ADS-B FOR LSA

[dnhill]

http://macsblog.com/2014/12/can-you-install-ads-b-now-maybe-not/

So, I thought we had a somewhat of a path to full ADS-B compliance.  The above article seems to show the path is more problematic.  Thoughts?

 

[dynonsupport]

LSA is a problem since you can't add things to the plane without the manufacturer's approval. In that way, Mac is right. The FAA is going to need to change some rules to allow LSA owners to install ADS-B on LSA aircraft that don't have manufacturer approval.

For experimentals, I wish he had called us or the FAA before writing that. The FAA is clear that they will allow any combination of equipment that has been STC'd to be installed on experimental aircraft, and we're working to have specific documentation written to directly state that Dynon equipment meets the ADS-B mandate.

 

[DHeal]

Aren't you using the term "LSA" a bit too broadly in this context? It is my understanding that S-LSAs have to have the aircraft manufacturer's approval; however, E-LSAs are treated the same as EABs in this regard.

 

[dynonsupport]

Fair enough.

S-LSA has an issue.

All E-AB aircraft, LSA or otherwise are fine.

 

[thibault]

Dynon,

I do not agree with Mac's conclusion about EAB, but can you respond point-by-point to what he said about the difficulty of installing ADS-B out in EAB and being completely legal in 2020?

Thanks

 

[lolachampcar]

"Some builders are installing ADS-B equipment that is potentially certifiable and believe they have met the rule. But they haven’t. The rule requires flight manual supplements, operating restrictions, a performance test and other approved paperwork and there is no way for a builder to get there."

I've brought these issues up before when the idea of adding a certified GPS source to the Dynon/Trig avionics to make a 2020 compliant system has been discussed.  Looking at it from the FAA's standpoint, 100% proper and correct TSO'd equipment was installed in helicopters in the Gulf yet the system failed.  The solution was an antenna to antenna certification element.  Put differently, make sure the system from receiving GPS signals to transmitting ADSB-Out packets performs as required as installed exactly in any particular airframe.  This is accomplished by STC or a field approval based on an STC for certified aircraft.

I tried to use the available documentation and existing STCs to place the Skyview system in a certified motor glider and failed (for lack of supporting documentation).  Ok, that is certified so why should anyone here care?  The answer is simple.

I believe the FAA's concerns are valid in that the system must work "antenna to antenna" to be of value irrespective of the aircraft the equipment is installed in.  Given that, it is not unreasonable for the FAA to require a little something more than a statement that "all our parts meet TSO" and we are experimental so leave us alone.

I would prefer that more time was spent on addressing valid concerns and less spent on pointing fingers as to who is responsible or why things can not be done.

...... and no, I do not agree that all EAB are fine. That simply does not pass even the most basic sniff test.

 

[swatson999]

Might I suggest that you not start your argument by quoting from a blog which contains patently false information? "The rule requires flight manual supplements, operating restrictions, a performance test and other approved paperwork..."

Really? Show me the rule that says that, please.

 

[lolachampcar]

That is a valid point. The few STCs I have reviewed as a basis for a field approval had those elements so perhaps the original author should have made the distinction that meeting the requirements entailed generating those items.

Similarly, I do not agree that EAB builders are incapable of generating that type of documentation or properly testing their installations provided the FAA has an open dialog which supports builder's efforts.

The above issues are real but they are nits and pale in comparison to the real issue and that is that there is no viable common sense method for EAB owners to generate 2020 compliant ADSB-Out systems. I'm happy to concede all the small points if progress can be made on the one that counts.

 

[swatson999]

... there is no viable common sense method for EAB owners to generate 2020 compliant ADSB-Out systems.

How do you figure? Dynon has *told* you what is required and how to do it with their system: use their XPDR in a SV system, connect a serial line from a certified WAAS-GPS (like a 430W or what have you from Garmin), configure the system in menus appropriately, do the usual static/XPDR tests and get the performance report from the FAA after a flight.

