posted by: Larry Stencel | March 22, 2017 10:43 AM    Report this comment

Larry et al:

There are many among this blog's comentariat who are intimately familiar with the FAA's anaphylactic-level allergy to innovation. Examples (including many of my own) are a dime a dozen. That's just one reason why I'm of an open mind regarding the potential separation of ATC from the Agency.

Although it doesn't surprise me, it nonetheless amazes me that, 16 years into the 21st century, the FAA's idea of "next generation" air traffic control has at its center thousands of humans, all talking on open-frequency VHF radios. Gosh - what will they think of next?

If you really want to make an ADS-B omelet.......

Posted by: Tom Yarsley | March 22, 2017 11:11 AM    Report this comment

I have almost pulled the trigger twice on an approved ADS-B Out unit this past year. I have decided to wait and see what happens in the next year.

IF, and this is a BIG IF, the FAA can explain how they can let homebuilts, which fly faster and are just as heavy as my certificated aircraft, make use of non-certified units for much less expense than I can in my certificated aircraft, only then will I install! Otherwise I will, "wait and avoid rule airspace". Has a nice ring to it, sort of like "see and avoid"!

Posted by: Richard Mutzman | March 22, 2017 11:16 AM    Report this comment

You're a genius, Richard ... "Wait and Avoid" I LOVE it !!!

Have you considered printing T-shirt that say this for SnF and Airventure? You'd make enough to ... well ... equip. :-))

Posted by: Larry Stencel | March 22, 2017 11:30 AM    Report this comment

Reminds me of how "position and hold" got replaced by "line up and wait."
I politely suggest a course of action: "wait and balance."

Posted by: Tom Yarsley | March 22, 2017 11:37 AM    Report this comment

Richard, it's simple: to the FAA, what's on the paperwork matters much more than reality.

That's why a Stearman is a "high performance" airplane but Nemesis was not.

That's why a turbocharged pressurized twin doesn't require a type rating, but the jet CriCri requires the experimental equivalent of one.

It's why your nav light lenses must be "flame resistantf" but your landing light need only "not present a fire hazard", even though nobody in the FAA can explain *why* there's a difference.

It's why you can use anything that calls itself a VOR receiver for IFR navigation in a homebuilt, but an IFR GPS must still be TSO'ed.

To the FAA, paperwork is what guarantees safety.

Posted by: Robert Gatlin-Martin | March 22, 2017 12:07 PM    Report this comment

The only guidance I can find all state something to the effect that "TSO'd equipment is required by various regulations", however there never seems to be any reference to those regulations. Please see Order 8300.16, Appendix A (page 49 of the pdf) which states

"Meet minimum TSO Established Standards. Means that the equipment need not have TSO approval, but that it meets requirements set by the TSO."

I am unable to provide the link as it causes this comment to be flagged as spam. But, this is the latest and current iteration of what used to be Order 8900.1. I've even asked an FAA inspector to please clarify this for me, with no response. What IS the requirement, then, for TSO'd equipment? Can someone please point out to me those regulations? And if not, then how are we supposed to perform legal maintenance if following published regulation is suspect?

Posted by: Evelyn Greene | March 22, 2017 2:37 PM    Report this comment

Evelyn,

You'll never get a real answer. "That's how we've always done it" is good enough for the FAA. I wish I could find the story about someone making a transponder according to whatever spec existed and the FAA refusing to accept it since every other manufacturer deviated from the spec some specific way. The FAA said, in effect, you have to do it the way everyone else does it, not necessarily according to our own documents on how to do it.

If anyone else remembers that story or knows how to find it, I'd love to read it again.

Posted by: Joshua Levinson | March 22, 2017 3:18 PM    Report this comment

NEW ALL-ENCOMPASSING FAR

New FAA Regulation / Part 0, Section 000 (a) 1 (c)


Section I: No pilot or pilots, or person or persons acting on the direction or suggestion or supervision of a pilot or pilot may try, or attempt to try or make, or make attempt to try to comprehend or understand any or all, in whole or in part of the herein mentioned, Aviation Regulations, except as authorized by the administrator or an agent appointed by, or inspected by, the Administrator.

Section II: If a pilot, or group of associate pilots becomes aware of, or realized, or detects, or discovers, or finds that he or she, or they, are or have been beginning to understand the Aviation Regulations, they must immediately, within three (3) days notify, in writing, the Administrator.

Section III: Upon receipt of the above-mentioned notice of impending comprehension, the Administrator shall immediately rewrite the Aviation Regulations in such a manner as to eliminate any further comprehension hazards.

