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We have specific authorization from the FAA that it is fine for the user to upgrade the transponder in place in the airplane. There is nothing I am aware of that disallows any manufacturer from doing this. All we had to do was make the label available and clear instructions. There is no interpretation here. A properly designed and documented software update can be done by the owner of an experimental aircraft. Databases are certified and pilots update those all the time because the process is designed to make it foolproof.
We know about the hassle our customers have to go through to update most certified avionics, and it is very directly one of our goals to not require this. We had to make the transponder easily upgradeable before we even shipped the first one so that we could do this when needed. The firmware update process was in the original certification explicitly so it could be used in the future. This is not some backdoor, unauthorized process we are using. This was designed in from the beginning because we knew it was important. We have never, ever, not once, said that our GPS is compliant with the 2020 rule. It is, without question, not. It is however, sufficient to get the ADS-B ground stations to start sending you traffic so that your ADS-B receiver gives you really awesome traffic coverage. From our install manual: Quote:
--Ian Jordan Dynon Avionics |
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It would be helpful if you would quote who you are talking to in your post. It appears that you are replying to several different people in the same post. As far as user updates to TSO'd gear goes... If there is nothing to disallow a manufacturer from doing this, why do you guys even need specific authorization from the FAA? Nobody ever said, that I am aware of, that you were using some backdoor, unauthorized process. All I said is something akin to Trust but Verify....surely you guys at Dynon have to understand that what you are doing just ain't the way it has been done in the past so it will raise some eyebrows. I know that the guy that normally does my static, alt, xponder check is very meticulous in checking the tags on my transponder. If he notices that the rev. has changed, most likely he is going to want to see the paperwork trail on who and how it was updated. How are Dynon customers going to respond to a request like that? Transponders are one of a few devices that most will agree are required to be TSO'd even when used in experimentals. How can a typical experimental end user verify that the transponder still meets the original performance specifications of a particular TSO after he/she flashes the firmware? Will a full xponder check be required by an authorized repair station? Every time I have put a new transponder in my airplane, I have had to have this done so what makes this different? Who knows, maybe you guys are paving the way to a future where all TSO'd gear can get updated in a similar manner for experimental's. Sounds good short term, hopefully it all works out long term as well. Looks like the rest of your post is pointed at Radomir.... |
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The Dynon rep specifically said: Quote:
Clearly, that is not the case. Whether our unnamed TSO'd WAAS-certified GPS manufacturer ever plans on getting their TSO amended to allow this is a different question, but hopefully, Dynon (and perhaps others) will, by way of example, be putting pressure on them to do so (and thus save their end users time and money) remains to be seen. My only point was that is IS allowed under the regulations. Kudos to Dynon for doing so. |
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My post on this subject are not meant to start a ruckus and have already went beyond my original intent. I am happy to just give this time and see what happens. Who knows Dynon might change the status quo on this one....I definitely don't want to be viewed as someone who is trying to block progress in this area. I just have some questions that would need to be answered in order for me to buy into or recommend the system to my buddies. I look forward to the response by Ian to my post above. His answers to those questions may help me settle my mind on the issue. Best regards and have a great day! |
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A lot of certified stuff is updated by you taking it out of the plane, mailing it to a shop, having them mail it back to you, and you re-install it. The FAA is smart enough to know that if they allow that, allowing you to press a single button in the plane that updates the transponder is probably acceptable. The update method is certified, so the FAA trusts that the transponder is either running fully verified, certified code, or it will fail to operate at all. Quote:
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In this case, the transponder was not removed from the aircraft, so there is no place where a data correspondence error could be introduced. The new software is TSO'd just like the old, and is fully self verified that it loaded correctly. The certification authorities agree that the software will not execute unless it is the TSO'd software, down to every last bit. Thus the software is certified to not act differently, and thus there is no way there could be a data correspondence error. We have discussed our system with the FAA and their opinion is that our method is fine with them. It's your airplane though, ultimately, and you can go beyond what is required by having your transponder re-tested, if you want, but we stand by the work we did to make sure that no such additional testing is required. If you want to mail the transponder to us to be updated, we would be happy to do that for you so that you can have a paper trail. Note that we are not a certified shop, if that's what you're after. We can offer a certified shop to update the transponder if you want, but this will require payment. Finally, we also don't want to at all imply that the update method that we've implemented here means that you can now update other certified products in-situ. It doesn't. Update methods for any certified product is prescribed by the manufacturer of a given product, after being worked out and approved with the certifying authority. --Ian Jordan and Michael Schofield Dynon Avionics |
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