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-   -   Possible AD for certain NAVWORX ADS-B Units (https://vansairforce.net/community/showthread.php?t=142967)

RobinHou 10-24-2016 05:57 PM

Model ADS600-EXP Part Number
 
I noticed the AD is applicable to Model ADS600-EXP P/N 200-8013. I just check my EXP order record from NavWorx and my part number is listed as 200-8012.

Does that mean the AD does not apply to my EXP unit?

What part number do you guys have on your EXP units?

Billvt 10-24-2016 06:30 PM

Navworkx Response
 
I sent an e-mail today to Bill Moffit and asked why they ( Navworx ) have not had any response.

He replied promptly as follows:

We will be commenting in the next week or so as we?re still in talks with the FAA.

Best Regards,

Bill Moffitt
NavWorx Incorporated
888-628-9679
(972) 372-0768 (direct)
469-644-2459 (cell)
469-327-2683 (fax)

Mike S 10-24-2016 06:36 PM

Quote:

Originally Posted by Billvt (Post 1121495)
I sent an e-mail today to Bill Moffit and asked why they ( Navworx ) have not had any response.

He replied promptly as follows:

We will be commenting in the next week or so as we’re still in talks with the FAA.

Best Regards,

Bill Moffitt
NavWorx Incorporated
888-628-9679
(972) 372-0768 (direct)
469-644-2459 (cell)
469-327-2683 (fax)

Pretty much what I was expecting.

Makes sense, I am more than happy to wait for an answer based in knowledge and fact than in fear and speculation.

theduff 10-24-2016 07:33 PM

I met Bill at Oshkosh and came away favorably impressed. He has been using images of my 4 on his website to promote the Exp. units. When I teased him about the unauthorized use of my 4 he offered me a promotional rate on an Exp box. I took him up on the offer and the unit sets unopened in the box slated for install next month. Now not sure what to do except to wait and see if Bill finds a solution. I checked with my credit card company and they told me I have till Nov. 15th to dispute the charge. I'm not sure I'd take that option, I'd rather just wait for Bill to get back to us.
I was told by an avionics guru that there are only 3 companies that make the TSO'd GPS chips and they have raised their prices exorbitantly which led Bill to looking for an alternative. Seems like the big players in the avionics universe weren't too keen on Bill's affordable solution.

RobinHou 10-24-2016 08:55 PM

Quote:

Originally Posted by RobinHou (Post 1121488)
Does that mean the AD does not apply to my EXP unit?

Just checked my unit and it has the same p/n as in the AD

Scott Hersha 10-25-2016 03:29 PM

I just received my ADS600-EXP yesterday and it has a serial number 200-8013. I'm hoping it either has a necessary software change (SIL 0), or they've worked something out with the FAA. Either way - the FAA has received my comment on what I think of their unannounced change to their previously acceptable protocol.

rvator51 10-25-2016 04:22 PM

Quote:

Originally Posted by Scott Hersha (Post 1121748)
I just received my ADS600-EXP yesterday and it has a serial number 200-8013. I'm hoping it either has a necessary software change (SIL 0), or they've worked something out with the FAA. Either way - the FAA has received my comment on what I think of their unannounced change to their previously acceptable protocol.


The problem is that if the SIL is changed to "0", the ground stations wont send traffic to it anymore. This started at the first of the year which prompted the change to SIL="3" to be able to receive traffic.

MartySantic 10-25-2016 04:27 PM

Quote:

Originally Posted by Scott Hersha (Post 1121748)
I just received my ADS600-EXP yesterday and it has a serial number 200-8013. I'm hoping it either has a necessary software change (SIL 0), or they've worked something out with the FAA. Either way - the FAA has received my comment on what I think of their unannounced change to their previously acceptable protocol.

Please let us know what SIL is reported on your 1st FAA ADS performance report. https://adsbperformance.faa.gov/PAPRRequest.aspx

AllThumbs 10-25-2016 05:15 PM

No new info...
 
I go on vacation for a few weeks out of the country and this happens...

I have no info on this issue from Bill and, if there are lawyers and FAA involved, I'm not likely to get any info before you do. If he tells me something I can post, I will. But please remember I'm just a contractor who did an app to configure the EXP box and also, on my own time, help with west coast installation issues and answer VAF questions when able.

