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  #521  
Old 06-06-2017, 10:09 PM
ccrawford ccrawford is offline
 
Join Date: Jul 2005
Location: Denver, CO
Posts: 295
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Quote:
Originally Posted by roadrunner20 View Post
So they want me to unplug it and transmit NO position & receive NO position on any aircraft in the NAS. Safer or Not Safer?
What would you rather have: no position reported, but you have your fallbacks to find aircraft (eg: eyeballs, radar), or: a bad position reported but indicating its a good position, so you think it's at position A when its really at position B?
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  #522  
Old 06-07-2017, 07:32 AM
DennisRhodes DennisRhodes is offline
 
Join Date: Jul 2007
Location: Taylorsville, Ga
Posts: 851
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Quote:
Originally Posted by ccrawford View Post
What would you rather have: no position reported, but you have your fallbacks to find aircraft (eg: eyeballs, radar), or: a bad position reported but indicating its a good position, so you think it's at position A when its really at position B?
For VFR flight and (Assuming you have a Navworx that has lost its intergity!) a default to "no position" puts you right back to the way we've done it for the last 100 years, look out the windscreen! And since in VFR we do have the possibility of encountering the J3Cub, that still not a bad idea.
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  #523  
Old 06-07-2017, 08:17 AM
Paul 5r4 Paul 5r4 is offline
 
Join Date: Oct 2006
Location: Foley, Al
Posts: 606
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Good morning all. I spoke with Scott Edwards from Dallas Avionics a few minutes ago. He stated they are working on the fix for the EXP units. It will more than likely be a two pronged approach.... first a software upgrade, (SIL to 0.... also the possibility of making the SIL end-user selectable. I don't understand that because the AD states it must be set to 0), and then a hardware upgrade down the road. He didn't want to speculate about cost at this time. He added that the communication letters on the Navworx site should be updated by the end of this week. He said navworx is very committed to taking care of all these issues with their customers. Hopefully things start happening soon and then as far as compliance we'll know exactly what we're facing.
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  #524  
Old 06-07-2017, 08:22 AM
roadrunner20's Avatar
roadrunner20 roadrunner20 is offline
 
Join Date: Feb 2005
Location: Bay Pines, FL, building in Andrews, NC (new base @ KRHP)
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Quote:
Originally Posted by ccrawford View Post
What would you rather have: no position reported, but you have your fallbacks to find aircraft (eg: eyeballs, radar), or: a bad position reported but indicating its a good position, so you think it's at position A when its really at position B?
In all the flying I have done with this system in 1 1/2 years, my traffic alerts have always been spot on. In most cases, I did not immediately see the traffic out the window, but knowing where to look, it was spot on. I continue, box or no box, to scan for AC regardless of what it reports.
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  #525  
Old 06-07-2017, 11:20 AM
BobTurner BobTurner is offline
 
Join Date: Dec 2011
Location: Livermore, CA
Posts: 7,356
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Quote:
Originally Posted by roadrunner20 View Post
So they want me to unplug it and transmit NO position & receive NO position on any aircraft in the NAS. Safer or Not Safer?
It will be safer for the airlines, because you will not be allowed to fly in "their" airspace (for the most part). Don't be fooled; ADSB is all about saving the FAA money and keeping the airlines safe from GA. Any concern for GA is a distant second.
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  #526  
Old 06-07-2017, 12:00 PM
DennisRhodes DennisRhodes is offline
 
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Location: Taylorsville, Ga
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Quote:
Originally Posted by DavidBunin View Post
Understandable. The thing to do right now is nothing. Wait and see what announcements are made at Oshkosh.

Yes, changing to a SIL of 0 is one potential solution acceptable to the FAA, but I think probably not acceptable to many aircraft owners. Wait and see what's behind door number two.
David , I think you may be correct, in the thing to do right now is nothing, But I think I will go the second step and continue to use my 600 EXP as it is until Dec 31 2017 and ask for a test report EACH time i fly just to be sure it doesn't lose its "integrity" . All the limits in accuracy are easy to read off the reports. And unless there's some breakthru from Navworx at that time which I don't expect, I'll throw it in the trash and buy again from another supplier. Maybe by that time the dust will be settled and the FAA can decide what it is they want. Looks like the international market place is keying in on ADSB and actually are making some pretty good " certified" products.
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  #527  
Old 06-07-2017, 05:11 PM
Paul 5r4 Paul 5r4 is offline
 
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Location: Foley, Al
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I agree with David and Dennis.... do nothing till OSH. I'll continue to use mine as is until I have to change/disable it. I bet Navworx/Bill/Dallas avionics know there will many eyes watching to see how this is handled.
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  #528  
Old 06-07-2017, 06:19 PM
Swoda Swoda is offline
 
