FAA rule change on ADSB

[rfinch]

Probably too early for Dynon to comment, but unofficially, what do you think of this FAA rule change for ADSB?

https://www.federalregister.gov/art...rformance-requirements-to-support-air-traffic

In particular this:

As the ADS-B Out rule is a performance-based rule, it was not the FAA's intent to arguably limit operators to only install equipment marked with a TSO in accordance with 14 CFR part 21, subpart O. The FAA's intent was to permit equipment that meets the performance requirements set forth in the referenced TSOs.

 

[dynonsupport]

To us, it's a clarification of what was always the way we operated. The old language was:

meets the requirements of TSO-C166b; or TSO-C154c

New language:

meets the performance requirements of TSO-C166b; or TSO-C154c

It's pretty easy to read in the first one that you didn't need to actually get the TSO, you just needed to meet it. It's nice they made this even more clear, but Dynon has not been holding out for this change to sell something.

The TSO for ADS-B and the GPS is extremely complex. In this case, the TSO paperwork is not the issue. It's the design the TSO requires and the tests you need to run in order to show you meet the TSO. Once you do all that work, why not file for the TSO?

Hence the reason Dynon sells a fully TSO'd transponder with ADS-B Out. There's no particular savings if you need to demonstrate compliance with so many technical details.

 

[rfinch]

Thanks for the clarification.

 

[gtae07]

I suppose the real question for the FAA is this: Why are these demanding requirements really necessary for VFR aircraft, especially those not operating inside actual Class B airspace?