Section IV: The Administrator may, at his or her discretion, require the offending pilot or pilots to attend remedial instruction in Aviation Regulations until such time that the pilot is too confused to be capable of understanding anything.

Posted by: jim hanson | March 22, 2017 4:25 PM    Report this comment

Jim ... what's in part (a) and (b) ... never mind ... :-)))

Those people are totally out of control!! To be honest, I, too, don't give a damn if ATC goes somewhere else. It's time to neuter them !!!!!!

Posted by: Larry Stencel | March 22, 2017 6:41 PM    Report this comment

Run out of steam Larry?

Posted by: Rafael Sierra | March 22, 2017 7:48 PM    Report this comment

By law and mandate, the FAA is a schizophrenic bureaucracy. It is tasked with promoting aviation, while at the same time promoting aviation safety. You can have 100% of one, if you'll accept 0% of the other. Pick one.

I've seen some pretty horrible designs come out of the LSA market, and they have disappeared because the market determined that they were...horrible. How many planes are still flying with the old KX-170 (non-TSO'd) radios? Identical to the KX-175 radios (TSO'd).

The FAA hasn't the manpower or expertise to oversee every piece of electronics. In this day and age, the market should decide.

Posted by: Ripley Quinby | March 22, 2017 8:27 PM    Report this comment

Ever read a TSO? ARCHAIC. Structured for "back in the day" when it was believed everything could be 100% specified and regulated in advance in a world where everything was thought to be known. In some ways TSO seem to be written as if to tell manufacturers what to do almost assuming they had no idea. Of course I would suggest it's the other way around. It's the regulators who are behind the curve these days.

Evidently it did not work out that way. Technology especially moved at a pace and direction that left this means of regulation in the dust.

A new way is needed. We might look to other industries such as experimental, automotive, electronic, and consumer goods to see what means, IF ANY, we wish to apply. I might suggest that regulation might even be accomplished by exception, i.e. only known problems draw correction, all else passes by definition. After all, what product maker would want to be tarred with a defective product event?

Posted by: FILL CEE | March 23, 2017 12:17 AM    Report this comment

ONLY $150 for the pingBuddy2 that plugs into the Stratux. But my Stratux already does dual-band without the pingBuddy2 for less than $100. Yes, it uses more current, but it plugs into the aircraft power supply so big deal. ONLY $150! I'll buy avgas instead, thank you. Wake me up when they have ADS-B out for $200.

Posted by: MICHAEL MUETZEL | March 23, 2017 6:51 AM    Report this comment

I WAS WRONG and confused the pingBuddy2 with the pingEFB, so RETRACT my comment about its value. Still hoping for a $200 ADS-B out, though :)

Posted by: MICHAEL MUETZEL | March 23, 2017 7:32 AM    Report this comment

We usually see eye-to-eye on a lot of issues Paul, but we're miles apart on "abolishing TSOs."

The point of a Technical Standard Order (and a production approval subject to one) is to ensure that equipment meets a certain minimum standard - in the case of ADS-B Out equipment that includes the accuracy and robustness of the position source.
Equipment used on Experimental aircraft must still meet the performance criteria of the TSO (though not necessarily be produced subject to a production approval based on that TSO, which is where the savings typically comes in).

You can equip an experimental aircraft with Non-TSO'd equipment, however if that equipment fails to meet the performance requirements of the applicable TSO (say it's broadcasting your position miles away from where you actually are) the FAA can turn around and tell you to stop operating the non-compliant equipment.
By contrast when you equip a Part 23 airplane with a TSO'd system installed per the manufacturer's instructions you're assured that the device WILL meet the performance requirements specified in the applicable TSO. Of course you still have to continue meeting those requirements (through necessary maintenance), but the uncertainty of initial compliance is removed.

You and others are arguing against the TSO requirement, but respectfully you are fighting the wrong war: You should be working with the FAA to streamline the testing and approval process so it's faster and less expensive to obtain production approval subject to a TSO, not arguing against having minimum performance standards for critical systems.

Posted by: Michael Graziano | March 23, 2017 12:04 PM    Report this comment

Michael:

Even TSO'd ADS-B installations have to undergo a successful "Proof of Performance" demonstration. Thus, the PoP - not the TSO - is the applicable standard.

The Agency's policy of approving non-TSO'd equipment in installations that successfully demonstrate PoP - in experimentals and LSAs - while prohibiting use of non-TSO'd equipment in installations in certificated aircraft, defies sanity and inspires contempt.

