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  #11  
Old 12-17-2012, 05:36 PM
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dynonsupport dynonsupport is offline
 
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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:
Although SkyView’s GPS output does not meet the 2020 requirements, it can be used until then to “wake up” the ADS-B ground stations so that they report back traffic targets around your aircraft’s position.
If you think we did this without talking to the FAA and Trig first, then you seriously underestimate the rigor we take when entering into enormous product development efforts here at Dynon, and the honesty with which we communicate product features to our customers.

--Ian Jordan
Dynon Avionics
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Last edited by dynonsupport : 12-17-2012 at 05:43 PM.
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  #12  
Old 12-17-2012, 05:40 PM
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Brantel Brantel is offline
 
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Quote:
Originally Posted by Flying Scotsman View Post
Not what I said at all. I only pointed out that it's *possible* and apparently perfectly legitimate/legal to design, implement and deploy TSO'd equipment which has field-updatable firmware serviceable by the owner.

I never said it applied to "all situations" or any other manufacturer's equipment.
Never intended to imply that you said anything...sorry if it comes across that way, I stink at English. Again, very sorry for the confusion.
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Last edited by Brantel : 12-17-2012 at 05:52 PM.
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  #13  
Old 12-17-2012, 06:02 PM
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Brantel Brantel is offline
 
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Quote:
Originally Posted by dynonsupport View Post
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:


If you think we did this without talking to the FAA and Trig first, then you seriously underestimate the rigor we take when entering into enormous product development efforts here at Dynon, and the honesty with which we communicate product features to our customers.

--Ian Jordan
Dynon Avionics
Ian,

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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Last edited by Brantel : 12-17-2012 at 07:34 PM.
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  #14  
Old 12-17-2012, 06:33 PM
RV8R999 RV8R999 is offline
 
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Quote:
Originally Posted by Brantel View Post
Ian,

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....
Your OP did imply perhaps Dynon was liberally interpreting the rules... at least the way I read it.
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  #15  
Old 12-17-2012, 06:59 PM
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Quote:
Originally Posted by RV8R999 View Post
Your OP did imply perhaps Dynon was liberally interpreting the rules... at least the way I read it.
Nope...All I said that it was their interpretation that what they are doing is OK. Ian now claims to have a specific authorization that allows them to do this, if this is true, good for them.
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---------------------------------------------------------------------
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Track N159SB (KK4LIF)
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  #16  
Old 12-17-2012, 11:28 PM
Flying Scotsman Flying Scotsman is offline
 
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Quote:
Originally Posted by Brantel View Post
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?
Perhaps by making the appropriate entries in the Avionics Logbook at the time the update is installed?
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  #17  
Old 12-17-2012, 11:34 PM
Flying Scotsman Flying Scotsman is offline
 
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Quote:
Originally Posted by Brantel View Post
Nope...All I said that it was their interpretation that what they are doing is OK. Ian now claims to have a specific authorization that allows them to do this, if this is true, good for them.
What do you mean "if this is true"?

The Dynon rep specifically said:

Quote:
The firmware update process was in the original certification explicitly so it could be used in the future.
I'll let Dynon defend themselves, but the whole point goes waaaaay back to earlier assertions that TSO'd equipment HAD to be updated by an authorized repair station, or conversely, that it could NOT be updated by an end user.

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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  #18  
Old 12-18-2012, 05:17 AM
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Brantel Brantel is offline
 
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Quote:
Originally Posted by Flying Scotsman View Post
What do you mean "if this is true"?

The Dynon rep specifically said:



I'll let Dynon defend themselves, but the whole point goes waaaaay back to earlier assertions that TSO'd equipment HAD to be updated by an authorized repair station, or conversely, that it could NOT be updated by an end user.

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.
Steve,

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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RV-10, #41942, N?????, Project Sold
---------------------------------------------------------------------
RV-7/TU, #72823, N159SB
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Track N159SB (KK4LIF)
Like EAA Chapter 1494 on Facebook
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  #19  
Old 12-18-2012, 10:44 AM
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dynonsupport dynonsupport is offline
 
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Quote:
Originally Posted by Brantel View Post
If there is nothing to disallow a manufacturer from doing this, why do you guys even need specific authorization from the FAA?
Did someone say trust, but verify?

Quote:
Originally Posted by Brantel View Post
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?
Put a note in your logbook, just like you did when you first installed it, like you do every time you update the software in your EFIS, and like you do when you remove a Brand X transponder, mail it to them to be updated, have it mailed back, and then re-install it. You didn't use a certified install shop to install your Transponder the first time, and you don't use a certified shop to remove and install it when you get it updated.

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:
Originally Posted by Brantel View Post
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?
Quote:
FAR ? 91.413
ATC transponder tests and inspections.

(b) Following any installation or maintenance on an ATC transponder where data correspondence error could be introduced, the integrated system has been tested, inspected, and found to comply with paragraph (c), appendix E, of part 43 of this chapter.
The above FAR is the one which requires re-certifcation when transponders are worked on. There is not universal agreement on what can cause a "data correspondence error" and thus some people read this as any removal and replacement of the transponder requires re-cert. This is somewhat reasonable in the days of gray code, where the transponder has no way to know that one of the pins is bent and line B3 is now totally disconnected. However, with modern transponders, all communication is over a digital bus that is fully error checked, so it's not really possible to send an altitude to the transponder that gets corrupted, so you can reasonably argue that just unplugging and re-plugging a transponder on a digital bus isn't an issue.

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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