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FAA Issues Alert for Transponder Use


stevez2436

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The FAA has changed it's ruling allowing LSA and Experimentals which already enjoy using non certified equipment to also be able to meet the 2020 mandate with non certified equipment....why do you keep my old posts from other forums?  :(

 

   Can you post that ruling change here then?

 

  I don't keep your posts…I just was looking through some stuff that I had copied and kept  because it was a good and accurate explanation of the ADSB requirements and light sport and I saw where you'd said something different. I thought you might remember and it would tweak your memory. No problem, whatever. :)

 

  I have Dynon SkyView with SV-261-XPNDR with ADS-B IN and OUT and it all works great and is compliant UNTIL 2020. At that point Dynon admits that Skyview doesn't meet the mandate because they don't have an installed compliant WAAS GPS source. I believe they're working on it and 2020 is a ways off yet. 

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The FAA has changed it's ruling allowing LSA and Experimentals which already enjoy using non certified equipment to also be able to meet the 2020 mandate with non certified equipment....why do you keep my old posts from other forums?  :(

 

Well...that's not *exactly* what the new ruling says.  It says equipment can be used in Experimentals and Light Sports that "meets the performance" of the TSO'ed gear.  The problem is, nowhere is it defined what "performance" must be met.  You are assuming it's WAAS GPS location accuracy.  

 

But, what if the FAA means *all* performance parameters:  Signal reception, resistance to radio frequency interference (RFI), bus current redundancy, or a host of other criteria?  This whole thing is a great big gray area, and the new ruling really did NOT clarify anything to the point where any installation that does not include a TSO'ed WAAS position source can be called "compliant" with the mandate.  At least not with any degree of certainty.

 

Your 796 might comply.  It might not.  There is nobody that can say for sure right now.  So again...why are you bugging all of us to equip now?? 

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From FAA "ADSB  INS and OUTS  Aug 2014


 


 


Some manufacturers are marketing uncertified ADS-B transmitters. Can I install these on my aircraft?


You may install an uncertified transmitter on amateur built aircraft and light-sport aircraft with experimental airworthiness certificates. However, you cannot install uncertified equipment, including uncertified transmitters on any aircraft with a standard airworthiness certificate. Also, uncertified ADS-B transmitters do not comply with 14 CFR Part 91.227 and will not be permitted to operate in §91.225 airspace requiring ADS-B after January 1, 2020, without prior approval from air traffic control (ATC).


ATC cannot use the data from uncertified transmitters — this means ATC cannot provide flight-following services or separation services to these aircraft. Data from the uncertified transmitters is not displayed on certified ADS-B-In displays. Therefore, your fellow pilots in aircraft with certified ADS-B equipment won’t be able to “see” you. The FAA strongly discourages the use of uncertified ADS-B Out equipment even in experimental aircraft. 


 


Can I install an uncertified GPS as my ADS-B position source?


You may install an uncertified GPS on amateur-built and light-sport aircraft with experimental airworthiness certificates. As stated above, you cannot install uncertified equipment, including an uncertified GPS on aircraft with standard airworthiness certificates. Additionally, these position sources do not comply with 14 CFR 91.227 and will not be permitted to operate in airspace requiring ADS-B in 2020 without prior approval from ATC.


 


What are the risks of using an uncertified position source?


The risk for any GPS receiver, when used to support separation services, is how far the position measurement can be in error without detection. If the position error gets large enough, air traffic control would not be able to provide safe separation between your aircraft and other traffic in your vicinity. FAA and our international peers conducted a safety analysis prior to publishing the final ADS-B rule to determine what this error detection boundary should be and the ADS-B performance requirements are based on the results of this safety analysis.


Certified GPS sensors compare GPS satellite measurements against each other. When a satellite signal error becomes large enough to detect, the receiver will reject that signal. The integrity performance specified in the ADS-B rule depends on the proper operation of this error detection feature. It ensures the safety of using ADS-B positioning based on GPS measurements. 


By comparison, uncertified commercial grade GPS sensors assume the system is working properly and do


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   Can you post that ruling change here then?

 

  I don't keep your posts…I just was looking through some stuff that I had copied and kept  because it was a good and accurate explanation of the ADSB requirements and light sport and I saw where you'd said something different. I thought you might remember and it would tweak your memory. No problem, whatever. :)

 

  I have Dynon SkyView with SV-261-XPNDR with ADS-B IN and OUT and it all works great and is compliant UNTIL 2020. At that point Dynon admits that Skyview doesn't meet the mandate because they don't have an installed compliant WAAS GPS source. I believe they're working on it and 2020 is a ways off yet. 

 

Sorry about the misunderstanding on one of my old posts.  Okay, here are a couple of links to the FAA's 'correction' letter of understanding discussion.  The gist is experimental and LSA are to meet the 'performance requirements' of TSOd ADS-B, not necessarily to have certified TSOd gear to meet the 2020 mandate.

 

http://generalaviationnews.com/2015/02/09/faa-correction-opens-door-for-lower-cost-ads-b/

http://www.suasnews.com/2015/02/34268/faa-revises-ads-b-rule-to-give-experimental-aircraft-more-options/

 

Here is a complete decision tree from the FAA on the subject:  https://www.faa.gov/nextgen/equipadsb/faq/

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Well...that's not *exactly* what the new ruling says.  It says equipment can be used in Experimentals and Light Sports that "meets the performance" of the TSO'ed gear.  The problem is, nowhere is it defined what "performance" must be met.  You are assuming it's WAAS GPS location accuracy.  

 

But, what if the FAA means *all* performance parameters:  Signal reception, resistance to radio frequency interference (RFI), bus current redundancy, or a host of other criteria?  This whole thing is a great big gray area, and the new ruling really did NOT clarify anything to the point where any installation that does not include a TSO'ed WAAS position source can be called "compliant" with the mandate.  At least not with any degree of certainty.

 

Your 796 might comply.  It might not.  There is nobody that can say for sure right now.  So again...why are you bugging all of us to equip now?? 

 

It's not a problem...it means LSA manufacturers can attest to the compliance with any gear they offer to meet the mandate whether it is TSOd or meets the same performance as TSOd gear....  and that is EXACTLY what is now being offered from Flight Design in the Dynon ADS-B xpndr and Garmin WAAS GPS.

 

Likewise experimental owners can install gear that also meets the performance criteria for ADS-B whether it is TSOd or meets the performance standard of TSOd gear. 

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It's not a problem...it means LSA manufacturers can attest to the compliance with any gear they offer to meet the mandate whether it is TSOd or meets the same performance as TSOd gear....  and that is EXACTLY what is now being offered from Flight Design in the Dynon ADS-B xpndr and Garmin WAAS GPS.

 

Likewise experimental owners can install gear that also meets the performance criteria for ADS-B whether it is TSOd or meets the performance standard of TSOd gear. 

 

Please point to a link describing this interpretation from the FAA counsel.  If that doesn't exist (it doesn't), your interpretation is meaningless and simply "what you think it means".

 

Trying to put words in the FAAs mouth rarely works out well.  I will continue to wait.

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