THAT is the key issue in play here.

Posted by: Tom Yarsley | March 23, 2017 12:19 PM    Report this comment

Michael, I think the vast majority of private owners/operators of Part 23 aircraft would take "the uncertainty of initial compliance" eight days a week, in exchange for a 50-75% reduction in cost. Unfortunately, the option isn't available to them. Quite why you can do this in an experimental, but not a privately-owned certified plane not used for commercial purposes, doesn't come down to any *rational* reason, only "because the rules say so".


Unfortunately, this is the FAA we're dealing with. Like any bureaucracy, it's going to fight a last stand over every inch of ground when it comes to relinquishing any control or authority, no matter how irrelevant, outdated, or useless.

Posted by: Robert Gatlin-Martin | March 23, 2017 12:48 PM    Report this comment

Michael and Tom,

I know I'm repeating myself, but where "do the rules say so"? The Order 8300 definition: "Meet minimum TSO Established Standards. Means that the equipment need not have TSO approval, but that it meets requirements set by the TSO."

I wonder if part of the issue is that if a non TSO'd piece of equipment is installed then the installer is certifying that the equipment meets the TSO. I don't imagine there are many A&Ps willing to take on such liability.

Posted by: Evelyn Greene | March 23, 2017 2:13 PM    Report this comment

I'm with you, Yars. The recent STC approvals of NON-TSO'ed equipment by EAA using NORSEE(Dynon D10/D100) to replace either the AH or DG primary instruments are a perfect example for the discussion. Likewise, the Garmin G5. Unfortunately, in THAT case, the STC'ed G5 has been slightly DE-modified (and, of course, costs almost double that of the non-STC'ed unit) but -- still -- it's essentially a non-TSO'ed device being used to replace a CRITICAL instrument. But, even there, either the Dynon or the Garmin devices COULD be used for both functions but the "boys" won't let that happen. You have to buy TWO of 'em, one for each instrument replaced. Nutty!

Here's two more examples. For years, Icon has been bringing their VHF radios to airshows and 'saying' that they'll be TSO'ed soon. Well, now they have a TSO'ed version of their A220 com radio BUT ... it costs $400 more. Why ... those magic three letters. And, if the radio needs repair, it must go back to Icon per the TSO agreement. Garmin makes a fine radio in the form of its GTR200 but it isn't TSO'ed. It has features that it's TSO'ed similar version GTR225 does NOT have and costs less. The third commenter here, Robert G-M, hit's the problem squarely on the head.

ADS-B 'out' is a little bit of a different animal in that it must meet the PoP requirement after the installation via a 30 minute test flight. Seems to me that if ANY 'out' setup meets PoP (and that RV-12 would HAVE to do so), then it ought to be approved. We are all using the same airspace. If an RV-12 is squitting it's position info, it's either right ... or it ain't ... TSO or no TSO. If you all move back to the early days of ADS-B, EACH installation had to be individually inspected and approved...even if they were identical airplanes sitting side by side. NUTTY!

Posted by: Larry Stencel | March 23, 2017 2:49 PM    Report this comment

Evelyn,

I think the key might be 21.9, that more or less says you can't make a modification part for a certified airplane without it being approved by TSO, PMA, etc. So the ADS-B requirement says you have to meet the performance standard, but Part 21 says that, because it's going on a TC'ed airplane, it has to have a production approval.

And looking at it, I think that might be how Dynon got the D10 on an STC without a TSO... they got it defined as a "commercial part" per 21.1(b)(3), and included it on the STC as a required part.

Posted by: Robert Gatlin-Martin | March 23, 2017 2:59 PM    Report this comment

"For years, Icon has been bringing their VHF"

Icom not Icon.

Posted by: Paul Bertorelli | March 23, 2017 3:28 PM    Report this comment

We're hardly fighting the wrong war, Michael. We won the war, but the FAA is ignoring the verdict. It has agreed that any equipment that meets MOPS doesn't need a TSO. But manufacturers are complaining that the FAA isn't sticking to this policy and/or is adjudicating it inconsistently.

There was a time when TSOs made sense, because the government, airlines and GA were aiming for commonality of safety standards and certified equipment was thought to be part of that. It no longer is. The disconnect is that experimental fly in the same system without certified equipment that airplanes of the same speed and same size have to have.

There is no safety data to support this and there probably never was. GA continues to be regulated, to a degree, like the airlines. So we'll just have to agree to disagree. TSOs stifle competition and favor the companies capable of performing the testing.