What part of this are you missing? The XPDR meets all appropriate TSOs, the GPS meets all appropriate TSOs, the ADS-B out portion of the system is sending all the required data with the required latencies, etc. How is this not a "viable common-sense method" to comply with the FARs?

 

[swatson999]

That is a valid point.  The few STCs I have reviewed as a basis for a field approval had those elements so perhaps the original author should have made the distinction that meeting the requirements entailed generating those items.

Similarly, I do not agree that EAB builders are incapable of generating that type of documentation or properly testing their installations provided the FAA has an open dialog which supports builder's efforts.

Once again...please show me the FAR which requires, for EABs, such things as a "flight manual supplement", "operating limitations", and so be generated.

Most EABs don't even HAVE a POH or Flight Manual.

I don't care what Mr. Ride-Around-In-Learjets-and-Write-Articles McClellan *thinks* is required. I want you to show me the *actual* requirements.

Near as I can tell, those are FAR 91.225, 91.227 and the TSOs. Period.

 

[lolachampcar]

Steve W.
I understand what I have said can be viewed as challenging Dynon to some degree and that doing so will bring the wrath of those that want to jump to their defense.  I'm ok with that so have at me.

My goal is to generate conversation about addressing valid concerns regarding installing compliant 2020 ADSB-Out installations.  I tested the waters regarding Trig/Dynon/Freeflight and could not generate sufficient acceptable data to request a field approval for my glider.  That is ok as I knew it was a long shot before I even started.

We are not yet to 2020 but I think it is perfectly reasonable to question that an installation that is insufficiently documented today to achieve a field approval will somehow be acceptable tomorrow.  Further, if attempting to use a combination based mostly on an existing STC is unacceptable, I think it would be doubly so for equipment that can not be linked to a proven installation.

I've made my bed (Skyview with GPS puck) and am enjoying the benefits of ADSB In and Out.  When the FAA addresses ADSB-Out and 2020 compliance for something other than certified aircraft with installations based on STCs or field approvals using an existing STC, I will revisit the issue and do what is necessary to be a safe contributing member of our community.

Until then, I'll continue to point out that sticking heads in the sand expecting the FAA to give Experimental aircraft a pass is simply not in keeping with the NexGen concept.

 

[GalinHdz]

Until then, I'll continue to point out that sticking heads in the sand expecting the FAA to give Experimental aircraft a pass is simply not in keeping with the NexGen concept.

Except that your statements are completely opposite than what the FAA's has been saying on this issue, most recently by David Hughes (FAA NEXTGEN Performance and Outreach) in the June 2014 issue of Avionics News Magazine. The article even specifically covers ADS-B installations for EAB on Page #7. Just like transponders, GPS Navigators, VOR receivers, etc, EAB does not need, and has never needed a "pass" on these kind of installations.

http://www.faa.gov/nextgen/ga/media/AEA-ADS-B Installation.pdf

 

[swatson999]

Please. Stop with the "challenging to Dynon" or "bringing the wrath of those who want to jump to the their defense" nonsense.

If your goal is to generate discussion on *valid* concerns, then you should state them and the reason they're valid. For example, you seem to think there's some regulation requiring "paperwork", like Field Approvals or the existence of some STC or another which must be satisfied before an E-AB can install an ADS-B solution. It's been explained to you numerous times why such a thing is not needed.

It's been explained to you several times how equipment which meets the TSOs can be installed and fully meet the FARs, even in the absence of STCs, on an E-AB. Perhaps a review of how we put transponders and IFR GPS Navigators into our planes would be a good thing for you.

It hardly seems that anyone at Dynon (or any other manufacturer of avionics for experimentals, really) is "sticking their heads in the sand". They're clearly working with the FAA to make sure their devices meet the appropriate TSOs, and can meet the FARs when installed.

The original post was about a blog which contained incorrect information. You jumped in with documentation requirements which do not exist, and extended it to some mythical "antenna to antenna" certification "requirement".