In the meantime I'd suggest everyone remain patient and not pelt Bill with questions he clearly won't, or can't, answer until the process has run its course.

BobTurner 10-25-2016 06:22 PM

Quote:

Originally Posted by MartySantic (Post 1121759)
Please let us know what SIL is reported on your 1st FAA ADS performance report. https://adsbperformance.faa.gov/PAPRRequest.aspx

This is meaningless. The SIL is not calculated by the FAA ground stations; it is programmed into the box by the manufacturer, and then sent out. As I understand the A/D - and I can easily be wrong - the FAA is saying that NavWorks was not authorized to put in SIL=3 into certain boxes using certain components.

Scott Hersha 10-25-2016 06:48 PM

Anybody know why traffic info isn't sent to equipment broadcasting SIL=0? Didn't that work at first? I thought SIL =0 meant the equipment wasn't 'certified', but what I think I also read was that this uncertified equipment met the position accuracy requirements of the TSO, AND was accepted by the FAA a year ago. If NavWorx changed the transceivers to send the info on the data string to SIL=3, then my question is why did the FAA change their protocol from what was previously accepted, why did they do that? In a non-certified airplane, why does it matter as long as the accuracy still meets the TSO?

RFSchaller 10-25-2016 07:40 PM

I don't have the NAVWORX unit, but it seems to me there are at least two issues:

1. ADs do not apply to aircraft that are not type-certified e.g. ELSA or EAB.
2. If your installation passes the FAA performance test as reported on the summary you can request, why would you replace it?

MartySantic 10-25-2016 08:17 PM

Quote:

Originally Posted by BobTurner (Post 1121787)
This is meaningless. The SIL is not calculated by the FAA ground stations; it is programmed into the box by the manufacturer, and then sent out. As I understand the A/D - and I can easily be wrong - the FAA is saying that NavWorks was not authorized to put in SIL=3 into certain boxes using certain components.

Meaningless?? Thought he mentioned his NEW ADS600-EXP unit had a new model number, not covered by the proposed AD?? As such, would be VERY interested in the SIL transmitted. Yes, I very much understand the definition of SIL.

Radomir 10-25-2016 08:27 PM

Quote:

Originally Posted by BobTurner (Post 1121787)
This is meaningless. The SIL is not calculated by the FAA ground stations; it is programmed into the box by the manufacturer, and then sent out. As I understand the A/D - and I can easily be wrong - the FAA is saying that NavWorks was not authorized to put in SIL=3 into certain boxes using certain components.

You are 100% correct :) That's the root of the whole issue.. you can't just randomly program the box to send any SIL you want without showing that it meets the requirements for that SIL.. Doesn't have to be certified, but has to show results of testing to meet the TSO.

Per that FAA letter, there's a clear disagreement between them whether test data provided by Navworx was sufficient to prove that equipment meets the requirements. And the FAA won't let Navworx just program any SIL they pick.... hence the AD...

PS. Doesn't matter that the plane is experimental.. requirements for ADS-B are equal for all. Experimentals are not allowed to transmit "made up" signal.

Jordan1976 10-25-2016 09:12 PM

The FAA "turned off" traffic for SIL=0 devices in Jan 2016 for a few reasons. You can read their justification here:

http://www.faa.gov/nextgen/programs/adsb/media/TIS-B_service_change_summary_final_508_5-13-15-webV2.pdf

Note that they left traffic on for SIL=1 or higher devices, while 2020 compliance requires a SIL=3, so they do not require a full complaint solution, just one with some pedigree.

Paul 5r4 10-26-2016 05:09 AM

question
 
I read the above post on the FAA's reason for their changing ADSB parameters. My question is this... why did it not affect any of the other manufactures of ADSB units? Why aren't they having problems like navworx?

Brantel 10-26-2016 05:36 AM

Quote:

Originally Posted by Paul 5r4 (Post 1121860)
I read the above post on the FAA's reason for their changing ADSB parameters. My question is this... why did it not affect any of the other manufactures of ADSB units? Why aren't they having problems like navworx?

