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01-13-2015, 01:33 PM
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Senior Curmudgeon
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Join Date: Sep 2005
Location: Dayton Airpark, NV A34
Posts: 15,419
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Quote:
Originally Posted by Bill Moffitt
the reality is that you don't want to work with any other ADS-B vendor as you sell your own equipment, and like Garmin, make your interfaces proprietary so that other vendors can't inter-operate. That's your business, but in my opinion doesn't serve the GA interest.
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Thanks Bill.
A voice for the GA interest here................
This has been an ongoing complaint of mine for years
It would be so nice if we end users had the ability to buy from various vendors, and that the various items would play nicely together, so we could just simply plug-and-play install of the various things and they would work
__________________
Mike Starkey
VAF 909
Rv-10, N210LM.
Flying as of 12/4/2010
Phase 1 done, 2/4/2011 
Sold after 240+ wonderful hours of flight.
"Flying the airplane is more important than radioing your plight to a person on the ground incapable of understanding or doing anything about it."
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01-13-2015, 02:16 PM
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Join Date: Jul 2013
Location: US
Posts: 2,251
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Quote:
Originally Posted by Bill Moffitt
Ian, with all due respect, Dynon's interpretation of some of the FAA stuff is bewildering to me. SIL refers to the certification level of the GPS receiver, and has nothing to do with the installation of the GPS antenna.
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He's quoting the regulation exactly:
Quote:
(1) For aircraft broadcasting ADS?B
Out as required under ? 91.225 (a) and
(b)?
(i) The aircraft?s NACP must be less
than 0.05 nautical miles;
(ii) The aircraft?s NACV must be less
than 10 meters per second;
(iii) The aircraft?s NIC must be less
than 0.2 nautical miles;
(iv) The aircraft?s SDA must be 2;
and
(v) The aircraft?s SIL must be 3.
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At least for SDA:
Quote:
System Design Assurance (SDA) indicates
the probability of an aircraft
malfunction causing false or misleading
information to be transmitted,
as defined in TSO?C166b and TSO?
C154c.
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01-13-2015, 02:26 PM
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Join Date: Oct 2014
Location: Port Orange, FL
Posts: 54
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Portable ADS-B Transmitters
This is entirely personal opinion, but I think the largest reason portable ADS-B Transmitters are prohibited is because of the ability to move them between aircraft and those associated issues.
For example, say I owned a Lancair IV-P and an RV-7. If I were to move a portable transmitter out of a IV-P into an RV-7, and forgot to reconfigure it, I'd take off and be transmitting the wrong tail number, size, and aircraft performance information. ATC could potentially issue dangerous instructions based on the assumption I was a pressurized aircraft or another piece of misinformation.
Again, no basis in fact for this, just my opinion.
__________________
Pahan Ranasingha
Spruce Creek Airport 7FL6
Port Orange, FL
RV-7A N705RV (Sold)
Lancair IV-P N530P
RV-14A (Under Construction)
Last edited by avionicsr : 01-13-2015 at 02:44 PM.
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01-13-2015, 02:27 PM
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Join Date: Dec 2014
Location: Rowlett, TX
Posts: 13
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Quote:
Originally Posted by RV7A Flyer
He's quoting the regulation exactly:
At least for SDA:
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Agree, Ian and you quoted the regulations - which are <certification> items. Again, nothing about SIL, SDA, or "Power Source" pertains to <installation> issues for a self-contained unit - the portable ADS-B unit - which was the topic of Ian's post.
__________________
Bill Moffitt
NavWorx Incorporated
888-628-9679
(972) 372-0768 (direct)
469-327-2683 (fax)
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01-13-2015, 03:24 PM
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Join Date: Jun 2005
Location: Woodinville, WA
Posts: 1,499
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Quote:
Originally Posted by Mike S
A voice for the GA interest here................
This has been an ongoing complaint of mine for years
It would be so nice if we end users had the ability to buy from various vendors, and that the various items would play nicely together, so we could just simply plug-and-play install of the various things and they would work
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Remember that modern avionics systems are largely software. You can't go and hook up ADS-B if that display doesn't have ADS-B code in it. If someone invents a $100 radar altimeter tomorrow, you can't hook that up until the EFIS knows how to display a radar altimeter. So the idea that a software based EFIS should play with all hardware forever is a bit of an impossible dream, since the general purpose of new hardware is to give a system capabilities it didn't have before, which would require new software to go with it.
While open standards are limitless interoperability would indeed be nice, we all have businesses to run that are pretty low volumes in a low margin market, and so far nobody has been able to make that business work with just selling an EFIS with hundreds of man years of software in it that just openly supports any hardware you want to hook to it, leaving the money to the hardware guys. I'm sure if someone can make that work, there will be some customers for it, but there will likely be some significant costs to the larger scale support.
Last edited by dynonsupport : 01-14-2015 at 12:26 PM.
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01-13-2015, 03:35 PM
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Join Date: Jun 2005
Location: Woodinville, WA
Posts: 1,499
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Quote:
Originally Posted by Bill Moffitt
SIL refers to the certification level of the GPS receiver, and has nothing to do with the installation of the GPS antenna. Quality of Power Source? Nothing to do with either SIL or SDA - it is part of the TSO however.
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Bill, the FAR (which has nothing to do with certification, since experimentals must follow the FARs that apply), says the AIRCRAFT must have a SDA of 2.