Posted by: Paul Bertorelli | March 23, 2017 3:34 PM    Report this comment

Just as an aside, we heard from a company that makes a capable portable ADS-B In/Out. It works. I haven't seen performance data on it, but it sounds like an inexpensive solution.

But the FAA is digging in on it and won't approval a portable solution and/or it's insisting on the TSO, which the company says would cost a quarter million dollars to do. The FAA desperately wants equipage, but they're not getting it because companies are unwilling to go bankrupt to meet their unreasonable and unyielding rules.

Posted by: Paul Bertorelli | March 23, 2017 4:21 PM    Report this comment

Wow, commercial parts under ICAs! Sounds like Dynon figured out how to use the FARs in a manner not intended - but good for them. Here's hoping more join in.

I'd be interested in learning more about the MOPS verdict that Paul is referring to. Any sources?

Posted by: Evelyn Greene | March 23, 2017 4:27 PM    Report this comment

PB: Good catch. It was likely a typo that I missed. OR ... maybe it was a Freudian slip? ;-)

Evelyn ... you bring up a very salient albeit subtle question. A long time ago, there was a company in Grass Valley, CA who made KIT avionics that weren't TSO'ed. They had an excellent treatise in their sales brochures on this very subject. Likewise, a company in Oregon who currently builds a very nice and well priced com radio in a milled out piece of billet aluminum (read HD!) has a similarly excellent discussion of TSO'ed vs non-TSO'ed on their website. Rather than pasting it here, I think ya'll know who I'm talking about. Google it. VERY interesting discussion.

The short story is that a TSO is ONE way to determine that a specific piece of equipment meets a standard but is not the only way. They FAA Order 8900.1 (which replaced Order 8300 that you referenced). They say that it IS up to the installer. It gets very complicated fast but ... if an A&P or IA feels it's OK and is willing to sign the installation off, then it's OK. There are some other requirements in FAR Part 23 but they're actually pretty straight forward with no issues.

Robert G-M ... you're aren't quite right. In FAR 21.9 a(5), it is permissible for the owner or operator of an aircraft to produce a 'one off' part for that specific airplane. He can't sell it to others, however. "Produce" has a long and specific meaning to the FAA ... too long to describe here other than to say that it requires owner/operator involvement in the specifying, design, building or other parts of the process. As an A&P myself, I can't build a replacement part for my own C172 but if I take my A&P cap off and put on my 'owner/operator' cap and take part in the design or build process, it becomes legal for me to then install that part when I put my A&P cap. And, I intend on doing just that on my own airplane. If I wanted to sell it to others, I'd have to get a PMA, STC, AML and OU812.

Posted by: Larry Stencel | March 23, 2017 4:32 PM    Report this comment

I get the "owner-produced" language for things like replacement brackets, skins, etc. But almost nobody is going to be designing or building their own ADS-B equipment, EFIS, com radio, etc. So that portion doesn't apply to purchased avionics, which was the subject of the discussion here.

Posted by: Robert Gatlin-Martin | March 23, 2017 5:31 PM    Report this comment

I would submit that the very existence of the Stratux project disputes that assertion, RG-M. What's the essential difference between fabricating a bracket on a CNC mill (or having someone do it for you) and fabricating a GPS antenna? Or, making another call-back to RST, what's the difference between fabricating a marker beacon receiver and a ADS-B or comm receiver using SDRs?

The maker-space is full of 3D printable parts, and the FOSS-space is a glut of software. And we've been building electronics since Heathkit. All we need is someone to design a workable ADS-B/out transmitter that meets the PoP, publish a parts list and a circuit diagram, and we're off to the races. It would probably even qualify under the 51% "rule"...

Posted by: Chip Davis | March 23, 2017 7:47 PM    Report this comment

You need to take Mike Busch's EAA / AMT course on the subject, Robert. Also, read the Val Avionics treatise on the subject, as well.

As an aside, I just received a new product announcement from Dynon for a new ADS-B 'in' box, SV-ADSB-472. Guess what's inside of it ... uAvionix. I think that's going to be a Company to watch.

Posted by: Larry Stencel | March 23, 2017 8:25 PM    Report this comment

Val's explanation of installing non-TSO equipment doesn't apply to ADS-B installations. More specifically, Notice 8900.362 is what's tripping it up.