It did... Garmin was also effected by this change in that they correctly output SIL-0 when using an uncertified (or approved equal) position source. When the FAA flipped the switch to not allow clients outputting SIL-0 to receive the traffic uplink, Garmin based panels (using an uncertified (or approved equal) position source) lost uplinked traffic data as well. Garmin refused to lie to the system by incorrectly outputting something higher than SIL-0. Other well known manufacturers also got hammered by this change as well but also followed the rules.

My understanding is that the manufacturers firmware is what decides what SIL level is going to be output. Looks to me like Navworx decided to break the rules by outputting a higher SIL level than 0 without a properly certified (or approved equal) position source. Essentially what appears to be lying to the system and therefore the FAA takes issue with that.

I doubt they are the only ones out there that have tried or are trying to get away with this. There are some other dirt cheap models that most likely are doing the same thing and will eventually get busted by the FAA.

GalinHdz 10-26-2016 07:50 AM

Quote:

Originally Posted by RFSchaller (Post 1121814)
I don't have the NAVWORX unit, but it seems to me there are at least two issues:

1. ADs do not apply to aircraft that are not type-certified e.g. ELSA or EAB.
2. If your installation passes the FAA performance test as reported on the summary you can request, why would you replace it?

You are right, aircraft AD's do not apply to ELAS or EAB. But this is not an aircraft AD, it is an equipment AD. It applies to the equipment indicated not the aircraft. That is why the proposed AD states:

"This AD applies to the following NavWorx, Inc., Automatic Dependent Surveillance-Broadcast (ADS-B) Universal Access Transceiver units (unit) installed on aircraft certificated in any category:

(1) Model ADS600-B part number (P/N) 200-0012;

(2) Model ADS600-B P/N 200-0013; and

(3) Model ADS600-EXP P/N 200-8013."


We experimental guys don't get a pass on this one if it becomes an AD.

:(

Jordan1976 10-26-2016 09:42 AM

Another reason you don't get to ignore the AD is that ADS-B is a performance based rule.

FAR 91.225 says:

Quote:

(b) After January 1, 2020, and unless otherwise authorized by ATC, no person may operate an aircraft below 18,000 feet MSL and in airspace described in paragraph (d) of this section unless the aircraft has equipment installed that--

(1) Meets the requirements in--

(ii) TSO-C154c, Universal Access Transceiver (UAT) Automatic Dependent Surveillance-Broadcast (ADS-B) Equipment Operating on the Frequency of 978 MHz;
If the AD goes through, the FAA is telling you that box doesn't meet the performance requirements of the TSO (even if it never had a TSO). You are now fully aware of this fact. You then fly into an ADS-B required airspace. The FAA then says that you, as a pilot, knowingly violated a FAR and takes enforcement action against your airmens certificate.

Peterk 10-26-2016 11:59 AM

All this said...how does the FAA know that you removed the box? Can they discover your manufacturer by recognizing the equipment that is receiving streaming data?

Or is it like flying a non-sport compliant aircraft without a medical...good till you get caught?

Billvt 10-26-2016 12:31 PM

Reported SIL
 
The SIL reported by my ADS600-EXP on my latest report dated 10/05/16 was SIL = 3

rleffler 10-26-2016 01:06 PM

Quote:

Originally Posted by Peterk (Post 1121985)
All this said...how does the FAA know that you removed the box? Can they discover your manufacturer by recognizing the equipment that is receiving streaming data?

Or is it like flying a non-sport compliant aircraft without a medical...good till you get caught?

As part of the data packet of the ADSB transmission, they know it's a NavWorx unit. If I recall correctly, the compliance report listed the Navworx model number.

Now whether or not they act on the data, is another issue........

Radomir 10-26-2016 01:15 PM

Quote:

Originally Posted by Peterk (Post 1121985)
All this said...how does the FAA know that you removed the box? Can they discover your manufacturer by recognizing the equipment that is receiving streaming data?

Or is it like flying a non-sport compliant aircraft without a medical...good till you get caught?

It's an honor system... there's nothing in the transmitted data that identifies the manufacturer.

