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NavWorx Inc. Penalty

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Runtoeat   

I was instructed to send my SkyGuard back to the factory for the GPS update.  SkyGuard installed the proper internal GPS, added a new antenna and upgraded the firmware.  This had to cost them a lot but they have a good relationship with the FAA and did what the FAA instructed them to do in order to keep the peace.  No cost to me other than the shipping back to them.  They handled the shipping back to me after the upgrade was done.

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As an electrical engineer I have to admit to being baffled by the Navworx saga. How hard would it be to put a compliant chipset into their product and declare victory. But no, they wanted to go to war with the FAA. That's a no win situation. For their part, the FAA seems to have lost all perspective when it comes to Navworx. The penalty they are proposing is bizarre in its size, unprecedented, and serves no purpose, being levied on a now defunct company. Further, it occurs to me that many other companies are flying under the radar (so to speak), using similar chipsets and other 'innovative' approaches (like Skyguard) that will need to get sorted out soon. Meanwhile the FAA is still beating the stuffings out of a tiny company that has already given up.

One wonders if the FAA isn't helping out the big companies like Garmin, Level3, Rockwell, Honeywell, etc.  Another oddity is other small companies like Dynon, Freeflight, and Uavionix who seem to have no problems with the FAA. I admit to being a little confused.

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10 minutes ago, SportFlyer1 said:

As an electrical engineer I have to admit to being baffled by the Navworx saga. How hard would it be to put a compliant chipset into their product and declare victory. But no, they wanted to go to war with the FAA. That's a no win situation. For their part, the FAA seems to have lost all perspective when it comes to Navworx. The penalty they are proposing is bizarre in its size, unprecedented, and serves no purpose, being levied on a now defunct company. Further, it occurs to me that many other companies are flying under the radar (so to speak), using similar chipsets and other 'innovative' approaches (like Skyguard) that will need to get sorted out soon. Meanwhile the FAA is still beating the stuffings out of a tiny company that has already given up.

One wonders if the FAA isn't helping out the big companies like Garmin, Level3, Rockwell, Honeywell, etc.  Another oddity is other small companies like Dynon, Freeflight, and Uavionix who seem to have no problems with the FAA. I admit to being a little confused.

Interesting thoughts.  I'm sure if you asked most of the FAA big shots, they would prefer we all have expensive, TSO'd name brand solutions to participate in "their" airspace.  So there may be something to that idea.

As for Navworx, is it possible that a truly compliant GPS chipset is simply too expensive for them to both include it *and* keep their price down?  With companies like uAvionix providing compliant solutions (at least to their claims), that seems doubtful, but then I don't think uAvionix is marketing to certified aircraft at all, so they only have to have "equivalent performance" and not adhere to every nuance of the TSO.  Navworks was claiming compliance with the full TSO for use in certified aircraft, correct?

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Well, they had 2 flavors, one for certified and one for experimental. Navworx was one of the first to produce a unit that cost less than half anyone else's, so maybe that is why they got FAA attention. However now there are several cheap solutions that seem to be doing ok. I am eyeing a Uavionix/GDL39 solution now. I have the burden of feeding the Garmin 696 with weather info and apparently the GDL 39 is the only 'cheap' thing that can format the proprietary data correctly.

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Tom, I’m eyeing the same setup, since I’m a Garmin pilot user.  I have the same problem, the GDL-39 is the only inexpensive IN solution for Garmin users.

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Anticept   

The FAA is flexing their muscle as a warning to play by their rules or go home. That's basically what that response is about, I feel.

I support them in their original decision only in regards to SIL levels and what they are designed for. Integrity monitoring is serious business.

I don't know if I can support them where they stopped working with units that broadcast SIL 0; if they never intended that to be used, they should never have made it part of the specification...

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I guess I'll become a Garmin Pilot user too. Currently I'm using Avare which is pretty good, and the price is perfect,  $00.00.  I'd prefer the Uavionix In because it will drive the Avare on my Android tablet, but I don't think they can use the proprietary RS-232 messages to send the FIS-B weather into my 696, darn it.

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I think the folks at uAvionix have had discussions with Garmin so hopefully there can be an agreement in the near future to support at least the 696/796.  I will try and get some updated info to share.

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Runtoeat   

Perhaps someone can help me understand my SkyGuard better.  I sent this in to the factory and a new GPS was installed.  SkyGuard (Don Houtz) sent my unit back and also sent me an email which said the FAA has changed their instruction on SIL and my original SIL=0 needed to be changed to SIL=3 and a different GPS has been installed to accompany this change.  Don said my SkyGuard now has "SDA=2" and "SIL=3".  Am I correct in thinking that if a ADS-B GPS reports out a "SIL=3", the FAA considers this GPS to be a device that is sending reliable and correct location information?  Am I also correct in thinking that SIL=0 was originally set up for  experimental and LSA non-certified ADS-B units to send out so that the FAA would be able to recognize the information being sent by these ADS-B units was "uncertified" location information?

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11 hours ago, SportFlyer1 said:

I guess I'll become a Garmin Pilot user too. Currently I'm using Avare which is pretty good, and the price is perfect,  $00.00.  I'd prefer the Uavionix In because it will drive the Avare on my Android tablet, but I don't think they can use the proprietary RS-232 messages to send the FIS-B weather into my 696, darn it.