I'm beginning to suspect that you are tossing out these ideas for more nefarious purposes than just your own skepticism...

 

[lolachampcar]

Let's try a different approach......

The document GalinHdz linked to is very informative (thank you).  One portion states-

Non-TSO ADS-B Out avionics may be installed on amateur-built and light sport aircraft with experimen- tal airworthiness certificates. In such installations, the ADS-B Out system must be configured to transmit
a system integrity level and system design assur- ance of zero (SIL/SDA=0). The SIL/SDA=0 settings prevent ADS-B data of unknown quality and integrity from being processed by ATC automation and other ADS-B equipped aircraft but allow for the avionics to receive FAA traffic and weather broadcast services:

This is not in keeping with my memory of the regs were certain position integrity standards were required.  Put differently, I do not think you can transmit SIL/SDA=0 in a 2020 mandate compliant system and yet this is exactly what the above statement says you can do.  Perhaps Mr. Hughes was speaking to EAB aircraft currently installing ADSB-Out prior to having to comply with the 2020 mandate as this is exactly how my Skyview system is configured.

It has been a while since I looked at it but I believe the required accuracy is defined in-
§ 91.227 Automatic Dependent Surveillance-Broadcast (ADS-B) Out equipment performance requirements.

Specifically-
(c) ADS-B Out Performance Requirements for NAC P, NAC V , NIC, SDA, and SIL—
(1) For aircraft broadcasting ADS-B Out as required under § 91.225 (a) and (b)—
(i) The aircraft's NACP must be less than 0.05 nautical miles;
(ii) The aircraft's NACV must be less than 10 meters per second;
(iii) The aircraft's NIC must be less than 0.2 nautical miles;
(iv) The aircraft's SDA must be 2; and
(v) The aircraft's SIL must be 3.
(2) Changes in NACP, NACV, SDA, and SIL must be broadcast within 10 seconds.
(3) Changes in NIC must be broadcast within 12 seconds.


So now I am confused.  Mr. Hughes tells us we can install any equipment and just set the integrity levels to untrustworthy while the governing regs state a performance requirement.

Senior member Steve,
Please be constructive.  My skin is far too thick for you to waste your time with personal barbs.

 

[GalinHdz]

So now I am confused.  Mr. Hughes tells us we can install any equipment and just set the integrity levels to untrustworthy while the governing regs state a performance requirement.

No he states that for uncertified (non-TSO) equipment (which can be permanently installed in an EAB aircraft) the integrity level must be as shown if it does not meet the performance standard. This applies to the Skyview transponder with the Skyview GPS puck or even a Garmin GTX 330ES connected to a Garmin 430W without the latest software updates. The manufacturer provides the method of setting the parameters. This section doesn't apply to certified equipment. The paragraph before covers equipment installed in an aircraft with a "Standard" Airworthiness Certificate. It has nothing to do with the parameter settings or certification, just the installation.

Aircraft with a "standard" type certificate require certified equipment and a supplement to the type certificate (STC) authorizing the installation. Since EAB do not require, or have, a Type Certificate the supplement requirement to the certificate does not apply. Just like transponders, GPS Navigators, VOR receivers etc. The FAA isn't re-inventing the wheel when it comes to ADS-B installations.

So if you install a certified ADS-B out unit in an EAB (Skyview transponder directly connected to a certified position source) you are 2020 compliant.

 

[GalinHdz]

Non-TSO ADS-B Out avionics may be installed on amateur-built and light sport aircraft with experimen- tal airworthiness certificates. In such installations, the ADS-B Out system must be configured to transmit
a system integrity level and system design assur- ance of zero (SIL/SDA=0). The SIL/SDA=0 settings prevent ADS-B data of unknown quality and integrity from being processed by ATC automation and other ADS-B equipped aircraft but allow for the avionics to receive FAA traffic and weather broadcast services:

This is not in keeping with my memory of the regs were certain position integrity standards were required.  Put differently, I do not think you can transmit SIL/SDA=0 in a 2020 mandate compliant system and yet this is exactly what the above statement says you can do.  Perhaps Mr. Hughes was speaking to EAB aircraft currently installing ADSB-Out prior to having to comply with the 2020 mandate as this is exactly how my Skyview system is configured.