PS. they "know" on compliance report cause "you told them what unit you have" (they ask for it when you ask for compliance report)

Scott Hersha 10-26-2016 07:11 PM

Well..... what I heard was a bit different, not that it matters much. I heard that last January the FAA stopped sending traffic info (TIS B) to aircraft broadcasting SIL=0 in the ADS-B data string (indicates EAB/light sport, I think). NavWorx changed the software to broadcast TIS=3, in order to get traffic info displayed on their customers ADS600-B and ADS600-EXP units. SIL 3 is for certified units, not experimental - I think..... The FAA has a beef with this because even though the internal GPS accuracy meets the TSO accuracy requirements, it's not a certified TSO'd GPS. I could be wrong about this, but that's the way I understand it from what I've read/researched. I do have a dog in this fight because I just received my new ADS600-EXP 3 days ago, and would like to use it.......forever...

Anyway, it sort of reminds me of what happened many years ago when PMA(parts manufacturing approval)was first introduced, but the PMA'd parts didn't have to meet any of the original design parameters other than basic shape, size and weight. Customers of major aircraft components, such as engines, expected the original manufacturer to warranty and support their product when it included PMA'd replacement parts that were installed that didn't meet the designed performance requirements of the original engine (Lycoming, GE, etc). Eventually the PMA system became a little more stringent and PMA'd parts became more like the original design (but not quite).

What this has to do with the NavWorx situation has to do with the way the FAA handles things. If NavWorx knowingly changed their software to broadcast a SIL=3 code with an uncertified unit in order to 'steal' the TIS-B info, well, bad on them. If the FAA changed the protocol on what was originally accepted by the FAA air traffic system without informing the previously approved venders of ADS-B systems and offering them a recourse, then bad on them - and I believe that is what happened here. Why? I don't know, but what if the thousands of certified 'light' aircraft were allowed to use uncertified parts that met the original TSO - via an extension or growth of a part 23 rewrite to meet the 2020 ADS-B mandate? Do you think any pressure could be exerted on FAA in the name of protectionism by certain groups, like, say, GAMA? I don't trust anyone in Washington and neither should you. What they are doing could ruin a small American company, and in the name of what? Safety?? Absolutely not! That has been proven, and they (FAA) proved, or shall I say, approved it. Write to them. It's on the NavWorx website - EASY link to make a comment. Experimental aviation needs to stand up to these kinds of threats.

rvator51 10-26-2016 07:38 PM

I wonder if a compromise solution that Navworx could change the software to broadcast SIL=1, which would make everyone happy and give Navworx and the FAA 4 years to come to agreement/solution on getting the SIL=3, while the user can still get traffic?

Jordan1976 10-26-2016 08:43 PM

Quote:

Originally Posted by Scott Hersha (Post 1122098)
SIL 3 is for certified units, not experimental - I think..... The FAA has a beef with this because even though the internal GPS accuracy meets the TSO accuracy requirements, it's not a certified TSO'd GPS. I could be wrong about this, but that's the way I understand it from what I've read/researched.

If the FAA changed the protocol on what was originally accepted by the FAA air traffic system without informing the previously approved venders of ADS-B systems and offering them a recourse, then bad on them - and I believe that is what happened here.

First and foremost, this AD is for TSO'd units. SIL has nothing to do with certified/not certified. It's all about the demonstrated reliability of the GPS to not transmit a wrong position. There are at least two non-TSO'd vendors sending SIL=3. In this particular case, the unit WAS TSO'd and the FAA still claims it's not SIL=3 capable. You can TSO a SIL=0, SIL=1, SIL=2, or SIL=3 device.

The FAA gave everyone (the public, the vendors) at least 9 months warning of the upcoming change, and engaged the vendors for almost a year before that. They did not change the protocol, they changed how the ground stations reacted to it, and they left the ability for SIL 1,2, and 3 to wake up the ground stations, not just SIL 3. Many vendors did object to the change, but it wasn't like the FAA didn't engage everyone beforehand, and didn't discuss multiple options. There was a specific safety issue with SIL=0 (certified planes couldn't see you AT ALL because of a quirk in the TSO), and that was a primary basis for the change, and the issue the FAA was looking to solve.

lr172 10-26-2016 08:44 PM

Quote:

Originally Posted by theduff (Post 1121510)
I was told by an avionics guru that there are only 3 companies that make the TSO'd GPS chips and they have raised their prices exorbitantly which led Bill to looking for an alternative. Seems like the big players in the avionics universe weren't too keen on Bill's affordable solution.