The notice requires that the first pairing of a particular GPS and ADS-B out system be approved on a TC, amended TC, or STC. Once that pairing is approved, then the Notice allows subsequent installation of those items on "other aircraft without further data approval" provided they meet certain other requirements... the first two of which specifically state that the equipment must be *manufactured* under the applicable TSO, not just "meet the performance requirements of".

By my reading of this, it means a couple things. First, it does appear to be possible that one could install non-TSO ADS-B equipment on certified airplanes, *but* every installation of such would have to be accomplished via STC (or incorporated in the TC) specifically for that aircraft and specific to that equipment. There is some precedent for this with the D10 and G5 approvals, and an AML STC may well be possible, but you couldn't just do it with a 337.

Second, Val's TSO pamphlet doesn't apply because the Administrator has "issued policy... that requires the use of approved data for this installation/alteration" (that is, N8900.362). Again, you either have to have a specific TC/STC approved for the installation, or you have to use true TSO'ed equipment.

Posted by: Robert Gatlin-Martin | March 24, 2017 6:06 AM    Report this comment

No worries, I heard Wal-Mart is working on releasing some ADS-B products for us all.

Posted by: Joe Braddock | March 24, 2017 7:05 AM    Report this comment

Some years back, FAA Flight Standards and ATO made a big deal about the new NAS being "performance based". If the performance based concept were applied to ADS-B, then you could easily show that the MOPS requirements that drive the TSO should be different for different classes of airplanes. One example, the TSO requires a performance level suitable for airplanes converging at an 875kt closure rate. My 90 knot antique airplane doesn't need to perform to that level, because it will never see Flight Levels. However, the performance of my airplane is in line with a lot of homebuilts - so why shouldn't I be able to equip with the same lower cost option as the experimental crowd? And for that matter, a slow airplane like mine, that doesn't use Class B airspace, but lives within a mode C veil, doesn't need a TSOd WAAS position source for an ADS-B to perform to the required standard.

Posted by: MICHAEL WERNER | March 24, 2017 11:05 AM    Report this comment

Fair question, Michael ... the answer requires common sense and we're running short of it, just now. And here's a follow-on ...

I just read that the FAA is predicting 3.6 million hobby drones will be in use by 2021. They're predicting 442,000 commercial drones if BVLOS and night flight isn't lifted; 1.6 million if it is.

Sooner or later, as Paul opines -- at least for the commercial drones -- the FAA will HAVE to mandate use of ADS-B for them. SO ... will TSO'ed equipment be required there, too? Hmmm

And here's another question. If you run out of some household product and push your associated Amazon 'Dash' button, a drone may ultimately bring it to your front door. So what happens if you live under the Class B airspace for one of the 37 airports; how about the Mode C veil. Boy ... the possibilities are mind boggling. :-)

I think the new Dynon box with uAvionix inside that I learned about last PM must be the box they told Paul about. The 472 replaces the 470 and is $200 cheaper, list. Maybe the $1K portable ADS-B IS a possibility? Just remember ... "Wait and Avoid"

Posted by: Larry Stencel | March 24, 2017 1:40 PM    Report this comment

Here's a reasonable suggestion. If you want pilots to embrace ADS-B Out, allow for portable ADS-B Out devices, at least for VFR. Pilots love portable. We gobble up headsets, GPSs, weather receivers, transceivers, traffic detectors, iPads, and of course ADS-B In devices. Portable ADS-B Out could keep the cost down and utilization up not just for our planes, but for all types of aircraft, including gliders, antiques, lighter-than-air, ultralight and drones. Keep it simple, FAA.

Posted by: R Dant | March 24, 2017 3:33 PM    Report this comment

FAA should be embracing portable ADS-B Out devices for another big reason--all of those gliders and non-electric airplanes out there will become "invisible" to the next gen equipment--and they number in the tens of thousands.

FAA got into full panic mode when people refused to equip their airplanes for the same reason--no incentive to do so--enough so that they offered the $500 bribe to equip. They were afraid of all of those "invisible" airplanes NOT showing up on their equipment. It seems that even with the bribe, owners are saying "no thanks."

As evidenced by the bribe program, bureaucrats are afraid of failed programs. The spectre of all of these "invisible" airplanes OUGHT to make them concerned for the viability of the program--and their jobs.

Consider this--the FAA could have ordered a $500 ADS-B out system for every one of the $160,000 GA airplanes out there and GIVEN it to them for less than the cost of time and money of this failed program. This mandate is to accommodate the government next gen program. If the government wants it, and it will save all of the money they SAY it will save, let them pay for it.

Posted by: jim hanson | March 25, 2017 3:53 PM    Report this comment

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