Join Date: Nov 2016
Location: McAlpin, FL
Posts: 33
Default Complying with AD via AFM Revisions

In reading the AD if I were making a log book entry stating that i was complying with the AD per Para. e(1)ii in an experimental aircraft how could I log that I complied IAW the AD per para. e(1)ii by Revising the Limitations section of the Aircraft Flight Manual supplement (AFMS) by inserting a copy of this AD or by making pen-and-ink changes to add the following: ?USING THE ADS-B SYSTEM IS PROHIBITED.? WHEN I DO NOT HAVE AN AFM OR POH? or para e(1)iv which states Revise the Limitations section of the AFMS by inserting a copy of this AD or by making pen-and-ink changes to add the following: ?OPERATION USING THE INTERNAL POSITION SOURCE IS PROHIBITED. USE OF THE ACCORD NEXNAV MINI P/N 21000 EXTERNAL POSITION SOURCE IS REQUIRED.? WHEN I DO NOT HAVE AN AFM OR POH?

I have reviewed FAR 21.5, 21.191, 21.193, 91.319, 91.9, AC 60-6B, AC20-27G and my aircraft's Operating Limitations no where is it required to have an Aircraft Flight Manual (AFM) or Pilot Operating Handbook (POH). How is it possible to comply with the two above methods for AD compliance if I have no AFM or POH to enter the required statements into and am not required to have an AFM or POH?

Definition:
Airplane Flight Manual (AFM). An FAA-approved document that contains information (operating limitations, operating procedures, performance information, etc.) necessary to operate the airplane at the level of safety established by the airplane?s certification basis.

Supplement. Information that supersedes or is in addition to the basic AFM
resulting from the issuance of a supplemental type certificate (STC), or from approved changes to AFM limitations, procedures, or performance information without an STC.

Terminology:

Airplane Flight Manual (AFM): The AFM is a document developed by the airplane manufacturer and approved by the Federal Aviation Administration (FAA) It is specific to a particular make and model airplane by serial number and it contains operating procedures and limitations which meet the requirements of FAR 21.5
Pilot Operating Handbook (POH): The POH is a document developed by the airplane manufacturer and contains the FAA approved Airplane Flight Manual (AFM) information The term "POH" came into existence in the mid-1970s as a result of AOPA's and GAMA's efforts to standardize and expand information contained in the owner's manuals or information manuals of the day
Airplane Owner/Pilot Information Manual (PIM): The PIM is a document developed by the airplane manufacturer containing general information about the make and model of an airplane The airplane owner?s manual is not FAA-approved and is not specific to a particular serial numbered airplane
This manual is not kept current, and therefore cannot be substituted for the AFM/POH It is often used as a way to learn and review aircraft information without removing legal information from the aircraft




(d) Compliance
You are responsible for performing each action required by this
AD within the specified compliance time unless it has already been
accomplished prior to that time.
(e) Required Actions
(1) Within 6 months, comply with either paragraph (e)(1)(i),
(ii), (iii), or (iv) of this AD
:
(i) Remove the ADS
-B unit.
(ii) Disable and prohibit use of the ADS
-B unit as follows:
(A) Pull and secure the circuit breaker and disconnect the internal GPS antenna connector from the ADS-B unit and secure.
(B) Install a placard in view of the pilot that states ?USING THE ADS
-B SYSTEM IS PROHIBITED.?
(C) Revise the Limitations section of the Aircraft Flight Manual supplement (AFMS) by inserting a copy of this AD or by making pen-
and-ink changes to add the following:
?USING THE ADS-B SYSTEM IS PROHIBITED.?
(iii) Revise the software so the ADS-B unit broadcasts a SIL of 0.
(iv) Couple the ADS-B unit with an approved external GPS as
follows:
(A) Interface the ADS-B unit with an Accord NexNav mini LRU GPS
Receiver P/N 21000.
(B) Revise the Limitations section of the AFMS by inserting a
copy of this AD or by making pen-and-ink changes to add the
following: ?
OPERATION USING THE INTERNAL POSITION SOURCE IS
PROHIBITED. USE OF THE ACCORD NEXNAV MINI P/N 21000 EXTERNAL
POSITION SOURCE IS REQUIRED.?
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  #529  
Old 06-07-2017, 09:08 PM
scottg scottg is offline
 
Join Date: Oct 2006
Location: Long Island
Posts: 54
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Regarding the no AFMS concern, the AD provides the option of contacting the FAA and asking for an alternate means of compliance. Standard aircraft are not required to have the operating limitations that are attached to our EAB airworthiness certificates. Maybe propose in an AMOC that a copy of the AD be attached to your operating limitations instead of an AFMS change? A quick call to the FAA can't hurt.