Seems the aviation business is learning from big Pharma - Pay the Gov't to eliminate your competition for you.

Larry

lr172 10-26-2016 09:01 PM

Quote:

Originally Posted by Brantel (Post 1121866)
It did... Garmin was also effected by this change in that they correctly output SIL-0 when using an uncertified (or approved equal) position source. When the FAA flipped the switch to not allow clients outputting SIL-0 to receive the traffic uplink, Garmin based panels (using an uncertified (or approved equal) position source) lost uplinked traffic data as well. Garmin refused to lie to the system by incorrectly outputting something higher than SIL-0. Other well known manufacturers also got hammered by this change as well but also followed the rules.

My understanding is that the manufacturers firmware is what decides what SIL level is going to be output. Looks to me like Navworx decided to break the rules by outputting a higher SIL level than 0 without a properly certified (or approved equal) position source. Essentially what appears to be lying to the system and therefore the FAA takes issue with that.

I doubt they are the only ones out there that have tried or are trying to get away with this. There are some other dirt cheap models that most likely are doing the same thing and will eventually get busted by the FAA.

A key difference here is that Garmin and most others are selling TSO'ed units and all parts must be TSO'ed. In essence, they must prove to the FAA that ALL TSO specs are met and receive the FAA stamp of approval.

Last year, the FAA gave makers of experimental units the ability to utilize non-TSO'ed parts inside of a packaged non-TSO product as long as they met the performance specifications outlined in the TSO. Unless Navworx used parts that didn't allow their units to meet the performance spec for SIL=3, they didn't do anything wrong by using non-TSO parts and outputting a SIL=3. You can't compare Navworx to Garmin, as they are selling different products. Unfortunately the FAA didn't publicly state if or how they would police the industry on "meeting the performance spec."

My guess is that the FAA is quietly pulling back on some of the freedom it issued last year in a quiet way. This is likely due to political pressure from the larger players in the certified arena.

Larry

Paul 5r4 10-26-2016 09:51 PM

FAA BS
 
It's absolutely amazing to me that right in the middle of the FAA's push... AKA $500 rebates... to get everyone on board with ADSB they pull something like this and I don't care if they gave everyone 9 months warning. It really looks like they didn't have things all figured out or as some stated, it's the big companies applying some political pressure to make life hard on smaller companies. Navworx puts out a fantastic product for a very reasonable price. Along with minimal install time, it's just a great unit.

After flying with my navworx ADSB a few months I can say it increases safety 1000%. Weather is one thing but with most of my flights local... weather is never much of an issue. Traffic on the other hand, well I never knew there was so much around me and so close too. The FAA changing the rules is a huge step back for lots of people. It took months of research/reading/asking questions/saving money to get ADSB.... and now the threat of having to take it out looms. Unbelievable!

Sorry, needed to vent a little. :-(

Jordan1976 10-26-2016 10:14 PM

Quote:

Originally Posted by lr172 (Post 1122132)
A key difference here is that Garmin and most others are selling TSO'ed units and all parts must be TSO'ed.

This AD is for a TSO'd unit. From the AD:

Quote:

NavWorx produces ADS-B units under Technical Standard Order (TSO) C-154c.

Brantel 10-27-2016 02:36 AM

Quote:

Originally Posted by rvator51 (Post 1122112)
I wonder if a compromise solution that Navworx could change the software to broadcast SIL=1, which would make everyone happy and give Navworx and the FAA 4 years to come to agreement/solution on getting the SIL=3, while the user can still get traffic?

Except that breaks the rules and is unfair for the rest of the manufacturers that have followed them...

rvator51 10-27-2016 09:52 AM

Quote:

Originally Posted by Brantel (Post 1122159)
Except that breaks the rules and is unfair for the rest of the manufacturers that have followed them...