Even with the greater cost, I don't think you'll be disappointed if you move to Garmin Pilot.  I feel like I get every penny's worth from the subscription cost.  It is rock solid stable (never had a crash or bug except when using a version of iOS Garmin has not yet blessed), and I think it has the nicest graphics of all the nav programs.  I really love the logbook feature, I have not had to make a paper logbook entry in over a year.  Garmin logs every flight for you, and it's uncanny how accurately it records number of landings, speeds, etc.  It even now records the ground track for every flight that you can overlay on the map.  Great for finding that landmark you saw that time on one of your flights...

Also I think the Synthetic Vision is second to none.

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8 hours ago, Runtoeat said:

Perhaps someone can help me understand my SkyGuard better.  I sent this in to the factory and a new GPS was installed.  SkyGuard (Don Houtz) sent my unit back and also sent me an email which said the FAA has changed their instruction on SIL and my original SIL=0 needed to be changed to SIL=3 and a different GPS has been installed to accompany this change.  Don said my SkyGuard now has "SDA=2" and "SIL=3".  Am I correct in thinking that if a ADS-B GPS reports out a "SIL=3", the FAA considers this GPS to be a device that is sending reliable and correct location information?  Am I also correct in thinking that SIL=0 was originally set up for  experimental and LSA non-certified ADS-B units to send out so that the FAA would be able to recognize the information being sent by these ADS-B units was "uncertified" location information?

I *think* this is correct.  I spoke to Shane at uAvionix a little about SIL levels.  He said the FAA specified that that as long as your unit reports SIL > 0 then you are good to go.  IIRC the uAvionix gears is also SIL 3.  I think there is some requirement in the full TSO'd units to report a specific SIL number (1?), but that does not affect us LSA and Experimental pilots.

Leave it to the FAA to design a compliance scheme very few can understand!  :)

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S3flyer   

Actually, the SIL value must be '3' to be compliant with the 2020 mandate.  '3' means that the GNSS position source is compliant with the applicable TSO.  The SIL value represents the probability of the reported horizontal position exceeding the radius of containment defined by the NIC:

1) ≤ 1x10-3 Per Hour

2) ≤ 1x10-5 Per Hour

3) ≤ 1x10-7 Per Hour

The NIC must be greater than or equal to '7' which means the radius of containment must be less than 370.4 meters.

A SIL > 0 will 'wake up' the ground stations and you'll receive traffic.

All the gory details are contained in AC20-165B.

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S3flyer   
12 hours ago, coppercity said:

I think the folks at uAvionix have had discussions with Garmin so hopefully there can be an agreement in the near future to support at least the 696/796.  I will try and get some updated info to share.

Huh?  The Sky Beacon is an ADS-B Out unit so there's no ADS-B In data to share.  Of course, they could be planning an In/Out unit.  I also think this might be problematic as it looks like the current unit is Wifi only which would rule out connection to the 69x/79x series but certainly could work with the IOS and Android apps.  The 79x does Bluetooth while the 69x is hardwire-only, I think.

 

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15 minutes ago, S3flyer said:

Huh?  The Sky Beacon is an ADS-B Out unit so there's no ADS-B In data to share.  Of course, they could be planning an In/Out unit.  I also think this might be problematic as it looks like the current unit is Wifi only which would rule out connection to the 69x/79x series but certainly could work with the IOS and Android apps.  The 79x does Bluetooth while the 69x is hardwire-only, I think.

 

A Skybeacon "in version" is in the works. The Echo Uat is available and preferred for hardwire and wifi compatibility with many products but not yet Garmin, perhaps soon 😊

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S3flyer   

Makes sense.  thanks.

The echo UAT looks very interesting.  In my case, it could replace my GDL-39 3D and first generation Skyguard (non-upgraded by current 2020 requirements) provided they get a deal with Garmin to talk to my 795.  $1400 is a pretty compelling price point.  I was leaning towards the GDL-82 ($1500) for ADS-B out and keeping the GDL-39 but would like to reduce the number of boxes in my plane.

Of course, the ideal solution (IMHO) is simply replacing my GTX-327 with a GTX-345 so I have one box to handle everything.  $5000 is a bit steep for elegance, though.

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Anticept   
On 11/3/2017 at 9:15 AM, FlyingMonkey said:

I *think* this is correct.  I spoke to Shane at uAvionix a little about SIL levels.  He said the FAA specified that that as long as your unit reports SIL > 0 then you are good to go.  IIRC the uAvionix gears is also SIL 3.  I think there is some requirement in the full TSO'd units to report a specific SIL number (1?), but that does not affect us LSA and Experimental pilots.

Leave it to the FAA to design a compliance scheme very few can understand!  :)

To understand what SIL is, we also need to know what NIC is.

 Navigation Integrity Category, or NIC, is a signal that informs ATC how accurate the onboard equipment is. It defines a "containment radius", which basically means "our aircraft is within this area". See the following table.

image.png.7ddd56ee74faa1a169d43cb739be8ed9.png

 

A containment radius of SEVEN or greater is required to fly in airspace defined in §91.225.

 

SIL, or source integrity level, defines the probability that the ADS-B equipment will make a report that lies outside of the containment radius WITHOUT generating an indication of failure. Consult the following table.

image.png.101727a67d5e5fbe59ad098ce50ea503.png


An SIL of THREE is required to fly in airspace defined in §91.225.

 

Now, if you review 91.227(c), you will see it does not state any minimum performance requirements for equipment UNLESS flying in airspace as defined in 91.225. However, I cannot think of a single sane company that would ever willingly and knowingly produce equipment that does not meet the requirements of 91.225, because who would buy it? In addition, I do not recall if the FAA is enforcing minimum levels on certified equipment, nor did I review this documentation thoroughly enough to find such a directive, but it wouldn't surprise me.

 

References:

 

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