(f) Alternative Methods of Compliance (AMOCs)

(1) The Manager, Fort Worth Aircraft Certification Office, FAA, may approve AMOCs for this AD. Send your proposal to: Kyle Cobble, Aviation Safety Engineer, Fort Worth Aircraft Certification Office, Rotorcraft Directorate, FAA, 10101 Hillwood Pkwy, Fort Worth, TX 76177, telephone (817) 222-5172, email kyle.cobble@faa.gov; or Michael Heusser, Program Manager, Continued Operational Safety Branch, Fort Worth Aircraft Certification Office, Rotorcraft Directorate, 10101 Hillwood Pkwy, Fort Worth, TX 76177, telephone (817) 222-5038, email michael.a.heusser@faa.gov

Last edited by scottg : 06-07-2017 at 09:28 PM.
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  #530  
Old 06-08-2017, 05:48 AM
rleffler's Avatar
rleffler rleffler is offline
 
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Location: Delaware, OH (KDLZ)
Posts: 4,227
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Here's the response I just received from the FAA concerning the AMOC and any future hardware/software upgrades from Navworx.

Mr. Leffler,
First, let me address how to apply for the AMOC. Please reference Advisory Circular (AC) 39-10. You can find this on the Regulatory and Guidance Library online. Go to http://rgl.faa.gov. On the right, select Advisory Circulars, and then you can do a search for 39-10.

Section 3-2 details the information that should be included in the AMOC. The AMOC should go through your Flight Standards Principal Inspector, according to paragraph 3-4. So, I would think you could e-mail the AMOC proposal to your PI, and he could forward it on to us, but that’s something you should ask him. Alternatively, if you wanted to present your proposal to the PI, he could give you an endorsement letter stating that he has reviewed the proposal and has no further comments. You could then e-mail the proposal to us (the ACO) and include the PI's endorsement letter. We ask that you submit an ADS-B performance report that has been performed since the AD was published (June 7, 2017). It would be ok to e-mail and electronic version to us at the ACO for inclusion with the AMOC. You should also list the data that was used for the installation, such as the NavWorx installation manual and version number. I believe we have enough experience and data with the GTN650 that it will allow us to issue an AMOC.

We are aware that some of the owners may not have a working relationship with a PI, especially those with experimental aircraft. If that is the case, let me know, as we may have to come up with a work around or provide further guidance on how to submit the proposal.

The other question on NavWorx upgrades is a little nuanced. If the NavWorx upgrade is to set SIL back to 0, then you can check with our office to see if that particular software version has been approved. If so, you could install that version, since the AD allows such a change to be installed if it becomes available. If the upgrade is to set the SIL to some value other than 0, then you may still have to apply for an AMOC for that version. When that time comes, you can call me or Mike Heusser for guidance.


Kyle Cobble
Fort Worth ACO
817-222-5172


Bill has insisted that external GPS units, such as the GNS430 and/or the GTN650 were approved GPS sources. The AD states that isn't the case. It appears that the burden is on us to file an AMOC for each of our certified GPS, but we may have to for each of the proposed Navworx upgrades. It appears that while Bill is offering what he thinks in an acceptable upgrade path to resolve this current situation, the FAA may have another opinion.

I have a good relationship with the local FSDO office, but I don't know how onerous is the AMOC process or is it something that an individual can accomplish. I guess it's time to get started. The link to the AMOC is: http://rgl.faa.gov/Regulatory_and_Gu...FILE/39-10.pdf

Update: I just read the AMOC instructions. It seems like a more bureaucratic process than a technical one, especially with well known certified GPS sources. It's going to be a couple weeks before I can start working on this, since I'm in the midst of a panel upgrade that I need to get completed first. It seems to me that we may want to organize and request a Global AMOC. The requirements seems to be that you need to add make/model and serial number of each aircraft to be included. I suspect that there needs to be an AMOC filed for each certified GPS. The question then becomes how to we handle the coordination and track all the aircraft that needs to be included in the Global AMOC. Thoughts?

Update 2:

I have been out for a few days.
I will get back with you regarding the Garmin GTN650 nav source.

Thanks,

Michael Heusser
Program Manager
Fort Worth Aircraft Certification Office
Phone: 817-222-5038
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Last edited by rleffler : 06-08-2017 at 06:10 AM. Reason: added AMOC Link
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