This is what Dynon is doing with their uncertified GPS source antenna on the Skyview system, I think. My understanding is that when the new certified GPS source is added, then the SIL changes to 3. So not sure if unfair or not. Isnt SIL=1 for uncertified GPS sources?

lr172 10-27-2016 11:06 AM

Quote:

Originally Posted by Jordan1976 (Post 1122147)
This AD is for a TSO'd unit. From the AD:

If you go further in that paragraph, you find:

NavWorx produces ADS-B units under Technical Standard Order (TSO) C-154c. NavWorx has implemented a design change by revising its software for ADS-B units, Model ADS600-B part number (P/N) 200-0012 and 200-0013 and Model ADS600-EXP P/N 200-8013.

Clearly the proposed AD will affect both the B and the EXP.

What I don't understand here is the FAA's statement that a TSO'ed GPS chip is required. I was under the impression that a year ago, the FAA gave manufacturers the right to use non-TSO'ed components that met the performance requirements of the TSO. They failed to mention that this would require a SIL=0, thereby rendering the product useless in 2020. I have a feeling this a new revelation to unwind what they initially offered.

Larry

Mich48041 10-27-2016 12:12 PM

The location of the GPS antenna on the aircraft can vary from plane to plane, perhaps 10 feet or more. So what difference does it make if the GPS position is accurate to within 10 inches or 10 feet? If a GPS receiver provides a position that is accurate to within 10 cm, but the antenna is located 10 feet off center, the ADS-B location of the aircraft will be 10 feet off. Is that dangerous? ATC usually provides 3 miles or more of separation between aircraft. The accuracy of even the cheapest GPS is a very small fraction of 3 miles. The argument has been made that very accurate GPS is needed for airport taxi operations. Really? What controller would issue taxi instructions that would allow aircraft to miss each other by a few inches?
Shouldn't the mission of the FAA be to improve safety, not to hinder it? It reminds me of a country to our south where the police are ones committing the crimes.
Regulations, that deprive pilots of traffic information and force manufactures to increase prices, do not contribute to safety. They are immoral.

Radomir 10-27-2016 12:24 PM

Funny that you mention that.. there are transceiver settings related to antenna position (offset from centerline of aircraft) to account for exactly the issue you're mentioning. :) So they already got that covered...

BobTurner 10-27-2016 12:42 PM

As posted above, your ADSB-out is supposed to broadcast wingspan, length, and GPS antenna position when you're on the ground. And in the FAA's vision of the future, no controller will issue ground instructions - a computer will.
Make no mistake, ADSB is all about saving the FAA money, and keeping GA out of the way of the airlines. Traffic and wx are just the 'carrot' to make the 'stick' ($$) seem more palatable.

Brantel 10-27-2016 03:27 PM

Quote:

Originally Posted by rvator51 (Post 1122239)
This is what Dynon is doing with their uncertified GPS source antenna on the Skyview system, I think. My understanding is that when the new certified GPS source is added, then the SIL changes to 3. So not sure if unfair or not. Isnt SIL=1 for uncertified GPS sources?

You can earn a TSO for SIL-anything. You can properly test/demonstrate to SIL-anything.

You can't just transmit SIL > 0 without demonstrating or earning the TSO to SIL-1 thru 3 which is what the FAA seems to be complaining about.

As far as I know neither Garmin or Dynon do this.....(output SIL > 0 without following the rules)

aerovin 10-27-2016 05:44 PM

Quote:

Originally Posted by lr172 (Post 1122252)
I was under the impression that a year ago, the FAA gave manufacturers the right to use non-TSO'ed components that met the performance requirements of the TSO. They failed to mention that this would require a SIL=0, thereby rendering the product useless in 2020. I have a feeling this a new revelation to unwind what they initially offered.

I keep seeing this as an 'impression' but does anyone actually have a source document that says this? It's not private information...it would be in some FAA document/AC/Order somewhere.

lr172 10-27-2016 08:28 PM

Quote:

Originally Posted by aerovin (Post 1122353)
I keep seeing this as an 'impression' but does anyone actually have a source document that says this? It's not private information...it would be in some FAA document/AC/Order somewhere.

you should check out this new thing they call Google;). Here is a press article about it. Didn't feel like digging deeper to find the actual FAA doc.

http://generalaviationnews.com/2015/...er-cost-ads-b/

BHunt 10-27-2016 10:48 PM

Does Navworx have any sort of EAA backing in this?


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