FAA DAR approval - Dynon EFIS in Experimental a/c

[gmcjetpilot]

There seems to be an ATTACK on "experimental" EFIS used in amateur built/kit plane/ experimentals by the FAA. What is UP?

I am sure this has been touched on before, but time and again I read of individuals, who are trying to get FAA or DAR inspector approval of their amateur built kit plane, getting denied by the Fed or designate inspector. The Fed/inspector balks at the Dynon (or other brand) EFIS, claiming it does not meet Regs. I know they are wrong, but HOW can we put this controversy and recurring hassle to bed, once and for all.

What are the definitive regs and precedence that allows the Dynon to be used as (either VFR or IFR):

Encoder (not TSO-88)
Airspeed
Altimeter (not TSO-10b)
Heading / Directional Gyro (DG)
Attitude Gyro (AI)
Compass

I have been through many of these FAA/Builder battles vicariously  from others post on the Web. I have done some research myself. The compass I'm sure is OK because the Dynon compass is a compass. Part 23 makes reference to non-electrical compass. Part 23 definitively does not apply to experimentals. However many builder when confronted just back down and buy another "jelly jar" passive compass to hang up for the Fed's amusement.

The latest FIGHT I just read of, is a shop refused to do an inital 24/mo - Pitot / Static (altimeter/encoder) test on a new, yet flown, homebuilt with a Dynon EFIS. The FAA guy was in the shop at the time and said NO, you must have a TSO'ed Altimeter & Encoder. I know this is not true, but would love to have information to make mine and other's future "certification" go easy, just in case.

As far as AI and DG, I will certify VFR. They are not even required, so they can't complain about that. However IFR? I just renewed my CFI and casually mentioned this to the inspector as a what if, does the EFIS need to be certified like a Garmin 1000, Avydine  or Chelton in an experimental. He said NO non-TSO'ed EFIS's are approved for use in ANY PLANE VFR or IFR, including experimentals. I smiled and took my temp CFI ticket. (I was shocked he had a strong opinion at all, much less an opinion of 'no way in hell'.)

Never heard of a beef with a Dynon *airspeed indicator*, but now there seems to be a "wave" of opinion from individual FAA inspectors & DAR's that a Dynon is not suitable for a stand alone ANYTHING! Ouch. We have to stop that cancer of ignorance. Once you say it enough, it becomes policy. Many builders would rather comply than fight. I understand giving in to get through it, but each time a builder does this, it's a precedence which encourages them to make their opinion law, which it is not..

How can the FAA be so inconsistent. PLEASE no FAA bashing or ad hominem just for fun; it won't help.

If you had a FAA fight and won, tell us how you did it.

Lets get the ammunition of facts in-line. At least WE can be consistent. I know some FSDO's are in the know and others have "issues".

If a FSDO approves 100 Dynons and another balks, there is an issue. A policy paper by the FAA head chief would be a nice document to have. Is there such a holy grail out there, to cut through all the horse-hooey.

It's like ground hog day; these issues keep coming up over and over. It's like a weed, you cut it down and than it grows again. The communication with in the FAA is worse than I thought. I was thinking it was getting better but apparently not. The WORD on the street is the FAA is going to be privatized like all the other services. It seems to be the trend with a certain party. They are worried about their jobs. The only Fed FAA will be in charge of airliner manufacturing and airlines. Services we use will be a FEE based service, everything. I can see an initial inspection costing a grand or two, and each flight $10 or $20 in fees. Yippee? :'(

 

[gmcjetpilot]

Re: FAA DAR approval - Dynon EFIS in Experimental

I did some research and found some opinions which answers my question, kind of?

I got this info off of BMA's site. Sadly I recall now, the FAR's are not totally black and white on this topic, but I'm still convinced "Experimental" is a broad approval to do many things not allowed on certified planes. The logic and facts that support it are below.


Great thread on BMA. Check out page 2 and even better
info / comments on page 3, which are most relevant.


http://tinyurl.com/2au2pe

Paper on legality of experimental EFIS (encoder,
altimeter, GPS, aka none TSO) in experimentals.


http://tinyurl.com/2fbloa

Bottom line is the pitot/static test is not an approval
of the equip. As the builder you state it meets the
TSO.

Some manufactures like GRT say their
encoder meets the TSO.

DOES Dynon say their encoder meets the TSO-88 spec?