No, he was talking about the configuration of Non-TSO ADS-B OUT equipment (authorized in an EAB) prior to the 2020 mandate. It has nothing to do with the installation, which is a separate issue.

There are some ADS-B OUT equipment being sold that do not meet the integrity requirements. You can use them in an EAB, and only in an EAB, up to 2020 when they become illegal. You can't permanently install any non-TSO's equipment in a certified aircraft no matter what some manufacturers claim. And you can't use a "portable" ADS-B OUT equipment in any aircraft.

 

[lolachampcar]

Ok, so the piece referenced was addressing what we Skyview users are doing today which is using non-TSO'd equipment in Experimental aircraft. You mention that this is only legal till 2020. Is there some follow up reference were I can read up on this element?

With respect to Certified, my comments were directed towards conversations with the FAA about using equipment that "meets TSO" to provide pressure information for air/ground determination. I never got to the point of having that conversation because no documentation was provided proving the equipment met TSO. However, the whole gist of the conversation deals with Exp and the ADSB-Out mandate.

 

[swatson999]

I AM being constructive. Over and over and over and over people explain this to you, and you just don't get it. Dynon has told you. The FAA has written about it. Posters here have explained it, numerous times. That's fine, you're free to go about your own life misunderstanding the regulations and making up your own requirements to impose on yourself.

But you're posting them here for others to read, and much of what you're saying is either confused or flatly untrue, which misleads *others*. Much like Mr. McClellan.

I'm not being personal here...I honestly am starting to think that you have some ulterior motive for continually claiming requirements which don't exist, and exhorting others about the legality of installations in E-AB aircraft.

As stated immediately above...yes, you CAN use a non-TSOd or non-WAAS GPS position source in an ADS-B OUT system, today. Period. You *can't* after January 1, 2020, which is *precisely* what the regulations (FARs) state: "As of January 1, 2020...no person may...unless...blah blah blah".

You are correct that after January 1, 2020, you can't broadcast SIL=0 data; until then, though, you can.

Seems pretty simple to me (and apparently, most everyone else).

Now...what about those "rules" requiring all that paperwork? Or have we accepted the fact that no STC or Field Approval is required for an E-AB installation?

 

[swatson999]

Ok, so the piece referenced was addressing what we Skyview users are doing today which is using non-TSO'd equipment in Experimental aircraft.  You mention that this is only legal till 2020.  Is there some follow up reference were I can read up on this element?

FAR 91.225 and 91.227

As we've probably said at least a dozen times in various threads.

Notice carefully how it opens with the phrase "After January 1, 2020...". That means that until January 1, 2020, there IS no regulation which applies or restricts what data integrity levels are output (e.g., SIL=0). None. Nada.

 

[GalinHdz]

With respect to Certified, my comments were directed towards conversations with the FAA about using equipment that "meets TSO" to provide pressure information for air/ground determination.  I never got to the point of having that conversation because no documentation was provided proving the equipment met TSO.

It is covered in this document, section 3-10(b):

http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC 20-165.pdf

It specifically states: "Installations that provide a means to automatically determine air-ground status based on inputs from other aircraft sensors are acceptable if they are demonstrated to accurately detect the status. These algorithms should be tested and validated during the installation approval".

You can also see options to determining air-ground status in this document on pages 11 and 29:

https://www.aea.net/Training/courses/ADSBForum/pdf/AEA ADS-B Installation Guidance.pdf

Note that there is no requirement for a squat switch, pressure information or any other device, TSO'd or not, to determine air-ground status. Nowhere in any FAA document will you see a TSO requirement for determining air-ground status. It doesn't exist. DYNON has stated on multiple threads that they have tested, validated and documented that the algorithm they use is accurate. This fulfills the air-ground status requirement.