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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? |
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) |
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Makes sense, I am more than happy to wait for an answer based in knowledge and fact than in fear and speculation. |
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. |
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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.
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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. |
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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. |
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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?
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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? |
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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. |
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. |
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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?
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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. |
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"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. :( |
Another reason you don't get to ignore the AD is that ADS-B is a performance based rule.
FAR 91.225 says: Quote:
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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? |
Reported SIL
The SIL reported by my ADS600-EXP on my latest report dated 10/05/16 was SIL = 3
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Now whether or not they act on the data, is another issue........ |
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PS. they "know" on compliance report cause "you told them what unit you have" (they ask for it when you ask for compliance report) |
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. |
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?
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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. |
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Larry |
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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 |
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. :-( |
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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 |
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. |
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...
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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. |
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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) |
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http://generalaviationnews.com/2015/...er-cost-ads-b/ |
Does Navworx have any sort of EAA backing in this?
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