 

[gmcjetpilot]

Re: FAA DAR approval - Dynon EFIS in Experimental

BUMP

No one is having FAA issues or Designee issues or Avionics shop issues when getting their Dynon encoder connected to their transponder and the 24/mo altimeter/encoder/transponder/pitot/static test???

NO ONE? Some are being turned down. :'(

 

[PhantomPholly]

Re: FAA DAR approval - Dynon EFIS in Experimental

Some just don't ask.

 

[N941WR]

Re: FAA DAR approval - Dynon EFIS in Experimental

George,

I had my EFIS D100 w/ EMS D10 VFR panel approved by the Charlotte FISDO w/o any problems. I did stick a temporary compass on the top of the glair shield just to make sure I would have no issues and he didn't even look at it. In fact, he didn't even have me power up the panel.

DAR's seem to make up their own rules, from what I have read.

It really sounds like it is based on the luck of the draw.

Are you getting close?

Best of luck,
Bill

 

[gmcjetpilot]

Re: FAA DAR approval - Dynon EFIS in Experimental

Thanks Bill I am dealing with the Greensboro FSDO and they seem reasonable. Not too close yet but when I went in for my CFI renewal I casually asked the pilot inspector doing my CFI renewl about EFIS. He said if it was not a Garmin, Chelton, Avidyne, Honeywell.......(ie cert unit) it was not legal even in an experimental, even VFR! This was not even the encoder issue. He just said you can't use them! I smiled and left with my temp CFI renewal.

The FAA guy I assume was more pilot inspector than maintence / inspector. Like you said, luck of the draw. My previous CFI renewal, two years earlier at the same FSDO, I talked to a Maintenance/Inspection guy. He was totally cool. Every time I asked, can I do this?, can I use this?, is this OK for my RV-7?, he said yes yes yes, no problem. G

With that said the last EAA mag last month talked about the Feds wanting to change experimental rules. The rules have been around since what the 50's. In that time things have changed, we have turbine-pressurized 4 place kit planes with all glass panels. No one figured on 20,000 experimentals, 5,000 RV's alone back than. Now the law makers in DC hear, "Home made planes that don't meet any safety rules flying all over." Van wrote an article in the EAA mag. He is on the advisory board to the FAA. Now its in the FAA hands. The HOT issue is commercial assistance in building planes, which people abuse to make planes to sell them for profit, not the intent of the amateur built category.

Like everything a few ruin it for everyone. The idea of the Gov getting involved scares me. I have been a EAA member and builder since 1986. It's possible QB kits might be affected but may be retroactively?

As far as avionics that could be up in the air (pun intended). Clearly there is a wide birth in interpretation of rules. If the Feds get more authoritarian, it could signal the FAA inspectors/ DAR's to be more conservative and restrictive, may just for self preservation. Many do mix certified rules with experimental. They just don't get it, we don't have to meet any of the Regs that apply to type cert planes, with a few exceptions. We can have experimental engines, airframes, props and AVIONICS! However when it interacts with "The System" there might be some gray area. However digital encoding is NOT critical. The chance of it failing in some dangerous way is unlikely and no more than any certified unit.

 

[jim]

Re: FAA DAR approval - Dynon EFIS in Experimental

Lots of S-LSA manufacturers are putting Dynon EFIS D100's as sole equipment in their panels. And these are Certified (Standard category) LSA, not experimental. Flight Design CT, Van's RV12, Zodiak XL, etc.

I wonder if they are using a blind encoder or using the D100 for input to the transponder?

 

[Mel]

Re: FAA DAR approval - Dynon EFIS in Experimental

S-LSAs are NOT "standard category"! They are "Light-Sport Category". They are issued an 8130-7, Special Airworthiness Certificate. They are NOT required to meet part 23 rules. I've certified 100s of them. Many with Dynons.

 

[GalinHdz]

Re: FAA DAR approval - Dynon EFIS in Experimental

I am looking into a DYNON package but had concerns about the "TSO" situation. Being a member of EAA, I checked with them and found the following:
---------------------
“TSO’ed” means that the unit was built under a Technical Standards Order authorization according to Section 21.601(b)(2). This says: “A TSO authorization is an FAA design and production approval issued to the manufacturer of an article which has been found to meet a specific TSO”. This is a DESIGN and MANUFACTURE specifications not an installation or operation requirement.

Home built Operating Limitations should state that the aircraft must be equipped in accordance with 91.205. This lists the minimum equipment required, but nowhere does it require TSO’ed equipment. This means that the instruments and equipment installed in a homebuilt under the requirements of 91.205 do NOT have to be “TSO’ed”.

