So looking at the
official guidance, it looks like our customers should be OK if they meet the requirements on timing/equipment installation/etc. On the eligible equipment part, note the bolded (by us) sections:
Eligible Equipment is defined as avionics that constitute a TSO-certified Version 2 ADS-B Out system,
purchased on or after the program announcement date.
Such equipment must have a TSO marking for
TSO-C154c, or TSO-C166b, or both. Eligible ADS-B Out system equipment may have an embedded
position source compliant with one of the following TSOs: TSO-C-145c (or subsequent versions), TSOC146c
(or subsequent versions), or may be connected to a separate position source compliant with TSOC-145c
(or subsequent versions) or TSO-C146c (or subsequent versions). Any separate position source
must comply with the guidance published in FAA Advisory Circular 20-165B.
ADS-B In/Out systems
compliant with TSO-C154c, TSO-C166b, or both, are also eligible.
Our transponder, which is made in partnership with Trig, is TSO-C166b, and is labeled as such (first bolded clause). Rebate applicants should probably use the Trig part numbers in their applications. The SV-GPS-2020 position source meets the performance requirements of TSO-C166b, and so it should be eligible too (second bolded clause).
As for the part about the AC. The AC's audience - per the AC itself - is "1.2 Audience. This AC is for anyone who is applying for an initial type certificate (TC), supplemental type certificate (STC), amended TC, or amended STC for the installation and continued airworthiness of ADS-B OUT equipment." In other words, it's for type certificated aircraft installations and the AC isn't applicable for non-type certificated aircraft installations.
The AC also says the following about experimental aircraft:
"3.1.2.1.2 For installations in aircraft with more complex system architectures, a
system safety assessment, as described below, is required to set the SDA.
Installations of uncertified ADS-B systems must set SDA = 0 with the
following exception: experimental category aircraft, including
experimental light-sport aircraft (E-LSA) (Part 91 aircraft), may install
unapproved equipment and set the SDA in accordance with the equipment
manufacturer’s installation manual, provided the equipment has a
statement of compliance to the performance requirements of § 91.227),
from the equipment manufacturer(s).
All that said, as we learn more we'll let you know.