Yes, the GPS has an SDA itself. You couldn't claim an aircraft SDA of 2 if the GPS was a 0 or 1. But just because the GPS is a 2 doesn't mean the whole ADS-B system is or that the aircraft is. I think we can agree that just because your GPS SDA was 2 doesn't mean your aircraft had an SDA of 2 if your ADS-B out device had no TSO or other pedigree, and was using a completely untested parser for the GPS data.
I fail to see how a pilot could get in a plane, put a portable device in that plane, and know that the aircraft he/she is operating is compliant with 91.227.
Maybe I'm wrong though and someone will come up with a foolproof enough ADS-B OUT device that the FAA will issue a letter saying "if this is in a plane, it is 91.227 compliant." What I do know up to this point is that the FAA has be unambiguous in saying that portable devices do not meet the requirements of 91.227.
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01-13-2015, 03:43 PM
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Join Date: Jan 2005
Location: SC
Posts: 12,887
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Quote:
Originally Posted by dynonsupport
...
Maybe I'm wrong though and someone will come up with a foolproof enough ADS-B OUT device that the FAA will issue a letter saying "if this is in a plane, it is 91.227 compliant." What I do know up to this point is that the FAA has be unambiguous in saying that portable devices do not meet the requirements of 91.227.
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I've always wondered if the FAA is going to mandate some type of simple, portable, battery powered transponder for aircraft with no electrical system. Of course, those planes would also need to have their mags, plug wires, and plugs changed also. Not exactly an inexpensive solution but then the FAA has never worried about how much their mandates cost us.
__________________
Bill R.
RV-9 (Yes, it's a dragon tail)
O-360 w/ dual P-mags
Build the plane you want, not the plane others want you to build!
SC86 - Easley, SC
www.repucci.com/bill/baf.html
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01-13-2015, 03:51 PM
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Senior Curmudgeon
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Join Date: Sep 2005
Location: Dayton Airpark, NV A34
Posts: 15,419
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Quote:
Originally Posted by dynonsupport
Gettin' kind of nasty in here.
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Not really, just repeating my long held position that it would be really nice if all of our magic boxes would talk to each other. See this post ( http://www.vansairforce.com/communit...14&postcount=8 ) from years back.
Quote:
Originally Posted by dynonsupport
Bill won't sell someone a standalone GPS receiver. He'll only sell it to you packaged with HIS ADS-B receiver as well. So it goes both ways, and I don't think there is any company that is pure in this regard.
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Apples and oranges---------you are talking hardware, I am talking compatibility of the communications used by that hardware, from various manufactures.
__________________
Mike Starkey
VAF 909
Rv-10, N210LM.
Flying as of 12/4/2010
Phase 1 done, 2/4/2011 
Sold after 240+ wonderful hours of flight.
"Flying the airplane is more important than radioing your plight to a person on the ground incapable of understanding or doing anything about it."
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01-13-2015, 03:52 PM
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Join Date: Jun 2005
Location: Woodinville, WA
Posts: 1,499
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91.225:
(e) The requirements of paragraph (b) of this section do not apply to any aircraft that was not originally certificated with an electrical system, or that has not subsequently been certified with such a system installed, including balloons and gliders. These aircraft may conduct operations without ADS-B Out in the airspace specified in paragraphs (d)(2) and (d)(4) of this section. Operations authorized by this section must be conducted--
(1) Outside any Class B or Class C airspace area; and
(2) Below the altitude of the ceiling of a Class B or Class C airspace area designated for an airport, or 10,000 feet MSL, whichever is lower.
However, the FAA is working on TSO-C199, which is exactly what Bill describes. C199 however is NOT 2020 compliant and only for advisory traffic. Doesn't get you into Class B/C. So they've allowed a "portable" system and even wrote a TSO for it, and it specifically doesn't comply with 91.227.
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01-13-2015, 04:04 PM
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Join Date: Jan 2005
Location: SC
Posts: 12,887
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Quote:
Originally Posted by dynonsupport
91.225:
(e) The requirements of paragraph (b) of this section do not apply to any aircraft that was not originally certificated with an electrical system, or that has not subsequently been certified with such a system installed, including balloons and gliders. These aircraft may conduct operations without ADS-B Out in the airspace specified in paragraphs (d)(2) and (d)(4) of this section. Operations authorized by this section must be conducted--
(1) Outside any Class B or Class C airspace area; and
(2) Below the altitude of the ceiling of a Class B or Class C airspace area designated for an airport, or 10,000 feet MSL, whichever is lower.
However, the FAA is working on TSO-C199, which is exactly what Bill describes. C199 however is NOT 2020 compliant and only for advisory traffic. Doesn't get you into Class B/C. So they've allowed a "portable" system and even wrote a TSO for it, and it specifically doesn't comply with 91.227.
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Wait? So, a Cub with no transponder can fly inside a Mode-C vale, under, but not in Class Bravo airspace but my RV with a transponder but not a certified ADS-B installation cannot fly in that same airspace.
Please tell me that I have that wrong.
__________________
Bill R.
RV-9 (Yes, it's a dragon tail)
O-360 w/ dual P-mags
Build the plane you want, not the plane others want you to build!
SC86 - Easley, SC
www.repucci.com/bill/baf.html
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