Transponders and Altitude encoders are a little different. FAR 91.215 says:

(a) All airspace: U.S.-registered civil aircraft. For operations not conducted under part 121 or 135 of this chapter, ATC transponder equipment installed must meet the performance and environmental requirements of any class of TSO-C74b (Mode A) or any class of TSO-C74c (Mode A with altitude reporting capability) as appropriate, or the appropriate class of TSO-C112 (Mode S).

So, transponder equipment is required to meet "performance and environmental requirements" of the applicable TSO, but does not have to be built under a TSO authorization. This means that you can build your own transponder IF you can prove it meets the applicable TSO. Here it is best to buy and install a transponder built under a TSO authorization instead of trying to get your home built transponder approved for use by the FAA.

Altitude reporting equipment associated with the transponder must meet 91.217(c). This states: the altimeters and digitizers must meet the standards of TSO-C10b and TSO-C88, respectively. TSO-C10b applies to the sensitive altimeter itself, while TSO-C88 applies to the automatic altitude reporting equipment. Again it has to meet TSO standards, but doesn’t have to be built under a TSO authorization. Once again, it is best to buy and install equipment already built under a TSO authorization.
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I hope this helps those who are interested in "Experimental" EFIS used in homebuilt aircraft when they have to deal with an FAA Inspector. I know researching this sure taught me a lot.

 

[gmcjetpilot]

Re: FAA DAR approval - Dynon EFIS in Experimental

Again it has to meet TSO standards, but doesn’t have to be built under a TSO authorization. Once again, it is best to buy and install equipment already built under a TSO authorization.
----------------
I hope this helps those who are interested in "Experimental" EFIS used in homebuilt aircraft when they have to deal with an FAA Inspector. I know researching this sure taught me a lot.

Yea I follow you and your opinion is just get the TSO'ed transponder and encoder. You also say TSO is not required but meeting the spec if, which I agree with. Also the easiest way to know this is just buy a TSO'ed unit, other wise you have to prove you meet the TSO. Fair enough. However there is a "loop hole" that I would put forward, that does NOT take away from you comments and opinion.

Lets forget the Transponder, because that is not the topic (its relevant but not the topic). There are not experimental Transponders and they are way more complicated than an altitude encoder.

ONE)
Does the TEST where the encoder is checked against pressure v altitude reported show it meets the specs. I say yes. The avionics shop pulls a calibrated vacumn on the static and with test equip receives what altitude is being transmitted by the transponder.  That shows it meets the standards. What about environment test and TSO standards? See THREE.

TWO)
The loop holes in 91.217 par (b) last word is "OR".  What that means is only par (b) needs to be met, which is just testing and calibration:

(b) Unless, as installed, that equipment was tested and calibrated to transmit altitude data corresponding within 125 feet (on a 95 percent probability basis) of the indicated or calibrated datum of the altimeter normally used to maintain flight altitude, with that altimeter referenced to 29.92 inches of mercury for altitudes from sea level to the maximum operating altitude of the aircraft; or

When we do the transponder check, it it passes it's good (in my opinion).


THREE)
Par (c) says "equipment meet the standards..." (of the TSO). Usually when you see this in other parts of the FAR's, it says meets the standards and environmental specs. They left out the environmental part. So the standard is it reports accurate altitude (per Par 'b' above).

The Dynon encoder is SPOT ON at ALL altitudes. Also for safety it displays you altitude on the EFIS, so you can see if its off.

So based on the "OR" clause (b) or (c) but not both AND also the omission of the word "environmental" (standard) in par (c), there is an out, albeit parsing the words like a lawyer.

Not withstanding the loop holes, I agree if it gets ugly just buy a cheap ACK encoder for about $2 bills and be done with it.

THE KEY is to get that transponder encoder check done and signed off. The DAR or FAA comes in should have no need to question it. This issue came up when a guy with a RV and Dynon was refused to even be tested by an avionics shop. Conincidently the FAA was there inspecting the shop. I guess in another case a radio Tech refused to even connect the Dynon to the transponder. Lesson, connect it and sign it off yourself.

Thanks for all the replys. Also about the S-LSA's. I was going to call some and ask what they do. Dynon has no control over that. I don't want to rock the boat. MAY BE BETTER LEFT UN ASKED. If you don't want the answer don't ask. let sleeping dogs lay.......